November 7, 2016
Susan T. Mayne, Ph.D.
Director, Center for Food Safety and Applied Nutrition (CFSAN)
c/o Division of Dockets Management (HFA-305),
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852
Re: Docket Number FDA-2016-D-2241 for “Substantiation for Structure/Function Claims
Made in Infant Formula Labels and Labeling.”
Dear Dr. Mayne:
On behalf of the National Coalition for Infant Health (NCfIH), we write to share concerns regarding the Food and Drug Administration’s Draft Guidance for Industry “Substantiation for Structure/Function Claims Made in Infant Formula Labels and Labeling.” The coalition applauds the FDA for raising this important issue on infant formula labeling and we encourage your office's oversight on this topic moving forward.
The National Coalition for Infant Health is a collaborative of professional, clinical, community health, and family support organizations focused on improving the lives of premature infants through age two and their families. NCfIH's mission is to promote lifelong clinical, health, education, and supportive services needed by premature infants and their families, and promote access to approved therapies. NCfIH also supports policy that meets our mission, impacting the family, community, state, and federal levels.
Fundamentally, NCfIH believes that labeling guidance should make clear that human milk is the recommended source of nutrition for all infants. Infant formula is a food product that may be used as a substitute only when an exclusive human milk diet is not available. Of note, not only is an exclusive human milk diet optimal for all infants, clinical evidence demonstrates that it should be the standard of care diet for all pre-term infants in order to reduce life-threatening infections and co-morbidities, decrease length of hospital stays and readmissions, and improve pre-term infants’ weak immune systems.
Additionally, the NCfIH and our member organizations urge FDA to use the labeling guidance to ensure labeling is clear, transparent, easy to understand, and devoid of information, titles or claims that may mislead consumers about the nutritional benefit of formula. Evidence-based clinical research must match the label, title and product content. It should be clear that bovine and other sources of protein should not be considered the dietary equivalent of human milk.
While infant formula is a core nutritional component of many infants and toddler diets, FDA labeling guidance must ensure that any labeling, packaging and marketing of formula not lead consumers away from the evidence-based, optimal nutrition source: exclusive human milk (mother’s own milk, qualified human donor milk, and human milk-based human milk fortifiers) for premature infants.
Last, the label should be clear that any nutritional supplements or human milk fortifiers added to formulas that are not exclusively human milk based must not mislead consumers to believe those additives replace or match the quality of an exclusive human milk diet.
An exclusive human milk diet is the recommended source of nutrition for all infants, so it is imperative that labeling guidance ensures consumers are not misled to believe that formula is an adequate substitute for the above-mentioned standard of care diet. To do so would present possibly dire and/or life-changing consequences, especially among the pre-term infant population.
NCfIH appreciates the opportunity to comment on this important issue and looks forward to continuing to support policies that benefit premature infants.
Mitchell Goldstein, M.D.
Medical Director, National Coalition for Infant Healt