I thought some of you might want to look at what I wrote to the FDA. The inaccuracy about Heinz having better labels came from a consumer affairs person at the supermarket. I really should have checked first. Oh, well, can't be perfect. Rachael Hamlet Mom to Hannah (6/14/92), bf advocate And Radical BF Lawyer Mom from Hell Falls Church, VA ------------------------------------------------------------------------------ ------------------------------------------------- J. Rachael Hamlet, Esq. Telephone (703) 903-8876 2026 Peach Orchard Drive Apt. T1 Falls Church, VA 22043 July 27, 1995 Food and Drug Administration 200 C Street, SW Washington, DC 20204 Attn: Nan Rainey Re: Labeling of Juices and Other Foods for Infants Dear Ms. Rainey: As a mother, and as an attorney concerned with food safety issues, I am writing to complain about the labeling of juices and other foods for infants. As an illustration, I have enclosed a copy of a label from White House brand apple juice. Please note the drawing of a baby bottle with the words "GOOD FOR BABY TOO!" written on it. The FDA itself, in its consumer publications, as well as the American Academy of Pediatrics and other entities concerned with the health of infants, recommend only breastmilk or approved infant formula for the first six months of life. I am very concerned that parents could interpret this label as encouragement to use apple juice to replace one or even more daily feedings of breastmilk or formula in a young baby. Because apple juice provides only the most minimal of nutrients (other than sugar), and babies' nutritional needs are very great and very complex, regularly replacing breastmilk or formula with apple juice could cause great harm to babies. An infant whose diet contained a substantial amount of juice instead of breastmilk or formula could end up seriously malnourished, as well as suffering from gastrointestinal distress In addition, baby food companies, such as Gerber and Beech-Nut, market juices and other foods for infants in a manner quite similar to the enclosed label. I have heard that Heinz is an exception: they do include information on their labels about foods other than breastmilk or formula being inappropriate for younger babies. I believe that Heinz has demonstrated that more responsible labeling is feasible. [Since mailing this, I have learned that Heinz is no exception, after all.] As I am sure you are aware, the United States has signed the World Health Organization's Code for the Marketing of Breastmilk Substitutes, which expressly prohibits this kind of labeling. While no enabling legislation has yet been enacted by Congress, existing laws permit the FDA to regulate labeling of foods in order to protect the health of infants. I would like to know if the FDA has any regulations in place regarding the labeling of foods as being appropriate for consumption by infants. If yes, I would like to know what those regulations are. I would also like to know what mechanisms are in place for enforcing such regulations. If no such regulations exist, I would like to know why not, and what mechanisms exist for enacting such regulations. Please feel free to contact me at the above address and phone if you need more information from me. I can also recommend that you contact Barbara Heiser, RN, IBCLC, of the National Alliance for Breastfeeding Activism, at (410) 995-3726, and Karlyn Sturmer of Action for Corporate Accountability, at (203) 787-0061. Sincerely, J. Rachael Hamlet, Esq. cc: National Fruit Products Company, Gerber, Beech-Nut, Heinz Center for Science in the Public Interest National Alliance for Breastfeeding Advocacy Action for Corporate Accountability encl.