Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

ICN2 provides a great opportunity to build on the current momentum for investing in nutrition.  Compared to ICN (2 plus decades ago), how can this document capture advances, challenges and new knowlegde in a dramatically different global environment to advance nutrition interventions and create action?

1.    Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?                   

I would like to see a more current and disaggregated description of the advances in the past 25 years and in the threats to malnutrition in global development.  First, a recognition that the past two decades have shown remarkable economic growth and reduction in child mortality (and a lesser degree) maternal mortality in many developing countries, with many of these countries graduating from low to middle income classification.  Second, although this is true throughout Asia, Latin America and Sub-Saharan Africa, recognition that countries are at different stages of economic development and nutrition transition.  Even in low or middle-income countries, there is variation in economic prosperity and nutrition transition, where some urban areas thrive and face threats similar health, environment and market threats to those in higher income countries.  Recognizing these differences up front and introducing language to be more specific to country typologies would be helpful.   Within this context, stunting rates have declined 35% globally since 1990, and wasting has reduced 36% since 1990.  It will be important to identify where the gains and progress have been made and how.  This should help to make the vision, reshaping food systems, and action more specific and relevant to the diverse exposures to risk factors.

The global environment has changed drastically since 1992, contributing both progress and new and emerging threats to nutrition.  The bullets in number 2 are predominantly negative and almost dismissive of what progress has occurred.  Have there really been no advances worth noting?  I would suggest some recognition of progress, advances or successes.  What about a bullet that recognizes advances that explicitly include improvements in nutrition outcome trends in some countries, regions, parts of regions, etc.?   What about recognition that the awareness and attention to nutrition in the past decade has increased, and then have a vision to leverage and build on that unprecedented momentum (i.e. two Lancet issues on child nutrition in 2008 and 2013, SUN, donor support to nutrition –USAID & DFID). 

The focus is very much on food, and fails to recognize more immediate determinants of malnutrition (food intake and disease), and some of the more critical underlying determinants of malnutrition (healthy environment, health services, access to health care, caring practices) and the enabling environment, which is mentioned later, but should be in the introduction (education, water and sanitation, infrastructure, markets).    Also, in number 3, this would be a good place to explicitly recognize how urbanization, globalization, & income growth have changed food availability, physical activity levels, diets, etc.

Recently, a number of reviews have identified what works for nutrition specific interventions (Lancet 2008 and 2013), and systematic reviews have also identified weaknesses in methods for looking at links between agriculture and nutrition—the latter being a major threat to designing and improving programs to address nutrition in the future.  The global environment that conditions nutrition and our knowledge base for nutrition are very different place from 1992, but the background does not capture that.

2.    Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?              

Make the life-cycle approach to nutrition more central to this document.  Can there be a vision for global action  that embraces and evolves around nutrition over the life-cycle?  Can this be expanded to be explicit—reference the first 1000 days and other critical age groups.  For instance, we know that maternal nutrition may be difficult to improve once a woman is pregnant, and recognition that we need to reach girl adolescents is emerging, as a way to prepare for 1000 days.  Similarly, from a macro perspective, recognize that countries are in different stages of the nutrition transition.  So, individual target groups have different needs, and countries have different needs.  

Add a new vision  that  explicitly commits actions by other sectors.  For instance a vision that commits to increase access to health care, to immunize children against preventable diseases, to increase access to education, water and sanitation, to improve the quality of national, household and individual diet.  This may have the effect of reaching across the aisle to other sectors that affect nutrition (agriculture, education, water & sanitation, health).  This is a great opportunity to expand the vision for global action to end malnutrition.  If these are explicit, then those sectors may also have a vested interest in success.  This links to number 12 and 13.

The focus of  ‘Reshaping the food system to improve people’s nutrition’ is too strongly on food systems and should be renamed to capture the complexity of different sectors, governments, and other actions listed in that section.  For instance numbers 12 and 13 actually reference other sectors that have independent affects on nutrition, not necessarily through food systems.    These seem out of place where they are placed in the document.  Similarly, number 15-20  focus on govenance, and other issues.   Also, number 13 which addresses an important issue of equity combines a number of different aspects, but could be rewritten to highlight this issue more clearly explain factors affecting supply and demand and what it means to make a food system more equitable.  This gets lost in the current version.

