Dear Dr. Grossklaus:

The International Council of Grocery Manufacturers Associations (ICGMA) is pleased to provide input on the "Draft Comments on the Proposed Draft Revised Standard for Processed Cereal-Based Foods for Infants and Young Children" at Step 3 of the procedure.

ICGMA, a recognized INGO before the Codex Alimentarius Commission, represents the interests of national and regional associations who collaborate with all sectors of the consumer packaged goods industry. ICGMA promotes the harmonization of scientific standards and policies concerned with health, safety, packaging, and labeling of foods, beverages, and other consumer packaged goods. ICGMA also works to facilitate international trade in these sectors by elimination or preventing artificial barriers to trade.

Section 8: Labelling

The Proposed Draft provides two alternatives for Section 8.1.1. Of the two alternatives presented, ICGMA supports the first, without the second sentence. ICGMA sees no need to include this sentence, as the provision is already included in Section 7.1 of the General Standard for the Labelling of Prepackaged Foods cited in the first sentence. In addition, reference to national jurisdictions is contrary to the goals of international harmonization.

ICGMA opposes the second alternative. This wording is not needed; the General Principles in Section 3 of the General Standard for the Labelling of Prepackaged Foods state the conditions under which pictures and other labelling devices are permitted.

Pictures are used on labels to describe the contents, uses and preparation of a product. Pictures on a complementary food also serve to communicate to the consumer the age of the child for which the product is intended. Pictures are especially important to communicate to consumers that are unable to understand the written instructions.

ICGMA requests that all information included in the brackets regarding nutrition and health claims be deleted. ICGMA believes that factual nutrient content claim and/or health claims on complementary foods (e.g., iron-fortified cereals) are very useful for parents purchasing products. Furthermore, it is unclear whether this provision would apply to only those complementary foods specifically manufactured for infants and young children, or whether it would apply to all foods that could potentially be consumed by infants and young children, e.g., ready-to-eat cereals, fruit juices, etc. Disallowing nutrition and/or health claims on these foods would again deprive consumers of valuable information regarding the nutrition and health benefits of these foods.

Section 8.6.4

ICGMA proposes that the second sentence "The label shall clearly state that the product is not recommended for use below 6 months" be deleted, as it is misleading. ICGMA also proposes to delete the square brackets around health worker and include this term in the section. The WHO recommendation to introduce complementary foods from six months is a recommendation for "populations" and recognizes that health workers may recommend earlier introduction depending on the needs and development of the individual baby.

ICGMA further proposes that the sentence " Additional requirements in this respect may be made in accordance with the legislation of the country in which the product is sold." be deleted. Reference to national jurisdictions is contrary to the goals of international harmonization, as stated earlier in these comments.

Again, ICGMA appreciates the opportunity to submit these comments.

Mari Stull
Director, International Regulatory Policy
Grocery Manufacturers Association




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