The US Council for International Business (USCIB) appreciates the opportunity to submit comments to the FAO consultation on the Framework for Action for ICN2 Draft. The private sector believes it is essential that all stakeholders work together to develop holistic, impactful and sustainable solutions. We are committed to public-private partnerships that support public health strategies. We believe that collaborative multi-sectoral actions represent one of the most cost-effective ways to address public health challenges. In the past, USCIB has submitted comments to the FAO regarding the role of non-state actor, as well as regarding the ICN2 Political Outcome Document draft. As a follow up, we have a several concerns with the language in the Framework for Action Draft.
Enabling environments (Page 3): USCIB agrees with these 4 key elements, and would recommend that the comments underscore the importance of employing “knowledge and evidence-based strategies, policies and programs”, and that this reflects industry’s view as well.
“Nutrition Justice” (Page 4): This phrase is not defined and the boundaries of this concept are unclear; USCIB would recommend removing, and the document focus on the action steps on policies to achieve explicit nutrition targets.
Engage implementation partners (page 5): The language in this paragraph could be misconstrued, in particular the “subordination of interests which conflict with government policies, agreed implementation…” in a way that continues to denigrate the role and contributions of the private sector. This language speaks to a larger point within the document in that there is limited language that acknowledges the importance of the food industry and the need to engage as a full partner in deciding strategies, actions and common goals for moving forward. The private sector is noted, including on page 27, but this is an area where we think the document could be significantly enhanced.
Priority Actions for nutrition governance (page 5): In this section as well as in sections on “recommendations for follow-up” (pages 26-27), there is a lack of clarity as to how all these platforms, mechanisms, processes and reporting relate to similar activities either in place or proposed by WHO and the UN – for example, the WHO Global Coordinating Mechanism and the UN HLM periodic “Progress Reports” on the 2011 Political Declaration. There appears to be significant potential for redundant, duplicative and overly burdensome processes that could present significant obstacles to achieving real progress. At a minimum, greater clarity is required regarding roles and responsibilities among the various multi-lateral organizations.
Language on lost productivity (page 5/6): important point that could be elaborated upon further in comments as a key driver for companies to engage in nutrition/wellbeing to mitigate productivity losses and support the health and wellbeing of our consumers/communities.
Page 6 and elsewhere on incentives/taxes: Fiscal policy is complex, often has unintended consequences, and requires caution, especially as food prices continue to rise. Unintended consequences include an effect on informal and illicit products and markets, problems of tax evasion, corruption, smuggling and product switching. The introduction of a fiscal approach can very quickly become cumbersome to manage and complex to administer.
Furthermore, fiscal measures also have potentially large re-distributive effects and would most likely hurt lower-income individuals who spend a larger proportion of their income on food. Tax rates should be kept low on products that account for a relatively high proportion of spending by the poorest groups in society. In this instance, taxes on food will discriminate against low income households.
Finally, the impact on consumption patterns from implementing fiscal measures is unpredictable. Changes in consumption will depend on the price elasticity of each good (assuming the tax is passed on to consumers). How consumers’ behavior changes in light of relative price changes is not always obvious and inherently difficult to estimate. The more likely impact is that consumers will switch to alternative goods that have characteristics that are closer to the originally purchased item and that remain exempt from the new tax regime, or taxed at a lower rate.
Comments on Section: From Commitment to Action: Policy and Programme Options Role of “highly processed foods of minimal nutritional value” (page 7): There are no definitions of “highly processed foods of minimal nutritional value” in this document or by other reference and yet the conclusion is drawn that they have “contributed to obesity and diet-related NCDs”. The lack of either a definition or an evidence base linked to those definitions, should dictate that this statement is not appropriate for inclusion in the WHO/FAO Framework For Action document.
Characterization of WHO recommendation on “free sugars” (page 8): The document appears to misstate WHO recommendations on free sugars –specifically with respect to the “5%” language. It is our understanding that the WHO is currently conducting a peer-review of proposed recommendations and in March 2014 requested public comments on those recommendations. With regard to a recommendation of intake below 10%, the authors of the WHO review noted that the relationship observed between free sugar intake and dental caries was based on evidence that was judged to be of very low quality. At that time, the Grocery Manufacturers Association (GMA), a USCIB member, commented on the proposed recommendations and concurred with WHO that more scientific substantiation and full engagement and collaboration of the many concerned stakeholders is required before a conditional recommendation of reducing sugar intake to 5% can be considered for adoption as policy. Furthermore, since the request for comments in March, WHO has issued no public statement with regard to its proposed sugar recommendations and the results of its peer-review process, so the statement in the Framework for Action seems premature at best.
