المنتدى العالمي المعني بالأمن الغذائي والتغذية

1. In Chapter No. 1 it is important to mention loss of nutrition in food itself. Research in the US and Great Britain has revealed that the nutrition of fruits and vegetables has declined drastically in the last fifty years. Average calcium content declined 19 percent; iron 22 percent; and potassium 14 percent. Today one would have to eat eight oranges to derive the same amount of Vitamin A as our grandparents would have gotten from one orange.

2. In Chapter 2 under guiding principles the Voluntary Guidelines should include the correcting mechanism of pricing patterns in favour of healthy foods. According to a survey by World Bank International Comparison Program conducted in 176 countries for  657 food products, unhealthy foods are much cheaper than healthy foods in poor countries. Hence unhealthy calories are easy preference for poor communities. And these poor diets are considered as the No. 1 risk factor in the global burden of disease.

3. Paragraph 41 should add policy measures to correct patterns in favour of healthy foods and against unhealthy foods. This could be done by imposing taxes on unhealthy foods and markets corrections for healthy foods.

4. For policy measures it is also important to include research and analysis of existing nutrients in healthy foods (related to the point 1 mentioned above). Additionally, rural women and  women farmers are deficient in various nutrients despite their significant contribution in food production.  Policy measure should include targeting rural women and women farmers for improving their level of nutrition.

5, Voluntary Guidelines should rolled out  for communities, CSOs, government and private sector through organized and concerted programs.

Please find attached the contribution from Humane Society International on the Zero Draft of the Voluntary Guidelines on Food Security and Nutrition. We appreciate the opportunity to comment on this draft!

Best regards,

Stefanie McNerney

Dear CFS colleagues,

On behalf of the Civil Society and Indigenous Peoples' Mechanism (CSM) Working Group for Food Systems and Nutrition, we are pleased to share our collective submission and comments on the Voluntary Guidelines on Food Systems and Nutrition.

 

Best regards,

CSM WG on Food Systems and Nutrition

Dear CFS colleagues,

Please find attached the contribution from World Cancer Research Fund International on the Zero Draft of the Voluntary Guidelines on Food Security and Nutrition. We are grateful for the opportunity to input into the zero draft and we look to forward to collaborating on this important document.

Kind regards

Kate Oldridge-Turner

Head of Policy and Public Affairs

Thank you very much for the opportunity to review this guideline which will be very useful for numerous governments and stakeholders working towards strengthening the food systems for improved nutrition.

Dear CFS colleagues,

Please find attached the World Bank’s comments on the Zero Draft for Voluntary Guidelines for Food Systems and Nutrition.

Best regards,

Astrid Jakobs

Dear FSN-Forum colleagues,

On behalf of the Thematic Group Food and Nutrition in Collective Health (GT- ANSC), from Brazilian Association of Collective Health (ABRASCOj), we are pleased to share our opinions and ideas about the Voluntary Guidelines on Food Systems and Nutrition and to submit our feedback.

Congratulations for the initiative.

Sincerely,

GT – ANSC/ ABRASCO - Brazil

***

1. Does Chapter 1 adequately reflect the current situation of malnutrition and its related causes and impacts, particularly in line with the goals and targets of the 2030 Agenda? What are the underlying problems that currently hinder food systems to deliver healthy diets?

COMMENTS:

The concept of healthy eating currently adopted in the document has already proved insufficient to meet the challenges of ensuring healthy eating for people. Focusing solely on the nutritional composition of diets does not foresee the immense challenges and the dimensions that condition people and societies to achieve this ideal composition. Therefore, it must be expanded to incorporate the aspects that determine and/or impact not only the individual health but also the economic, social and environmental sustainability of the food systems. An example of what we are proposing is the concept adopted in the "Dietary Guidelines for the Brazilian population":

“Adequate and healthy diet is a basic human right. This right implies ensuring permanent and regular access, in a socially fair manner, to food and ways of eating that satisfy the social and biological requirements of everybody. It also takes into account special dietary needs, and the needs to be culturally appropriate, and allow for differences in gender, race, and ethnicity. An adequate and healthy diet should be accessible both physically and financially, and harmonious in quantity and quality, meeting the needs of variety, balance, moderation, and pleasure. Furthermore, it should derive from sustainable practices of production and distribution.” (Brazil, 2014[1]).