I’d love to see a header that promotes integration nutrition as part of public health programs, community outreach, agriculture policies and programs.   What would that look like?  How can strengthening policies, investment, integrated programs maximize nutrition outcomes?

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)?

The commitment to action is heavily focused on food systems to improve nutrition.  This is a limited view of improving nutrition, and must recognize the other pathways that affect nutrition, including health services, health environment, caring practices, etc.

It is hard to align the commitments to the numbered points in 4-20.  I think each commitment should be clearly and strongly linked to specific numbers 4-20, so the reader can fully understand the commitments.

Lastly, I found many of the terms within commitments, i.e. ‘aligning food systems’ or ‘making food systems equitable’ or the commitments themselves too vague, and further crafting of the commitment could strengthen the full set.

SCs comments on the Rome Accord – ICN2 zero draft political outcome document for 19 November 2014

Save the Children would like to thank the organisers of ICN2 for the effort they have put into organising the event so far, and the opportunity to comment on the zero draft.

22 years after the first ICN, enormous progress has been made to tackle malnutrition but much work is still to be done. Save the Children calls upon the organisers of ICN2 to make the most of this opportunity and to garner strong commitments from states towards nutrition. The proposed zero draft is a good first step in ensuring that ICN2 is a success. But for political commitments to translate into action they must be specific.

We find the document a bit too weighted towards food security and systems. Whilst this is obviously important it doesn’t really include any emphasis on direct nutrition interventions. We make some suggestions on this but we think this should come out more strongly overall, for example the package of 10/13 DNIs should be mentioned. This may also be reflected more in the commitments, eg. under commitment 5 “establishing governments’ leadership for shaping food systems” we should have an addition of “promoting good nutrition”.

This said, Save the Children would like to make the following comments on the ICN2 zero draft:

1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?

Paragraphs 1-3 do a good job of setting the scene for the document, and for ICN2. Paragraph  3 could mention that a growing global population is also causing challenges in achieving food security for all. In general, it would be good to bring out the following more strongly: The challenge of inequity, especially within countries and the need for specific action to  address this. Linkages to newborn mortality - perhaps in bullet 2 add to the point on anaemia something like “Poor maternal nutrition is a contributing factor to maternal, infant and child mortality. Stunted mothers are more likely to give birth prematurely and have an underweight baby. Fetal growth restriction is a cause of 800 000 deaths in the first month of life each year, more than a quarter of all neonatal deaths (Lancet)” or add a bit more under paragraph 5.

It would also be good to mention SUN as another initiative to support. In addition it would be suggestable to add a paragraph on the need  to tackle underlying causes of malnutrition e.g —inequity, women's nutrition and empowerment, food distribution, conflict and emergencies, and climate change.

1. Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?

Paragraph 4: It is important to recognise here that the right to food is a basic human right that has been internationally recognised since 1948. A human-rights based approach can effectively and sustainably tackle inequalities in food and nutrition security, targeting the most vulnerable people and improving accountability and participation in decision making.

Paragraph 5: The consequences of malnutrition during the critical first 1,000 days of life between the start of a woman’s pregnancy and her child’s second birthday are irreversible, and can cause long-lasting damage. The nutrition of pregnant women is therefore crucial. 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 when girls are adolescents”.

Paragraph 7: This paragraph should state specifically that states will support and work towards the 2012 WHA nutrition targets.

Between Paragraph 9 and 10: The text should recognise that people are at the heart of food systems and that the majority of the world’s poor are also smallholder farmers. There is a need to focus on smallholder farmers, women, indigenous and other vulnerable people and the role that they play in producing food for all.

Paragraph 14: Rules and regulation to ensure good nutrition should apply to all companies, in all countries. The text is this paragraph should be strengthened in this way. Breastfeeding and the marketing of breast-milk substitutes deserve special attention here because of the potential for breastfeeding to save the lives of millions of children.

Paragraph 15: When enhancing the nutrition of people through programmes, special attention should also be paid to adolescent girls.

1. 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)?

