CODEX-PANEL PORTRAIT

CODEX-PANEL PORTRAIT
Implementation of the WHO International Code
of Marketing of Breast-milk Substitutes in Switzerland
IMPRESSUM
© 2012
Swiss Association for Foods for Special Dietary Uses, Berne
Swiss Foundation for the Promotion of Breastfeeding, Berne
Design: Nicole Eckert, Baden
Text: Christine Aeschlimann, Berne; Beat Hodler, Berne
2
INHALT
Purpose, Objectives and Methodology of the Codex Panel ..................................................................................................................... 4
The WHO International Code and the Swiss Producers’ Code .................................................................................................................. 5
The main provisions of the Swiss Producers’ Code ................................................................................................................................. 6
Monitoring in Switzerland ...................................................................................................................................................................... 7
Organizations and companies represented in the Codex Panel ............................................................................................................... 8
What has the Codex Panel achieved so far? ........................................................................................................................................... 9
Situation in Third World countries – basic consensus with the Federal Authorities ................................................................................. 10
Criticizing the Code and the Codex Panel – is it justified? ..................................................................................................................... 11
Sources ............................................................................................................................................................................................... 12
Contacts .............................................................................................................................................................................................. 13
3
PURPOSE, OBJECTIVES AND METHODOLOGY OF THE CODEX-PANEL
The activities of the Codex Panel aim at fostering the relationship
between mother and child and at supporting the mother in breastfeeding. The goal is to achieve a best possible ratio of breast-feed
babies in Switzerland.
By signing the Producers‘ Code of Marketing of Infant Formula
(«Verhaltenscodex der Hersteller über die Vermarktung von Säuglingsanfangsnahrungen», 1st edition 1982, 3rd revised edition
2010) the producers have committed themselves to exercising
restraint in the marketing of infant formula and to encouraging
mothers to breastfeed their babies during the first six months of
life. In some aspects the rules of the Code of Marketing go beyond
the legal requirements.
In the Codex-Panel, which is equally composed, the representatives of the organizations affiliated to the Swiss Foundation for the
Promotion of Breastfeeding and the Swiss manufacturers cooperate in view of achieving these aims. The Panel supervises the
abidance by the Code. It monitors the advertising and the marketing practices of the manufacturers and verifies continuously
their compliance with the basic principles of the Code. It develops
recommendations regarding the interpretation of the Code.
Any groups or individuals interested in the promotion of breastfeeding can inform the Codex Panel of violations of the Code as well
as about any conduct that might possibly constitute a violation.
The Panel presents the reported facts to the company concerned
and asks it to make a statement in response. On the basis of the
facts of the case, the Panel then tries to find a mutually acceptable
solution. In this way overt and usually unintentional violations that
occurred during advertising campaigns have been corrected by
the companies concerned. The Panel can also make recommendations to the companies.
With the revision of the Ordinance on Foodstuffs and Objects of
Utility («Verordnung über Lebensmittel- und Gebrauchsgegenstände», LGV; SR 817.02) of March 7, 2008, restrictions on the
promotion of Infant Formula have been introduced on a legal basis
(see new article 11a LGV). The implementation of these rules falls
within the competence of the Cantonal enforcement authorities.
The Codex-Panel cooperates with the Federal Office of Public
Health (BAG) and offers its assistance in all issues regarding the
enforcement of article 11a LGV and the implementation of the International Code.
4
THE WHO INTERNATIONAL CODE
AND THE SWISS PRODUCERS‘ CODE
The International Code of WHO (1981)
The Swiss solution
In 1981, the World Health Organization (WHO) adopted the
«International Code of Marketing of Breast-milk Substitutes». The
International Code was the result of intense negotiations between
governments, non-governmental organisations (NGO’s), professional associations and manufac-turers of infant formula.
The International Code applies to the world as a whole. As a matter of principle, WHO does not issue different recommendations
and regulations for developing countries and industrialized countries (in order to avoid so called «double standards»). However,
the International Code mainly aims at regulating the situation in
the developing countries where malnutrition and adverse sanitary
conditions (lack of clean drinking water supplies) have particularly
negative effects on the status of newborns.
The International Code is a recommendation to the Member
States requesting them to take appropriate measures to achieve
the following objectives (article 1):
• to provide safe and adequate nutrition for infants,
• to protect and promote breastfeeding,
• to ensure the proper use of breast-milk substitutes on the
basis of adequate information and through appropriate
marketing and distribution.