It is necessary to clarify the unsustainability of the hegemonic food systems. We highlight here some of its characteristics of this unsustainability:

-      They are structured based on non-applicable assumptions (e.g., a stable climate, abundant water, cheap energy);

-      They are based on large estates, monoculture, and large-scale production;

-      They widely use non-food/natural components (pesticides, antibiotics, hormones, additives) harmful to the health of people and the planet;

-      They degrade ecosystems due to their methods of producing, storing, transporting and marketing food;

-      They are inefficient at various stages of the production process, generating waste and impacting prices;

-      They use technologies that threaten food sovereignty and biodiversity (e.g., genetic modification, biofortification);

-      They induce, through various mechanisms, the shift of consumption from fresh and minimally processed foods to processed and ultra-processed foods;

-      They threaten food culture and heritage;

-      They concentrate stages of the food chain in large transnational corporations (e.g., input and seed industries, food industries, large retail chains) that have high political and economic power and act to block public policies that go against their interests. Moreover, to enable measures that favor their business;

-      They reproduce and deepen the social inequities in access to land, water, energy, and income.

In short, hegemonic systems are based on an income-concentrating model that is highly dependent on large transnational corporations, which favors the production of unhealthy food, deepens inequities, and generates critical environmental repercussions. These characteristics impact not only individual and collective health but endanger the democracy and reach of the SDG as a whole, not just the SDG2.

It is also necessary to recognize the relationship between social inequalities and the occurrence of chronic diseases, as well as the decisive influence of hegemonic food systems for the current epidemiological scenario of increasing obesity and other chronic diseases. One publication that can help substantiate this argument is a report entitled "The Global Syndemic of Obesity, Undernutrition, and Climate Change: The Lancet Commission Report" by Boyd Swinburn and colleagues (Lancet, 2019[2]).

Similarly, another report also released by The Lancet brings resembling evidence and proposals indicating the urgency of incorporating a broader view of what is "healthy eating" and the strategies to make it viable and accessible to people.

References:

Swinburn, B. et al. The Global Syndemic of Obesity, Undernutrition, and Climate Change: The Lancet Commission Report"

https://www.thelancet.com/journals/lancet/article/PIIS0140-6736(18)32822-8/fulltext?utm_campaign=tlobesity19&utm_content=83639620&utm_medium=social&utm_source=twitter&hss_channel=tw-27013292#articleInformation

Willett, W.; Rockström, J.; Loken, B.; Springmann, M.; Lang, T.; Vermeulen, S. et al. Food in the Anthropocene: the EAT-Lancet Commission on healthy diets from sustainable food systems. The Lancet Commission, v. 393, n. 10170, p. 447-492, January 2019. http://dx.doi.org/10.1016/ S0140-6736(18)31788-4.

2. What should be the guiding principles to promote sustainable food systems that improve nutrition and enable healthy diets? What are your comments about the principles outlined in Chapter 2? Are they the most appropriate for your national/regional contexts?

COMMENTS:

Principle (f), "Realization of the human right to adequate food" should be the first to be cited and should be recognized as the structuring axis of all guidelines. In this sense, the guidelines must assume the inseparability of human rights, since rights such as land and territory are essential for the sustainability of food systems.

Principle (d), "gender equality and women's empowerment", should be addressed not only within the limits of women's role in food systems but in the promotion and protection of the rights to gender equality as a whole for the free and full realization of women, and, therefore, to reduce social injustice.

