ISDI has responded to the public consultation organised by WHO on its proposed Draft Guidance on Regulating Digital Marketing of Breast-milk Substitutes. Our overarching comments on the draft are the following:

1. Digital marketing is already covered by the Code, relevant WHA resolutions and several national laws. To avoid duplication, any additional guidance should focus on only those items that are not already covered by existing WHO instruments, including the Code and WHA resolutions.
   • For example, the Code defines marketing in broad terms – as “product promotion, distribution, selling, advertising, product public relations, and information services – allowing for any form of marketing, including digital, to be included within its scope. Resolution WHA69.9 specifies that “promotion” should be “broadly interpreted” to include communications “through traditional mass communication channels, the Internet and other marketing media using a variety of promotional methods.”
2. Preserving access to factual, scientific information in digital channels, where many parents and caregivers seek information, is essential to providing timely information that furthers public health goals. 
3. ISDI supports efforts by national governments to ensure that compliance with national laws extends to all stakeholders in the digital ecosystem, beyond manufacturers. Manufacturers continue to evaluate new technologies and means to help monitor independent websites.  ISDI would welcome further discussions with the WHO, Member States and relevant stakeholders in the digital ecosystem.

Read the full response here.