Forum global sur la sécurité alimentaire et la nutrition (Forum FSN)

La Organización para la Alimentación y la Agricultura de las Naciones Unidas (FAO) y la Organización Mundial de la Salud (OMS), en colaboración con el FIDA, IFPRI, la UNESCO, UNICEF, el Banco Mundial, el PMA, la OMC y el Grupo de Trabajo de Alto Nivel sobre la Crisis Mundial de la Seguridad Alimentaria (HLTF), están organizando conjuntamente la Segunda Conferencia Internacional sobre Nutrición (CIN2), una conferencia intergubernamental de alto nivel que tendrá lugar en la sede de la FAO, en Roma, del 19 al 21 de noviembre de 2014. Hay más información disponible en: http://www.fao.org/about/meetings/icn2/es/ y en www.who.int/mediacentre/events/meetings/2014/international-conference-nutrition/es/

En Roma tuvo lugar una Reunión Técnica Preparatoria del 13 al 15 de noviembre de 2013, basada en una serie de conferencias regionales y documentos técnicos de referencia y otros documentos y análisis relevantes, así como en tres debates temáticos en línea (Protección social para proteger y promover la nutrición, Sistemas agrícolas y alimentarios que mejoran la nutrición, y La contribución del sector privado y la sociedad civil para mejorar la nutrición).

Tomando en consideración los resultados de la Reunión Técnica Preparatoria y siguiendo el mandato recibido por los órganos rectores de la FAO y la OMS, los Estados Miembros de la FAO y la OMS han estado discutiendo y revisando un proyecto de Declaración y el Marco de Acción (FFA, por sus siglas en inglés) que le acompaña para orientar su implementación.

Para dar seguimiento a dos rondas de discusiones en línea sobre el proyecto de Declaración, celebradas a principios de este año, nos gustaría ahora recibir sus comentarios y aportaciones sobre el borrador cero del Marco de Acción (FFA), disponible en los seis idiomas de la ONU. Esta consulta abierta les dará, como partes interesadas, la oportunidad de contribuir a la Conferencia y a sus resultados.

Los comentarios recibidos serán recopilados por la Secretaría Conjunta FAO/OMS de la CIN2 y se utilizarán para continuar revisando el Marco de Acción (FFA), ayudando en última instancia a garantizar el éxito de la Conferencia.

Le invitamos a acceder al documento aquí (AR, EN, ES, FR, RU, ZH) y a compartir sus observaciones centradas en el conjunto de preguntas formuladas a continuación.

Preguntas:

1.       ¿Tiene algún comentario general sobre el borrador del Marco de Acción?

En términos generales sería relevante que este borrador marco de acción partiera por   exponer  de forma explícita  el resultado de lo logrado o no alcanzado, desde el planteamiento hecho en el  CIN de 1992 y en la cumbre de 1996, con los indicadores y las cifras sobre las cuales se pueda hacer una continuidad de forma tal que Cada 10 años se refleje  en  la acción no solamente en los planteamientos marco en un documento.

Así mismo este nuevo marco de acción deberá plantear indicadores sobre los cuales se deban evaluar los resultados alcanzados en el periodo planteado.

Paralelamente gustaría  que el enfoque de esta gran iniciativa focalizara a la nutrición como  FUNDAMENTO PARA DESARROLLO DE CAPITAL HUMANO y acorde con esto cada uno de los puntos tan maravillosamente centrados en el  documento giren en torno a este eje. De tal forma todos los sectores, asociados e involucrados tengan el mismo norte y se lleve a cabo un resultado integral.

• ¿Tiene algún comentario sobre los capítulos 1-2?

Como este marco de acción esta soportado en compromisos derivados de múltiples cumbres y reuniones desarrolladas con fines afines sería bueno unificar un solo tiempo de observación para las acciones propuestas en todos estos ámbitos y que dichas intervenciones sean evaluadas también con iguales indicadores.

Si cada país debe establecer su línea de base seria clave que este marco de acción delimitara los lineamientos sobre los cuales trace su línea de base.

En términos de la gobernanza al ser el tema nutricional transversal en todas las áreas del conocimiento y multidisciplinar , más que consultas periódicas a diferentes instancias ,debe  haber un ente nacional especifico , que agrupe la representación de los  asociados  y los  sectores  con miras a dar integralidad coherencia en la implementación (gobierno, industria ,academia , sociedad civil)de las estrategias , este ente trazaría las directrices de trabajo intersectorial, la facilitación la rendición de cuentas etc.  Planteados.

Los planteamientos de estos capítulos carecen de  un pilar fundamental que es la  equidad a nivel mundial no solo los países con elevadas tasas de malnutrición deberán asignar más de sus recursos a la nutrición, (claramente los más pobres) sino que los que no tienen este flagelo podrían contribuir y ser incentivados a ello.

• ¿Tiene algún comentario sobre el capítulo 3 (3.1 Sistemas alimentarios, 3.2 Protección Social; 3.3 Salud; 3.4 Comercio internacional e inversión)?

·         Además de potenciar el agro y todos los componentes de la cadena productiva  y de suministro en este sector. Se requiere  conectar  a la ingeniería de  alimentos para la consecución de los objetivos de este marco de acción. Los avances en tecnología e innovación de alimentos podrían contribuir a la reducción en el consumo  de grasas, sal, azúcar  en los productos, si se actuara de la mano con esta área de la ciencia.  

·         Lo anterior particularmente en lo que se refiere a alimentos infantiles, esto tiene  fundamento  en  que la  alimentación temprana incide en el desarrollo de un metabolismo sano o errático en la vida posterior, en ese orden de ideas ,todos los adultos independiente de que sector provengamos, deberíamos vigilar y saber que és importante en el menú de nuestros hijos o de cualquier niño que crece cerca, sean  formulas  infantiles específicas, o productos no hechos para infancia, pero de alto consumo infantil . De acuerdo a lo anterior el mundo adulto es el principal ENTORNO ALIMENTARIO.

·         Paralelamente se requiere de un refuerzo en lo pedagógico y educativo para garantizar que el consumidor adulto tenga elementos de juicio para tomar decisiones sobre su propia alimentación y la de los infantes cercanos.

·         El costo del  acceso a los alimentos naturales se incrementa sustancialmente porque son perecederos y su transporte  a regiones donde no se consigue su producción, debe tener garantía de rapidez y eficiencia.  Abordar la mejora en este punto  es una prioridad, aquí aparece de nuevo el tema de equidad, el suministro de productos frescos debe ser igual para todas las regiones  y todos los estratos.

