Global Forum on Food Security and Nutrition (FSN Forum)

The International Diabetes Federation (IDF) response to the ICN2 Framework for Action zero draft to implement the Rome Declaration on Nutrition, August 2014

The International Diabetes Federation (IDF) is an umbrella organization of over 230 national diabetes associations in 170 countries and territories. It represents the interests of the growing number of people with diabetes and those at risk. As a founding federation of the NCD Alliance, IDF fully supports and reinforces all comments made in the NCD Alliance submission.

The International Diabetes Federation (IDF) welcomes the opportunity to provide comments on the diabetes perspective to the ICN2 Framework for Action zero draft.

 Chapter 1

IDF regrets that overconsumption (defined as population-wide increased consumption of energy-dense food products) does not appear listed as a form of malnutrition in the background section. However, we welcome the inclusion of the ‘food systems’ concept and the acknowledgement of the deep and fast changes they are undergoing and their implications in nutritional outcomes.

We request that the omission of diabetes in the commitment made by the 66th WHA on ‘halting the increase in obesity prevalence in adolescents and adults’ is amended.

Chapter 2

IDF agrees that further global and national financing is needed to improve nutrition outcomes and develop interventions that are cost-effective in the mid- and long-term. Diabetes and other non-communicable diseases (NCDs) pose an economic burden to society on two counts.  Diabetes predominantly affects people of working age leading to significant loss of economic activity and productivity. In addition, diabetes-related health expenditure totalled at least US$ 548 billion in 2013 and IDF estimates that it will exceed US$ 627 billion by 2035.

We agree that resources for financing improved nutrition outcomes should be partly generated through national taxes: according to a recent report by the European Commission[1], food taxes result in a reduction in the consumption of the taxed products. However, taxation measures need to be coherent, to avoid consumers switching to similar but un-taxed or less-taxed unhealthy products.

Chapter 3

IDF agrees that the protection of the nutritional quality of diets needs to be prioritised. We particularly appreciate that WHO recommendations on the intake of free sugars are included in this Framework for Action. However, in order for these recommendations to have the highest possible impact, we urge WHO to finalise its work on the guidelines on free sugars intake for children and adults as soon as possible.

Among the set of priority actions proposed across this chapter, those regarding maternal nutrition status before and during pregnancy, and nutritional status during the ‘first 1000 days’ are of particular relevance for diabetes. Maternal overweight and obesity at the time of pregnancy (a risk factor for childhood obesity and gestational diabetes) have steadily increased in low- and middle-income countries (LMICs) since 1980. This trans-generational transmission of obesity is fuelling the diabetes epidemic in the LMICs, where 80% of the people with diabetes live. 

IDF also welcomes actions regarding nutrition education for behavioural change as a measure to tackle diabetes in the long-term. Nutrient profiling can be one useful tool to help consumers make healthy choices, but so far implementation has been geographically uneven and information about servings has proven to be insufficient, unclear and, in some cases, misleading.

Chapter 4

IDF welcomes the accountability framework to be developed with input from different national ministries and international agencies, given nutrition is a cross-cutting issue. However, as the Rome Declaration will be adopted during ICN2 in November 2014, we urge the involved actors to agree on a Framework for Action within the shortest possible time.

 The Framework for Action provides two groups of priority actions to incentivize healthy dietary choices, including price reductions on healthy foods and the creation of fiscal incentives and disincentives. However, these actions will not be successful if the production of crops used in highly-processed food (e.g. sugar) continues to be incentivized. Therefore, IDF requests that the priority actions for food systems specifically include disincentivizing the production of such crops, in order to attain policy coherence across the different areas of action.

As for the format of the Framework for Action, we believe that priority actions would be clearer if they are set out in the same format as the commitments included in the Rome Declaration, in the shape of a shorter and more concise document.

 Although some of the priority actions offered are well developed and even offer examples, others lack that depth. IDF recommends priority actions to be specific and, where possible, to reference good practices that have proven to be effective to date.

 With the Sustainable Development Goals’ discussions ongoing, now is the moment to act to address malnutrition in all its forms. Therefore, as previously stated in the comments for chapter 4, IDF recommends finalising the work on this Framework for Action as soon as possible, so it can contribute to the post-2015 framework from the beginning.

We also urge to continue involving civil society in consultations and call on assuring its participation in accountability processes.