1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?
We believe this is a great effort that is being made and we are very pleased to be able to make contributions.
In general, we observed that there is many valuable aspects in the document, but overall it is ambiguous in many ways, many definitions are not well established. Examples: malnutrition-it is not clear and it does not exactly define that overweight and obesity is part of malnutrition, it refers only to “overconsumption”; safe food- leads to think it is regarding to only processed foods and that traditional fresh grown foods from the different localities do not meet in this concept).
It is not based on the best interest of the child nor children´s rights; children are even mentioned as “consumers” but not as right holders. Overall human rights are not mentioned, only economic, social and cultural rights; which is very important but it is also important to mention and to base all the proposals and policies regarding human rights.
Breastfeeding is only mentioned once in the whole paper when it is one of the most effective measures for malnutrition; we believe it needs to be reinforced.
Accountability of private sector is not mentioned at all, nor the importance of conflict of interest when regarding industry involvement and partnerships, industry is only partially mentioned as part of the problem when it has been a big part of the problem for NCD´s and for undernutrition as well.
Marketing to children is not mentioned and it needs to be very clear that is a very strong issue regarding nutrition in children.
Some words can be complemented: sugars- for free sugars or added sugars; safe food- for safe nutritious food; regulations- for strong regulations; healthy food- for healthy, natural and fresh food.
In the commitments part VI, it does not establish if it is including private sector and what would the role be.
2. Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?
Paragraph 4 establishes elimination of malnutrition is imperative for ethical, political and economic reasons but not for the best interest of the child, nor for the child´s rights, nor for human rights.
Paragraph 5 does not recognize the importance of the protection of women and children particularly when breastfeeding. Instead of using word “including” it can be “specially” women and children. Breastfeeding is only mentioned in paragraph 7, when it is one of the most important effective measures for malnutrition.
Paragraph 8 only mentions Economic, Social and Cultural Rights; Human rights need to be mentioned too.
Paragraph 13 mentions safe food, it can be substituted for “safe nutritious food”.
Paragraph 14 where it says “Reliable and relevant nutrition information, sensitive to cultural norms and preferences, needs to be effectively disseminated to improve behaviour and practices”, the idea is confusing. The food that needs nutrition information is usually processed food, then the sentence is followed by sensitive to cultural norms and preferences… it leads to think that processed food´s nutrition information needs to be sensitive to cultural norms and preferences, when what it needs is to warn about the risks of intake and inform consumers of the real contents of it, allowing the population to make real informed decisions. On the same paragraph, when it talks about regulation, it can say “strong regulation” instead. On the last part, where it talks about local food cultures, it is better if it establishes “local foods and cultures”.
Paragraph 15 must establish that the “partnerships” must be without conflict of interest and it must clarify that these “partnerships” must be for the public interest.
Paragraph 19 must specify the role of private sector, the importance of the public interest and the conflict of interest.
Paragraph 20 must include monitoring on programmes and policies. Also it must include industry´s form of accountability.
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:
21.Commitment I: aligning our food systems (systems for food production, storage and distribution) to people’s health needs;
Food production that allows countries their own sustainability and sovereignity, coming from small and medium producers.
Commitment II: making our food systems equitable, enabling all to access nutritious foods.
Nutritious fresh, natural foods.
Commitment VI: encouraging contributions from all actors in society;
Is not clear is all actors include private sector. If it does, what would the role be of private sector and the regulations they need to follow on, as well as the forms of accountability.
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