·         en cuanto a salud:

·         incorporación del tema metabolismo de nutrientes a la formación de recursos humanos en salud.

·         incorporación de diagnóstico nutricional en consulta a la mujer en edad fértil  y establecer la consulta preconcepcional

·          a la gestante diagnostico nutricional y seguimiento de composición corporal del feto.

·         reglamentación y monitoreo a la suplementación de nutrientes en la gestación

·         reglamentación y monitoreo de la lactancia materna exclusiva

·         monitoreo de aplicación del código a sucedáneos de la leche materna

·         reglamentación y monitoreo de la alimentación del neonato prematuro y el bajo peso al nacer

·         propiciar al máximo el parto natural como factor clave en la consolidación una microbiota intestinal sana y una inducción  al metabolismo de nutrientes adecuado. lo anterior también potencia la intervención propuesta en cuanto al control de eda y a la resistencia  microbiana

3.       ¿Proporciona el Marco de Acción orientación suficiente para cumplir con los compromisos adquiridos?

·           Falta trazar lineamientos ,metas e indicadores de evaluación a mediano y largo plazo

4.      ¿Existen cuestiones que faltan en el borrador del Marco de Acción para garantizar la implementación efectiva de los compromisos y acciones para alcanzar los objetivos de la CIN2 y de su Declaración?

·         La priorización del seguimiento y cuidado en el estado nutricional de  la mujer particularmente en la edad fértil es uno de los pilares para mejorar el estado nutricional de la población, no es solo proteger su mejora laboral y su tiempo para cuidar a los hijos, sino que desde antes de la concepción debe tener un estado nutricional y una cultura nutricional  que garantice un mejor comienzo metabólico  y una mejor cultura nutricional para sus hijos.

·         No escapar a los entornos alimentarios el propiciar el desarrollo de la masa muscular mediante la actividad física, el metabolismo de la glucosa en el musculo garantiza el balance nutricional general y debe considerarse por esto la actividad física como un factor nutricional.

Soporte bibliográfico contactar a

[email protected]

Gracias.

Le damos las gracias de antemano por su interés, apoyo y esfuerzos, y por compartir con nosotros sus conocimientos y experiencia.

Quedamos a la espera de recibir sus aportaciones.

Secretaría Conjunta FAO/OMS de la CIN2

I am responding to this open consultation as Chair of the UK Need for Nutrition Education/Innovation Programme (NNEdPro: www.nnedpro.org.uk). The NNEdPro Group represents a strategic partnership between doctors, dietitians, nutritionists, and other healthcare professionals. It is composed of several partner organisations including the British Dietetic Association, Society for Nutrition Education and Behaviour, the Cambridge University Hospitals/School of Clinical Medicine, the University of Ulster and the UK Medical Research Council Human Nutrition Research unit in Cambridge, UK.

I commend the spirit of this draft framework for action and welcome the Second International Conference on Nutrition in November this year. Particularly following the United Nations High Level Meeting on Non Communicable Diseases (NCDs) in June and July this year, the November meeting is both timely and necessary to move from recommendations into implementation. I would be interested in attending the meeting in November and representing a section of the UK academic sector particularly in relation to translation into healthcare practice which is a key domain of interest.

However, upon internal discussion with colleagues I do have some key comments for consideration, below…

Comments on the draft ‘Framework for Action’

Overall, the draft document contains a number of balanced recommendations that will be useful to give flight to the Rome declaration. However, in addition to highlighting key evidence supporting the recommendations made (chapters 1-2), some ‘grey’ areas (chapter 3) are also highlighted below:

Ø  Chapters 1-2

The following references made in chapters 1 and 2 are of key positive value:

o   “nutritionally appropriate diets” (par. 1.1), without singling out any specific type of food as “unhealthy” – it is increasingly recognized that despite the nature of evidence in nutrition which often relies on single nutrient research, individuals consume foods in the form of diets and dietary patterns which can also be observed at regional/population level providing a composite indicator linked with health which can be monitored at population level.

o   “knowledge and evidence-based strategies, policies and programmes” (par. 2.1) – as nutrition is a multipartite discipline the knowledge bases can be incongruous as well as the ways in which quality of evidence is assessed in the wake of incorporation into generalised policies or more focused programmes; placing emphasis on the need for a ‘knowledge economy’ in nutrition and a strong evidence base are of key importance in keeping policies and programmes fit for purpose.

o   “involve regular consultations among all implementing partners, including consumer groups, other civil society organizations, producers, processors, distributors and retailers of food” (par. 2.2) – this recognises the importance of the food chain and how the importance of ensuring a harmonized approached across various partners in this chain.

o   “professional nutritionists, research scientists, educators” (par. 2.2) – there is great potential for these groups of professionals to work in partnership, alongside healthcare professionals who may not be nutritional experts but have the opportunity to provide advice/advocacy in a nutrition and health related context.

Ø  Chapter 3

The following statement is encouraging as it recommends a ‘whole systems’ approach: “interventions in isolation may have limited impacts within such a complex system, interventions that consider food systems as a whole are more likely to succeed” (par. 3.1). However, the following points made in chapter 3 require further review and possible fine-tuning:

o   “Food systems” (3.1, paragraph 10): the reference to WHO recommendations on diets contained in this paragraph, refers to draft recommendations not yet approved or enshrined in policy by Member States, such as the one included in the 5th bullet point (“WHO recommends that intake of free sugars is less than 10% of total energy intake or, preferably, less than 5%”). These Guidelines are still in a draft version, recently put to public consultation and currently under revision. The WHO website (http://www.who.int/nutrition/sugars_public_consultation/en) states the following: “Once the peer-review and public consultation are complete, the guideline will be finalised and reviewed by the WHO Guidelines Review Committee for final clearance prior to its official release”. The real practical concerns with this particular recommendation are gaps in Level-1 evidence alongside concerns around achievability but also appropriateness for this to apply to different geographic and socioeconomic contexts as a blanket policy.  This paragraph should be modified, maintaining only the references to WHO documents already approved by Member States.