In order to achieve these objectives, the International Code
proposes a series of measures and restrictions concerning public
advertising, relationships between producers and health professionals, labeling of products and product quality.
A number of questions remained controversial after adoption or
had to be readdressed, in response to lessons learned and to a
changing environment. Recognising the need for clarification, the
World Health Assembly adopted a series of resolutions between
1983 and 2001. These resolutions address the following issues:
• the scope of the Code
• the implementation and monitoring processes
• the donation of infant formula to health care institutions
• the duration of time during which breastfeeding should be
protected (until 6 months).
The UN-Resolution of October 19, 2010, on the «Millenium
Development Goals» (Doc. A/RES/65/1) sets a target to reduce
child mortality (goal 4) and to improve maternal health (goal 5).
In this context the protection of breastfeeding plays an important
role (see ciff. 74).
WHO calls upon the Member States to take action to implement
the principles and aims of the International Code «as appropriate
to their social and legislative framework» and their overall development objectives, including national legislation, regulations or
other suitable measures (article 11.1).
Therefore it was necessary to reformulate the general and sometimes vague WHO recommendations in a way that takes the
specific Swiss situation into account. For this purpose, as early
as in January 1982, the Swiss producers signed a national Producers’ Code of Marketing of Breast-milk Substitutes. This Code
followed the recommendations which the Swiss Association for
Paediatrics (Schweizerische Gesellschaft für Pädiatrie, SGP) had
issued at the time.
In 1994 a revised version was adopted expressing the spirit of the
various WHO resolutions as well as that of Commission Directive
91/321/EEC of 14 May 1991 on infant formulae and follow-up
formulae. Several additional provisions were incorporated into this
second version of the Code, such as:
• the interdiction of giving free products to hospitals and clinics
(a particular concern of WHO in 1994),
• the producers’ obligation to extend the principles of the Code
to downstream marketing levels, i.e. sensitizing retailers about
the Code’s aims and principles.
In 2008 article 11a was introduced in the Ordinance on Foodstuffs and Objects of Utility («Verordnung über Lebensmittel- und
Gebrauchsgegenstände», LGV) taking on the provisions of Directive 2006/141/EC on restrictions to advertising (article 11 of the
Directive). Further rules on the labeling of infant formulas (and of
follow-up formulas) of the Directive were transposed in the Ordinance on Foods for Special Nurtrition Purposes («Verordnung des
EDI über Speziallebensmittel», SR 817.022.104, articles 17a and
18a).
The revised edition of the Producers‘ Code of Marketing agreed in
2010 reflects the new food law provisions and additionally contains several interpretations developed by the Codex-Panel over
the years.
5
THE MAIN PROVISIONS OF THE SWISS PRODUCERS‘ CODE 1
Principles
Communication to parents
• Breast-milk is the natural food for an infant during the first
months of life. Breastfeeding should be protected and
promoted.
• With respect to their quality, composition and nutritional value,
infant formulae should be suitable for use:
- as a complement to breast-milk when breast-milk becomes
insufficient to satisfy the nutritional requirements of the
infant (mixed feeding),
- as a substitute for breast-milk only in cases when the
mother does not breastfeed.
• Health professionals – physicians, midwives, lactation
consultants, mother-child advisors – should inform and advise
mothers about the best nutrition for their infant.
• Any communication to parents concerning the use of infant
formula should contain a statement pointing out the need to
consult a health professional and emphasizing the superiority
of breast-milk (see above).
• Any information should be worded so as not to discourage
mothers from breastfeeding.
• Advertising in magazines directed to the general public is
prohibited. Permitted is only advertising in publications
dedicated to the infant care and in scientific publications. The
information should not imply or create a belief that bottle
feeding is equivalent or superior to breastfeeding (article 11a
para. 1 of LGV).
• In the retail trade advertising with the aim to stimulate the
sale of infant formula is not permitted. Equally not permitted
are specific displays, cent-off coupons, tie-in sales, special
promotional activities (reduced price campaigns), teasers or
package deals (article 11a para. 2 of LGV).
• The distribution of free or reduced-price products, samples or
any other promotional gifts directly or indirectly via the health
care system is prohibited (article 11a para. 3 of LGV).
