Global Forum on Food Security and Nutrition (FSN Forum)

This member contributed to:

    • Dear Drafting Team,

      Inequality is one of the root causes of hunger and food insecurity, therefore, I consider this topic relevant and timely, reminding that Hungary was one of the sponsor countries proposing this issue to be included in the CFS Multi Year Programme of Work (MYPOW).

      I appreciate the open, transparent and inclusive process, providing opportunity for all stakeholders to submit comments in the framework of this online consultation. I wish to start by congratulating the HLPE, its Steering Committee and the Drafting Team for the high quality of the V0 Draft, commending their efforts to rely also on previous HLPE reports and CFS policy papers.

      I agree with the concept outlined in the V0 Draft, seeking to address inequalities and inequities as main drivers of food insecurity. In this regard, I appreciate that the definition of food security is used in a broader sense, confirming that in addition to availability, access, stability and utilisation, the two new dimensions (agency and sustainability) play an essential role in the fight agains food insecurity. Among the definitions, I appreciate and find helpful the clearly explained distinction between inequity and inequality.

      I very much welcome the human rights approach throughout the document, putting in evidence the universality and the interlinkages among the various human rights. Similarly, I appreciate references to a number of SDGs as well. I would suggest to include also SDG 8 (Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all), considering the high number of food workers and other employees in the food systems and their labour rights. Furthermore, I would suggest to include explicit reference to the right to decent work (including decent rural employment[1]) and consider it appropriate to make clear reference to the respective UN resolutions, for example when it comes to decent livelihood[2] or clean environment[3], on page 19. of this document mentioned only in brackets.

      Regarding the "Systemic Drivers" in page 21, I find it not sufficiently comprehensive and exhaustive. I miss in particular the following important drivers of inequalities.

      1. Lack of sustainability assessments of food systems, based on independent and neutral science. Outcomes of these assessments could help policy makers take the right decisions aiming to reduce inequalities. Science-based sustainability assessments should give due consideration to all environmental and particularly social externalities, including the „hidden costs”, applying the principles of true costs accounting[4].
      2. Lack of appropriate policy environment (due to lack of appropriate sustainability assessments of food systems), with consequences listed below: a) Incorrect distribution of subsidies, (favouring mainly large entities) which further aggravate the existing inequalities. As a current prevailing practice, farm subsidies mainly support unsustainable, input-intensive, monoculture farming, with all the well-known negative consequences (biodiversity loss, soil degradation, etc.). This is confirmed by the recent FAO/UNDP/UNEP joint report on public support to agriculture. As the document says: „Globally, support to agricultural producers currently accounts for almost USD 540 billion a year, or 15 percent of total agricultural production value. This support is heavily biased towards measures that are distorting (thus leading to inefficiency), unequally distributed, and harmful for the environment and human health. Under a continuation of current trends, this support could reach almost USD 1.8 trillion in 2030.” According to the report, these “harmful” subsidies benefit mainly large-scale farms (to the detriment of smallholders) and include farm supports provided in the frameworks of the Common Agriculture Policy and the US Farm Bill. b) Misconceptions about taxes, including neoliberal policies guaranteeing low level of taxes for the largest and richest stakeholders, and often tolerating tax avoidance/dodging with no efficient measures against tax heavens. c) Limited access for smallholders and other marginalized groups (women, indigenous people, etc.) to

               - land and other natural resources,

                - loans or credits

                - inputs and technologies

                - markets,

                - research and innovation (The main focus of research is industrial farming and corporations…)

      I welcome the references to power imbalances along the food supply change, often creating conflicts of interest situations, which are the major obstacles to transformative changes of food systems. I would find it indispensable to make a clear distinction of roles and responsibilities of the various stakeholders. Contrary to the present practice, multinational corporations and other lobby groups could be consulted but they are NOT supposed to be involved in decision making and they should not be allowed to use their strong power to influence policy decisions[5]. Decision making is the competence of governments. Furthermore, we consider it essential to draw attention to and duly address in the report the greenwashing attempts by many corporate stakeholders, including their Corporate Social Responsibility (CSR) measures[6]. Although CSR activities are generally welcome, the CSR messages are regularly positive, they cannot be considered in any way sufficient for the necessary transformative changes.