o   “Food Environments” (3.1.1 page 12, 2nd bullet point in the section on “incentivize healthy dietary choices”): “Create fiscal incentives and disincentives to encourage healthy diets by reducing the cost of more healthy diet options relative to less healthy ones” - this sentence opens the door to unjustified forms of “food taxes” which, without adequate research based evidence towards effectiveness of such a policy on appropriate health outcomes. This may disproportionately discriminate certain types of foods which, when consumed in moderation as part of a balanced diet/lifestyle, would not be considered as “unhealthy”.  Food taxes can be a risky venture as their social and cultural value/acceptability has not been fully assessed. Additionally, the Danish experience of implementation without adequate piloting led to the following statement by their government:  “the fat tax hit jobs and increased cross border trade, with rising numbers of Danes heading into Germany to buy butter”.  This sentence would therefore merit significant modification.

o   “Nutrition education for behavior change” (3.3.4, page 21, 7th paragraph): “Nutrient profiling has been used as a tool to qualify the nutritional value of individual foods and help consumers make healthy choices, as well as governments design schemes to control food marketing and label food products”.  Particularly given that current focus has shifted to diet and lifestyle patterns rather than single foods investment in nutrient profiling may be a blunt instrument, further offset by difficulty in reaching agreement e.g. since 2007 the European Commission has been trying to define nutrient profiles to regulate health claims, without being able to reach any agreement among Member States. This section also does not refer to behaviour change and nutrition education geared towards healthcare professionals. The aforementioned sentence should, therefore, be reviewed.

o   “International Trade and Investment”, (page 24, third paragraph- it follows par. 3.3.6 and before par. 4): “The availability of and access to unhealthy foods should be effectively regulated and discouraged. International standards in regulations for nutrition content to promote compliance with nutrition requirements should be established, implemented and enforced.” This may lead to negative consequences particularly on traditional quality European products including component foods of the Mediterranean Diet which would all be classified as “unhealthy” due to fat, sugar and/or salt content. This sentence requires rethinking.

In addition, throughout the draft document there is a lost opportunity through heavy focus on policy but without accompanying strategies for implementation into practice or impact evaluation relating to uptake of policy or indeed translation into practice. In order to emphasize the practice angle further in relation to public health nutrition and the control/prevention of non-communicable diseases it is also necessary through this document to highlight the need to build capacity in the nutrition and healthcare workforce as well as improve engagement on the part of healthcare practitioners to foster ‘nutritionally informed’ health advice and advocacy, underpinned by robust evidence based policies, wherever possible.

I would be happy to provide further clarification/information and further supporting references if required and hope that there will be an opportunity to attend/feed into the meeting in November.

Kind regards

~Shumone~

Dr Sumantra Ray

Senior Medical Advisor | Senior Clinician Scientist

UK National Diet and Nutrition Survey (NDNS) Lead Clinician

Contextual comments

Thank you for instituting this process of consultation with civil society organisations and social movements. Our specific comments are in the separate document below.

Work on ICN2 has a practical context. We recognise that this participatory process, not used for the 1992 International Conference on Nutrition, imposes an additional load on the UN agency secretariats. This response is in a spirit of sympathy and solidarity. We also recognise other strains that are stressing the UN system. Relevant UN agencies need much more unrestricted funding, absolutely and relatively, from member states, in order to fulfil their mandates, to serve member states and the public interest, and to protect and preserve sustainable agriculture, food and health systems.

ICN2 needs to be positioned as within a very broad context of knowledge, policy and action. We emphatically support the commitment of the UN Food and Agriculture Organization to family farming, which will and must remain fundamental, and the commitment of the World Health Organization, frequently emphasised by Director-General Margaret Chan, to universal primary health care.

What people eat and the effect of diets on personal health, and of dietary patterns on population health, are now well known to have environmental, economic, political, social and cultural as well as behavioural and biological determinants. These can be grasped only by use of systems methods. The linked financial, fuel and food crises are symptoms of world disorder that can be addressed only at the very highest level. Climate change has now been identified by the President of the World Bank as potentially profoundly disruptive of food systems and population health, so much so as to be a cause of wars. The deliberations and outcomes of ICN2 will make a real and lasting difference for the better if, and only if, they focus on the basic and underlying causes of disease, health and well-being in the whole sense of these terms.

We appreciate that our overstretched colleagues in the UN system who are working on ICN2, together with many member state representatives especially from the more vulnerable regions, know all this. We pledge to give the ICN2 process and its outcomes all the support we can.

General comments

The main ICN2 input and output documents should include explicit reference to and citation of other documents on which ICN2 has been built, or that are relevant to its work. This is of course normal in UN processes. Two recent examples are the May 2014 publication on Family Farming, Food Security, Nutrition and Public Health in the Americas, prepared by UN agency colleagues; and the June 2014 Santa Cruz Declaration For a New World Order for Living Well of the G77 group of member states (now 133, + China). Pdfs of these documents are attached.

Of the statements and recommendations made in comments seen so far, we wish to give broad support to four that have, as here, been submitted by named people on behalf of international organisations. These include that by Corinna Hawkes, on behalf of World Cancer Research Fund International and the NCD Alliance, on achieving an effective process. They also include those by Lida Llotska on behalf of the International Baby Food Action Network; by Claudio Schuftan on behalf of the People’s Health Movement; Xaviera Cabada on behalf of El Poder del Consumidor; and Flavio Valente on behalf of FIAN International. We basically agree with their comments on the broad issues that are neglected in or missing from the Framework For Action draft. We also agree that the draft is still not in a state where it is sensible to propose drafting changes and adjustments. Its general approach requires new thinking, much of which has now been proposed.

• The structural determinants of states of population health, and the realisation that epidemic diseases are symptoms of sick societies.
• The need to enable impoverished populations to determine their own ways of being and living and to gain sustained agriculture and food security.
• The imperative need in all normal situations for extended exclusive breastfeeding followed by freshly prepared culturally appropriate food and meals
• The devastating impact of the penetration by transnational food and drink product corporations of middle and low income countries in the global South.

These and other statements made in these three documents are amply supported, not seriously contested, and need emphasis. On the issue of transnational corporations, we agree with the position reached in a relevant February 2013 Lancet paper in its Non-Communicable Diseases series, attached. To include such powerful industries, whose interests directly conflict with those of public health, in any form of policy planning (as distinct from implementation) is absurd.

In addition, we propose that all the main ICN2 input and output documents need to be introduced by a short set of governing and guiding principles which set out the conceptual and ethical framework of ICN2 and in effect of all other high-level meetings whose intention is to preserve and protect agriculture, food, nutrition and health systems. If this recommendation is accepted we will propose some principles, one of which certainly is that concerning the human right to adequate and nourishing food.