The commitments to action listed in the ICN2 zero draft cover many of the areas that Save the Children would like to see in this document, but they are high-level commitments that will not mobilise the kind of action that is required to address malnutrition. In order to ensure that commitments are realised they should be specific. Save the Children would like to see the following commitments made in the ICN2 zero draft:

A global target to reduce stunting is in place, and commitments and targets to prevent stunting equitably are secured at the national level

Governments and donors commit to, and ensure implementation of an adequately resourced, equitably delivered national minimum package of direct nutrition interventions

• All countries adopt a human rights-based  approach to food and nutrition security
• All countries incorporate nutrition outcome targets into national food production goals.
• All countries take steps towards the sustainable production and consumption of food. This includes altering food systems to minimise environmental impact and food waste. 

• All countries establish  a multi-sectoral coordination mechanism for nutrition to ensure that policy decisions are owned by all relevant ministries

• All countries expand their target nutrition group to include adolescent girls.

• ICN2 develops formal guidance for states on incorporating nutrition objectives and appropriate metrics into agricultural plans

• All Governments commit to incorporate the International Code on the Marketing of Breast-milk Substitutes in full into national laws, while companies commit to comply fully with the Code, regardless of the national law.

• All Governments commit to develop and launch a new robust and well-resourced mechanism to monitor and enforce the implementation of the International Code on the Marketing of Breast-milk Substitutes.

• In commitment n 5: “establishing governments’ leadership for shaping food systems” we would like to see added “and promoting good nutrition”.

Depending on the country context:

• Countries take steps to increase the level of agricultural biodiversity present, providing the basis of a more diverse diet, resulting from a more diverse enterprise and cropping base. 

• Countries design and put in place, or strengthen, comprehensive, nationally-owned, context-sensitive social protection systems for food and nutrition security;
  1. Focus on both achieving food and nutrition security now and building resilience building for the future
  2. Improve the design and use of social protection interventions to address vulnerability to chronic and acute food and nutrition insecurity.

• Include school nutrition programmes as part of every child’s education
  1. Promote the entry of girls into education systems, beyond primary education - critical to breaking the intergenerational cycle of poverty and malnutrition.

We would like to stress the need for the commitments and an comprehensive accountability framework to be aligned with existing mechanisms and commitments already made, such as the EWEC and the N4G commitments.

Save the Children looks forward to seeing the next version of this document and further contributing to ICN2.

General Comments:

The declaration is not grounded in human rights. No reference is made to nutrition as core element of the human right to adequate food and nutrition and corresponding State obligations (to respect, protect and fulfill this right). The elimination of malnutrition is considered imperative for “ethical, political and economic reasons” and not because it is a human rights obligation (para. 4). Moreover, no link is made to human rights violations that cause malnutrition, including violations of women’s rights, child rights, and people’s access to natural resources, and those that result from malnutrition. No reference is made to women’s rights and the essential role of women in food production and nutrition (including through breastfeeding).

While the declaration acknowledges “governments’ leadership for shaping food systems” as central (para. 21 V.), it nevertheless talks about people as “consumers” as opposed to rights holders and does not mention States’ human rights obligations (for example para. 14 talks about “empowering the consumer”). In line with this, there is no mention of people being at the center of decision-making processes related to food and nutrition.

Paragraphs 3, 10 and 13 are problematic in that they seem to open the door for the argument that “more traditional” food systems/peasant farming agriculture cannot provide “safe and nutritious food for all” and thus “more nutritious food” means fortified foods, more calories and increased production. Such a view completely disregards the people and food sovereignty component, self-determination and nutritional well-being.

1.            Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?

Paragraph 3:

This paragraph contains highly questionable assumptions regarding the positive evolution of food systems, which is said to have led to “enhanced dietary diversity” and “greater consumption of vegetables and fruits”.

International approaches to food security focused on boosting cereal production have led to significant decreases in crop and dietary diversity. The promotion of soy beans and certain grains over fruits and vegetables has moreover contributed to the shifting of diets towards unhealthy, highly processed foods and meat products (both of which have benefited from subsidized inputs) and related increases in non-communicable diseases (NCDs).

The promotion of large-scale industrial farming, based on monocultures and high levels of chemical inputs, has moreover led to the displacement of small-holder farmers, including many subsistence farmers, who produce the vast majority of food for human consumption. The agro-industrial model of food production is moreover a key driver in the loss of biodiversity, pollution of soil and water sources, and climate change - all of which threaten present and future availability of diversified and nutritious food.

