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Proposed Changes to NHMRCs 2012 Infant Feeding Guidelines submission

This submission reflects the views of
Organisation Name: 
Australian Food and Grocery Council (AFGC)
Please identify the best term to describe the Organisation: 
Personal Details
Question 3
Do you agree with the proposed change? If no, please provide rationale and relevant citations: 
AFGC Response: Breast milk is the best nutrition for infants and the AFGC considers that continued breastfeeding during the introduction of complementary foods is very important for public health. The AFGC considers that with the recent review of Minimum age labelling on infant foods in the Food Standards Code 2.9.2 and the outcome that the status quo of the youngest minimum age labelling permitted on infant foods is from 4 months, that the wording could be amended to ensure clarity and alignment of National guidelines with Food Regulation. “Around 6 months” was initially defined in the initial DRAFT NH&MRC guidelines (Oct 2011) as 22-26 weeks, which is not aligned to “From 4 months” (17 weeks as per ESPGHAN, 2009). An accumulating body of scientific evidence suggests a potential window of opportunity to reduce allergic responses in infants by the introduction, not avoidance, of solid foods, between 4 and 6 months of age. This is recognized by national and international competent authorities and scientific bodies such as EFSA (2009), ESPGHAN, American Academy of Paediatrics, ASCIA, and confirmed in recent and well-designed Australian and international studies. The AFGC considers the advice of the Australasian Society of Clinical Immunology and Allergy (ASCIA) to be of particular relevance, given that it is the peak association of clinical specialists working under Australian conditions and with Australian consumers. On the introduction of solid foods ASCIA advises: “The reported protection from breastfeeding against allergic disease in the early years of life is relatively small, and some studies suggest there may instead be an increased risk of disease in later life. More research is needed to determine the optimal time to start complimentary solid foods. Based on the current available evidence, many experts across Europe, Australia and North America recommend introducing complementary ‘solid’ foods from around 4 – 6 months”. AFGC note the following in relation to introduction of gluten: “…a reduced risk for the infant developing coeliac disease seems to be associated with (i) breastfeeding during the introduction of dietary gluten, (ii) longer duration of breastfeeding, and (iii) introducing gluten in small amounts between 4-7 months and slowly increasing it while breastfeeding.” Therefore, for the age for introduction of solids to be consistent with the accumulating evidence around the reducing risk of food allergies, we consider that the wording needs to be clearer. It is the AFGC’s view that the recommended minimum reference age of ‘around 6 months’’ is confusing. This may lead to confusion about what ‘around’ 6 months means.

Page reviewed: 16 September, 2015