50. The Committee, recalling that the Proposed Draft had been considered in detail at its last session and circulated for additional comments, considered the text section by section and made the following amendments.
SCOPE
51. The Delegation of Bolivia proposed to amend the Scope to refer to “the age of about 6 months” instead of “4 to 6 months”, stressing the health problems associated with complementary feeding when introduced too early, especially in developing countries. This view was supported by the Delegations of Egypt, Hungary, Norway, Korea, India, Brazil, Venezuela, Uruguay, by the Representative of UNICEF (who referred to WHA resolution 47.5), and the Observers from Consumers International, IBFAN, ENCA, ILCA. They pointed out that the use of a range (4 to 6 months) would be confusing to health workers and parents, and that a precise limit for the introduction of cereal-based foods provided better guidance in order to address problems related to microbial contamination and intolerance.
52. The Delegation of France, supported by several delegations and the Observer from the EC, supported the current text and stressed the scientific basis for the range of 4 to 6 months, as it allowed to take into account the health and nutrition status of the population in different countries and the growth needs of the infant, whereas a limit of six months did not allow any flexibility in this respect. The Delegation also noted that the Guidelines on Formulated Supplementary Foods for Older Infants and Young Children referred to older infants after 6 months and it had been decided to keep the Standard and the Guidelines separate because they applied to different age ranges and had different purposes.
53. The Representative of WHO indicated that there was no change in the current WHO position concerning the introduction of complementary feeding between four and six months, as current scientific evidence did not support an amendment at this stage; the range was an essential element as it reflected the need to take into account the diversity of needs of the individual infant. The Representative informed the Committee that a comprehensive study, to be concluded in 2002, had been initiated to revise the current International Growth Reference Standards, on the basis of data collected in several regions on breast-fed children (representing ideal nutrition); the results of this study would provide the scientific basis for reconsidering this issue in the future. The Representative also pointed out that the Scope should be considered in conjunction with Section 8.5.4 concerning Information for Utilization, whereby the decision to introduce complementary feeding should be made in consultation with a health worker on the basis of the specific needs of the infants, and additional requirements could be established at the national level.
54. Some delegations including India the Representatives from UNICEF and CI drew attention to the recent WHA resolution where “about six month” was adopted instead of “four to six month” in view of the global nature of the standard.
55. Some delegations stressed the fact that a decision on this issue had already been taken at the last session on the recommendation of WHO representative[12] and that the current text should be retained as there was no scientific basis to amend it. India and other delegations were opposed to this. The Committee, recognizing that there was no consensus at this stage, agreed with the proposal of the Delegation of Canada to include the current text in square brackets for further comments and consideration at the next session.
56. As a consequential amendment, all related references to the age of introduction in the standard were put in square brackets: sections 3.8.1 (optional ingredients), 8.5.3 (gluten declaration), 8.5.4 (use of the product).
2.1 PRODUCT DEFINITIONS
57. The Committee agreed to delete the first sentence of this section as it repeated the text of Section 2. Description.
58. Some delegations proposed to delete the reference to biscuits, rusks and pasta as specific foods for young children since there was no need for special regulation of these products for children, because these products, as defined for infants and young children, were not different from products used by other age groups. This view was supported by the Observers from Consumers International and ENCA. The Representative of WHO indicated that, the fact that the products were not necessary did not mean that the products could not be regulated. Other delegations indicated that these products were used and regulated by legislation in their countries and that it was useful to provide nutritional criteria for their composition at the international level and as guidance for governments. This view was supported by the Observer from ISDI.
59. The Committee noted the proposal from the Delegation of India to delete the reference to starchy roots as they did not provide protein and all countries should be able to use cereals for their babies. It was however noted that starchy roots had been included in the standard to take into account the needs of countries where no other raw materials were available. The Committee recognized that the standard was intended to cover all types of foods and raw materials used in different regions and agreed to retain the text as currently drafted.