The same paragraph also takes a highly uncritical view on increases in the consumption of meat and dairy products which is portrayed as something positive without considering its effect on NCDs, food and nutrition security (withover one third of total grains being used for livestock production), environmental sustainability, and so on. 

While recognizing that the “food system is still unable to provide safe and nutritious food for all”, no analysis is provided as to why this is the case. No mention is made, for example, of the negative impacts of growing corporate control over the global food system, the agro-industrial model of food production or the ongoing land and natural resources grab. There is also no acknowledgement/ critical reflection on past policy/ governance failures in the food and agriculture sectors (e.g., failure of the green revolution).

2.            Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?            

Paragraph 7 talks about breastfeeding during the first 6 months without any mention of the importance of breastfeeding past this point, which opens the door to justifying private interests coming in after 6 months.

Paragraph 12 does not mention trade as a sector of central relevance for nutrition. As illustrated by the current negotiations for a Transatlantic Trade and Investment Agreement (TTIP) and a Transpacific Partnership Agreement (TPP), trade and investment agreements provide a useful avenue through which transnational food corporations and industry associations cancircumvent and water down national food and safety regulations in order to expand and open up new markets for unhealthy or even unsafe (including GMO-based) food products.  The inclusion of investor-to-state dispute settlement mechanisms, which protect the interests of private investors over those of the public, in several trade and investment agreements, moreover effectively limits States’ ability to enact policy and legal measures required to protect and fulfil the right to adequate food and nutrition, as well as other human rights.

Apart from affecting the safety, diversity and nutritious content of the food that becomes available on local markets, the opening up of national markets to food and agricultural imports can significantly affect the livelihoods of local food producers and the food and nutrition security of the country as a whole, which becomes vulnerable to world food price fluctuations. Trade and foreign direct investment in the field of food and agriculture is hence highly relevant for nutrition.

While paragraph 14 recognizes that “governments are obliged to protect consumers, especially children, from misleading commercial messages promoting energy-dense, but nutrition poor foods (…)”, the declaration avoids engaging in any substantive discussion on the role of the food industry in malnutrition and the urgent need for regulation.  

The phrase “a thriving market economy requires rules and regulations to keep it fair to all” is highly problematic given that there are different perceptions as to what is fair. States have legally binding obligations to protect the human rights, including the right to adequate food and nutrition, of persons living within or beyond their national boundaries and, therefore, must put into place effective rules and regulations that ensure private actors, including transnational corporations, do not infringe upon these rights (see Maastricht Principles 23-27).

International nutrition governance and structures are mentioned only marginally and need to be elaborated further.

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)?

Please provide your comments in the appropriate fields relating to these commitments:    

This section needs to emphasise that it is people, in particular small-holder farmers (including fisherfolk and livestock farmers) and other small-scale food producers as well as groups most affected by malnutrition, who must be at the centre of international and national efforts aimed at reshaping food systems - as beneficiaries as well as designers and implementers of such systems.

21.Commitment I: aligning our food systems (systems for food production, storage and distribution) to people’s health needs;    

Food systems should not only be aligned to people’s health needs but should be fully grounded in respect for human rights and promote food sovereignty and the right to adequate food and nutrition.

Commitment IV: ensuring that nutritious food is accessible, affordable and acceptable through the coherent implementation of public policies throughout food value chains.          

Nutritious food should be accessible, affordable, culturally acceptable, sustainable, safe and in line with people’s nutritional well-being and food sovereignty.

Commitment VI: encouraging contributions from all actors in society;              

Governments must set clear rules on private sector engagement in nutrition with view to managing potential conflicts of interest. 

Dear Sir, Madam,

Please find attached comments on the Zero draft of the political outcome document I am pleased to submit on behalf of the International Dairy Federation.

Kind regards,

Laurence Rycken

Dear Sir / Madam

Please find attached the comments that in behalf of International Pediatric association I made on the document with 23 para logically grouped under the three sections.

I received the zero draft very recently. In order to keep the given deadline I’m sending it now. Should I give an additional explanation, please do not hesitate in contacting me.

Yours faithfully

Manuel Moya

Catedrático E Pediatría/E Professor and Head

Chair of Technical Adviser Group on Nutrition.  International Pediatric Association

International Pediatric Association Foundation, Board of Directors

Vice President European Pediatric Association

Academician of the Real Academia de Medicina

1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?

