Digital Marketing Under The Scanner at WHO: The Case of Breast-Milk Substitutes
Newsletter Edition #256 [The Files In-Depth]
Hi,
Across sectors, regulators are mostly playing catch up in the face of technological change and reduced capacities, while trying to keep pace with corporate strategies aimed at market expansion.
But this becomes even more acute and urgent, when it comes to regulating corporate practices especially when they impact health outcomes.
Today’s edition focuses on a resolution being discussed at the World Health Organization that seeks to address digital marketing, and its impact on information and consumption of breast-milk substitutes.
These efforts also show the crucial role provided by civil society organizations in their support for WHO member states on matters that affect all countries. This assumes even greater significance at a time when WHO is under pressure financially.
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Digital Marketing Under The Scanner at WHO: The Case of Breast-Milk Substitutes
By Priti Patnaik & Bhadra G
WHO member states treasure the organization’s norms setting mandate, that has now come under threat as a result of a financing crisis precipitated by the Trump administration, exacerbating the challenges at the chronically under-funded institution.
At the Executive Board meeting last month, countries struggled to reconcile financial realities with the many resolutions that have been proposed. By May 2025, countries will closely monitor the costs of resolutions as a part of a broader exercise of reprioritisation of activities at WHO, in time for adoption at the World Health Assembly.
One of the resolutions being considered by countries is on regulating the digital marketing of breast-milk substitutes. While the costs associated with the resolution is not significant, such an initiative shows the importance of WHO’s norms-setting functions and how it builds on previous efforts.
More importantly, the resolution draws attention to the imperatives for regulation in a context where swiftly changing marketing strategies, often determined by algorithms, result in selling personalized content to vulnerable users.
Work in this area has been initiated for the last several years. Activists and regulators have documented that digital marketing is emerging as a predominant source of exposure to promotion of baby feeding products globally.
In 2022, WHO mapped the cross border extent and power of such marketing approaches in a report on digital marketing of breast-milk substitutes. This has only accelerated with the rise of paid influencers and misinformation undermining recommendations from WHO and national authorities, and disempowering parents, activists say.
WHO followed up the 2022 report with a guidance on regulatory measures aimed at restricting digital marketing of breastmilk substitutes published in November 2023.
The latest resolution takes these efforts further by recognizing the “inappropriate promotion of foods for infants and young children”, and refers to previous commitments by countries to address these matters, by emphasizing expanding the kinds of stakeholders regulators could work with, building on good governance, better monitoring and compliance among other measures.
In this story we take a detailed look at the issues at stake and the efforts made by various stakeholders to address such marketing approaches, as described by WHO. We take a step back and look at an earlier guidance issued by WHO, that helps put in context the importance of this resolution.
International Baby Food Action Network, (IBFAN), an international coalition working on maternal and infant and young child health through the protection, support and promotion of breastfeeding, said at the Executive Board meeting last month:
“IBFAN welcomes the draft Resolution and urges all to support it. Mothers are being bombarded by misleading marketing online. In one click health authority advice is disregarded. This has long-term consequences for child health and survival. There are 144 national laws based on the International Code and when these are enforced breastfeeding rates improve. However, many laws do not include the 20 resolutions that keep pace with new marketing strategies and the ultra-processed products for children that are causing so much harm. There is no need for significant resources to enforce this Resolution. Governments must allocate specific legal duties to the social media platforms and service providers who have control over their content. Governments must follow the WHO Guidance that this Resolution is about.”
The group also said that there is no need for governments to expend significant resources to enforce every violation.
“The other actors in the digital supply chain have control over monitoring the content on their platforms and in many countries already do so for other regulated marketing practices and products such as pharmaceutical, tobacco, alcohol as well as intellectual property infringements etc. The approach set out in the WHO Guidance is not new or practically difficult to implement, but is very important to implement as soon as possible,” a statement from IBFAN said.
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