Dear members of the Joint FAO/WHO ICN2 Secretariat,
El Poder del Consumidor would like to contribute with the following comments, also attached.
El Poder del Consumidor A.C. (Consumers Power NGO) recognizes the efforts made for this documents and highlights the great importance for civil society, academia and experts to comment on it.
Do you have any general comments on the draft Framework for Action?
Our general observations are the following:
- The Framework For Action overall does not include the human rights approach in the different proposed actions nor in the different subjects established
- There are strong inconsistencies between the background and justification given in each point with the actions proposed. The actions are very limited and broad.
- Private sector is being given much interaction and space in the “food systems”, when it has been one of the key elements that have “diminished” the food systems of the world.
- Conflict of interest is poorly mentioned
- Accountability mechanisms stay broad and unknown
- Proposals for “food systems” are not based on small and medium agriculture, but in “bio-fortification”, which does not necessarily mean is based on traditional practices and supportive to small producers. When biofortification is mentioned it must be accompanied with “biofortification through traditional methods that protect native seeds, not through any form of genetic modification for biodiversity will be severely affected.
-Biodiversity needs to be mentioned as a priority.
-A system of protection of native seeds and origin centers needs to be established.
-Actions do not include the protection of native seeds of the different regions, origin centers, and biodiversity throughout the world.
-Violations to human rights through unethical procedures are not mentioned at all, nevertheless the accountability for them.
- Sovereignty is not mentioned at all in the entire document. Sovereignty is one of the most important aspect in the different food systems of the world and essential to combat malnutrition in all its forms.
-Full recommendation for breastfeeding is only mentioned once and is not mentioned in the proposed actions. The full recommendation needs to be promoted and protected among governments.
-Proposals for healthy diets are very broad, not concrete at all and they do not lead to the desired outcomes. A Convention framework with Global Recommendations needs to be implemented in the different countries, as it was with tobacco.
-It does not establish which will be the mechanisms to reach free access to drinking water in all regions. It leaves it open to whoever (industry), instead of structuring a mechanisms for governments to fully cover such issue.
-12 different official documents are mentioned in the background and justification, but non are mentioned in the priority actions, except for breastfeeding, and the International Code for Marketing of Breastmilk substitutes is not mentioned among the priority actions to implement.
-Background mentions very broadly the need to integrate private sector, multisectorial approaches, private-public partnerships, but it does not make the same emphasis for academia, scientific public interest bodies and public interest civil society integration.
-Actions on access to water and sanitation needs to establish the mechanisms and the need for such mechanisms to be without conflict of interest.
-Compromises on breastfeeding need to integrate the complete recommendation of WHO, which the introduction of safe nutritious foods, and to continue breastfeeding until 2 years or beyond.
Do you have any comments on chapter 1-2?
Industry involvement needs to be very well established, the accountability mechanisms and the management of conflict of interests. Though in the priority actions for nutrition governance is mentioned once, the mechanisms need to be very well established.
Definition of the term global food system needs to be clear. Additional, food systems have been gravely transformed in the past decades, but it cannot be assumed that all the different food systems in the world are failing.
We believe that when referring to “partnership” with private sector it needs to be substituted by “interaction” with private sector.
Do you have any comments on chapter 3 (3.1 Food systems, 3.2 Social Protection; 3.3 Health; 3.4 International trade and investment)?
Rights vs-Risk Approach
Pg 7 (last paragraph): The wording of this paragraph makes me a bit uncomfortable because it seems to follow a risk-based approach rather than a rights-based approach and it barely mentions regulation. Access to sufficient, safe and nutritious food is a human right so the idea of making ‘trade-offs’ between ‘nutrition targets and other goals’ (ie. financial) of food systems seems too lenient and pro-industry. Sure, win-win solutions that work for improving both public health and business should be identified when possible but this paragraph seems to give industry too much leeway. It seems to suggest that only if ‘it pays to do so’ should the private sector be expected to facilitate public health improvements. I think the importance of regulating industry should be mentioned more prominently here because sometimes doing what is right for public health is not going to be in the financial interest of companies but it still needs to be done to uphold human rights. Ultimately, the private sector cannot be excused from acting in support of public health just because it doing so doesn’t support its financial interests.