Scope of the Code
The Code refers to the promotion and marketing of infant formula
as defined in article 17 para. 1 of the Ordinance on Foods for
Special Nutrition Purposes2 and Directive 2006/141/EC (today
Regulation (EU) No. 609/2013 on «food intended for infants and
young children, food for special medical purposes, and total diet
replacement for weight control»).
Advertising for and labeling of infant formula
• The labeling is regulated by the general provisions of the
Ordinance on Labeling and Promotion of Foodstuffs («Verordnung des EDI über die Kennzeichnung und Anpreisung von
Lebensmitteln», LKV, SR 817.022.21) and article 17a of the
Ordinance on Foods for Special Nutrition Purposes.
• Advertising texts and labels should:
- point out the superiority of breastfeeding over the use of the
product as a substitute or complement to breast-milk,
- objectively and comprehensively communicate the
appropriate preparation and use of the formula and contain
a warning about the health hazards of inappropriate
preparation (on the package).
• The packaging should carry the following IMPORTANT NOTICE
(or equivalent) in an easily visible manner:
Breastfeeding is ideal for your child.
Please consult a health professional if your child requires a
complementary food or if you do not breastfeed.
• The display of pictures of infants on formula containers and
wordings which idealize the product are prohibited (article 17a
para. 8 of the Ordinance on Foods for Special Nutrition
Purposes).
Communication to physicians, health professionals,
clinics and hospitals
• Any information provided to health professionals has to be
factual and objective and should not create the impression
that bottle feeding of formula is equivalent or superior to
breastfeeding.
• Health professionals shall decide independently and according
to the indication on the use of infant formula in the hospital,
thus ensuring that the mother is in no way restrained from
breastfeeding.
• The manufacturers respect the free and autonomous decision
of the health professionals in the establishment of the feeding
plan for the infant and in the advice given to the mother.
• Direct or indirect financial or material inducements are not
permitted.
• Any delivery of infant formula to hospitals, clinics and other
health institutions – whether for the internal use or for
dispensing to the mother leaving the establishment – has to be
invoiced.
6
MONITORING IN SWITZERLAND
The International Code requires in its article 11 that governments
monitor the application of the Code and cooperate for this purpose with manufacturers and distributors as well as with nongovernmental organisations, professional groups and consumer
organizations (Article 11.2 and 11.4). Manufacturers are urged to
implement the Code‘s requirements within their respective companies (Article 11.5).
In the Swiss context the implementation of this aim had to be
achieved within the framework of existing legislation. This meant
taking into account health policies, the federal structures (legislative authority lies with the Confederation, but implementation with
the Cantons) and the principles of commercial law (freedom of
trade and of economic pursuit).
Based on these insights, the Swiss UNICEF Working Group for the
Promotion of Breastfeeding (today the Swiss Foundation for the
Promotion of Breastfeeding) and the section Infant Nutrition of the
Swiss Association for Foods for Special Dietary Uses initiated the
formation of a Codex Panel in 1995. The open dialogue within a
body representing both sides in equal numbers made it possible
to achieve a consensus on all essential matters of the Code, to
discuss questionable marketing practices openly and to implement
corrections speedily whenever necessary. This cooperation has re-
sulted in a «spirit of shared purpose» that also guides the Panel in
matters that are not formally within the scope of the Code (such as
follow-up formula and complementary foods) and places the wellbeing of the child and the mother first and foremost.
The implementation of the legally binding rules on advertising and
promotion of infant formula introduced in article 11a LGV now falls
in the competence of the Cantonal enforcement authorities. Nevertheless it is considered expedient that the primary concerned and
interested parties, who have expert knowledge of the market, continue to monitor the activities of the manufacturers and to discuss
presumed infringements in a board composed of an equal number
of representatives.
It is of paramount importance that the organisations involved in
the surveillance have an all-embracing view over all aspects of
the marketing activities and by that are in a position to apply a
systematic monitoring. The Panel remains available to the Cantonal
authorities as a board of specialists.
We would like to see the public more deeply involved in the Panel’s
activities and the opportunity to report violations to the Panel used
more actively.