Specific comments

The specific comments that follow indicate general concern about the nature of the draft Framework For Action. The stage has not yet been reached when the sole or main focus should be on specifics. This said, here are some specific concerns, keyed to the text of the Framework draft.

What customers acquire and consumers eat and drink is not influenced just by availability and access, as indicated and implied. One of other determinants that are decisive, are the product formulation and marketing policies and practices most of all of gigantic transnational and other huge food and drink manufacturing and catering corporations. The Framework needs to emphasise this and other determinants explicitly (page 1, paragraph 3)

The draft fails to specify the basic and underlying causes of malnutrition. It identifies the problems and then quickly moves on to propose solutions. But unless social, economic, political and other determinants are understood, it is all too likely that policies will be irrational and actions and programmes ineffective or unsustainable. (page 1, paragraph 3-4)

The scientific basis of the Framework should be governed by human rights principles, to which there is no reference. (page 2, paragraph 1)

The Framework refers to ‘the global food system’. This is a basic error. The term implies among other mistakes, standardisation, concentration of power, sources, supplies, inequity, cultural monotony, and reduction of cultivars. What is needed is the identification, protection and strengthening multiple, traditional, democratic, equitable, sustainable and heath promoting food systems. (page 2, paragraph 1)

While referring to its alignment with World Health Assembly agreements, the Framework fails to indicate the need to recognise and uphold family farming, as emphasised by the UN Food and Agriculture Organisation as responsible for most of the food produced supplied worldwide. (page 3)

Member states are indeed primarily responsible for implementing UN agreements, such as those planned for ICN2. But the term and concept of ‘partnering’ with other sectors is not appropriate. This in particular implies a community of interests with corporations whose business depends on unhealthy products. Instead, the term and concept of ‘negotiation’ is appropriate. (page 3, paragraph 3)

It is essential to state indicate that solid mechanisms to avoid conflicts of interest are put in place. A fifth key element is needed, on the need for enhanced, strong and sustained monitoring and sanctioning mechanisms. (page 3, last paragraph)

The fourth element of ‘Better governance for nutrition’ should also state the need to assess corporate commercial practices, policies and products promoting or associated with unsustainable or unhealthy ways of production or consumption. (page 3, last paragraph)

Business jargon and its implications should be avoided. For instance, the ‘stakeholder’ concept should be eliminated. Instead, social participation forums and councils should be specified to be used to engage social movements and those most affected by nutrition problems. (page 5, bullet points)

Fiscal measures to reduce the demand for products contributing to unhealthy eating, such as taxes on sugared drinks, should be identified as a source of revenue earmarked for public health initiatives, such as guaranteeing the right to safe drinking water. (page 6, bullet points)

The Food Systems section is inadequate. It indicates that achieving foods adequate in quantity and in quality is the aim. However, who and how these foods have been produced are essential for the environmental, cultural and social adequacy and sustainability. It is possible to supply food adequate in quantity and quality from a biomedical perspective that nevertheless causes calamitous loss of biodiversity, cultural and socioeconomic impoverishment, and vast increases in inequities. (page 7)

The text on traditional and industrial food systems is incoherent. On the one hand it states problems with industrial systems. Yet at the same time, the Framework recommendations favour or assume ‘modern’ industrial systems. The value of traditional systems, universal until very recently in history, which are still the norm in many parts of the world, needs to be clearly stated. For instance, the use of pesticides in modern systems impoverishes the soil. In this vein, the document elides reference to low-input traditional technologies to improve food production. (page 7, paragraphs 3 and 4)

‘Increasing productivity and economic growth can improve nutrition outcomes’. But it can also cause and worsen nutrition problems. The document also includes inappropriate and misleading statements implying that automation of agriculture and food production gives more time to women to take care of children and prepare food. Massive mechanization does indeed reduce rural employment, but thereby increases immiseration in rural communities and urban slums. (page 8, first paragraph)

The use of nutritional supplements should be identified on most situations as a temporary expedient only. (page 8, 4th paragraph)

‘At each step in the chain…’ – This paragraph is mainly about artificial measures. It should include suggestions of the value of traditional technologies in farming, cooking, eating. (page 9, paragraph 4)

Page 10: Priority actions

Under ‘Promoting dietary quality and diversity,,,’ there should be included the sub-item:

• regulating the demand for unhealthy products and associated unhealthy eating practices by fiscal and other formal means that restrict propaganda for unhealthy products and that make healthy foods relatively more accessible and affordable.

Page 10: Priority actions

On the action: ‘Identifying and promoting good practices for improving nutrition enhancing food and agriculture based approaches on a large scale.’ This should give foremost emphasis to small scale farming.

Page 10: Priority actions

An additional item is needed that recommends radical scaling-down of the use of agrochemicals of all types, including antimicrobial drugs, and corresponding scaling-up of diversification.

Page 12 and several other passages in the following pages

Priority actions to improve the food environment. Mainly from this item on, the term ‘nutrient-rich food’ is continually used. It is confusing and misleading and should be avoided. For nutrition specialists the term refers to micro and trace nutrients. But it can be and is also interpreted as energy-rich foods, fat-rich foods, and so on. Also, the term and the way it is used implies that food products however unhealthy that are fortified with nutrients are therefore healthy.

Under ‘Healthy Diets’, the term ‘nutrient-rich foods’ should be replaced by ‘unprocessed or minimally or moderately processed foods’. (page 12)

Under the text on social protection it needs to be made clear that the impact of in-kind food transfers has been considerably higher than cash transfers where food is not available on the market, particularly in emergency contexts, as cash transfers can have an inflationary effect, resulting in further local food price increases. Food distributed through these scheme needs to be nutritionally adequate, and preferably produced by and purchased from the most socioeconomic vulnerable communities that grow food. (page 14, white bullet point 3)

On actions to addressing micronutrient deficiencies, it is a mistake to give priority to artificial addition of nutrients to food. The priority needs to be diversification of diet and preservation of agro-biodiversity. (pages 16-18)

On the priority actions on water, sanitation and hygiene. This needs to identify water as a public good and a human right. (page 22)

o  Nutrition and health goals should be the primary function of any food system.   Other services rendered by the food system include biodiversity, water conservation, humane treatment of animals, and climate stability.  Climate change will be a critical input towards food system redesign. Therefore, we believe that shifting the discussion from “trade-offs” to “priority actions” that improve nutrition goals would be a more valuable approach.