2.2. OTHER DEFINITIONS
60. The Committee had an exchange of views on point 2.2.3 referring to milk, and discussed whether sweetened condensed milk, evaporated milk and skim milk should be excluded. Some delegations pointed out that confusion should be avoided between composition requirements which were relevant for the manufacturer and the instructions for use provided to consumers in the labelling. The Committee recognized that nutritional requirements, as defined in Section 3, would ensure that the end-product would not be too high in fat or sugars and that additional requirements concerning different types of milk were not necessary; it was also noted that a definition for milk, recently revised by the Committee on Milk and Milk Products, existed within Codex. The Committee therefore agreed to delete section 2.2.3.
3.1 ESSENTIAL COMPOSITION
61. The Committee agreed to delete the reference to peanut “arachis” in view of allergenicity risks.
3.3 PROTEIN
62. The Committee agreed to retain the second option proposed in the current text, referring to 80% of the reference protein, for the expression of protein contents. The Delegation of Japan proposed to indicate that the values for protein could be set at the national level in the light of dietary habits. This view was supported by the Delegation of Norway, who proposed to lower current values in order to avoid excessive protein intake. The Committee however retained the current text as it was intended to provide a common approach at the international level, including the inclusion of Annex 1 on casein. The Committee agreed that only natural forms of L-amino acids can be used.
3.4 CARBOHYDRATES
63. The Committee agreed to change the amount of added carbohydrates in para. 3.4.2 from 1.2 - 2.0 g per 1 kJ as suggested by the Delegation of Spain.
3.5 LIPIDS
64. The reference to the products covered in point 2.1.4 (biscuits) was deleted as the provisions of section 3.5.1 concerned only simple cereals to be reconstituted.
65. Some delegations pointed out that the provisions for (a) lauric acid and (b) myristic acid were not considered essential and the Committee agreed to delete them.
3.6 MINERALS
66. The reference to the expression of sodium per 100 kcal was introduced in square brackets for further consideration. In section 3.6.1, the Committee agreed to retain reference to products intended for children over one year with an editorial change for clarification purposes. The Committee agreed to delete section 3.6.2 referring to products covered by 2.1.4 (biscuits) and to transfer this reference to section 3.6.1.
3.7 VITAMINS
67. Some delegations supported the deletion of section 3.7.2 on the addition of vitamins A and D as fortification with these vitamins was not necessary in some countries and could even result in excessive intake and serious health hazards; decisions on fortification should be left to national authorities, as indicated in section 3.7.3. Other delegations recalled that these provisions were already included in the standard for infant formula and that they applied only to cereals with an added high protein food (2.1.2). Some delegations pointed out that fortification should not be mandatory.
68. The Committee also noted that the provisions for vitamins A and D should be consistent with section 3.7.3 whereby the addition of vitamins and minerals was left to national legislation. Some delegations proposed that section 3.7.3 should not mention specifically vitamin A, iodine and iron, while other delegations stressed the importance of such a reference in view of public health concerns related to micronutrient deficiencies.
69. The Committee, with the exception of the Delegation of Norway, agreed 1) to retain the current values for Vitamins A and D in section 3.7.2 and 2) to amend section 3.7.3 to specify that derogations to these maximum values and the addition of other vitamins and minerals, for which no provisions were set in the standard, was left to national legislation.
3.8 OPTIONAL INGREDIENTS - 3.8.3 COCOA
70. The Committee, while noting the suggestion of some delegations to delete this section and the proposal of the Delegation of Korea to refer to one year of age for the introduction of cocoa, agreed to retain the current text, which referred to nine months.
3.10 CONSISTENCY AND PARTICLE SIZE
71. Several delegations and observers proposed to introduce a reference to “spoon feeding”, which would to ensure that these products were not marketed as breast milk substitutes which could be fed by bottle, and to current practice for infants above six months. Other delegations pointed out that this requirement was conditional on the decision relative to the age of introduction of supplementary feeding. The Committee recognized that no conclusion could be reached at this stage and agreed to include “spoon feeding” in square brackets for further comments. The Observer from ILCA noted that the additional word “spoon” before feeding was consistent with this draft as these products are not breast milk substitutes.