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ORGANISATIONS AND COMPANIES REPRESENTED
IN THE CODEX-PANEL
Swiss Foundation for the Promotion of Breastfeeding
(since 2000)
Swiss Association for Foods for Special Dietary Uses
(Association Diet)
6 seats, represented are among others the following
organisations:
- Swiss Committee for UNICEF (UNICEF Switzerland)
- Swiss Society of Paediatrics
(Schweizerische Gesellschaft für Pädiatrie – SGP)
- Swiss Association of Health Visitors
(Schweizerischer Verband der Mütterberaterinnen – SVM)
- Association of Swiss Lactation Consultants IBCLC
(Berufsverband Schweizerischer Stillberaterinnen – BSS)
- La Leche League Switzerland (LLL CH)
- Swiss Federation of Midwives
(Schweizerischer Hebammenverband – SHV)
6 seats, the following companies are represented:
- Nestlé Suisse SA
- Milupa SA
- Hero AG
- Hipp GmbH & Co. Vertrieb KG
- Holle baby food GmbH
- Bimbosan AG
Co-signatory of the Code but not represented in the Panel (production in Switzerland without marketing):
Hochdorf Nutrifood AF / Hochdorf Nutritec AG
The chairmanship of the Codex Panel alternates from meeting to
meeting; the Secretary’s duties lie with the Association Diet. For
the present composition of the Panel see: www.stiftungstillen.ch
 Codex-Panel  Codex-Panel
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WHAT HAS THE CODEX PANEL ACHIEVED SO FAR?
The equal representation of members of the Swiss Foundation for
the Promotion of Breastfeeding (replacing the former Swiss UNICEF
Working Group for the Promotion of Breastfeeding since July 2000)
and of Swiss manufacturers within the Panel ensures that the restriction on promotion stipulated by the food law regulations in force
and the complementary provisions of the Code can be monitored
area-wide and violations responded to quickly. The Panel also receives suggestions from the general public.
Since the Codex Panel was established in 1995, regular meetings
have been held, usually at 6 months intervals. Numerous individual
cases have been examined and general criteria for the assessment
of advertising and product information have been elaborated. A
summary of the Panel’s decisions can be obtained by the Association Diet and by the Swiss Foundation for the Promotion of Breastfeeding.
Some examples of the cases examined are:
IMPORTANT NOTICE on the superiority of breast-milk and
of breastfeeding
The Panel considers it as very important that the IMPORTANT NOTICE does not remain an empty phrase. The IMPORTANT NOTICE
should guide the product information as well as the communication to mothers and health professionals. The breastfeeding mother
should not be led to doubt what she is doing.
The Panel has scrutinized a large number of statements and has
succeeded in convincing the manufacturers to avoid ambiguous
phrases such as «if you do not have enough milk, use the product
…» or «After four months, your child needs a change». The phrase
«This product resembles breast-milk» was also ruled out.
Feeding schedules
As a result of a Panel initiative, today the manufacturers list breastmilk as the first choice among infant feeding tables and schedules.
Samples
Already on the basis of the Code of 1994 the Panel had defined clear
rules regarding the distribution of samples: Under no circumstances
samples were to be distributed without specific request and simply
for advertising purposes. Additionally the Panel had intervened with
pharmacies and drugstores that samples should only be given to
mothers in the context of a consultation and that samples should
not be laid out for free self-service.
In 2008 in accordance with the EU-Directive the prohibition to
give free samples was introduced into Swiss legislation3. Portion
packages of infant formula must be sold at a price which corresponds at least to the price per kilogram of the respective product
on the market.
Advertising for follow-up formula and complementary
food
The Code applies to infant formula only. However, the basic principle
of protecting and promoting breastfeeding and appropriate conduct
should also be reflected in advertisements for baby foods intended
for children after the age of 6 months.
As a result of the Panel’s initiative in this matter, the manufacturers have agreed to refrain from any disparaging statements about
breast-milk and breastfeeding in their advertising and marketing of
such products.
Age indication
The Panel has monitored adherence to the age indication «after 4
to 6 months» – today «after 6 months» – for all follow-up formula. Discussions were held with suppliers of products which do not
fall under the scope of the Code but may influence breastfeeding
practices in the first 6 months, e.g. fruit and vegetable beverages
or infant teas.
The same goes for retail companies in particular with regard of the
promotional activities by large distributors of non-branded products.
The Panel holds a constructive dialogue with these companies.
