المنتدى العالمي المعني بالأمن الغذائي والتغذية

The International Dairy Federation (IDF) is grateful for the opportunity to comment on the First Draft of the Work Programme of the UN Decade of Action on Nutrition, 2016-2025 (dated 27 January 2017). Since 1903, IDF is the pre-eminent source of scientific and technical expertise for all stakeholders of the dairy chain. IDF commits to help nourish the world with safe and sustainable dairy.

We congratulate the UN for drafting such an ambitious working program. As clearly addressed in the document, the solution to achieve this work program is by combined and coordinated efforts across all actors. International federations such as the IDF through the broad membership they represent can play an essential role in facilitating these partnerships. Industry can help through its expertise by knowledge sharing of social responsibility programmes, technical expertise for cost-effective product development, processing and distribution, as well as providing platforms for advocacy and education. We therefore strongly urge for that open and inclusive dialogue amongst all stakeholders.

We continue to advocate for a focus on foods and diets rather than single nutrients in any policy development and activities, other than where specific micronutrient deficiencies need to be addressed through targeted food fortification and/or supplements. Foods and diets are far more than the sum of their individual nutrients. Nutrients are not consumed in isolation and it is inaccurate to generalize about the effects of a single nutrient without considering the food matrix in which it is present. In some countries, dietary guidelines are shifting away from recommendations based on nutrients or foods in isolation and now focus primarily on healthy eating patterns. Overall, no single food or nutrient creates a healthy dietary pattern, but instead, it is the combination of nutrient-dense foods that is emphasized: “…dietary components of an eating pattern can have interactive, synergistic, and potentially cumulative relationships, such that the eating pattern may be more predictive of overall health status and disease risk than individual foods or nutrients[i]”.

Nutrition science has moved on from just focusing on nutrients in isolation – it also considers foods and dietary patterns that are associated with good health.  Nutrition policies need to take this into account[ii].  

We note that Point 21 suggests that a healthy diet is one that contains adequate macronutrients, fibre and essential micronutrients.  This is too reductionist a view as food is much more than this. 

• We suggest that the text is amended to reflect these points. 

Table 1 suggests establishing an action network focused on food reformulation.  The danger with this is that there is too much focus on single nutrients and too little on the overall impact of a food.   Focusing on reformulation can lead to the use of oversimplified paradigms which in turn may undermine minimally processed, naturally nutritious foods.  Nutrition policies that target the decrease or increase of the consumption of single nutrients will result in a modification of the effects of the food and even the diet itself. Food reformulation can be complex, and simply taking out a nutrient is often not feasible. Typically, the nutrient that is removed provides properties that are important for food safety and/or acceptability of a product. In products where fat is removed to produce a low fat or fat free product, carbohydrates (mostly refined) are often added to maintain an acceptable flavour or texture profile[iii]. This could be counterproductive to reducing levels of obesity and risk of non-communicable disease. As addressed in the FAO/WHO report replacing SFA largely with refined carbohydrate has no benefit on CHD and may even increase the risk of CHD and favour the development of metabolic syndrome [iv] [v].

Reformulation is also a way for highly processed unhealthy foods to be positioned as being healthy. 

• We suggest that all action networks should take a whole of food/dietary pattern approach rather than focusing on single nutrients in isolation.

It is essential that before implementing any new policies or activities there should be clear evidence for a positive impact and a risk based assessment should be considered to identify any potential negative consequences.

We also note that table 1 reference sustainable livestock production. While the concept of sustainable food systems is not new, much more research is needed to establish the scientific foundation on which informed recommendations for sustainable, healthy diets can be made.

A sustainable food system must meet the nutritional needs of the human population while not depleting or degrading the natural resources upon which life depends, as indicated in this definition by the United Nations Environmental Program:

“Sustainable food systems enable the production of sufficient, nutritious food, while conserving the resources that the food system depends on and lowering its environmental impacts. Such systems are based on the idea that all activities related to food (producing, processing, transporting, storing, marketing and consuming) are interconnected and interactive.[vi]”

The concept of sustainable diets contains additional aspects of sustainability related to the human population, as described in the Food and Agriculture Organization’s definition of sustainable diets:

“Sustainable diets are those diets with low environmental impacts which contribute to food and nutrition security and to healthy life for present and future generations. Sustainable diets are protective and respectful of biodiversity and ecosystems, culturally acceptable, accessible, economically fair and affordable, nutritionally adequate, safe and healthy; while optimizing natural and human resources.[vii]”

Whether framed as sustainable food systems, sustainable healthy diets, or nutrition security, the underlying systems - agricultural, environmental, social, and economic - are connected to one another in ways that are only recently being understood and appreciated by scientists and policymakers. A coordinated, interdisciplinary approach is needed to gain vital insights on interrelated dynamic and adaptive processes within and across these systems. Dietary guidance based on an incomplete research base could lead to unintended consequences for both human health and the long-term sustainability of the food system.

Finally, we continue to support policy development that acknowledges the important and valuable role that dairy plays in balanced and varied diets. Dairy products are nutrient-dense foods that can help reduce malnutrition throughout the world, with increasing evidence that diets containing dairy help reduce the risk of obesity and NCDs.