"follow-on formula", which was not in the purview of the milk code which predated its market entry. in 2006, the department of health banned the advertising of infant formula and the practice of providing free samples, regardless of intended age group (in the revised implementing rules and regulations of executive order 51, or rirr). the new regulation was challenged by the infant formula industry in the supreme court. initially the challenge was dismissed, but this decision was reversed following industry pressure and a controversial letter by american business leader thomas donahue, then president and ceo of the us chamber of commerce, resulting in the regulation being suspended and advertising continuing. the guardian newspaper reports widespread illegal advertising and marketing of formula milk contrary to world health organization guidelines. doctors and midwives are encouraged to promote feeding babies formula milk, advertising also targets mothers directly. babies get sick and sometimes die because poor mothers cannot sterilize bottles. south africa in south africa, there is a move towards plain packaging of infant formula under r 991 of the foodstuffs, cosmetics and disinfectants act; as of 6 december 2013, regulation 7 (sale and promotion) is force, whereas regulations 2-6 (primarily with respect to labelling) are scheduled to come into force on 6 december 2014. one of the key requirements as per regulation 3.1.a.iii is a conspicuous message stating “his product shall only be used on the advice of a health professional”. united kingdom in the united kingdom, infant formula advertising has been allowed since 1995; advertising for "follow-on formula" is legal, which has been cited as a loophole allowing advertising of similarly packaged formula. united states in the united states, infant formula is both heavily marketed—the country has not adopted the code, nor is it being systematically implemented by manufacturers for domestic marketing—and even heavily subsidized by the government: at least one third of the american market is supported by the government, with over half of infant formula sold in the country provided through the special supplemental nutrition program for women, infants, and children (known as wic). according to surveys, over 70% of large u.s. hospitals dispense infant formula to all infants, a practice opposed by the american academy of pediatrics and in violation of the code. the gerber products company began marketing its brand of infant formula directly to the public in october 1989, while the carnation company began marketing good start infant formula directly to the public in january 1991. infant formula costs are a significant fraction of the wic program costs: 21% post-rebate and 46% pre-rebate. formula manufacturers are granted a wic monopoly in individual states. meanwhile, breastfeeding rates are substantially lower for wic recipients; this is partly attributed to formula being free of charge to mothers in the wic program, who are of lower socio-economic status. violations of federal policy have also been found in terms of infant formula company advertising using the wic trademark, to reach both wic and non-wic participants. in recent years wic has been expanding its breastfeeding promotion strategies, including providing subsidies for clients who use milk banks. 2022 united states baby formula shortages supply chain disruptions related to the government response to the covid-19 pandemic in the united states have been reported as responsible for causing widespread shortages of infant formula in the united states, as of may 2022. this contrasts with far less severe shortages of infant formula around the globe. reason magazine reported that this was largely the result of food and drug administration (fda) processes delaying approval of otherwise safe infant formula from europe or other sources abroad, which might otherwise have eased demand for infant formula tensions in the united states. as a result of the shortages, on may 16, 2022, the fda announced that it would temporarily ease enforcement of some labeling rules to allow the importation of foreign formulas. fda commissioner robert califf stated, "today's action paves the way for companies who don't normally distribute their infant formula products in the u.s. to do so efficiently and safely. we anticipate that those products that can quickly meet safety and nutrition standards could hit u.s. stores in a matter of weeks." former fda associate commissioner, peter pitts, asserts that the fda's regulatory scheme is at least partially to blame for the shortage. pitts states, "the difference between european baby formula and american baby formula, more or less, is that the labeling is different. the knot in getting that product into the u.s. isn't safety, it's a regulatory issue. i don't want to say it's a nitty issue, but it's certainly something the fda could have jumped on a lot quicker." amid and prior to the formula shortages, woman and infant children (wic) centers in georgia and north carolina were disposing of infant formula. this was done under the usda's recommendation that unused, returned wic infant formula were to be disposed of upon return. despite an attempt by the usda to walk back this recommendation by stating that it is a recommendation rather than a requirement, the usda confirms that it will not reverse this recommendation, even amid the formula shortage. as a result, from october 2021 through may 2022, 16,459 cans of baby formula were destroyed by wic clinics in georgia and an unknown amount of baby formula cans were destroyed in north carolina and other us states. on july 6, 2022, the fda announced that it would change its rules to allow foreign formula manufacturers to permanently import their goods into the u.s., potentially reducing the severity of the shortage. critics of the fda note that this does not remove the regulations entirely and that this shortage has been self-imposed by the fda from the start. additionally, critics note that if a formula maker passes eu regulations, this should be good enough for the fda to allow importation of that formula. critics of the fda's regulatory policy note that the regulatory scheme surrounding european formulas is not borne from a science-based desire to protect children, but rather an influence that the us dairy industry has on the agency. critics also note that if there were an issue with european formulas, the issue would be widespread among the european babies that regularly consume the formula. the formula