4. FOOD ADDITIVES
72. The Committee noted that a number of proposals had been made for amendments to the additives section and recalled that appropriate technological justification should be provided when submitting additives for endorsement to the Committee on Food Additives and Contaminants. The Committee recognized that these provisions should be considered carefully taking into account all relevant technical aspects, which was not feasible at the current session due to time constraints; it was therefore proposed that a Working Group[13] coordinated by the Delegation of the Netherlands should work by correspondence in order to provide a revised Section on Food Additives for consideration by the next session.
5. CONTAMINANTS
73. The Delegation of Spain expressed the view that the current reference to “practically free” (from contaminants) was not acceptable as it did not provide the legal and practical basis for official control of foodstuffs nor guarantee the free circulation of goods. This view was supported by other delegations, who proposed the inclusion of precise figures for pesticides, heavy metals and other contaminants.
74. The Committee recalled that the Committee on Pesticide Residues had asked for clarification on its earlier request for the establishment of MRLs for foods for infants and children, and recognized that justification should be provided. The Committee therefore agreed to request the CCPR to consider the feasibility of establishing specific MRLs for cereal based foods and infant formula. In setting MRLs for each pesticide residue in these foods, the CCPR should describe the general principles for risk assessment that have been taken into account. These principles should include, but not be limited to, consideration of:
- the physiological and developmental characteristics of infants and young children who would be consuming these products;6. HYGIENE- the relative contribution of these foods to the total daily intake of these infants and children; and
- the types of ingredients used in these foods.
75. The Committee noted that the reference statements on food hygiene had been amended by the last Session of the Commission and agreed to amend the current section accordingly.
8. LABELLING
76. The Committee had an exchange of views on the reference to labelling in the appropriate language of the country and noted that a reference to Language was included in the General Standard for the Labelling of Packaged Foods. However, some delegations and observers supported a specific statement in the standard to this effect and the Committee retained the current text.
8.3 DECLARATION OF NUTRITIVE VALUE
77. In order to clarify and simplify this section, the Committee agreed to replace the current section with the text proposed in the comments of Canada, whereby the energy value was expressed in kcal or kJ, and protein, carbohydrate and fat were “expressed in grams per 100 g of the food sold as well as per specified quantity of the food as suggested for consumption”. The text of the Section 8.3 was amended as proposed by the Observer from EC.
8.5 INFORMATION FOR UTILIZATION
78. In Section 8.5.2, the Committee agreed to delete the reference to protein and to refer to “products covered by point 2.1.1” for clarification purposes.
79. In Section 8.5.3, the Committee had an exchange of views on the declaration of gluten and recognized that questions relating to gluten-free foods were addressed in the relevant standard and should be compatible with the reference to gluten in foods for infants. The Committee agreed that “the presence or absence” of gluten should be declared, in order to provide flexibility. The sentence was left in square brackets. The Observer of AOACS expressed the view that a sufficient declaration of gluten including gluten containing processing aids the “75% rule” should be extended to all processed cerealbased foods for infant and young children for better information of gluten intolerant consumers. The Observer from ISDI remarked that there was no need for this request because the presence of gluten containing cereals was indicated on the list of ingredients.
80. Section 8.5.4 was left in square brackets pending a decision on the Scope, since it included the reference to age. Some delegations and the Representative of WHO noted that this section would not be necessary if a precise limit was introduced for the age of introduction; other delegations stated that the decision should be taken with a health worker even in the framework of a recommendation for “about six months” which was not absolute.
81. The Delegation of India and of Consumers International proposed to include the following additional provisions: a reference to the need for breast feeding to continue when supplementary foods were introduced; a prohibition of pictures representing children or suggesting an inappropriate age of introduction; a prohibition of health and nutrition claims. The Committee noted that under the current provisions of the General Guidelines on Claims, health claims were allowed only in conformity with national legislation.
STATUS OF THE PROPOSED DRAFT REVISED STANDARD FOR PROCESSED CEREAL-BASED FOODS FOR INFANTS AND YOUNG CHILDREN
82. The Committee, recognizing the progress made on the revision of the text, agreed to forward the Proposed Draft to the Commission for adoption at Step 5 (see Appendix IV).
