In our view, the draft political declaration presents a good opportunity for accelerated and concerted action on multiple threats of malnutrition. However, its vision could benefit from inclusion of a notion of urgency, persistency of the problem, as well as – beyond stating its unacceptability and injustice – the fact that the matter is of avoidable and preventable nature by reasonable and known means, many of which remain within the remit of systemic approach to good governance and redistribution of power and resources at local, national and supranational level.

We agree that the causes of malnutrition are complex and multidimensional, indeed, as the draft political declaration state; however, the ‘causes of the causes’ of such a state, have not been adequately and clearly brought to a limelight – the past and current food and agriculture systems failed to address hunger and malnutrition due to unfavourable economic and political choices and have neglected to systematically and sustainably put health and nutrition for all at the heart of their decision makers. In this regard, ‘access to food’, ‘right to food’ and ‘adequacy’ should come upfront when listing key determinants of malnutrition and inequalities at population level (strongly referred to the UN SR Right to Food). Moreover, the vision would benefit from a stronger alliance of the – so it seems – predominant food and farming sector with health and social systems at large, objectives of the fight against poverty and social exclusion as well as advancement of gender equality and a strong human rights protection in all approaches towards food and nutrition - from a point of 'curative' but mostly 'preventive' way and mindset.

Furthermore, to go beyond ‘just’ focusing on the whole food and agriculture system that is to say the traceable food supply chain and actions across sectors to ensure coherence with health and equity, due consideration should be given to the entire enabling food environment so that a healthy and nutritious choice is an easy one.

We very much value a specific focus put on increasing the rate of exclusive breastfeeding in the first six months as well as support towards adequate supply of (fresh) fruit and vegetables, having seen a slow but persistent decline in political commitment towards these objectives and misguided agricultural subsidies that favour intensive production of products not considered to contribute to healthy and sustainable diets (such as the recent reform of the EU Common Agricultural Policy or the US Farm Bill).

In addition to recognising that ‘nutritional protection is provided to people who are food (EPHA add. and nutrition) insecure, unable to purchase the (EPHA add. adequate amount and/or type of) nutritious foods they need, have special needs, or are nutritionally vulnerable for other reasons’, it should be made clear that by no means people should find themselves in a situation of food and nutrition poverty in the first place. Of course, any emergency food aid is welcome when it is needed and necessary in unfortunate conditions but its temporary character should not be seen as a long term solution; neither should it replace or overshadow structural systemic good governance policies on a government side to address, mitigate and prevent such insecurities or inequalities through a variety of available measures.

When considering ways how to reshape and fix our broken and unsustainable food system to improve people’s nutrition and ultimately health and well-being, the entire food supply chain has to be scrutinised, including food environments in which people make food and nutrition-related decisions, how the foods are advertised and marketed, especially to the most vulnerable consumers such as the child population, young parents, people on low income or minorities, among others. For better health and nutrition, the length of the food supply chain has to be considered – with the short(er), local, regional food production-consumption links found supporting healthier food options, reducing food waste, price volatility and ever-increasing power and market concentration in the agri-food sector.

This would bring us to another macro-economic level of influence in food and agriculture system - international ‘free’ trade agreements aimed to remove trade barriers, such as tariffs but also regulatory or harmonization framework of existing and future regulations aimed to guide production of foods considered safe, healthy, nutritious or environmentally-friendly; how the food could be grown, produced, processed, distributed, advertised and so on. The already happening increase in food commodification, globalization and disappearing diversity in our diets (usually towards cheaper and more convenient but unhealthy, western-type, highly-processed and intensively farmed) may be only further aggravated by such trade negotiations as the current Transatlantic Trade and Investment Partnership (TTIP) between the US and the EU. In parallel with discussing policies on investment and subsidies to be aligned with nutrition goals, taxation policies could be used to support such an objective – favourable or no VAT for products clearly contributing to a healthy diet, increased taxes on foods considered unhealthy and which consumption should be discouraged – especially among the most vulnerable population groups who tend to consume relatively more of such products (aka ‘heavy users’ according to the food and drink industry) as compared to the general population and therefore taking a significantly heavier toll of the poor diet-related burden of disease.

In addition to all the above suggested issues, the vision for a food system that cares for people’s nutrition, health and equity should take into account the issues of antibiotics’ over- and misuse in the livestock production system and these adding to this emerging public health threat, overproduction and overconsumption of animal proteins as compared with insufficient supply and consumption of fruit and vegetables, whole grain and legumes. It should also be emphasised to consider various health, social and environmental ‘externalities’ of the current food and agricultural production and consumption systems, that is to say both short- and long-term consequences of the current system that favours unsustainable cheap highly-processed and intensively-farmed calories and trades away regulatory power to a handful of agri-food multinationals accountable neither to governments, international institutions nor citizens but to their shareholders.

 

Having said that, we welcome the following statement ‘(EPHA add. before interests of industry) Governments are obliged to protect consumers, especially children (EPHA add. and other  highly vulnerable consumers), from misleading commercial messages (EPHA add. and financially appealing/attractive activities) promoting energy-dense but nutrition-poor foods, which can induce addictions and heighten the risk of disease’. Indeed, according to a ‘good governance-for-health’ approach, all relevant ministries and departments, together with whole-of-society actors should coordinate towards a shared goal of agriculture-food-health system.

 

For our comments on specific committments, please do see the attachment enclosed.