If you have experienced trauma related to not being able to exclusively breastfeed, please be advised that this article includes the World Health Organization’s language about breastfeeding vs. formula.

There is perhaps no text more foundational to the work of International Board-Certified Lactation Consultants than the WHO’s International Code of Marketing of Breastmilk Substitutes. It’s so fundamental that we often refer to it as just the Code.

IBCLCs are ethically bound to comply with the WHO Code. It is part of our Standards of Practice and Code of Professional Conduct. And healthcare workers in countries or organizations that require Code adherence must also follow its mandates. The provisions in the WHO Code were adopted in an effort to protect breastfeeding around the world, particularly in lower-income countries where the formula industry’s unscrupulous forays had well-documented tragic consequences widely publicized in the 1970s (Rollins et al., 2023). If you happen to have time, the 2023 deep dive from The Lancet on formula marketing is fascinating work.

That said, in creating a resource for moms with low supply, we have realized that complying with the WHO Code while serving our particular population is far from simple. This site is for people who want to breast/chestfeed, but who are not able to make a full supply. So by definition they need to use supplementation in the form of donor milk or formula. There is only so much donor milk out there. We believe people with low milk supply should not have to listen to messaging that demonizes formula, which moms in our support group report can worsen the considerable psychological turmoil that often accompanies low supply.

So why is it important for us to learn about the WHO Code? We deserve to know that when we are being counseled, or when we are reading educational materials, information might be coming through a filter of WHO Code compliance. This is not a bad thing, and as we explained before, we believe it is important. But policies aimed at protecting babies and breastfeeding can exacerbate the feelings of inadequacy and sometimes trauma that members of the low supply community experience, and we have the right to understand the context of the guidance we receive.

In service of providing that well deserved information to the low supply readers of this site and the professionals who support them, we present a few passages of the WHO Code, along with our thoughts on how the Code is relevant to low supply families.

First, the scope of the Code, as defined in Article 2, is of particular note to the low supply population:

The code applies to the marketing, and practices related thereto, of the following products: 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. It also applies to their quality and availability, and to information concerning their use (World Health Organization, 1981).

Now let’s look at how that scope relates to people with low milk supply.

  1. It affects what IBCLCs and healthcare workers in WHO Code–compliant countries can say about infant feeding.

How is this relevant to the guidance low supply parents receive? When IBCLCs talk about formula, we are not allowed to promote any particular brand. Further, Article 5.1 states that “There should be no advertising or other form of promotion to the general public of products within the scope of this Code.” Article 5.3 states that “Manufacturers and distributors should not use indirect means to promote products within the scope of this Code.” And finally, Article 7.3 states that “Health workers should not be used by manufacturers or distributors of products within the scope of this Code to promote such products” (World Health Organization, 1981).

That said, while we are not permitted to promote specific brands, the Code does not preclude us from providing education about formula; Baby Formula Expert, for example, is an incredible resource by a researcher of human milk who educates parents, presumably often ones with low supply, while complying with the WHO Code, as far as we can tell. When donor milk is not used due to access or parental choice, low supply moms rely on formula, and we see in our group that a lot of us have questions about its use. If we ask those questions of an IBCLC who is fulfilling her professional obligations, we should understand that she may phrase her response in a particular way to avoid any possible perception of bias toward or promotion of one company.

  1. It means there are certain messages IBCLCs and other healthcare organizations are required to convey in educational materials, such as this site.

Article 4.2 of the Code states:

Informational and educational materials, whether written, audio, or visual, dealing with the feeding of infants and intended to reach pregnant women and mothers of infants and young children, should include clear information on all the following points: (a) the benefits and superiority of breast-feeding; (b) maternal nutrition, and the preparation of and maintenance of breast-feeding; (c) the negative effect on breast-feeding of introducing partial bottle-feeding; (d) the difficulty of reversing the decision not to breast-feed; and (e) where needed, the proper use of infant formula, whether manufactured industrially or home-prepared. When such materials contain information about the use of infant formula, they should include the social and financial implications of its use; the health hazards of inappropriate foods or feeding methods; and, in particular, the health hazards of unnecessary or improper use of infant formula and other breast-milk substitutes. Such materials should not use any pictures or text which may idealize the use of breast-milk substitutes (World Health Organization, 1981).

