The Formula Shortage Crisis: Our Public Comment to the FTC – Serenity Kids
The Formula Shortage Crisis: Our Public Comment to the FTC & How You Can Join our Advocacy
Estimated time to read 6 minutes
Are you as fired up about the formula crisis as we are? Help end the oligopoly that created it by speaking up to the Federal Trade Commission (FTC)—we’ll be right alongside ya. Keep reading for more info, but head's up comments should be submitted to regulations.gov and must be received no later than Friday, June 24, 2022 by 11:59pm ET.
MAKE YOUR VOICE HEARD
The domination three large companies have over the infant formula supply leaves our babies vulnerable to future shortages, and the only solution is to diversify the infant formula space.
As a baby food + formula company dedicated to the health of America’s children (thanks to prioritizing real, nutrient-dense farm-to-high-chair ingredients), we believe there are effective ways to ensure the nutritional quality and safety of an infant formula that does not create such a large barrier to entry—especially for small companies like us.
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Our Grass Fed A2 Whole Milk Formula
In mid-2021, we launched our Grass Fed A2 Whole Milk Formula, and it has already improved the lives of thousands of little ones—and parents—many of whom turned to our formula during this crisis.
However, because of the FDA’s current infant certification process, we are only allowed to label our product a “Toddler Formula” and market it to babies 12m+. This severely limits our ability (and other like-minded companies) to produce and provide product in large quantities, which could have alleviated some of this year’s formula shortage.
LEARN MORE ABOUT OUR FORMULA
Why It's So Complicated
The FDA requires infant feeding studies that take over three years and several million dollars to complete, even when a formula’s ingredients are already proven safe. This makes it incredibly hard for small innovative companies like us to get approved. The U.S. is the only country in the world (that we know of) that requires these final formulation studies.
We want the U.S. to adopt a similar process that would encourage innovation and competition and allow more companies like ours to quickly bring nutritious and safe infant formulas to market.
MAKE YOUR VOICE HEARD
Dear FTC: We Demand Change
Join us in speaking up and out to the FTC (repost the photo above to your social media channels to advocate alongside us!)
We know you’re a busy parent, so we’ve made the process even easier for you…
Copy & paste the following message (editing as you see fit):
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Dear Members of the Federal Trade Commission,
I’m writing to ask that you help end the oligopoly that created this formula shortage crisis by making it easier for small, innovative companies to get safe, quality products approved as infant formulas.
The single biggest barrier to entry is the FDA’s requirement of an infant feeding study process even when there is already adequate scientific data that demonstrates a formula’s ingredients are safe.
Please work with the FDA to reform this requirement with an infant formula certification process that is safe and thorough and also encourages innovation and competition.
Sincerely,
FIRST NAME, LAST NAME
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SUBMIT YOUR STATEMENT HERE
As both parents and as a company, little ones’ health and safety is always our number one priority. Cheers to feeding babies quality formula and demanding greater access to it! We can’t thank you enough for your continuous support and for rallying with us for change—because #EverySipCounts.
P.S. Here is our public comment to the FTC:
Dear Members of the Federal Trade Commission,
We at Serenity Kids developed a revolutionary new formula, made in the United States from the highest quality, nutrient-dense ingredients. Using recent, cutting-edge scientific studies, we have created a formula more similar to breastmilk than any other. Ours contains a 2:1 whey to casein ratio as well as a balance of proteins, carbohydrates, essential fatty acids, prebiotics, vitamins, and minerals to support growth and development.
We launched our formula in mid-2021, and it has already improved the lives of thousands of parents and children. Many of whom turned to our formula during this crisis.
We believe there are equally effective ways to ensure the nutritional quality and safety of an infant formula that does not create such a large barrier to entry.
Here are a few changes that would allow the U.S. to increase Americans' access to infant formulas:
- Remove the infant feeding study requirement for formulas that are made from ingredients whose safety and suitability for a particular use by infants from birth have been established by generally accepted scientific data.
- Recognize the infant formula approvals conducted by regulatory agencies of other industrialized countries and allow a fast-track process for those formulas to be approved for sale in the U.S.
- Give small American businesses that employ hard-working Americans the same support being granted to large international brands that are quickly being brought into the U.S. market.
- Prioritize small American businesses for fast-track temporary approval under the Infant Formula Enforcement Discretion Policy.
- Update infant formula standards that have not been updated since 1987.
- Create a clear pathway for those who achieve temporary approval under the Infant Formula Enforcement Discretion Policy to keep this certification permanently.
We hope that the FTC will work with the FDA to reform the infant formula certification process to find an alternative to these feeding studies that will allow more companies to quickly bring nutritious and safe infant formulas to market.
Sincerely, Serenity & Joe Carr, Co-Founders of Serenity Kids