Priority actions to improve the food environment
Pg 11-12: In the general text about food environments the goals of the Global NCD Action Plan are reiterated. These goals include setting policies and guidelines that aim to replace trans fats with unsaturated fats, replace staturated fats with unsaturated fats and reduce added sugars in food and non-alcoholic beverages. The FFA notes these goals but when stating the priority actions for the food environment only a regulation on trans-fat is discussed. To be consistent and more thorough the FFA should also include priority actions related to reducing sat. fats and added sugars in foods and beverages. It doesn’t seem sensible to just prioritize the removal of trans-fats.
Pg 12: Standards vs Regulations: It might be useful to highlight that the FFA talks about setting regulations to remove industry trans fats but when discussing other measures for creating a healthy environment they use terms like ‘standards’, ‘incentives’ and ‘rules’. There might be a reason for the use of these different terms but I’m not sure why they can’t use a stronger term like regulation for these measures. For example, improving the school environment by setting food-based or nutrient-based standards for foods—why can’t this be statutory policy/regulation and not just a ‘standard’. I might be misunderstanding something but I wanted to flag the terminology.
Pg 12: Institutional standards: When the FFA talks about setting standards for healthy food it should state the need to use a nutrient profile model free of conflict of interest to define these foods.
Pg 21 (3rd full para): This paragraph says ‘nutrient profiling has been used as a tool to qualify the nutritional value’. I think a sentence should be added that nutrient profile models should be developed by experts (nutritionists, nutrition scientists) and free from conflicting commercial interests. This rationale is based on Brinsden and Lobstein (2013) who state that:
‘[I]ndustry-led nutrient profiling schemes are less effective in restricting the advertising of energy-dense foods compared to government-led models.’
‘[I]ndustry-led nutrient profiling schemes particularly favour the continued advertising of foods high in sugar.’
Bio-fortification & Agroforestry
Regarding the topic of bio-fortification and the multiple references to ‘bio-fortified crops’ and ‘bio-fortified foods’ there needs to be established the importance of protecting native seeds and the centers of origin. It needs to specify and make clear that such bio-fortification can be proposed but by using traditional methods, not genetically modified methods. Also can be a mention of agroforestry that might be useful. ‘Agroforestry intentionally combines agriculture and forestry to create integrated and sustainable land-use systems.’ (USDA). It can be an alternative method for improving conventional agriculture, improving biodiversity and soil quality and reducing deforestation, erosion and the use of fertilizers. The term agroforestry is also mentioned in the civil societies Recommendations for the FFA yet not in the draft FFA. It might be useful to point out that the FFA does not mention agroforestry despite its priority to ‘promote dietary quality and diversity’ and improve the nutritional quality of foods and diets.
Reiterate Civil Society Recommendations for the FFA (Rome, June 20 2014)
· CS recommendations state that ‘Commitments made in the FFA should be specific and time-bound’. It doesn’t seem like the FFA has taken this into consideration.
· CS recommendations state that processes should be participatory and bottom-up. These words and the spirit behind them should be incorporated in the FFA. The success of the proposed actions is dependent on getting concensus and buy-in from the community and community leaders.
Do you have any comments on chapter 4-5?
Use of term ‘Appropriate’
Throughout the document the term ‘appropriate’ is utilized. It seems very ambiguous. There is a need for this document to be general enough to be applicable in many settings but maybe using terms like ‘just’ or ‘equitable’ rather than ‘appropriate’ is preferable.
Does the Framework for Action adequately reflect the commitments of the Rome Declaration on Nutrition, and how could this be improved?
No. We believe it does not reflect the commitments. We believe civil society´s contributions need to be incorporated.
Does the Framework for Action provide sufficient guidance to realize the commitments made?
No, we believe it does not provide sufficient guidance and it can be confusing. We are very concerned for we are observing comments coming from different organizations and movements from civil society are not being incorporated.
Are there any issues which are missing in the draft Framework for Action to ensure the effective implementation of the commitments and action to achieve the objectives of the ICN2 and its Declaration?
Accountability mechanisms overall and conflict of interest management.
Genetically modified organisms
Protection of biodiversity
Protection of native seeds and centers of origin