1. Definitions. Malnutrition is still interpreted as undernutrition, perhaps it would be worth applying the terms of Undernutrition (underweight ?) Overweight and Obesity where appropriate.
2. Among the multiple threats perhaps the lack of a basic nutritional education program  should be included to be applied by health providers. This could help the items covered in para 2 and 3.

1. Political declaration (para 4-20)

7 para. Prevention of pediatric obesity in children > 2years (i.e. beyond breast feeding period) should be considered, because of the persistence in adulthood with all its comorbidities.

9-19 para. Related to political actions, para 18 is very important and should be emphasized not only in low and middle income countries but also in higher ones with specific actions (obesity prevention, Iodide etc)

21 para. ‘Better metrics’ This is a small point in this general approach, but one of the present problems is the different ways of quantifying the nutritional status particularly in pediatric ages due to variable  growth periods and the reluctance for changing methods. I would suggest the use of a plastified card for each health provider with the data of T. Cole ( TJ Cole et al. BMJ 2000; 320:1) that allows to identify underweight, overweight and obesity from 2-18 y  in both genders with the simple BMI (kg/m2) for the whole world population.

1. Technical guide for commitment (21-23 para)

This approach (21-23) is very adequate to the present global nutritional situation. Para 21/ vii is to be emphasized (and budgeted) as monitoring will improve the undertaken action.

In this section of Committing to action, basic nutritional education for health providers will contribute to a proper use of available food in different areas. This can be a link between the general plan and the individual application.

Concern Worldwide welcomes the opportunity to comment on The Rome Accord political outcome document for the ICN2. Cognisant of the potential of ICN2 as a critical moment to garner commitments from Member States, to reshape how the food system is governed and to embed the work taken forward to scale up nutrition in formal government mechanisms, Concern remains committed to working with the organisers to ensure the optimal outcome from the conference. To this end, we believe the paper would be greatly strengthened by being more specific, presenting a clear ambition, supported by concrete targets.

1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?

Concern welcomes the distinction made between the prevalence of undernourishment and the numbers of people who remain affected by it.

Paragraphs 1-3 highlight and convey the point that there is clearly a lot of work that still needs to be done and the challenges that lie ahead.

In addition to restricting the attainment of human potential and impacts on physical and cognitive development, as the Cost of Hunger Study in Africa[1] highlighted, undernutrition can cost a country as much as 16.5 percent of its GDP. Outlining the economic consequences of undernutrition is important and further emphasises the urgency and imperative to act. This omission should be addressed.

Paragraph 3: the point that malnutrition is complex and multidimensional is stressed. However, the paragraph goes on to focus only on the food system dimensions. Many social and environmental factors such as gender, environmental health, optimal caring and feeding practices etc are key determinants. The paragraph should be expanded beyond the food system to reflect this complexity.

1. Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?

Women are the main producers of food, and carers for children. As such, women, and their ability and empowerment to support optimal new born, infant and young child feeding, are essential. Gender needs to come out stronger throughout these sections.  

Paragraph 4: Elimination of malnutrition in all its forms is indeed an imperative for ethical, political and economic reasons. It is also a matter of human rights. The Rome Accord should be firmly rooted within a rights framework, and reference explicitly the right to food and the right to be free from hunger.

Paragraph 5: We welcome the reference to a life cycle approach and agree that this is needed to address varying nutritional needs. The particular importance of the first 1,000 Days should be acknowledged. The impact of malnutrition during this time is largely irreversible and the consequences last a life time. Adolescence is also a particularly important time for girls if the intergenerational cycle of malnutrition is to be broken. Both should be referenced in the paragraph.

Paragraph 7: Mentions the areas covered by the World Health Assembly (WHA) targets, but stops short of referencing the WHA targets and endorsing. Member State’s continued commitment and support of the WHA targets should be explicitly articulated, as well as recognising the need for commitments that go beyond the WHA 2025 targets.

Paragraph 13: Sanitation should be added after water to read ‘… more equitable access to safe food, water AND SANITATION, income, education and healthcare…’

Paragraph 14: The Code on Marketing of Breastmilk Substitutes is conspicuously missing from this paragraph. We welcome the statement that governments are obliged to protect consumers, especially children, from misleading commercial messages. This should be followed through with a recognition and recommitment to the Code. 