o  We would appreciate the committee providing clarity on the following statement: “Food system-based policies which work to reduce malnutrition via increased purchasing power stand a better chance of success when implemented within a broader pro-poor context, including social protection and other measures to reduce risk.” It is currently simply text that is hard to interpret or understand. Examples would be beneficial.

o  While  diverse  diets  are  necessary  for  achieving  good  nutrition  and  health,  other approaches  including  supplements  are  needed  when  it  is  not  physically  possible  or culturally acceptable to consume sufficient quantity of nutrient dense foods. Groups that are especially vulnerable to nutrient deficiencies are infants and young children and pregnant women and the elderly. Emergency situations exacerbate underlying deficiencies but are not the only instance when supplements are necessary.  Clarifying the statements made on page 17 is important for validating the interventions outlined by the committee to reduce stunting and improve maternal nutrition.

o  Fortified  foods  should  be  part  of  a  diverse  diet,  particularly  in  places  where  fruit, vegetables, and animal source foods are too expensive for low-income families. Food fortification is a proven and cost effective strategy for alleviating micronutrient deficiencies in the population and should be a priority.

o  Indicators for nutrition quality should be defined and clarified.

o  Resilience strategies are favored over emergency responses.

o  Under  the  priority  actions,  please  clarify  what  is  meant  by  ‘affordable  nutritionally enhanced foods’? Does this mean fortification?

o  It appears that the food environment section is aimed at addressing NCDs, while the food system section is aimed at food value chain, rural livelihoods, and malnutrition. This separation seems unnecessary and contradicts earlier statements made in the FFA that a systems view is the most appropriate. Please consider integrating most of the points found in 3.1.1. in to 3.1.

o  Workplaces  that  facilitate  breastfeeding  should  also  offer  on-site  quality  daycare  so women can breastfeed rather than feed breast milk.

o  Section 3.2 “Improved targeting, using a nutrition lens to identify individuals, households and/or communities who are most nutritionally vulnerable, may help.” Please clarify who will be helped by improved targeting.

o  “Ensuring universal coverage” Please clarify what universal coverage should be ensured?

o  Please  clarify  the  term  “sustainability”  in  reference  to  food-based  dietary  diversity.

Perhaps a more appropriate term in this context would be long-term strategies for food and nutrition security.  From an environmental perspective fortified food may be more sustainable than diverse diets, in precarious agro-ecological zones.

o  Section 3.3. “Nutrition should be fully integrated into each of the building blocks of health systems. This includes, for example, the strategies for human resources, essential medicines, governance, information and monitoring, health system financing, and service delivery”. The priority action is unclear.

o  There is compelling scientific evidence to replace iron-folic acid in pregnancy with multiple micronutrient supplements.

o  3.3.4 Nutrition education and behavior change is a priority action throughout. A separate section that addresses behavior change emphasizes a distinction that shouldn’t exist and could be confusing to policy makers. Therefore, we encourage the committee to integrate each of the paragraphs on nutrition education into the appropriate sections in the document.

o  3.3.6. This section should be separated into two as food safety belongs with food system discussions and antimicrobial resistance with infections and health.

o  Section 3.4 “Trade policies”. We recommend that this section be moved to section 2, as part of the institutional policies that create an enabling environment.  Also, the section on incentives has already been previously addressed.

o  Under  the  priority  actions  and  the  regulating  of  marketing  should  be  included  that countries should not only regulate but also monitor and enforce.

o  Under  the  priority  actions  and  the  regulation  of  marketing  should  be  included  that countries should implement the International Code of Marketing of Breast-milk Substitutes.

Chapters 4 and 5:

o  The private sector should be urged to achieve the commitments of the Rome Declaration.

o  Implementation challenges will be too large for countries to deal with on their own. A global network that brings together practitioners, scientists, and policy makers to address implementation should be created. This network works in coordination and support of local  implementation  teams.  Such  a  network  would  provide  an  ideal  platform  for enhancing local capacity development.

Question 2. Does the Framework for Action adequately reflect the commitments of the Rome

Declaration on Nutrition, and how could this be improved?

o  The Rome Declaration on Nutrition 2014 emphasizes improvements in the food system.

The FFA document, on the other hand, appears to emphasize equally the role of the food and health system. At times the document reads as though sections have been written separately by experts at FAO and WHO and integration is lacking. We would encourage further editing and review from experts who work in both the food and health systems. Furthermore, various redundancies and the use of different terms to describe similar concepts may give rise to confusion and we believe this should be avoided.

Question  3.  Does  the  Framework  for  Action  provide  sufficient  guidance  to  realize  the commitments made?

o  The FFA document provides a checklist of priority actions and encourages countries to embark on an assessment or landscape analysis. In our opinion, however, it does not offer guidance on how to implement these actions.

Question 4. 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?

o  In light of the comments above, technical advisory groups (TAG) at country level who are familiar with implementing programs should be encouraged.   It would be easier to coordinate international support through TAG.

Its wonderful to have this great document. We expect much more, the entire document addresses pressing issues and I agree with it.

Actions, are much more required to meeting goals.

Dear members of the Joint FAO/WHO ICN2 Secretariat

Thank you for the first draft of the zero draft of the Framework for Action (FFA) and the opportunity to comment.

We applaud the inclusion of malnutrition in all its forms and believe that it is of paramount importance to not only treat and prevent the occurrence of malnutrition but also build sustainable food systems to ensure long-term impact.

Please consider the following comments for subsequent drafts:

1. Do you have any general comments on the draft Framework for Action?

1. Do you have any comments on chapter 1-2?
   1. Critical 1,000 day “window of opportunity”: We welcome the inclusion of the critical 1,000 day “window of opportunity” from a woman’s pregnancy to her child’s second birthday throughout the document. However, we urge you to include a statement in the opening paragraph regarding the critical importance of the 1,000 day window and improving maternal, infant and young child nutrition. It should be noted that the evidence that demonstrates the significant impact that focusing on nutrition during this time came to light only relatively recently (i.e. through the Lancet series on maternal and child undernutrition in 2008)  We suggest adding the following to Paragraph 1 in the Introduction section on Page 1:

“Moreover, science has revealed that nutritional needs change over the life course, and that nutrition early in life—particularly during the 1,000 days between a woman’s pregnancy and a child’s second birthday—has an enormous impact on a human being’s physical and cognitive development and long-term health.”  