The following should also be included as guidelines principles:

-      Equality and non-discrimination;

-      The rights of indigenous peoples and traditional communities to land, territory and free exercise of their livelihoods;

-      Recognize that regenerative and traditional practices are services provided by indigenous peoples and traditional communities to protect the planet and humanity;

-      Protection and promotion of regenerative and sustainable production models;

-      Protection of the heritage and food culture of different peoples and communities;

-      Protection and health promotion of all workers involved in all stages of the food system;

-      Democratic governance, representative of the right holders, transparent and free of conflicts of interest.

3.     In consideration of the policy areas identified in Chapter 3 and the enabling factors suggested in paragraph 41 of the Zero Draft, what policy entry points should be covered in Chapter 3, taking into account the need to foster policy coherence and address policy fragmentation?

COMMENTS:

Considering the sharing of macro determinants of food systems and food and nutrition, we emphasize that for the Voluntary Guidelines to have the potential for effectiveness in addressing the unsustainability of food systems and addressing all forms of malnutrition, public policies need to move forward taking back the regulatory role of Member States (promoting, protecting nutrition and sustainable food systems) so that food is a public good. The inclusion of protection and promotion of socio-biodiversity is also suggested.

4.     Can you provide specific examples of new policies, interventions, initiatives, alliances and institutional arrangements which should be considered, as well as challenges, constraints, and trade-offs relevant to the three constituent elements of food systems presented in Chapter 3? In your view, what would the "ideal" food system look like, and what targets/metrics can help guide policy-making?

COMMENTS:

-      Taxation to reduce the consumption of unhealthy products;

-      Incentives to expand financial access to healthy food (exemption);

-      Public policies to expand access to healthy food. Food supply system to promote physical and financial access to healthy foods (short circuits, growers' markets, fairs, protection, and promotion of small businesses). Generating a direct action to induce retail trade with healthy products in regions of lower purchasing power, to reduce deserts and food swamps;

-      Regulation of all practices of commercial promotion of unhealthy products mainly aimed at children (advertising, TV, internet, event financing, marketing and merchandising in public equipment in general and in schools in particular)

-      Food labeling with front warning;

-      Update of health claims regulation rules on food labels;

-      Prohibition of marketing and advertising of unhealthy products in government administered facilities in general, and in schools in particular;

-    Inclusion in the school curriculum of an approach of the multiple determinants of food and nutrition to promote autonomy, valorization of self-care and development of skills;

-    Approach to food and nutrition education beyond the biological dimension to generate autonomy, critical capacity, and skills. Following the concept and principles adopted in Brazil (BRASIL, 2012):

"Food and Nutrition Education, in the context of the realization of the Human Right to Adequate Food and the guarantee of Food and Nutrition Security, is a continuous and permanent, intersectoral and multi-professional field of knowledge and practice that aims to promote the independent and voluntary practice of habits. healthy eating”.

-      Food and Nutrition Education should be governed by the principles:

• Social, environmental and economic sustainability;
• A comprehensive approach to the food system;
• Appreciation of the local food culture and respect for the diversity of opinions and perspectives, considering the legitimacy of knowledge of different natures;
• Food and meals and as references;
• Cooking skills as an emancipatory practice;
• Education as a continual process that generates autonomy and active and informed participation of the subjects;
• Diversity in practice scenarios;
• Intersectoriality;
• Planning, evaluation, and monitoring of actions.

Reference:

Brasil. Marco de Referência de Educação Alimentar e Nutricional para as Políticas Públicas, 2012. http://www.cfn.org.br/wp-content/uploads/2017/03/marco_EAN.pdf

5.     How would these Voluntary Guidelines be most useful for different stakeholders, especially at national and regional levels, once endorsed by CFS?

COMMENTS:

In both central and peripheral countries, contemporary food systems respond to the private logic of capital, which operates globally. As a result, there is a homogenization in dietary patterns, and industry determine what and how populations should eat. Dominated by large transnational corporations, food systems, in their present configuration, are unsustainable in terms of promoting food and nutrition security, either nationally or regionally.