Additionally, the private sector understands that many consumers are increasingly seeking ways to improve their dietary quality and manage their calorie intake, including reducing sugar consumption. For example, to meet these needs, members of the International Food and Beverage Alliance (IFBA) have been formulating products with less added sugar, using alternative sweeteners and other ingredients as alternatives to sugars and reducing calories by offering smaller portion sizes and providing portion guidance. Reducing sugar levels is complex and challenging, both technically and in terms of consumer acceptance.
Empowering Consumers to make healthy dietary choices (page 9): We agree that nutrition education is key, and that we need to collectively work to effectively educate consumers through labeling and nutrition programs about food, how to combine them into diets (quality and quantity) that fit their needs as well as address other aspects of a healthy and productive lifestyle including physical activity, energy balance, etc.
Role of women in food systems (Page 9): Another crucial issue includes ensuring the empowerment of women and girls both economically and socially. These members of society have an important role in the decisions made at the household level with regards to food and nutrition. Therefore, we believe that it is important to promote policies that help women become farmers, traders and business owners. Equally important is that these members of society are educated and properly informed to make healthy choices for their households. The private sector can play a crucial role in empowering women and girls.
Backyard farming/gardens (Page 10): This is certainly one small element to the overall approach, but recommend that we provide a caution given huge global demands on food, increased production/yields, change in diets, demographic shifts (move to cities) that will all require a more robust approach.
Regulating marketing and financial incentives/disincentives (pages 11-12): It is not clear what the evidence base is for the specific strategies noted in this section, raising the question of why national governments should rely upon this analysis. This section references the WHO Set of Recommendations on Marketing Food and Non-alcoholic Beverages to Children in the context of “Regulating Marketing” despite the fact that these WHO recommendations also note the role that industry self-regulation can and has played in this arena.
Priority actions to improve the food environment (Page 12): USCIB is concerned about the language on Priority Actions to Improve the Food Environment; the Framework for Action document should highlight how the food and beverage industry is already responding to the WHO‘s 2004 Global Strategy by:
--Offering healthier products through product innovation and reformulation
--Providing more information to consumers through nutrition labeling so that they can make informed choices
--Adopting responsible marketing policies, particularly with respect to children
--Working with other stakeholders to promote physical activity and nutrition education
Page 22, access to safe water: USCIB strongly supports work in access to safe water and would like to highlight some of the efforts that industry/TCCC are already undertaking to ensure access to clean water: http://www.coca-colacompany.com/water-stewardship-replenish-report/
International trade and investment (page 24): There appears to be a presumption underlying this section that the impact of trade and investment is primarily negative, despite the fact that no evidence is offered to support this presumption and despite significant evidence to the contrary, including FAO and WTO reports, indicating that increased trade, particularly in agriculture and food, increases the standard of living in developing countries and improves the performance of national economies. This section continues this presumption with respect to trade and nutrition specifically, not by providing any evidence of harm, but by implication simply constructing each proposition in the negative. Without any science or evidence basis, this entire section should be reconsidered.
Providing evidence for the definition of a healthy diet (Page 26): This is an area in which the private sector could contribute. USCIB would like to recommend and welcome a dialogue between the private sector and FAO and WHO on the subject.
Intergovernmental Panel on Nutrition (Page 28): USCIB would support such a panel and would like to recommend inclusion of representatives with substantial expertise from the food and beverage industry.
On behalf of the US Council for International Business, I would like to thank the organizers of ICN2 for the opportunity to contribute to this online consultation on the revised draft of the Rome Declaration on Nutrition. While we greatly support the submission made by IAFN, we would like to offer some additional comments.
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.
In general, we believe the outcome document should reflect that the private sector can contribute in the area of nutrition through its innovative 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.
In addition, we believe that advancing health and nutrition requires a multi-stakeholder approach that reflects the complexities of the issues. For this reason, we believe that ICN2 should include participation from civil society as well as the private sector. There is no quick or simple solution to addressing nutritional challenges. While we believe that the private sector has a role in producing healthy and nutritious food, 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. We believe that developing the economy, including promoting women’s role in the economy, is important. The private sector can play a critical role in further strengthening markets, spurring economic growth and improving livelihoods including nutrition.
We look forward working with the FAO, the WHO and the Civil Society Mechanism to help create the environment for building trust as we seek to demonstrate the effective value of leveraging our capabilities in these partnerships to address the nutritional challenges ahead.