1. Do you have any comments on the commitments proposed in the political declaration? In this connection, do you have suggestions to contribute to a more technical elaboration to guide action and implementation on these commitments (paragraphs 21-23 of the zero draft)?

Clarity and guidance should be provided in this section as to the linkages between the ICN2 commitments and the broader WHA targets as well as those made at Nutrition for Growth in 2013.

Paragraph 21: While we agree that collective commitment, action and results are needed to reshape the food system, improving people’s nutrition will require a much broader emphasis and focus. Water and sanitation, access to health care, access to education particularly for women, and social protection are all areas that need to holistically be considered as part of an integrated approach in order to sustainably address malnutrition.

Additional commitments that the ICN2 should consider including:

• Ensuring universal access to safe drinking water, sanitation, and hygiene for households, schools, and health facilities. WASH is critical to addressing malnutrition, preventing infections and diseases such as diarrhoea.
•  
• Ensuring that women are supported in optimal breastfeeding through women’s nutrition, education, breastfeeding support, maternity leave, and empowerment. This includes establishing and implementing the necessary work place legislation and incorporating the International Code on the Marketing of Breast-milk Substitutes into national law. Evidence shows that good nutrition during the first 1,000 day window of a child’s life, including early and exclusive breastfeeding for 6 months, followed by continued breastfeeding with age-appropriate responsive feeding with best available complementary foods, has multiple and long lasting benefits from saving more than one million lives each year, to reducing the human and economic burden of diseases, to reducing the risk of developing various non-communicable diseases later in life, to increasing a country’s GDP by at least 2-3 percent annually.

• Ensuring access to sexual and reproductive health services for all women.

• All countries incorporate nutrition outcome targets into national food production goals.

• Ensuring that social protection systems are designed or strengthened in order to address food and nutrition security.

• Ensuring an end to all forms of gender discrimination, recognising this as one of the greatest causes of undernutrition. Action to end hunger must transform societal norms that result in girls eating last and least, that keeps girls out of school, limits women’s income, voice and productivity, and that lead to child marriage. Improving women’s status and role, their access to education as well as their access to and control over resources is key (i.e. land, income, agricultural inputs and agricultural services).

Thank you for giving the US Council for International Business the opportunity to provide comments on the Second International Conference on Nutrition (ICN2) zero draft political outcome document for 19 November 2014.

The US Council for International Business (USCIB) would like to thank the Food and Agriculture Organization of the United Nations (FAO) for the opportunity to submit comments to the online discussion on the political outcome document of the Second International Conference on Nutrition. USCIB is the American affiliate of the International Chamber of Commerce (ICC), the Business and Industry Advisory Committee (BIAC) to the OECD, and the International Organisation of Employers (IOE). As such, we work closely with intergovernmental bodies, including the Organization for Economic Cooperation and Development (OECD), the World Trade Organization (WTO), the International Labor Organization (ILO), United Nations bodies and vis-à-vis foreign business communities and their governments.

In addition, we would like to highlight that USCIB is a membership based organization which operates under bylaws that provide the framework under which we consult with our own stakeholders. Our processes are transparent. We provide views and inputs which are built through a consultative process and reflect a consensus among our large membership. We therefore hope that the FAO reads this submission as well as our previous one within this context.

Although an online consultation will solicit some input, we would like to suggest that the FAO and the WHO create a more targeted approach to engaging with stakeholders, including the private sector. We recommend a formal consultation with stakeholders, including the private sector, to have a more robust and complete discussion on these important issues related to nutrition.

We found that the stakeholders participation in the technical meeting for ICN2 which was held in November of 2013 as being extremely useful. If fact, several countries including the US, the Netherlands and others were supportive of our engagement at the technical meeting. We therefore look forward to our participation in the ICN2 later this year.

In general, we would like to recommend that the outcome document reflect that the private sector can contribute in the area of nutrition through its innovate products, its science and technology know how, as well as good production and management practices, which can be increasingly harnessed through effective partnerships with research institutions, farmers, policy-makers, and civil society.

