7.0 Advertising Aspects

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Infant, Follow-up, and Young Child Formula
Singapore

This section provides information on regulations on advertising and if there are any restrictions or approval processes.

7.1 Applicable Advertising Regulation

Infant, Follow-up, and Young Child Formula [1]

Singapore Food Agency has similar rules for labeling and advertisement. All claims related to food products used for advertisement must comply with Singapore Food Regulations, as per Section 6 "Claim requirements" regarding permitted and prohibited claims.

7.2 Specific Restrictions on Advertising

Infant Formula and Follow-up Formula [2]

The promotion, marketing, and distribution practices of infant formula should comply with the requirements of the “Code of Ethics on the Sale of Infant Foods in Singapore”. This Code is administered by the Sale of Infant Foods Ethics Committee Singapore (SIFECS) which is administered by the Health Promotion Board (HPB). The responsibilities of the Infant Nutrition Industry are:

A) Promotion and Advertising

1. Promotion or advertising (in all retail, online, or other electronic channels, including but not limited to broadcast, print, and out-of-home media) featuring products (breastmilk substitutes for infants 0 to 12 months) and infants within the scope of the Code is prohibited. These include:

Financial or material inducement such as discount vouchers, gifts, loyalty points, coupon codes, bonuses, cashback, free samples (including taste sampling), tie-in sales, supplies, gifts, or other benefits towards the specific purchase of products within the scope of the Code.
The use of nutrition and health claims, terms, and related terms such as “smart”, “intelligent” or “intellectual potential” to create the belief that products within the scope of the Code are equivalent or superior to breastfeeding.
Special displays and shelf labeling including but not limited to shelf-talkers, shelf-labels, shelf-branding, wobblers, block-stack, and end gondola display.
Cross-promotional practices including but not limited to materials or information that carry instructions or illustrations that encourage progression to formula milk products outside the scope of the Code e.g. Step Diagram, displays of other formula milk products that are on promotion alongside products within the scope of the Code (in both retail and online channels).
Production or distribution of information, collaterals, and educational materials on general infant feeding and products (or containing product names) within the scope of the Code in any form to the public. These include but are not limited to health booklets, growth charts, calendars, stationery, pamphlets, posters, etc.
Participation in Mother and Baby events for the promotion of products within the scope of the Code.

2. Support distributors’ and retailers’ understanding of the existence, contents, and operationalization of the Code.

3. Providing advice or any form or type of educational services on the use of products within the scope of the Code and general infant feeding for pregnant women or parents of infants and young children by company personnel is prohibited. Such advice should only be given by doctors, dietitians, nutritionists, nurses, and qualified lactation consultants not employed by the Infant Nutrition Industry.

4. Direct public communications on any product changes are prohibited unless approved by the SIFECS Chairperson under exceptional circumstances. All communications can only be done through healthcare personnel.

5. The sale or display of products within the scope of the Code at polyclinics, maternity wards, nurseries, specialists’ clinics, general practitioners’ premises, or any healthcare institutions is prohibited, with the exception of third-party retailers. This does not apply to food for special medical purposes (FSMP) and specific medically indicated infant formula products.

6. The sale of ready-to-feed (RTF) infant formula to the public by manufacturers is prohibited.

7. The provision or funding of mother-craft or similar services for infant formula products is prohibited.

8. Solicitation and use of personal information in any form for the purpose of promotion of infant formula products. This includes solicitation and use of personal information by third parties.