How is this relevant to people with low supply? We have made a point of covering these topics throughout this site. If it seems like we’re talking a lot about the benefits of breastmilk over formula when breastmilk is available, that’s one reason why. Such information can feel like a knife in the wound of moms with low supply, since many of us had every intention of exclusively breastfeeding, and found out that we would not be able to in upsetting conditions, sometimes after undergoing weeks or more of emotionally and physically draining triple feeding. By complying with the WHO Code, we ensure that the education on this site will not be misinterpreted, especially by people who are capable of making a full milk supply.

  1. It limits how we can talk about particular bottles and pumps.

As you can see above, the Code also extends to infant bottles and teats (or nipples). Some consider this aspect of the Code an artefact of earlier times, before the adoption of electric breastpumps in many well-resourced countries. Many people now choose to breastfeed by pumping, sometimes exclusively, and they often rely on bottles to breastfeed their babies. (Because pumping is breastfeeding!) And in the low supply community, a lot of us end up exclusively pumping because our babies will not latch, which can happen when breastmilk production does not meet the baby’s biological needs. This part of the Code is why lactation consultants are not allowed to promote many pump brands, since they often manufacture bottles as well. While it may not be totally clear in the text above, WHO guidance equates product promotion with brand promotion in subsequent publications. For example, in a document from 2023 the WHO made several statements to this point, such as, “Member States should ensure that regulatory measures effectively prohibit the promotion of products within the scope of the Code, including brand promotion, across all channels and media, including digital media” (World Health Organization, 2023).

  1. It limits when and how we are allowed to depict formula feeding.

Article 6.5 states:

Feeding with infant formula, whether manufactured or home-prepared, should be demonstrated only by health workers, or other community workers if necessary; and only to the mothers or family members who need to use it; and the information given should include a clear explanation of the hazards of improper use (World Health Organization, 1981).

What does this mean for low supply parents? Though many of us rely on formula and combo feeding for our babies’ survival and we might appreciate seeing pictures of infants being fed formula, such images will not appear on this site.

The WHO Code was not designed for the low supply community. That is probably OK. It is there to protect the world population of babies from the formula industry’s predatory marketing practices. But if you are reading all this and wishing that the international community could acknowledge our plight too, we hear you. In their 2025 article on primary low milk supply, Whelan et al. wrote, “The condition is not listed among conditions that are deemed by the WHO and UNICEF as acceptable medical reasons for the use of breastmilk substitutes.” We as lactation consultants must do our best to comply with the WHO Code. But we also cannot forget about how it affects the low supply community. By promoting awareness and suggesting a new paradigm for screening and treating patients, the Low Supply Lactation Project aims to help low supply moms feel more seen, even when they are not the focus of this particular foundational text on breastfeeding.

 

References

International Lactation Consultant Association. (2013). Standards of practice for International Board Certified Lactation Consultants (4th ed.). https://ilca.org/wp-content/uploads/2021/05/Standards-of-Practice-for-International-Board-Certified-Lactation-Consultants-newlogo.pdf

 

International Board of Lactation Consultant Examiners. (2017). IBLCE Code of professional conduct. https://iblce.org/wp-content/uploads/2017/05/code-of-professional-conduct.pdf

 

Rollins, N., Piwoz, E., Baker, P., Kingston, G., Mabaso, K. M., McCoy, D., Neves, P. A. R., Pérez-Escamilla, R., Richter, L., Russ, K., Sen, G., Tomori, C., Victora, C. G., Zambrano, P., & Hastings, G. (2023). Marketing of commercial milk formula: A system to capture parents, communities, science, and policy. The Lancet, 401(10375), 486–502. https://doi.org/10.1016/S0140-6736(22)01931-6

World Health Organization. (1981). International Code of Marketing of Breast-Milk Substitutes. World Health Organization. https://www.who.int/publications/i/item/9241541601

World Health Organization. (2023). Guidance on regulatory measures aimed at restricting digital marketing of breast-milk substitutes. World Health Organization. https://www.who.int/publications/i/item/9789240084490

Whelan, C., O’Brien, D., & Hyde, A. (2025). Breastfeeding with primary low milk supply: A phenomenological exploration of mothers’ lived experiences of postnatal breastfeeding support. International Breastfeeding Journal, 20, Article 7. https://doi.org/10.1186/s13006-025-00699-4