1. Framework for Action (FFA):
2. Paragraph 2:
   1. While important that the FFA and Decade of Action on Nutrition are endorsed and led by the United Nations General Assembly and taken forward by Member States, equally important is offering clear channels for partners to engage in these processes. Please add the following to the end of Paragraph 2: “…and give clear options for partners to engage.”

1. Decade of Action on Nutrition: Thank you for establishing the Decade of Action on Nutrition, we recommend the following in order to make it as successful as possible:
   1. Establish and cultivate Special Envoys and champions (governments, faith leaders, SUN leaders, celebrities and athletes) to push for nutrition in relevant international processes and agreements, including:
      1. Actively ensure that nutrition features prominently in the Sustainable Development Goals (SDGs)
   2. Host an ICN3 in 5 to 10 years, as well as conduct a 5 year review to ensure that we are on track to meet the 2020 Nutrition for Growth targets, 2025 World Health Assembly global nutrition targets and the nutrition component of the 2030 SDGs.
   3. Establish/Create global and local campaigns on nutrition and breastfeeding, in a coordinated way

1. 2.3 Financing for improved nutrition outcomes
   1. We agree that “more money for nutrition” is needed but also “more nutrition for the money”.  This is to recognize that current and future investments in agriculture, social protection, water and sanitation, etc. should be better harnessed and maximized to contribute to improved nutrition outcomes. 

2.1 Enabling Environments

a. Paragraph 1:Thank you for recognizing the importance of creating an enabling environment to successfully combat malnutrition and, while we find all fours key elements outlined as important, we suggest adding a fifth: Resources. The ability to find and utilize resource is critical for country-level actors to fully understand and implement priority action to combat malnutrition.

        2.2 Better Governance for Nutrition

1. Coherent government-endorsed policies with explicit targets and situation-specific strategies: Thank you for including the importance of conducting regular consultations to develop appropriate strategies to combat malnutrition, however, consultations should be developed in collaboration with all interested stakeholders and through participatory processes. Please change the following sentence to read: “The development of appropriate strategies should be developed in collaboration, through participatory processes, among all implementing partners…”

1. Institutional arrangements that encourage effective multi-sector working: In order to ensure effective multi-sector coordination, countries mustenshrine a high-level focal point for global nutrition and principal level representatives from each ministry with defined responsibilities to ensure continued nutrition coordination across government and civil society. Further, the high-level focal point for nutrition should have the ability to work effectively across relevant government ministries to coordinate and track budgets for greatest possible nutrition impact.

1. 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)?

1. Food Systems:
   1. Thank you for including the “do no harm” principle under the trade section, however, we recommend including a sentence in the section on food systems on government’s role in reshaping the food system. Please add the sentence:“Governments should take responsibility for leadership on nutrition by developing food policies that at a minimum do not harm people’s nutrition and ideally one that is aimed at improving nutrition status.”
   2. Thank you for including the economic argument for reductions in undernourishment, however, income growth is not directly linked to reductions in undernourishment. Please remove this sentence and change the paragraph to read:“For income growth to improve diets, it must be accompanied by specific actions to improve dietary adequacy and quality to reduce malnutrition in all its forms.”
   3. We applaud the recognition of the important role that women have in improving the nutrition status of the households and in particular, how raising women’s incomes has important implications for nutritional outcomes. Please also include the important role that improving women’s land and property rights have on improved household food security and nutrition (http://www.landesa.org/wp-content/uploads/Landesa-Issue-Brief-Land-Rights-and-Food-Security.pdf).
   4. Please include bio fortified foods promotion, and the importance of developing local nutritious varieties and promoting locally available and affordable foods to improve the food environment in-country.

1. Social Protection:
   1. Priority actions on social protection: 1,000 day window
      1. We applaud and welcome the inclusion of the 1,000 day “window of opportunity,” and on the need to give special attention to the “first 1,000 days”.  However, the point could be further strengthened by defining this critical period, as well as including a mention of the importance of pre-pregnancy. Please revise the point to read:

“While special attention needs to be given to the 1000 days between pregnancy and age two when vulnerability to nutritional deficiencies is greatest, children’s nutrition after age two and before they attend school requires continued attention.  Moreover, it is important to address the nutritional needs of women before they enter pregnancy, in many cases starting in adolescence, in order to maximize health outcomes for both mother and child in the 1,000 day window and beyond.“

1. Health:
   1. Nutrition education: We suggest adding another priority action on nutrition education that includes informing and communication on the importance of balanced, nutrient-rich diets in schools, communication for behavior change of consumers / users in food waste and losses post-harvest.

1.  International trade and investment
   1. We applaud the inclusion of a “do no harm” policy be adopted in international trade and investment. Please also include how availability of and access to healthy foods will be ensured, i.e., through nationally appropriate combinations of imports and domestic production, and investments in food production, especially by smallholders.

1. Do you have any comments on chapter 4-5?
   1. Accountability Mechanisms
      1. We applaud the inclusion of a possible FAO/WHO global trust to mobilize resources for nutrition, and recommend that such a trust be hosted at the World Bank. Additionally, RESULTS UK is carrying out a research that looks at the optimal aid architecture for the Nutrition sector that might be useful as such a trust is explored (Please contact Steve Lewis,[email protected], and Tena Nevidal, [email protected], for more information).
      2. We also recommend changing the last sentence be changed to read: “The trust fund will produce an annual report on the status of funds received and expenditures incurred, and provide technical assistance and support for countries and implementing organizations.”
      3. Mechanisms for monitoring and accountability: this framework appears in a vacuum. Please be explicit about how it will connect with other plans that countries have already developed and how it will be a part of an integrated framework with other international initiatives, such as REACH and SUN.

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.  

Specific comments

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.

Nutrient Profiling

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

Sovereignty

Protection of biodiversity

Protection of native seeds and centers of origin

Thank you. 

Comments of the International Union of Nutritional Sciences (IUNS)

This review of the document has been done on behalf of the International Union of Nutritional

Sciences (see: www.IUNS.org).

In the FFA the background-part is presented precisely and clearly, considering a wide range of significant nutrition-related health problems from malnutrition to overnutrition. The FFA addresses ambitious but achievable goals and focusses on main nutrition related health problems taking al- so environmental factors – such as climate change and climate variability – into account. In the paragraph of the institutional mechanisms the requirements to improve nutrition are openly ad- dressed, also reflecting actual developments.