       

      [2] In July 2022 UN General Assembly declared access to clean and healthy environment a universal human right.

      [3] According to Article 25(1) UDHR, ‘everyone has the right to a standard of living adequate for the health and well-being of himself and his family’. This provision sets out some of the elements of this right: a) food; b) clothing; c) housing; d) medical care; and e) necessary social services.

      [5] As Jeffrey Sachs put it in his speech at the U.N. Food Systems Pre-Summit: „...We cannot turn this over to the private sector, we already did it a hundred years ago!... The key for the private sector is simply this: behave, pay your taxes, and follow the rules. That's what businesses should do...” https://www.jeffsachs.org/recorded-lectures/5jf86pp5lxch35e6z3nct6xnmb8zy5

      [6] As a CEO of a multinational corporation acnowledged, the role of CSR (corporate social responsibility) is „either to hide the dirty part of the business or to simply promote sales”. Adding that the amount spent for CSR is very small

      See the attachments:

    • To whom it my concern.

      I wish to express compliments to the HLPE and its Project Team and Steering Committee Members, along with the HLPE Secretariat and Drafting Team for the comprehensive document.

      I fully agree that availability of reliable data is essential for any decisions to transform our failed/broken food systems. The zero draft provides an excellent basis for further discussions and in this regard the inclusive and transparent preparatory process is much appreciated.

      I am making now some comments only on the collection/control/ownership of data and the privacy/security/protection of data. These are undoubtedly the most important issues and the Authors touched the related valid concerns in Chapter 4.1.1. However, it would be indispensable to make further efforts to provide a deeper analysis of the situation and include in the conclusions some guidance and recommendations in this regard.

      Ownership of data and information means power to control and it would be unacceptable and a huge mistake to give this power to corporations and monopolies, for obvious reasons.

      In addition, some data to be collected might contain confidential, sensitive personal data, including data of smallholders, family farmers, consumers and others.

      For the above reasons, guarantees and appropriate safeguard mechanisms are required, to protect privacy and security but also to build confidence and trust.

      As the document itself mentions, there is a risk that people may have concerns that “…their data may end up in the wrong hands, be used against them, be used to exploit them, or put them in precarious positions in the future.” This issue should be duly addressed in the next version, because it is a real danger, again as acknowledged by the authors: “This can also lead the risk of agro-food market dominance by few monopolies that have control or ownership of data.”

      There is another challenge mentioned in the chapter 4.4.2. Trust and transparency issues: “If the decision-making process is hidden from the person directly affected by the outcomes, then the underlying technologies can raise trust issues.” This again confirms the need for respecting the principle of inclusivity.

      I think the above short comments can clearly confirm and justify the need for elaborating this part in more details, in addition to the summary of governance challenges mentioned in chapter 5.4.

      It would be also necessary that in its last (“to be completed”) chapter on Conclusions and Recommendations, the document could provide clear guidance, including on the needed appropriate safeguard mechanisms.

      I am looking forward to the revised version of the draft.

      Best regards,

      Zoltan Kalman

      See the attachments:

    • Contribution by Zoltan Kalman

      Permanent Representative of Hungary to the UN Food and Agriculture Agencies in Rome

      1. Does Chapter 1 adequately reflect the current situation of malnutrition and its related causes and impacts, particularly in line with the goals and targets of the 2030 Agenda? What are the underlying problems that currently hinder food systems to deliver healthy diets?

      Chapter 1 provides a comprehensive overview on the situation. However, among the causes of malnutrition the reference to the root causes is still missing: poverty and inequalities. It is a rather complex issue and would require a holistic approach and would also necessitate structural changes in our current food systems.

      One of the basic problems with our food system is the misconception of low food price policy. The impacts of low food prices on the consumers' behaviour are significant, including their buying preferences. The situation of “low food prices” appears to be the result of competition among retailers and as such they seem to be positive and useful, favouring the poor people. In reality, all people, including the poor, suffer the consequences of this low food price policy, because low food prices regularly linked to low quality of food. These low quality, ultra-processed food (frequently with high fat, sugar and salt content, the so-called junk food) have serious consequences on the nutrition status of the poor populations, many times leading to obesity and overweight. Food prices are frequently kept artificially low; they do not reflect the real costs of production, ignoring the positive and negative impacts (externalities) of the various food systems on the environment and on the human health.