Furthermore, the private sector plays a critical role in further strengthening markets, economic growth and livelihoods. While private sector involvement is key, there is also a need for government collaboration, particularly in helping ensure greater policy coherence, such as reducing barriers to trade.

As we expressed in our comments in the previous submission to the FAO online consultations, USCIB would like to underscore that advancing health and nutrition requires a multi-stakeholder approach that reflects the complexities of the issues. There is no quick or simple solution to addressing challenges such as obesity, under-nutrition and disease. While we believe that the private sector has a role in producing healthy and nutritious food. In fact, the private sector role is much broader than food production. It can do its part to combat obesity and other challenges for example, by continuing to innovate and make available healthier choices and help to educate and inform consumers of those products.  However in addition to the private sector, it is equally important to address issues that impact the community’s ability to thrive such as poverty, hunger, gender inequality, water access and sustainable agriculture.

Given, the positive and unique role that the private sector has in nutrition, we could recommend that the zero draft document reflect that perspective rather than a negative one especially with regards to processed foods.  The assumption that processed foods are lacking in nutrient density and therefore categorically non-nutritious is unwarranted. In fact, Scientific and technical achievements through the food system including food processing, allows people to have access to diverse, abundant supply of food that is safer, tastier, more nutritious, more convenient and relatively expensive than would otherwise be the case.

With regards to paragraph 14 of the zero document, we believe that the role of government is to help consumers by “raising awareness and ensure access to choices” as opposed to “empowering consumers to make” choices. With regards to paragraph 18 and 21, USCIB would like to edit the statement that the governments should take responsibility for leadership on nutrition. This statement is rather vague and doesn’t give any real direction to governments. Therefore, we would like to suggest that as it relates to nutrition, governments should take responsibility for leadership on informing consumers about the importance of nutrition and a balanced lifestyle.

Thank you for giving us the opportunity to comment. We look forward to engaging further as we get closer to ICN2.

11. et 12.

Une meilleure connaissance des propriétés fonctionnelles des aliments basée sur des résultats de la recherche et qui pourraient avoir des effets bénéfiques sur des sur la santé et/ou certains facteurs de risque de maladies

Pour une action mondiale capable de mettre fin à toutes les formes de malnutrition,

reconnaissons aussi qu'il y a une nécessité de renforcer les capacités des institutions de formation en Nutrition pour  avoir une masse critique de spécialiste de la nutrition pour prendre en charge les problèmes de nutrition dans nos pays

Dear Forum administrators and facilitators,

Thank you for stewarding this discussion on a 'zero' draft of the political outcome document that will be further worked upon during the Second International Conference on Nutrition (ICN2) to be held later this year and which appears to provisionally be called 'The Rome Accord'.

At the outset, I find it unsettling that Forum members are requested to comment on a draft 'political outcome' document that instead ought to emerge as a shared statement of political - and social - will to correctly recognise the roots of the nutrition problem, and to outline ways to deal with this problem that can be both local and feasible.

No doubt, FAO and WHO are likely to point out that this outcome document is to go through a complex mill of additions, emendations and rewriting by a joint working group. Such a process I think will very substantially dilute most of the distinct advice that our consultation can offer and, if that is indeed so, employs participation in the FSN Forum as 'evidence' of a wide and 'global' consultation that will, at both 'high level' and otherwise, point to a consensual taking of a position that fits the ICN2 deliberations. Moreover, two documents are expected to come out of the ICN2 (this one, which we are reading, and a framework of action), and both should relate to one another and to the discussion to take place in November 2014.

That is why I find this call for comment out of place at this time and in this form. If anything, the FSN Forum would better serve the efforts of FAO and WHO in their work for ICN2 by (a) reviewing in one or two stages what the joint working group readies as its draft, and (b) through a comment and submission channel that is kept current between now and the conclusion of ICN2.

Hence, as for general comments on vision of this 'zero' draft, there is only the expectation that the many gatherings hosted by FAO (often in collaboration with IFAD, WFP, UNICEF, the World Bank and WTO) concerning agriculture, food, nutrition and health will be carefully recalled, reviewed and renewed. But in 2014, with fifteen years of MDG programmes behind us, this is not enough. And this is where the remaining two broad questions fall short:

- "the background and analysis provided in the political declaration" - declarations that emerge from an exercise in multilateralism are notoriously empty of background and analysis and - without prejudice to the drafters of this 'zero' baseline in both FAO and WHO - this one is no exception. It doesn't help us at all at this stage to adopt a technique that has come into vogue over the last decade, and that is, a public draft, a commenting text that uses the internet to canvass views (or criticism), a semblance of democratic participation that nonetheless is reined in before it crosses a boundary.