In various parts of the document the development of “evidence-based strategies” and the control of measures are mentioned. However the urgent need of supporting the obligatory research in this field is yet not sufficiently addressed in all parts of the FFA: e.g. the introducing paragraph “Better results for the investments” of chapter 2.3 „Financing for improved nutrition outcomes”

(pp 6) should be expanded: “This needs to be accompanied by investment in relevant sectors

(e.g., agriculture, education, research, health, water, sanitation, hygiene [WASH], etc.)”.

The prioritization of actions of improving nutrition on the different levels is one of the strengths of this document. This is accompanied by a detailed description of potential measures to improve nutrition quality and safety along the food-chain. From the perspective of nutritional sciences these measures are comprehensive, relevant and meaningful. The addressed specific changes in the diet (pp 11) refer to evidence-based nutrition research and are widely supported by the community of nutritional sciences.

However there are some points of critics we want to mention:

Paragraph 3.3.3 Breastfeeding: There is the need to resuscitate the Baby Friendly Hospital Initia- tive. The document is silent on this.

Paragraph 3.3.4: Section on nutrition education is too long. This can be shortened to quarter of a page without losing content. This long narrative is not really needed. It is not focused and has no priority actions.

4. Accountability:  Biannual means every 6 months.  Is this what the document implied here? Every 6 month can the responsible organizations handle this?

How will ICN2 link up with other global initiatives in monitoring progress? The UK’s Global Nutri- tion Report will be monitoring progress on a yearly basis. How is ICN2 linking up to ensure that is done in a coherent manner; this saves time, money and efforts.

5. Recommendations: The formation of an IPN is not needed. There is no need to establish new structures. There are enough of such; however there is a strong need to link up with existing structures.

The document should clearly show how ICNs can facilitate commitment and action by countries.

Overall: The document is too long. I should be made sharper by reducing repetitions and redun- dant sections. The final document should be subjected to language editing to make it clearer and consistently bring the main messages to the point. A much shorter and crispier document will be more likely to be read and acted upon.

Thank you for the opportunity to contribute to the effort. Kind regards

Prof. Dr. Helmut Heseker

(IUNS council)

Please refer to the attachment for Action Against Hunger's feedback on the zero draft FFA.

The International Food & Beverage Alliance (IFBA) would like to thank the Food and Agriculture Organization of the United Nations (FAO) for the opportunity to submit comments on the ICN2 Framework for Action zero draft to implement the Rome Declaration on Nutrition.

IFBA is a group of eleven companies - The Coca-Cola Company, Ferrero, General Mills, Grupo Bimbo, Kellogg, Mars, McDonald’s, Mondelēz International, Nestlé, PepsiCo and Unilever. IFBA is committed to leading the industry to support the implementation of the 2004 WHO Global Strategy on Diet, Physical Activity and Health (the WHO Global Strategy), the 2012 Political Declaration of the High-level Meeting of the General Assembly on the Prevention and Control of Non-communicable Diseases (the UN Political Declaration) and more recently, the WHO Global Action Plan for the Prevention and Control of Noncommunicable Diseases 2013-2020, (the WHO Global Action Plan) through product innovation, improved access to nutrition information, responsible marketing practices, the promotion of healthier diets and physical activity.

1.            General comments on the ICN2 Framework for Action zero draft

Stakeholders in global nutrition share a common interest in tackling the problems of malnutrition and noncommunicable diseases (NCDs).  IFBA was one of the NGOs consulted by WHO throughout the process of developing the WHO Global Action Plan.   In line with the   UN Political Declaration, WHO strategies recognize that the solution requires a whole of society approach, multisectoral actions and the collaboration of governments, civil society and the private sector.  IFBA members strongly support this approach.  One of the fundamental principles underpinning IFBA’ s work is a commitment to public-private partnerships that support public health strategies.  Given the complexity and multifactorial causes of malnutrition and NCDs, it is essential that all stakeholders work together to develop holistic, impactful and sustainable solutions.  IFBA strongly supports the frequent references to these principles in the FFA zero draft document

The FFA zero draft is positioned on page 3 as a document to provide a “technical basis” for adopting major policy guidelines and strategies for governments, in partnership with non-state organizations (including NGOs and the private sector). We consider that the words “technical basis” do not reflect the content of the document, and instead propose

“This FFA provides the technical basis framework for adopting major policy guidelines and strategies and for developing and updating national plans of action and investments to improve nutrition.”

IFBA would encourage a more concise and precise document, with clarification of the following elements:

-              The status of this document vis-à-vis the Member State-approved WHO Global Action Plan.  In particular, to highlight those areas where the finally approved FFA calls for actions beyond the scope agreed to by Member States in the WHO Global Action Plan.

-              How duplication of the processes already established by WHO and the UN will be avoided (e.g. the Global Coordinating Mechanism.)

-              As a framework for action, it is important that assertions made in the FFA are evidence-based. In its comments, IFBA will cite a number of paragraphs where more precise scientific evidence would be helpful.

2.            Comments on chapter 2

2.1          IFBA supports the following references made in chapter 2:

◦                              2.1 Enabling environments (1st paragraph)

◦                             IFBA also believes that “knowledge and evidence-based strategies, policies and programmes” are essential to the creation of an enabling environment to improve nutrition. 

◦                             2.2 Better governance for nutrition (1st paragraph)

IFBA is committed to multistakeholder collaboration and supports the inclusion of all stakeholders in a consultative process for the development of appropriate strategies to improve nutrition should “involve regular consultations among all implementing partners, including consumer groups, other civil society organizations, producers, processors, distributors and retailers of food…professional nutritionists, research scientists; educators 2.2                Priority actions for nutrition governance, pg. 5:  More clarification would be helpful with regard to the call for the establishment of a  “cross-government, inter-sectoral governance mechanism ...” .

How would this align or link in with the Global Coordinating Mechanism or UN Inter-Agency Task Force for the implementation of the WHO Global Action Plan? Will there be any linkage to the work down in the Scaling up Nutrition (SUN) movement?

3.            Comments on chapter 3

3.1          IFBA supports the following reference:

             3.1 Food systems, 2nd paragraph

• IFBA supports the important point that: “interventions in isolation may have limited impacts within such a complex system, interventions that consider food systems as a whole are more likely to succeed.”

3.2          IFBA does not support the following statements: 

                (3.1 Food systems, 4th paragraph):

“However, they have also increased the availability of highly processed foods of minimal nutritional value which have contributed to obesity and diet-related NCDs.”

IFBA considers that this statement is over-simplistic.

It is well known that food processing can affect the nutritional value of foods.  This includes processes that expose food to light, oxygen, high temperatures, or mechanical processes such as the milling of cereals. 