      For the decisions to transform our current food systems, true cost accounting is essential, giving due consideration to all environmental and human health externalities. This could help shape the Voluntary Guidelines, recommend appropriate measures, policy incentives in support of sustainable solutions. There are ample scientific evidences related to the true costs of food and there are several studies available on this topic, for example http://www.fao.org/family-farming/detail/en/c/436356/; or http://teebweb.org/agrifood/measuring-what-matters-in-agriculture-and-f….

      In addition, artificially distorted, low food prices have a strong impact on the food waste as well. If food is cheap, it conveys the message that it does not represent a real value. Therefore, consumers will care much less about it, they are throwing away food more easily. Higher food prices (reflecting the true costs of food) would discourage consumers to buy more than they effectively need. Realistic prices (reflecting the true costs) of food do not imply generally high food prices. Only the prices of those (ultraprocessed, junk) food would go up which do not internalize the environmental and public health externalities. Studies show that as a result of true cost accounting, prices of locally produced, fresh, healthy, unprocessed (whole) food would become more competitive. For the benefit of those who produce them, and in particular, the consumers and the whole society. Obviously, there would be the need for measures to provide decent wages as well, but these are necessary anyway to combat extreme poverty. In addition, the costs of these measures are much lower than the benefits of saving great amounts of public health care expenditure.

      2. What should be the guiding principles to promote sustainable food systems that improve nutrition and enable healthy diets? What are your comments about the principles outlined in Chapter 2? Are they the most appropriate for your national/regional contexts?

      Guiding principle a) Systemic and holistic and evidence-based approach. This is essential and it should include scientific evince of true cost accounting. Respecting the principles of sustainability is indispensable, paying due attention to the (so far neglected) environmental and social dimensions. Obviously, the economic dimension should also be considered. However, it should be kept in mind that economic sustainability is nothing else but the result of the national and international "economic environment", in particular the financial policy incentives or subsidies, promoting one or another type of food systems. In this regard, national legislators have enormous responsibility in providing the appropriate policy incentives to those food systems which are really sustainable.

      Guiding principle b) Coherent and context-specific policies. Appropriate policies should include targeted measures to create an enabling economic environment for all stakeholders, with positive and negative financial incentives. These measures should be based on the above mentioned scientific evidence of true cost accounting and should address the power imbalances along the food supply chain.

      Guiding principle e) Nutrition knowledge and awareness. This should include nutrition education starting with the youngest children at school.

      Guiding principle f) Realization of the Right to Food. Reference to the root causes of hunger and malnutrition is missing: poverty and inequalities. Realization of the Right to Food is possible only if poverty and inequalities are adequately addressed.

      3. In consideration of the policy areas identified in Chapter 3 and the enabling factors suggested in paragraph 41 of the Zero Draft, what policy entry points should be covered in Chapter 3, taking into account the need to foster policy coherence and address policy fragmentation?

      The Chapter dedicated to shaping the Voluntary Guidelines, in particular paragraph 41 rightly provides a list of the cross-cutting factors and specific operational fields. As agreed earlier, the objective is to provide recommendations applicable and usable in practice, providing real help to Member States in their efforts to improve the nutritional status of their population. Therefore, it is important that policy decisions to provide incentives to transform our current food systems, improve nutrition and enable healthy diets, should be based on scientific evidence. In this regard, it is indispensable to apply the true cost accounting concept, giving due consideration to all environmental and human health externalities. See more reference above, under Section 1.

      It appears evident again the lack of reference (in paragraph 43.) to the root causes of malnutrition: poverty and inequalities. In this regard, the first sentence of this paragraph should refer to economic affordability, in addition to food availability.

      Several times in the document, including in sub-paragraph h) food fortification is mentioned. Fortification can constitute a short/middle term solution against micronutrient or other deficiencies but should not be presented in the Voluntary Guidelines as a global solution for nutritious, healthy diet and sustainable food systems. Fortification has an important role in emergency situation, but it should be considered only as a temporary solution in specific, fragile contexts and not as a final goal. The real, longer term solution should be the consumption of diverse, locally produced, nutritious food for a healthier diet, benefitting also the local communities who produce these food products. These products contain all nutrients, minerals, vitamins for a healthy diet; therefore, on the longer run there is no need for fortification. This should be made clear while shaping the Voluntary Guidelines.