Implementing billing of formula deliveries to hospitals and
clinics
The interdiction of distributing infant formula free of charge to hospitals and clinics can only be implemented if these institutions are
sensitized to the issue. To this end, the Panel supports the activities
of the Swiss Foundation for the Promotion of Breastfeeding in connection with the «Baby-Friendly Hospital Initiative».
The Code requests that the health personnel must not be influenced
in any way in the decisions about the eventual use of infant formula.
For this reason the Panel has defined to what extent and up to what
value donations or gifts of useful items (e.g. thermometers) may be
given to hospitals and clinics. The display of a company logo without
explicit product advertisement is not prohibited.
Defining acceptable advertising media
Only infant care journals, scientific publications and publications for
health professionals are allowed to carry advertisements for infant
formula. Advertising in general publications is not permitted. The
Panel defines a list of journals in each category.
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SITUATION IN DEVELOPING COUNTRIES –
BASIC CONSENSUS WITH THE FEDERAL AUTHORITIES
In view of the deliberations in the WHO, the manufacturers and
the competent federal authorities – Swiss Federal Office of Public
Health (SFOPH), Swiss Agency for Development and Cooperation
(SDC) and the Political Directorate of the Federal Department of
Foreign Affairs (DFA) – have agreed upon a basic consensus on
the issue of infant and child nutrition in developing countries4:
Nobody contests
• that in Third World countries too many children die of diseases that
can be prevented and treated,
• that the most important of these diseases is diarrhea, often combined
with malnutrition,
• that extended breastfeeding (> 1 year) together with oral rehydration
therapy (ORT) are the two main pillars in the fight against diarrhea in
young children,
• that breastfeeding is one of the cheapest and healthiest practices for
the well-being of mother and child,
• that breastfeeding is a significant factor in the fight against population
growth in poor countries,
• that after the age of 4 to 6 months, all children need complementary
food that meets their nutritional requirements.
For these reasons, all forces have to be pooled in order
• to encourage mothers to breastfeed their children,
• to warn against a careless abandonment of breastfeeding. This
applies in particular to the growing number of mothers who have to
live in poor economic and sanitary circumstances,
• to avoid having infant formula marketing and early introduction of
complementary food negatively affect mothers’ readiness to breast
feed and result in premature abandonment of breastfeeding, this
applies in particular to mothers living in poor countries,
• to inform mothers about the correct use of children’s food,
• to find sustainable ways to reconcile the opposing interests of food
manufacturers and health promoters.
(unofficial translation)
10
CRITISING THE CODE AND THE CODEX PANEL – IS IT JUSTIFIED?
Activist groups are of the opinion that the International Code is
not insufficiently respected and implemented. Their criticisms
mainly concern the situation with respect to several developing
countries. However, they also think that the Swiss Code does not
sufficiently respect the International Code. The following aspects
are controversial:
Scope of the Code
The International Code applies to «breast-milk substitutes, including infant formula, other milk products, foods and beverages, including bottle fed complementary foods, when marketed
or otherwise represented to be suitable, with or without modification, for use as a partial or total replacement of breast-milk;
feeding bottles and teats.» (article 2) This provision has caused
a considerable number of controversial discussions on international level. Activist groups deduce from this provision that advertising not only of infant formula, but also of follow-up formula,
is not permitted.
The scope of the Swiss Code is limited to infant formula and restricts – in accordance with the EU-Directive – advertising for this
group of foods only. The Codex Panel is of the opinion that advertising of follow-up formula which are clearly only recommended
for the time after 6 months is not liable to prevent a mother from
breastfeeding at an early stage in the infant’s life. However, the
Panel places great emphasis on the intention that the basic principles of the Code should also be respected in the advertising and
marketing of follow-up formula. The manufacturers have agreed
to take on this commitment.
Implementing a general ban on advertising
In the interpretation of the International Baby Food Action Network
(IBFAN) and of other organisations, the International Code contains
a general ban on advertising. The Panel is of the opinion that a
general ban on advertising is incompatible with Swiss legislation currently in force and esteems that a general ban does not
constitute an appropriate means to achieve the objectives of the
Code, that is to protect breastfeeding and to guarantee optimum
nutrition of the infant.
Advertising and product information are not intrinsically bad and
undesirable. The main point is that advertising should not discourage a mother from breastfeeding. At the same time, the mother
should not be denied access to necessary information enabling
her to choose an appropriate complementary food at a time of her
choice. The Panel supports breastfeeding-friendly advertising that
allows the mother to make her own decision responsibly.