act is set to expire at the end of 2022, which will subsequently reinstate tariffs on foreign made formula. experts worry that this will result in a repeat formula shortage for 2023. the ceo of the national milk producers federation, a lobbying organization for dairy producers, wrote in a letter to congress and the biden administration to allow for the reinstatement of tariffs on foreign baby formula to commence. history the wabanaki and other native american tribal nations of north america made an infant formula from nuts and cornmeal. elizabeth hanson was captured by wabanaki in 1725 and a native american woman showed hanson how to make this infant formula and she included this in her captivity narrative. early infant foods in 1865, the first infant food was invented. throughout history, mothers who could not breastfeed their babies either employed a wet nurse or, less frequently, prepared food for their babies, a process known as "dry nursing". baby food composition varied according to region and economic status. in europe and north america during the early 19th century, the prevalence of wet nursing began to decrease, while the practice of feeding babies mixtures based on animal milk rose in popularity. poster advertisement for nestle's milk by théophile alexandre steinlen, 1895 this trend was driven by cultural changes as well as increased sanitation measures, and it continued throughout the 19th and much of the 20th century, with a notable increase after elijah pratt invented and patented the india-rubber nipple in 1845. as early as 1846, scientists and nutritionists noted an increase in medical problems and infant mortality was associated with dry nursing. in an attempt to improve the quality of manufactured baby foods, in 1867, justus von liebig developed the world's first commercial infant formula, liebig's soluble food for babies. the success of this product quickly gave rise to competitors such as mellin's food, ridge's food for infants and nestlé's milk. raw milk formulas as physicians became increasingly concerned about the quality of such foods, medical recommendations such as thomas morgan rotch's "percentage method" (published in 1890) began to be distributed, and gained widespread popularity by 1907. these complex formulas recommended that parents mix cow's milk, water, cream, and sugar or honey in specific ratios to achieve the nutritional balance believed to approximate human milk reformulated in such a way as to accommodate the believed digestive capability of the infant. a 1915 advertisement for "nestlé's food" at the dawn of the 20th century in the united states, most infants were breastfed, although many received some formula feeding as well. home-made "percentage method" formulas were more commonly used than commercial formulas in both europe and the united states. they were less expensive and were widely believed to be healthier. however, formula-fed babies exhibited more diet-associated medical problems, such as scurvy, rickets and bacterial infections than breastfed babies. by 1920, the incidence of scurvy and rickets in formula-fed babies had greatly decreased through the addition of orange juice and cod liver oil to home-made formulas. bacterial infections associated with formula remained a problem more prevalent in the united states than in europe, where milk was usually boiled prior to use in formulas. evaporated milk formulas in the 1920s and 1930s, evaporated milk began to be widely commercially available at low prices, and several clinical studies in the period suggested that babies fed evaporated milk formula thrived as well as breastfed babies. these studies, accompanied by the affordable price of evaporated milk and the availability of the home icebox initiated a tremendous rise in the use of evaporated milk formulas. by the late 1930s, the use of evaporated milk formulas in the united states surpassed all commercial formulas, and by 1950 over half of all babies in the united states were reared on such formulas. commercial formulas in parallel with the enormous shift (in industrialized nations) away from breastfeeding to home-made formulas, nutrition scientists continued to analyze human milk and attempted to make infant formulas that more closely matched its composition. maltose and dextrins were believed nutritionally important, and in 1912, the mead johnson company released a milk additive called dextri-maltose. this formula was made available to mothers only by physicians. in 1919, milkfats were replaced with a blend of animal and vegetable fats as part of the continued drive to closer simulate human milk. this formula was called sma for "simulated milk adapted." in the late 1920s, alfred bosworth released similac (for "similar to lactation"), and mead johnson released sobee. several other formulas were released over the next few decades, but commercial formulas did not begin to seriously compete with evaporated milk formulas until the 1950s. the reformulation and concentration of similac in 1951, and the introduction (by mead johnson) of enfamil (for "infant milk") in 1959 were accompanied by marketing campaigns that provided inexpensive formula to hospitals and pediatricians. by the early 1960s, commercial formulas were more commonly used than evaporated milk formulas in the united states, which all but vanished in the 1970s. by the early 1970s, over 75% of american babies were fed on formulas, almost entirely commercially produced. when birth rates in industrial nations tapered off during the 1960s, infant formula companies heightened marketing campaigns in non-industrialized countries. unfortunately, poor sanitation led to steeply increased mortality rates among infants fed formula prepared with contaminated water. additionally, a who has cited over-diluting formula preparations as resulting in infant malnourishment. organized protests, the most famous of which was the nestlé boycott of 1977, called for an end to unethical marketing. this boycott is ongoing, as the current coordinators maintain that nestlé engages in marketing practices which violate the international code of marketing of breast-milk substitutes. generic brand formulas in addition to commercially marketed brands, generic brands (or store brands) of infant formula were introduced in the united states in 1997, first by pbm products. these private label formulas are sold by many leading food and drug retailers such as wal-mart, target, kroger, loblaws, and walgreens. all infant formula brands in the united states are required to adhere to the food and drug