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©iStockphoto.com/MKucova
by Heidi Green
March 28, 2011
Have an opinion about the way infant formula is marketed? Now’s your chance to be heard. The Food and Drug Administration (FDA) recently announced plans to conduct a study “to assess women’s understanding of and response to various statements on infant formula labels.” The FDA will accept public comments on the proposed study until May 2, 2011.
Background
Breastfeeding advocates have long argued that the marketing statements made by formula companies influence mothers’ infant feeding decisions, discouraging them from breastfeeding and prompting them to buy more expensive formulas. The independent think tank Cornucopia Institute expressed particular concern about the marketing of formula additives docosahexaenoic acid (DHA) and arachidonic acid (ARA), a pair of manufactured fatty acids added to nearly all infant formulas currently on the market. (You can read more about the controversy here).
In its 2008 report, Replacing Mother: Imitating Human Breast Milk in the Laboratory, the Institute asserted that these oils “appear to be added to infant formula primarily as a marketing tool designed to convince parents that formula ‘supports brain and eye development’ and is now ‘as close as ever to breast milk.’” Such claims are a “detriment to public health” because they “undermine breastfeeding.”
“Adding these two fatty acids to formula does not make it ‘close to breast milk,’” Wisconsin pediatrician Jennifer Thomas notes. “Breast milk has nutrients, live cells, and bioactive compounds that are absent from formula. Formula advertisements featuring DHA and ARA make it a lot harder for me, as a pediatrician, to convince new mothers to breastfeed if they have seen advertisements or labels implying that formula is just as good as breast milk.”
Following the publication of its report, the Cornucopia Institute, together with the National Alliance for Breastfeeding Advocacy, filed a petition with the FDA and a complaint with the Federal Trade Commission (FTC) calling for greater attention to infant formula labels and marketing. However, the FTC has not yet taken action because its lawyers say it “need[s] data showing that these claims actually impact mothers’ feeding decisions,” explains Cornucopia Institute Farm and Food Policy Analyst Charlotte Vallaeys.
About the study
As proposed, the FDA study will focus on statements on labels that are “structure function claims or similar to those claims,” one example being that a formula “supports brain and eye development.” It will involve a survey of four groups:
An online consumer panel will select 5,000 women who meet these criteria. Participants will be shown two sets of infant formula labels and asked to compare the labels in terms of:
Participants will also be asked to provide information about month of pregnancy, plans for infant feeding, number of children, age of youngest child, infant feeding history, infant formula purchasing, formula selection, and attitudes about the differences between breast milk and formula.
Considerations
Attention to the influence of formula marketing on mothers’ infant feeding decisions is long overdue, and baby gooroo applauds the FDA for tackling the issue. However, the details of the proposed study deserve attention.
The study focuses only on infant formula labels. As any mother can tell you, infant formula claims are everywhere—not just on labels. By focusing only on the labels, the FDA is failing to capture complete data on the infant formula marketing juggernaut—from TV commercials to free formula samples at hospitals, brochures in physician’s offices to parenting magazine advertisements, coupons to customer reward incentives. Mothers are inundated with messages about formula’s health benefits long before they step into the infant feeding aisle of the grocery store.
In addition, the study relies on consumer response rather than scientific findings. The well-respected Cochrane Review has stated that the studied claims are false. Even the advertising industry’s own watchdog has repeatedly requested that formula makers desist in making such claims. Why is the FDA paying more attention to consumer attitude than scientific proof?
Despite the fact that the FDA has received reports that some infants fed formula with DHA and ARA experience diarrhea, vomiting, and dehydration (a finding explored in the Cornucopia Institute report) the organization is not eliciting information about possible side effects experienced by formula-fed infants.
Be heard
The FDA has proposed this long-overdue study, but there’s no assurance that it will take place. Given tough budget choices being made at all levels of government, it’s important to let the agency know that you support this effort. Public comment must be submitted by May 2, 2011. Submit your comments electronically or send them to Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. All comments must refer to Docket No. FDA-2011-N-0098.
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