In addition to the environmental impact, which is destructive to large-scale agricultural production based on the intensive use of transgenic seeds and pesticides, there has been a marked change in global food systems in recent decades, with the replacement of meals based on with food and culinary ingredients for ready meals, made up of ultra-processed foods, which significantly affects the health and nutrition of populations. From this perspective, there are no sustainable food systems, since they are not subordinated to human needs, but the needs of capital.

On the other hand, thinking about public policy actions related to food and nutrition, presupposes an understanding that states operate in line with the global logic of the commodity-producing system, in its different phases of accumulation. This will lead to more or less investment in national policies that will reduce social inequalities and different forms of malnutrition and promote the development of sustainable food systems.

Thus, the discussion here does not end with the finding of common sense, according to which it is a matter of the political will of rulers to end social inequalities since they are a constitutive element of the successive crises of capital. Thus, to tackle this issue at its root, it is necessary to broaden the discussion to other global forums that focus on the direction that world economic policies are taking and their societal consequences. Depending on the global pressure, caused by broader movements, it will be possible to envisage public policies that favor state regulation of food systems, towards the construction of sustainable systems capable of producing healthy food. Under these assumptions, it is necessary to consider the correlation of forces that is capable of forcing national states to act more closely to human needs, producing movements of state regulation regarding agricultural and industrial food production.

References:

Machado PP, Oliveira NRF, Mendes AN. O indigesto sistema do alimento mercadoria. Saúde Soc. São Paulo, v.25, n.2, p.505-515, 2016 http://www.scielo.br/pdf/sausoc/v25n2/1984-0470-sausoc-25-02-00505.pdf

Monteiro CA et al. Ultra-processed products are becoming dominant in the global food system. Obesity Reviews, Londres, v. 14, n. 2, p. 21-28, 2013.

MONTEIRO, G.; FARINA, EMMQ; NUNES, R. Food-retail development and the myth of everyday low prices: the case of Brazil. Development Policy Review, London, v. 30, n. Jan 2012, p. 49-66, 2012. Disponível em: < http://onlinelibrary.wiley.com/doi/10.1111/j.1467-7679.2012.00559.x/pdf >.

Pochmann M. Estado e capitalismo no Brasil: a inflexão atual no padrão das políticas públicas do ciclo político da nova república. Educ. Soc., Campinas, v. 38, nº. 139, p.309-330, abr.-jun., 2017. http://www.scielo.br/pdf/es/v38n139/1678-4626-es-38-139-00309.pdf.

[1] http://bvsms.saude.gov.br/bvs/publicacoes/dietary_guidelines_brazilian_population.pdf

[2]https://www.thelancet.com/journals/lancet/article/PIIS0140-6736(18)3282…

In regards to the below consultation on 'CFS policy process on the development of the Voluntary Guidelines on Food Systems and Nutrition', Freshfel Europe (The European Produce Association) would like to submit a response.



Please find attached Freshfel Europe's response to the consultation.



Thank you for this opportunity to contribute to the development of the Voluntary Guidelines and please do not hesitate to contact me if you have any queries.  



Kind regards,



Nicola Pisano

Communications Manager & Policy Advisor

Freshfel Europe

The forum for the fresh produce industry



 

Dear FSN-Moderator

We are pleased to take the opportunity to submit feedback and ideas on the zero draft of the Voluntary Guidelines on Food Systems and Nutrition.

Our submissions emphasises the importance of engaging women in all relevant topics of the VG, the role of fish and other points on education and multi-sectoral actions.

We trust this will be useful in revising the zero draft.

Sincerely

Kafayat Fakoya and Meryl Williams

To the CFS Secretariat

The Embassy of Colombia on behalf of the government of Colombia would kindly send the attach documents which contains the main feedback and comments regarding the five main guiding questions presented on the template.

Best regards,

Angélica María Castillo Moncada