B) General Sponsorship

1. When sponsoring a symposium, congress, or other medical/healthcare events targeted at the public and/or healthcare personnel, (including public education forums and parental counseling sessions on infant feeding) for both local and overseas meetings, the industry must comply with the following:

The main organizers should be the relevant professional association and Infant Nutrition industry members should not be the main organizers;
The sponsorship must be able to withstand public and professional scrutiny and conform to the professional standards of ethics and good trust;
Industry-employed personnel are not allowed to conduct talks of any form to the public under the banner of the companies;
Product names should not be featured at these talks;
Industry-employed personnel can only deliver talks and lectures to healthcare personnel. Any conflict of interest must be declared;
No payments should be made to compensate healthcare personnel for time spent in attending the event;
Payments of reasonable honoraria and reimbursement of out-of-pocket expenses, including travel and accommodation, may be provided to healthcare personnel who are providing genuine services as speakers, presenters or moderators on the basis of a written contract with the company at the Event;
Any support provided to individual healthcare personnel must not be conditional upon any obligation to recommend or promote infant formula products;
Companies should not pay any cost of guests, spouses, or family members accompanying invited members of the medical and allied health personnel;
Sponsorship to healthcare personnel should be limited to travel, meals, accommodation, and registration fees, with travel and accommodation applicable to overseas meetings only;
If the program is accredited for postgraduate medical education by medical or other professional associations, responsibility for the program content remains with the organization responsible for obtaining accreditation for the meeting, and industry support should be disclosed;
Invitations to such meetings should not be extended to spouses unless they themselves are practicing members of the medical or allied health personnel;
Only Economy Class tickets for air travel of less than 6 hours should be provided. This should apply to all faculty members e.g. speakers, members of Advisory Boards as well as attendees;
When a Congress/Symposia organized by the infant nutrition industry based in Singapore is held in an overseas location, the majority of the attendees should not be from Singapore;
When a Congress/Symposia is organized, a minimum of 75 percent of the time should be spent on core activities of the Congress/Symposia and a maximum of 25 percent of the time may be devoted to recreational activities e.g. entertainment, sight-seeing tours of modest or nominal cost.

2. Donation or provision of infant formula products at a price lower than the wholesale price to any organizations or persons, including but not limited to healthcare institutions and charities, is prohibited.

3. Donation or distribution of any equipment, services, or articles to healthcare institutions for the promotion of infant formula products is prohibited. This includes but is not limited to stationeries, collaterals, calendars, growth charts, health booklets, and toys.

4. Promotion of infant formula products through healthcare personnel or institutions is prohibited.

C) Educational Materials for Healthcare Personnel

1. All information on infant formula and product use to healthcare personnel must satisfy the following:

Be scientific and factual with appropriate referencing. Copies of cited references will be made available upon request. Company personnel distributing these materials should remind healthcare personnel that the detailing aids are for their information only and should not be distributed nor displayed to the public.
Pictures or text within these materials should not:
1. Make a comparison to breast milk or imply that infant formula products are equivalent, similar, or superior to breast milk.
2. Idealise the use of infant formula, or discourage breastfeeding.
3. This includes but is not limited to the use of:
  1. Pictures of infants, young children, or carers (e.g. mothers or fathers);
  2. Images that imply infant health, happiness, well-being, or enhanced abilities (e.g. intellect, growth), or the health, happiness, and well-being of carers, are associated with infant formula.
No solicitation of contact information from pregnant women and mothers with infants for the purpose of promotion of infant formula products.
The materials must carry statements concerning the importance of breastfeeding and advisory on the proper use of infant formula products:
1. A statement concerning the superiority of breastfeeding, such as “Breast milk is the best food for baby.”
2. Statement in (i) shall be preceded by the words “Important Notice” or equivalent terms.
The description “For use by healthcare professionals. Not for public display.” must be clearly watermarked on each page of the material.

Young Child Formula

None.

7.3 Advertising Approval

Infant, Follow-up, and Young Child Formula

Authority approval is not required [3].

7.4 Other Notes or Requirements for Advertising

Infant, Follow-up, and Young Child Formula

Food businesses are encouraged to refer to the guiding principles in the Singapore Code of Advertising Practice administered by the Advertising Standards Authority of Singapore, an advisory Council under CASE, on ethics in advertising [4]. The purpose of the Children's Code is for “child” defined as a person 12 years old or younger [5].