Submitted to the ACCC (March 2021).

Accredited Practising Dietitians (APDs) should play a key role in educating carers on infant and toddler nutrition. In particular, giving advice on breastfeeding, and where clinically indicated breast milk alternatives.

The existing Marketing in Australia of Infant Formula: Manufacturers and Importers Agreement (MAIF Agreement) fails to protect parents and children. It should not be re-approved but instead replaced by legislation.

The new legislation should address these shortcomings:

• The marketing of infant and toddler formulas should be regulated under Australian law.
• We must extend the restrictions on the advertising of infant formula to include all breast milk substitutes, including toddler milks.
• Regulations should incorporate the marketing of complementary foods for infants, feed bottles, and promotion and price discounting by retailers.
• The new legislation must be enforceable by law.
• Updated regulations must be free of conflicts of interest arising in its governance.

Breastmilk is the best option for infant nutrition. It offers the best support for optimal growth, development and health in a child's early years. Infants should be exclusively breastfed for the first 6 months of their lives where possible. Beyond this, a diverse range of foods should start to be introduced alongside breastfeeding. It's critical that new legislation reflects the importance of breastfeeding.

Currently, the regulations consist of voluntary, self-regulated codes. This is not an appropriate substitute for legislation and is currently failing Australians.

The regulations on the marketing of infant formula and breastmilk substitutes must be formalised within Australian law. This makes the regulations enforceable and mandatory. This will prevent inappropriate marketing practices that undermine breastfeeding.

The Infant Nutrition Council established the existing MAIF agreement. This Council consists of companies that manufacture breastmilk substitutes. As a result, serious conflicts of interest are present. These must be addressed immediately to protect the Australian public.

For more download our full submission.