- "the commitments proposed ... a more technical elaboration" - for reasons that are well known to many of those who have watched, and perhapas participated in, inter-governmental and multi-lateral meetings for the last two decades, commitments have alas become all too cheap. The promises - repeated over years at many international meetings - that richer countries would give between 0.5% and 1% of their national income have yet to be made good, and I cite this as perhaps one of the most durable examples of commitments easily made but rarely delivered. The 'technical elaboration' aspect requires the consultations around ICN2 to gather in density and frequency before elaboration becomes possible because we are ignorant of what national positions are on the major themes, and without these there is no starting position.

What will ICN2 seek to do? We are given key objectives and these are to:

* review progress made since the 1992 ICN including country-level achievements in scaling up nutrition through direct nutrition interventions and nutrition-enhancing policies and programmes.

* review relevant policies and institutions on agriculture, fisheries, health, trade, consumption and social protection to improve nutrition.

* strengthen institutional policy coherence and coordination to improve nutrition, and mobilise resources needed to improve nutrition.

* strengthen international, including inter-governmental cooperation, to enhance nutrition everywhere, especially in developing countries.

That is a time-table quite full of objectives, heavy with policy intent and just as needy for technical capacity locally, and that is why critical reviews of the inter-governmental cooperation as well as national measures are needed, but will become possible closer to November 2014.

What I find absent from the 'zero' draft - unsurprisingly for this is meant to be a politically neutral starting point, but doing so does not help us nor does it bring us closer to the ICN2 objectives - is mention of the structures of contemporary macro-economics that have given rise to the conditions that cause hunger and malnutrition to persist. It will be inadvisable for this and other drafts meant for use by ICN2 to ignore the work and impacts of the many food justice and food rights-based movements. Only very few, if there any at all, are limited to agricultural activity, nutrition or health - the vast majority of this multitude of movements and associations work within (and remain critical of) the market structures of contemporary capitalism - fair trade, agro-ecological transition, community food security, urban and community resilience, seed sovereignty, community-supported agriculture, slow food, food policy, agriculture and development, and so on.

These today thrive and contribute materially and culturally to people's lives in a world that is more beset by crisis than it was in the decade of the 1980s. And it was that period which led to the ICN 1992 final documents being marked by a decidedly reflective tone. Such as: "The effects on the poor of structural economic imbalances, particularly in low-income countries in the 1980s, have stressed the relevance of macro-economic policies for food security. Macro-economic variables, such as the exchange rate, import/export policies, inflation and budget deficits, can have significant implications for prices, incomes, and employment, especially for the poor. Therefore, to be effective and sustainable, food security policies must be set in a growth-conducive macro-economic framework. Striking an optimal balance between fiscal policy requirements and food security needs presents a difficult policy choice for developing countries implementing structural adjustments programmes." (From 'Major issues for nutrition strategies summary', 1992.)

Over two decades later, none of these factors have in any way become more conducive to ensuring food justice and equity, bringing adequate nutrition to citizens, and fostering a cultivation system that is respectful of biophysical limits as much as of natural cycles. If they were, then paragraphs 1, 3, 10, 11, 13, 17 and 19 of the 'zero' draft would not have been necessary.

What has however changed are the political implications of greater and swifter financialisation of food systems - and this is visible and has been so for at least the last decade in every country that is a member of the World Trade Organisation (WTO). There has been growing recognition of the insidious and destructive role that predatory finance plays in food systems - whether global or sub-national. The food price spikes of 2007-08 revealed how financial markets worked in tandem with large transnational - and national - agribusiness actors within the current food regime. And that is why, especially when considering paragraphs 9, 10, 11, 13, 14, 16 and 18, such implications and the consequences of their continuing needed elaboration. Whether this will be done through the 'framework of action' that is to accompany this 'zero' draft is a question I put directly, through the FSN Forum, to the FAO-WHO joint working group.