Public Health (Breast-milk Substitutes, Infant and Young Child Nutrition Regulations, 2024

The Minister of Health and Child Care has made new regulations governing breast-milk substitutes and infant and young child nutrition. Most provisions take effect on 1 January 2025. The labelling provisions come into force one year after the regulations are proclaimed.

The regulations cover a broad class of "designated products": infant formula (0–6 months), follow-up formula (6–36 months), complementary foods, any beverage, milk or food marketed for infants and young children including breast milk fortifiers and foods for special medical purposes, feeding items such as bottles and teats, and pacifiers. The Minister can declare further products designated. The definitions deliberately reach digital marketing — social media, websites, messaging and streaming services, search engines, eCommerce and apps are all inside the definition of digital environments, and cross-promotion or brand stretching is defined and caught.

A nineteen-member Infant and Young Children Nutrition Committee is set up to police the regime. Nine members represent state, mission and local authority health workers (including two environmental health practitioners, a health promotion officer, a government analyst, a nutritionist, a dietician, a pharmacist, a paediatrician and a nurse), with one each from private health practice, industry and trade, ZIMRA, small and medium enterprises, information, the Standards Association of Zimbabwe, the Consumer Protection Commission, social welfare, and a registered legal practitioner, plus two from voluntary associations — and those voluntary association members must not be funded or governed by companies selling designated products. Members serve at most four years, renewable once. The committee meets at least quarterly, needs eleven members for a quorum, and its minutes are restricted to members.

The committee's job is to monitor enforcement, approve informational and educational materials and product labels, review reported contraventions and report to the Minister, advise on action against contraveners, commission research, and address conflicts of interest. Subcommittees are provided for packaging and labelling, education and advocacy, and marketing and advertising.

The regulations go on to restrict education and information materials on infant feeding, require label approval, prohibit general advertising and sales promotion of designated products and promotion within the health care system, restrict donations, free samples and reduced-price sales, prohibit manufacturer and distributor sponsorship, restrict marketing personnel from approaching pregnant women and mothers, set food safety and quality standards, and give inspectors powers of entry, search, seizure, recall and stop-sale. They repeal the earlier regulations they replace.

Caveat on completeness: this is a long instrument and the extract available here runs out partway through the committee's meeting procedures. The account of the advertising prohibitions, the labelling requirements, the investigatory powers, the penalties and the repeal above is taken from the arrangement of sections rather than from the operative text. Anyone who needs the exact prohibitions, label wording requirements or penalty levels must read the instrument itself.