      In the same paragraph 43, a whole sub-paragraph (i) is dedicated to Climate change adaptation and mitigation. This area is extremely important but adaptation and mitigation measures alone are able to provide solutions only to some of the overall problems. It is the concept of sustainability that fully includes the climate change adaptation and mitigation concerns and goes well beyond, provides adequate responses to a number of other environmental challenges (biodiversity loss, soil degradation) and to social issues as well, like rural employment.

      In sub-paragraph j) Antimicrobial resistance it would be appropriate to specify and add at the end of the sub-paragraph the need for phasing out of use of antibiotics for animal growth promotion.

      In paragraph 44 sub-paragraph a) Food losses and waste: This paragraph should be complemented. The main drivers of Food losses and waste (including low food prices and the policies of retail chains) are to be identified and appropriate measures should be recommended.

      Paragraph 46 refers to local markets. The Voluntary Guidelines should explicitly recommend establishment and promotion of local farmers’ markets. Short supply chains have a number of advantages like the supply of fresh, diverse food for a healthy diet to consumers. This paragraph also refers to the challenge of lower prices in supermarkets. The situation of “low food prices” is rather complex and therefore should be elaborated in more details. For further references, see above my responses related to low food prices, under section 1.

      Under a) and b) of paragraph 46 the issue of true cost accounting could provide relevant inputs for the Voluntary Guidelines. Regarding food products high in fat, sugar and salt, the Voluntary Guidelines should recommend serious restrictions on the advertising and marketing.

      4. Can you provide specific examples of new policies, interventions, initiatives, alliances and institutional arrangements which should be considered, as well as challenges, constraints, and trade-offs relevant to the three constituent elements of food systems presented in Chapter 3? In your view, what would the “ideal” food system look like, and what targets/metrics can help guide policy-making?

      5. How would these Voluntary Guidelines be most useful for different stakeholders, especially at national and regional levels, once endorsed by CFS?

      The Voluntary Guidelines would be useful for governments and parliaments preparing/adopting appropriate legislation. It would be important to follow these guidelines by the other stakeholders (private sector, civil society, etc.) as well.

      FAO has a crucial role to give due consideration to these Voluntary Guidelines while providing policy advice to countries. (This would be important for all the other, previous CFS policy recommendations, guidelines and principles…)

      See the attachments:

    • Dear Dr. Silvia Gaiani,

      Dear Ms. Maryam Rezaei,

      Congratulations for the work done so far. I wish to submit some remarks regarding the serious issue of food waste, prevalent in particular in the developed countries.

      I have not seen comments related to the main drivers of food waste. If we want a significant improvement, it would be essential to address all these drivers. These are rather complex and would need a holistic approach and would require structural changes in our current food systems.

      Let me mention just two of these drivers.

      1. The impacts of low food prices on the consumers' behaviour, including their buying preferences. In particular, I wish to refer to the food prices which are kept artificially low. The situation of “low food prices” seem to be the result of competition among retailers and as such they are apparently positive and useful. In reality, the prices are frequently kept artificially low; they do not reflect the real costs of production. Food industry suppliers are often under serious pressure by the retailers, and consequently, many times they are constrained to bring their costs further down, also by lowering the quality of the food they produce.

      These low food prices seem to favour the poor people, but in reality, the poor suffer the consequences of this low food price policy, because low food prices regularly linked to low quality of food. These low quality, ultra-processed (frequently junk) food have serious consequences on the nutrition status of the poor populations, many times leading to obesity and overweight.

      The artificially low food prices do not reflect the actual costs of production, due to our broken food system. The indirect or “hidden cost” are not paid by those who produce the food, they are paid by the wide public, the consumers. These are the so-called environmental and social externalities and there are many studies available related to this issue. Among these studies, I can mention the one prepared by the KPMG international audit company: https://assets.kpmg/content/dam/kpmg/pdf/2014/10/a-new-vision-of-value-v1.pdf. The KPMG study itself is much broader than food systems. On page 10 there is a graph, showing that the cost of environmental externalities is about 224 (!!!) % of the profit of industrial food production. It is only the industrial food production where the value is higher than 100%... The social, and in particular the public health externalities mean an even more serious and much higher “hidden” costs, including costs of treating malnutrition, obesity, and diseases like diabetes, cardiovascular and other non-communicable diseases. In this regard the TEEB AgriFood (a UNEP institute) has prepared some studies, including a report here: http://teebweb.org/agrifood/home/scientific-and-economic-foundations-report/. Another article related to the topic: https://futureoffood.org/cheap-food-aide-memoir/. These studies confirm the need to involve health and finance ministers in shaping the national food policies...

