The Children’s Investment Fund Foundation (CIFF) thanks the FAO and WHO for the opportunity to comment on this draft. We would like to see greater recognition of the cross-cutting nature of nutrition in this accord. The food system is vital, however given that ICN2 looks beyond FAO’s mandate, this accord should recognise the importance of making family planning, social protection, health systems, water and sanitation provision, education, poverty reduction, trade, finance and governance more nutrition-sensitive.
1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?
The first half of paragraphs 12 and 13 outline the importance of safe food and water, income, education and healthcare. The introduction would be stronger if it reflected this from the outset:
Paragraph 1. As well as recognising malnutrition as one of the greatest threats to people’s health and well-being, the paragraph should recognise that malnutrition is a threat to livelihoods, health, education and, as a consequence of this, a nation’s future.
Paragraph 3. This paragraph focuses on food systems as a critical cause of malnutrition. The Accord would be stronger if it went beyond food systems and recognised the multiple causes of malnutrition. Alternatively, the drafting committee could include a fourth paragraph highlighting the importance of health, education, income, access to markets.
2. Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?
Overall, we would like to see this section focus both on nutrition within the food system and nutrition outside of the food system. The acknowledgement of nutrition as a cross-cutting issue is cursory at present.
Paragraph 5. If a child’s nutritional status is to be given every possible chance, it is also imperative that the nutrition of adolescent girls is also targeted in order to break the intergenerational cycle of malnutrition. As such, we recommend adding the following text to the end of the paragraph 5: “such as the first 1,000 days of life or during girls’ adolescence”.
Paragraph 7. This paragraph should recognise the 6 WHA goals to improve maternal, infant and young child nutrition.
Paragraph 8. This should recall WHA65/6 : Comprehensive implementation plan on maternal, infant and young child nutrition.
Paragraph 12. The first half of the paragraph recognises that nutrition cuts across every sector in government. However the second half of the paragraph focuses again on food systems, stating that “Public policies should deal with both food supply and demand”. We suggest that the second half of the paragraph should state that “public policies should deal with malnutrition across all sectors, focusing on both prevention and treatment”. We suggest the second half of this paragraph is moved into a separate paragraph as it currently weakens the message that malnutrition is a cross-cutting issue.
Paragraph 13. The first sentence in this paragraph, which recognises that “increased public investment to improve nutrition is needed, including more equitable access to safe food and water, income, education and healthcare – all necessary to ensure universal access to healthy diets.” We suggest amending the last part of this sentence to “all necessary to reduce malnutrition”. In the same vein, we suggest making the second half of this paragraph a separate para (from “continued efforts are needed”) in order not avoid dilution of the impact of all sectors on malnutrition.
Paragraph 18. We welcome the focus on government leadership and responsibility on nutrition. We also welcome the focus on institutional capacity. However, we believe that the sentence, “Governments’ investment plans should target food systems with the aim of improving the availability, accessibility and acceptability of healthy food” should not just focus on food systems, but should recognise the importance of nutrition-sensitive family planning[i], social protection, health systems, water and sanitation provision, education, poverty reduction, trade, finance and governance.
Paragraph 19. This paragraph is focused on the food system; again, we’d like to see it broadened out to recognise the factors beyond the food system which would contribute to eradicating malnutrition, as per the first halves of paras 12 and 13.
Paragraph 20. We strongly support the emphasis on data systems and accountability, and would welcome more reference to this as a factor that would contribute to better nutrition outcomes throughout the document.
3. Do you have any comments on the commitments proposed in the political declaration? In this connection, do you have any suggestions to contribute to a more technical elaboration to guide action and implementation on these commitments (paragraphs 21-23 of the zero draft)?
Although the food system is critical, this section – including the commitments - should recognise nutrition outside of the food system more. This should include reference to all countries establishing a multi-sectoral coordination mechanism for nutrition to ensure that policy decisions are owned by all relevant ministries, and emphasise the need for nutrition-sensitive plans across government sectors.
22. Commit to launch a Decade of Action on Nutrition guided by a Framework for Action and to report biennially on its implementation to FAO, WHO and ECOSOC.
Paragraph 22. We would like to see this reference the WHA 2025 targets on nutrition specifically. It’s also vital that this decade of action focuses on nutrition as a cross-cutting issue, not just within the food system.
23. Commit to integrate the objectives and directions of the Ten Year Framework for Action into the post-2015 global development efforts.
Paragraph 23. Again, reference to the WHA targets, which are widely accepted, should be included here.
[i] Given the importance of adolescent mothers in nutrition, family planning should include a specific focus on adolescent reproductive health.