Dear FSN Forum Team, Dear FSN Forum members,
The International Dairy Federation has been actively engaged through the CFS Private Sector Mechanism in drafting these voluntary guidelines on food systems and nutrition, and appreciates this additional opportunity to provide comments through this open consultation. We would like to commend Dr Liliane Ortega, CFS Food Systems and Nutrition OEWG Chair as well as the CFS secretariat for the work done so far.
We support the report acknowledgment of the complexity of the food systems and the many drivers which impacts them, as well as the need to take a holistic and evidence-based approach and foster dialogue among the different sectors.
As a general comment, throughout the document, CFS should:
- Ensure definitions of “healthy diets” remain focused on encouraging consumers to adopt and maintain balanced diets and do not directly or indirectly exclude or limit consumption of nutrient dense whole foods such as dairy products;
- Ensure all guidelines are science-based and consistent with WTO, Codex, and other international obligations;
- Ensure nutrient dense foods such as dairy are recognized as a critical source for their key nutrients; especially for populations at high risk of nutrient insecurity such as children and pregnant women
- Ensure the voluntary guidelines recognize the positive role of international trade in increasing access to and availability of a variety of foods, including dairy products;
- Guard against overt or disguised protectionism that decreases access to and availability of a variety of foods, including dairy products;
- Ensure environmental sustainability considerations are science-based and reflect the relative and absolute nutritional benefits of dairy foods.
- Carefully consider whether the voluntary guidelines as currently drafted will duplicate work or overlap with the mandates of other international organizations.
- Provide mechanism to revisit guidelines/set timeframe for update of global progress towards reduction in malnutrition.
- Acknowledge that due to regional and population differences that affect the HLPE five main categories of food system functionality, there is no single universal diet that combats malnutrition and ensures sustainable practices.
- Importantly, they should allow for the definition of “healthy diets” to include countries’ own national dietary guidelines instead of solely being defined by WHO indications.
- Acknowledge that trade-offs will exist within a food system in order to sustainably achieve a reduction in malnutrition and that countries should make these trade-off decisions based on regional and population relevant science-based information.
- Recognize that while smallholder farmers are necessary to help combat malnutrition, large holder farmers also play a significant role in sustainably reducing global malnutrition.
Milk and dairy foods are well-known for being naturally nutrient rich, providing an abundant supply high quality protein, calcium, phosphorus, potassium, iodine, and vitamins B2 and B12. This unique package of essential nutrients contribute to address all forms of malnutrition; it is associated with better growth, micronutrient status, cognitive performance and motor function development. In addition, several dairy products are scientifically proven to protect against some non-communicable diseases. There is an inverse association between dairy intake and colorectal cancer as well as between yogurt intake and risk of type 2 diabetes and between milk and stroke.
Dairy is then part of healthy diet and a major contributor to helping achieve many of the UN Sustainable Development Goals (SDGs) such as zero hunger and health and well-being as well as providing reliable livelihoods, helping to lift people out of poverty, empowering women, caring for the land, and much more.
The dairy community supports the CFS work to develop these voluntary guidelines on food systems and nutrition but wants to ensure that the role dairy products in making whole diets healthy is recognized.
Please find in attached documents our detailed comments on the draft voluntary guidelines on food system and nutrition.