Thank you.
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.
With regards to RAI as they are being developed at the moment, the US Council for International Business (USCIB) has the following comments:
The private sector has concerns with regards to monitoring and evaluation as well as roles and responsibilities. I would like to stress that it is important to create an environment that encourages investment. Otherwise, the private sector actors that you are trying to work with may be deterred from the RAI principles. We heard this not only during the US meeting but several Canadians have also expressed this.
Furthermore, we have some questions about the role of monitoring and evaluation. Who should do what and to whom should be clarified and be made more explicit. I understand that at the moment, there is no method for monitoring and implementing the roles defined. What entity will keep an eye on the companies and countries that commit to implementing the principles?
Finally I would like to highlight again that in general the roles and responsibilities should not be too prescriptive as it is a voluntary document.
Thank you in advance for accepting my comments and for providing me the opportunity to comment. I look forward to working with you as the RAI Principles develop.
Helen Medina,
Senior Director, Product Policy and Innovation
USCIB
As we expressed in our comments in the previous submission to the FAO online consultation, 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, 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. It is within this context that we share with you in our comments some examples of programs and approaches that reflect this complex reality.
Mme Helen Medina
The United States 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 on the Maximizing the Impact of the UN Decade of Action on Nutrition. USCIB promotes open markets, competitiveness and innovation, sustainable development and corporate responsibility, supported by international engagement and regulatory coherence. Its members include U.S.-based global companies and professional services firms from every sector of the economy, with operations in every region of the world. With a unique global network encompassing the International Chamber of Commerce, the International Organization of Employers and the Business and Industry Advisory Committee to the OECD, USCIB provides business views to policy makers and regulatory authorities worldwide, and works to facilitate international trade and investment.
It is indisputable that nutrition provides a vital foundation for human development and is central to meeting one’s full potential. Nutrition is also important from an economic point of view. Hunger and under-nutrition weaken the mental and physical development of children and adolescents. This in turn lowers the work capacity and income potential of adults and leads to huge social and economic costs. According to estimates by a 2013 FAO report, hunger and under-nutrition cost the global economy an estimated 2-3 percent of global gross domestic product, equivalent to $1.4-2.1 trillion per year.
So what is the private sector doing on nutrition? For starters, the private sector is a key actor in providing nutrition from investing in agriculture; to improving the social, economic and environmental practices in farming and the supply chain; to mobilizing, innovating, and finally delivering agricultural products and food. As an employer, the private sector also has a vital role in increasing the livelihoods of society as a way to address poverty, malnutrition and under-nutrition. But that’s not the whole picture. It’s far from it and more can be done. One stakeholder alone can’t solve complex nutrition challenges.
The importance of good governance policies and regulations that support private sector involvement in agriculture should not be underestimated. Access to finance and empowering women is also crucial for improving nutrition around the world. Women are often the family’s primary caretakers and they tend to invest in their children’s health. It’s therefore important for governments to promote policies that help women become farmers, traders and entrepreneurs. Promoting trade and investment in agriculture is also crucial for combating global hunger. There is significant evidence from UN reports that demonstrate increased trade, particularly in the agriculture and food industry, raises the standard of living in developing countries and improves the performance of national economies, all of which are necessary for healthy societies.
Additionally, multi-stakeholder partnerships should be encouraged. More and more of these types of approaches are widely recognized as necessary to increasing the scope of financial and human resources in order to tackle nutritional challenges on a large scale. The private sector often partners with governments and researchers to innovate and create new tools for farmers that improve nutrition. It is essential for all stakeholders to work together and develop a global food system that improves people’s nutrition in a sustainable way. We are committed to public-private partnerships that support nutrition strategies and to preserving natural resources to continue to grow food which is necessary for nutrition.
The 2030 Sustainable Development Agenda provides a terrific opportunity for the private sector to demonstrate the central role it plays in nutrition and society. While government has been successful in outlining a visionary mission for global development, businesses have the unique ability to bridge the capacity gap to reach the impact and scale necessary to meet the SDGs and in particular those that relate to nutrition. Partnership between the public and private sectors, at both the global and at national levels, is vital in creating an effective strategy and successfully implementing it to achieve these goals.
USCIB has been at the forefront of this initiative. Last year USCIB launched Business for 2030, an online platform showcasing business engagement with the SDGs. We invite you to review what business is doing to meet the 2030 goals including those related to nutrition.