Formula regulation and breastfeeding promotion are two sides of the same coin. Analyse in light of WHO norms and India's regulatory framework.

The WHO's International Code of Marketing of Breast-milk Substitutes (1981) accepts formula as a legitimate product. It requires that formula is never promoted in a way that displaces breastfeeding [3]. FSSAI's October 2026 draft banning added sucrose and fructose in products for infants up to six months [1] shows the same point. Making formula safer and protecting breastfeeding are two parts of one goal, not rival goals.

WHO norms: one framework, two levers

• Exclusive breastfeeding for six months means breast milk only, not even water. WHO's target is at least 60% by 2030, but only about 47% of infants worldwide are exclusively breastfed today [2].
• The Code (WHA34.22) limits promotion so that formula reaches only infants who genuinely need it [3].
• WHO/Europe's Nutrient and Promotion Profile Model (2022) combines both levers. It bans added sugars in commercial baby foods and restricts marketing to children up to 36 months [8].

India — Side 1: what goes into formula

• FSSAI sets science-based standards under the FSS Act, 2006 [9]. The 2020 Infant Nutrition Regulations cover products for children from birth to 24 months [1].
• The 2026 draft brings formula closer to breast milk. Lactose and glucose polymers remain the preferred carbohydrates [1].

India — Side 2: how formula is sold

• The IMS Act, 1992 restricts how formula is promoted. A National Steering Committee reviews enforcement, and notified voluntary bodies file complaints [5].
• In 2020, MoHFW issued an advisory asking food safety officers to prosecute violations of Sections 3, 4 and 9 [6]. The National IYCF Guidelines allow substitutes only when they are needed for health reasons [7].

Where the coin splits

• Marketing outweighs composition: more than half of parents and pregnant women surveyed in eight countries had been exposed to formula marketing [4]. A healthier recipe does not stop that pressure.
• Reactive enforcement: the IMS Act depends on complaints, and officers had to be told by advisory to prosecute [5][6].
• Narrow scope: the draft covers only 0–6 months and names only two sugars, so fruit concentrates can still sweeten products [1][8].
• Institutional silos: FSSAI regulates composition, while IMS enforcement runs on a separate track.

Composition rules protect infants who need formula, and marketing rules protect breastfeeding for infants who do not. Each fails without the other. The final rule should extend sugar limits to foods for 6–24 months and cap total sugar. MoHFW should also enforce the IMS Act on its own initiative. Aligning both tracks with the WHO Code would advance SDG 2.2 and the right to health under Article 21.