As early as 1981, during the negotiations about the International
Code, the Swiss Delegation to the 34th World Health Assembly
stated the following:
The Code explicitly respects an objective need for breast-milk
substitutes, the Code does not seek to prevent the sale and use of
such products where use is indicated. The Code intends to prevent
all practices – particularly marketing practices – that undermine
the basic principle of active protection and promotion of breastfeeding and seeks to ensure the proper use of such products
when these are necessary.
(unofficial translation)
The Panel aims to establish monitoring processes that guarantee the observance of the legal requirements, define binding provisions and guidelines for the implementation of the Code and
that are capable of assessing new developments and innovative
marketing practices without delay (e.g. via the internet). In this
context prohibitions are not as important as the interpretation on
whether an advertising slogan and marketing practice hampers
the promotion of breastfeeding. Only specific examples can help
the Panel to define what is permitted and what is not.
Monitoring the implementation of the Code
Article 11 of the International Code regulates the implementation
and monitoring and requests governments to «take action to give
effect to the principles and aim of this Code, as appropriate to
their social and legislative framework». For this purpose governments should collaborate with «nongovernmental organisations,
professional groups, and consumer organizations» (article 11.2).
Manufacturers are urged «to regard themselves as responsible for
monitoring their marketing practices according to the principles
and aim of this Code and for taking steps to ensure that their
conduct at every level conforms to them» (article 11.3).
The Codex Panel thinks that voluntary self-regulation based on
constructive dialogue between all parties concerned and going
beyond the exigencies of article 11a LGV is a better strategy to
achieve the aim of the WHO Code than government action (see
Monitoring in Switzerland, page 7).
Implementing decisions and recommendations
The International Code obliges manufacturers to ensure their own
monitoring, that is to monitor the implementation of the Code’s
provisions within their own companies. Since all important manufacturers are represented on the Panel internal monitoring is
guaranteed and the companies themselves report their members’
11
violations to the Panel. Additionally the Cantonal authorities now
enforce the restrictions on advertising and promotion based on
article 11a LGV in the framework of their inspection activities.
Transparency of Panel activities
Activist groups reproach the Panel for exercising its duties in
closed session.
Through the Panel’s contact with retailers, in particular with large
distributors, the basic principles of the Code can be implemented
at the retail level. The same applies to pharmacies and drugstores
which have been requested to comply with the restrictions on advertising in their retail outlets.
The Panel has repeatedly informed the public about its activities
and achievements, in particular during the International Breastfeeding Weeks (40th week of the year). Furthermore, advertising
and marketing practices of manufacturers can be reported to the
Panel at any time. Each input will be carefully examined and the
reporter will receive a response after the investigation has been
completed.
SOURCES
1
Extract from: Producers‘ Code of Marketing of breastmilk substitutes, revised
edition 2010; Codex-Panel summary of decisions, status May 2011.
2. Infant Formulae means foodstuffs intended for particular nutritional use by
infants in good health (children up to 12 months) during the first months of life
and satisfying by themselves the nutritional requirements of such infants
until the introduction of appropriate complementary feeding.
3. LGV article 11a: The distribution of free or price reduced products, samples or
any other promotional gifts to the public or pregnant women, mothers and
members of their families is prohibited, be it directly or indirectly via the
healthcare system. (unofficial translation)
4. «Grundkonsens für eine gemeinsame Haltung zu Fragen der Säuglings- und
Kleinkinderernährung»; signed by: Association Diet, section Infant Nutrition,
Beat Hodler; DFA, Swiss Agency for Development and Cooperation, Ambassador W. Fust; DHA, Swiss Federal Office of Public Health, Prof. T. Zeltner; DFA,
Political Management, Ambassador J.-M. Boulgaris; February 1997
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CONTACTS
Swiss Association for Foods for Special Dietary Uses
(Association Diet)
Swiss Foundation for the Promotion of Breastfeeding
Elfenstrasse 19, PO Box 1009, 3000 Berne 6
Tel. +41 (0) 31 352 11 88 / Fax. +41 (0) 31 352 11 85
[email protected]
Schwarztorstrasse 87, 3007 Berne
Tel. +41 (0) 31 381 49 66 / Fax. +41 (0) 31 381 46 67
[email protected]
www.stiftungstillen.ch
Vereinigung
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