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The International Diabetes Federation (IDF) response to the draft political declaration of the ICN2 prepared by the FAO and WHO Secretariats, March 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) believes that the ICN2 draft political declaration is a very comprehensive and valuable document and welcomes the opportunity to comment on it. In this response, IDF answers to the document from the diabetes perspective.
General comments on the draft political declaration and its vision, paragraphs 1-3
1. IDF welcomes that malnutrition in all its forms is acknowledged as one of the greatest threats to health and well-being. However, we request that overconsumption, defined as population-wide increased consumption of energy-dense food products, is listed as a form of malnutrition together with undernourishment, micronutrient deficiencies and unbalanced diets.
2. IDF shares the concern regarding the moderate progress in reducing malnutrition since ICN1 in 1992 and would like to add the following facts and figures to show this modest improvement more explicitly:
· Despite the decrease in children chronic and acute under nutrition, the figures remain unacceptably high.
This situation needs to be addressed without delay as, apart from its immediate and devastating consequences, an adverse nutritional status early in life is among the risk factors for developing diabetes and other non-communicable diseases (NCDs) later in life, with profound effects on life expectancy.
· The prevalence of obesity worldwide is escalating and far from being controlled. It has doubled since 1980, affecting 10% of men and 14% of women in 20081. More than half a billion adults worldwide are obese, being at an increased risk of developing diabetes and NCDs.
· IDF estimates that 8.3% of adults – 382 million people – have diabetes worldwide in 2013. The number of people with type 2 diabetes, which risk factors include obesity and poor diet and accounts for about 90% of the total, is increasing in every country. If we do not take action now, the number of people with diabetes will rise up to 592 million within 25 years.
· Socio-economic factors have a key influence on the nutritional status both among and within countries, which has a direct impact on diabetes and NCDs. Maternal overweight and obesity at the time of pregnancy, which is a risk factor for childhood obesity and gestational diabetes (GDM), have increased steadily in LMICs since 1980. Most overweight children younger than five years (32 out of 43 million worldwide in 2011) live in LMICs and are at a particular risk of adult obesity, diabetes and NCDs2. This trans- generational transmission of obesity is, among other factors, fuelling the diabetes epidemic in the LMICs, where 80% of the total number of people affected by diabetes live.
3. IDF request that this paragraph specifies that nutritious food (and not only “food”) availability, affordability and accessibility are key determinants for all forms of malnutrition. The benefits attained from the greater consumption of vegetables, fruits, meat and dairy over recent years in the developing countries have been overshadowed by an even higher global increase in the consumption of processed food and beverages, rich in sugars, saturated and trans-fat and salt.
Comments on the background and analysis provided in the political declaration, paragraphs 4-20
4. IDF suggests that dietary risk factors may account for more than 10% of the global burden of disease and disability, as stated in this paragraph. Of the estimated 8.3% of adults that have diabetes in 2013 about 90% are affected by type 2 diabetes, which has obesity as one of its main risk factors. For this reason, we believe that 10% is a low figure that does not comprehensively reflect the global burden of disease and disability.
5. IDF agrees that nutritional needs change during the life cycle and suggests that this paragraph has to reflect that nutritional choices at all stages of life have long-term health consequences. IDF also recommends including elderly people among the groups that have specific nutritional needs.
7. We recommend dividing this paragraph into two: one on the overweight-related commitments and another one on under nutrition commitments. In the current paragraph the overweight-related commitments (halt the increase in the prevalence of overweight in children under five and reverse the rise in obesity and diabetes) are hidden between the markers more closely linked with under nutrition. We also believe that the commitment “halt the increase in the prevalence of overweight in children under five” needs to be stronger, and propose “reverse the rise in the prevalence of overweight in children under five” instead.
9. IDF strongly recommends that this paragraph adds “marketed” to the list of procedures food undergoes within the food systems, as it has an obvious impact on nutrition and consumer choices and preferences.
IDF applauds the content of the rest of the paragraphs, specially the proposals of nutrition as a goal of all developing countries, empowering the consumers to make healthy food choices and facilitation of healthy food practices by Governments. IDF recognises that nutrition policy and programmes are generally poorly developed; we also support that Governments should take responsibility for leadership in nutrition and that an effective coordination across all stakeholders is needed to tackle this issue.
Comments on the proposed commitments, paragraphs 21-23
21. IV. IDF would like this commitment to reflect that nutritious food needs to be more accessible, affordable and acceptable than it is now, while poorly nutritious food needs to become less affordable. Only this will help achieve our goal of the healthier choice becoming the easiest one for consumers around the world.
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1 Global Health Observatory (GHO). http://www.who.int/gho/ncd/risk_factors/obesity_text/en/
2 Maternal and child under nutrition and overweight in low-income and middle-income countries. The Lancet 2013. http://www.thelancet.com/journals/lancet/article/PIIS0140-6736%2813%2960937-X/fulltext
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Mme Beatriz Yáñez
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.
General comments on the draft Framework for Action
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.
Does the Framework for Action adequately reflect the commitments of the Rome Declaration on Nutrition?
How could this be improved?
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.
Does the Framework for Action provide sufficient guidance to realize the commitments made?
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.
Is the Framework of Action missing any issues to ensure the effective implementation of the commitments and action to achieve the objectives of the ICN2 and its Declaration?
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.
[1] Food taxes and their impact on competitiveness in the agri-food sector. ECORYS – DG Enterprise and Industry. 2014