However, the extent of any deterioration in nutritional quality is probably less than many consumers realise.  The USDA data set of factors for calculating the retention of micronutrients during food preparation shows that many food processing methods only weakly impair the nutritional the value of foods, if at all. 

Eicher-Miller et al (2012) have recently evaluated whether the level of food processing is associated with nutritional quality. The study looked at the contribution of processed foods to the US diet using data from 25,351 people over the age of 2 years from the 2003–2008 NHANES survey. The authors categorised foods according to five levels of processing:

1.            Minimally processed (e.g. milk, coffee)

2.            Processed for preservation (e.g. frozen or canned fruit and vegetables)

3.            Mixtures of combined ingredients (e.g. sauces and dressings)

4.            Ready-to-eat foods (e.g. breakfast cereals, yoghurt, ice-cream)

5.            Prepared foods (e.g. frozen meals, pizza).

They found that the level of processing was only a minor determinant of the nutritional quality of a food, and conclude:

“In conclusion, processing level is not a major determinant of foods’ nutrient contributions to the diet and does not have a clear association with the health of a food as determined by either “nutrients to encourage” or “food components to reduce” as specified in the Dietary Guidelines for Americans 2010. A food’s nutrient composition and the frequency and amount eaten, rather than level of processing, should be stressed as the most important considerations for the selection of a healthy diet.”

                (3.1 Food systems, 5th paragraph):

                IFBA would urge caution and recommend the FFA not use statements such as “the private sector will facilitate more sustainable and nutritionally desirable diets when it pays to do so.” In IFBA’s view, the private sector should not be singled out and it is an unfair depiction of the motives and role of the private sector in global nutrition.

Moreover, it already “pays” for the private sector to contribute to more sustainable and nutritionally desirable diets if companies want to be in the business for the long-term. 

(3.1 Food systems, 10th paragraph):

The reference to WHO recommendations on diets contained in this paragraph, refers to draft recommendations not yet approved by Member States, such as the one included in the 5th bullet point:

“WHO recommends that diets should ensure: Intake of free sugars is less than 10% of total energy intake or, preferably, less than 5%”.

These Guidelines are still in a draft version, recently put to public consultation and still under revision. The WHO website itself states, in fact, the following: “Once the peer-review and public consultation are complete, the guideline will be finalized and reviewed by the WHO Guidelines Review Committee for final clearance prior to its official release”.  We recommend that this paragraph be amended to read:

“The WHO draft guideline recommends that diets should ensure: Intake of free sugars is less than 10% of total energy intake or, preferably, less than 5%”.

(3.1 Food systems, a suggested addition)

Strengthening facilities for local food production and processing while at the same time ensuring that local markets are developed (e.g. through school meals and corner stores) for the sale of these foods

3.3          (3.1.1 Food environments: Priority actions to improve the food environment: Incentivize healthy dietary choices, pg. 12):

Well-constructed fiscal measures might be effective as part of a wider public policy programme.  However, we would like to see that any economic tools are supported by evidence. Therefore we propose the following edit: “Review the scientific evidence for creating fiscal incentives and disincentives to encourage healthy diets by reducing the cost of more healthy diet options relative to less healthy ones”. 

·         Unedited, this sentence does not cite or provide the evidence base of the effectiveness of fiscal instruments, specifically applied to nutrition. This could open the door to unjustified forms of “food taxes” which, without proper scientific evidence, would unfairly discriminate certain types of foods which, when consumed in the correct portions and with the correct frequency, would not be considered as “unhealthy”.  Food taxes have unpredictable and negative consequences. They are regressive and their social and cultural value has not been fully assessed.  Our understanding of the academic research indicates there is no science to show that the taxation of food products is an effective means to address NCDs, nor is there any evidence to show that food taxation will achieve behaviour change or improve consumers’ access to healthier foods. [1]

It is also worth recalling the recent failed experience of the Danish “Fat Tax”, introduced by the local Government in 2011 but withdrawn after just one year by the same Danish Administration, which admitted unpredictable and even negative consequences:  “the fat tax hit jobs and increased cross border trade, with rising numbers of Danes heading into Germany to buy butter”2.We would therefore recommend that this proposed action either be removed or modified.

3.4          (3.3.4 Nutrition education for behavior change, 3rd paragraph)

IFBA fully supports the FFA call for nutrition education and information.  We too believe “People need clear and accurate information to be able to make healthy choices.”

Empowering the consumer to make healthy food choices is essential. The product label and nutrition facts panel or table is a principal source of information for consumers. Experience has shown that providing data, i.e. transparency around the nutrient content of food as well as increasing nutrition facts in a simple and easy-to-use format help consumers understand the information and make healthier choices. IFBA supports a fact-based approach to nutrition labelling as set out in its commitments (www.ifballiance.org). Fact-and science-based labelling systems, which provide meaningful and understandable nutrition information on overall diet, allow consumers to make the dietary decisions to meet their individual nutritional needs.

4.            Comments on Chapter 4

4.1          (4.4 International trade and investment, 3rd paragraph)

IFBA has concerns about the following statement: “The availability of and access to unhealthy foods should be effectively regulated and discouraged. International standards in regulations for nutrition content to promote compliance with nutrition requirements should be established, implemented and enforced.”

This sentence goes beyond what was agreed by Member States in the WHO Global Action Plan.  Regulating the nutrition content of food products with pre-set standards applicable to International Trade would not only most likely be contrary to applicable competition rules, but would also pave the way for burdensome legislation which, without any proper scientific basis, would unjustly discriminate certain foods, with serious negative consequences particularly on traditional quality European products (such as olive oil, parmigiano, mozzarella, feta, camembert, prosciutto di Parma, Jamon Serrano, honey, jam and even fruit compote), which would all be stigmatized as “unhealthy” for their fat, sugar and/or salt content.  We recommend therefore that this sentence be removed or modified. At the least, a precise definition of both “healthy” and “unhealthy foods” should be developed in consultation with all relevant stakeholders.

4.2          Accountability Mechanisms, 1st paragraph

IFBA would encourage FAO / WHO to consult widely on the establishment of credible, independent accountability mechanisms.  From IFBA’s experience, the complexity and cost involved in the development of an independent monitoring and evaluation system is underestimated. This applies especially to NCD-related areas such as reformulation of products, marketing to children and labeling. IFBA would be willing to share its experience and methodologies used.            

5.            Other questions