      It should also be mentioned that IPES Food has interesting and relevant studies on the industrial vs agroecological farming and food production: http://ow.ly/V4O730lBbmW or http://www.ipes-food.org/images/Reports/UniformityToDiversity_FullReport.pdf?platform=hootsuite.

      FAO had some papers as well related to true cost accounting: http://www.fao.org/family-farming/detail/en/c/436356/. Unfortunately, more recently I have not seen any similar documents from FAO.

      The general conclusions of these studies clearly demonstrate that true cost accounting does provide appropriate scientific evidence and guidance and this guidance should be duly taken into consideration while transforming our broken food system.

      Finally, and most importantly, artificially distorted, low food prices have a strong impact on the consumers. If food is cheap, it conveys the message that it does not represent a real value. Therefore, consumers will care much less about throwing food away. Higher food prices (reflecting the true costs of food) would discourage consumers to buy more than they effectively need. Realistic prices of food do not imply generally high food prices. Only those (ultraprocessed, junk) food prices would go up which do not internalize the environmental and public health externalities. Prices of locally produced, fresh, healthy, unprocessed (whole) food would become more competitive. For the benefit of all the population. Obviously, necessary measures would include decent wage level as well, but the costs of these measures are much less than the benefits of saving great amounts of health care expenditure.

      As Pope Francis said, “Wasting food shows a lack of concern for others”. He also said: “When financial speculation manipulates the price of food, treating it as just another commodity, millions of people suffer and die from hunger.”

      2. The other issue I wish to mention comes from the question of “cui prodest”? We need to understand who are interested to prevent food waste and who benefit from wasting food. In our world where “money makes the world go round”, all stakeholders along the food supply chain are clearly interested to decrease food waste, with one exception. The big multinational food retail chains can maximize their profit through increasing their sales volumes. This is why these retail chains regularly apply large-scale sales promotions (discounts, pay 2 – get 3, etc.) strongly encouraging consumers to buy food products (because prices are attractive...) even if they do not really need those products, and buy big quantities, much more than they really need. Big retailers do not care about food waste. On the contrary, the more food is wasted by consumers, the higher of their volume of sale will be…

      At the same time, we need to acknowledge that there are efforts by some of the big retail chains to exercise for example “corporate social responsibility” (although it is considered another form of promoting image to increase sales…). Some of the retailers are even involved in actions of donations of unsold food to the poor through food banks. Some others are making real efforts to decrease the quantities of unsold food, in collaboration with the national legislators, through the development of markets for substandard products, amending food labelling regulations and establishing policies and legislation to facilitate food donation. Some others again, as also suggested by the proposed outline, do capacity building in inventory management and waste audits and measurement, and use differentiated pricing for products near the use-by date.

      By putting all the above in evidence I had no intention to point fingers on the retail chains as the only player responsible for the problems. I am just proposing to do appropriate analysis of the role of all involved stakeholders, including the retail chains.

      Regarding the measures above I consider them extremely important, but I think they do not address the root causes of the problem. For real improvements, we would need deeper, more targeted measures. Including the Development of a Code of Conduct on Food Loss and Food Waste Prevention.

      As far as the transformation of the food system is concerned, structural, systemic changes are required, based on the scientific evidence provided by true cost accounting. Respecting the principles of sustainability is essential, paying due attention to the (so far neglected) environmental and social dimensions. Obviously, the economic dimension should be considered as well. However, we should also keep in mind that economic sustainability is nothing else but the result of the national and international "economic environment", in particular the financial policy incentives. In this regard, national legislators have enormous responsibility in providing the appropriate policy incentives to those food systems which are really sustainable.

      Best regards,

      Zoltan Kalman

      Permanent Representative of Hungary

      to the Food and Agriculture UN Agencies in Rome