This member participated in the following discussions
Dear FSN Forum Team, Dear FSN Forum members,
The International Dairy Federation has been actively engaged through the CFS Private Sector Mechanism in drafting these voluntary guidelines on food systems and nutrition, and appreciates this additional opportunity to provide comments through this open consultation. We would like to commend Dr Liliane Ortega, CFS Food Systems and Nutrition OEWG Chair as well as the CFS secretariat for the work done so far.
We support the report acknowledgment of the complexity of the food systems and the many drivers which impacts them, as well as the need to take a holistic and evidence-based approach and foster dialogue among the different sectors.
As a general comment, throughout the document, CFS should:
- Ensure definitions of “healthy diets” remain focused on encouraging consumers to adopt and maintain balanced diets and do not directly or indirectly exclude or limit consumption of nutrient dense whole foods such as dairy products;
- Ensure all guidelines are science-based and consistent with WTO, Codex, and other international obligations;
- Ensure nutrient dense foods such as dairy are recognized as a critical source for their key nutrients; especially for populations at high risk of nutrient insecurity such as children and pregnant women
- Ensure the voluntary guidelines recognize the positive role of international trade in increasing access to and availability of a variety of foods, including dairy products;
- Guard against overt or disguised protectionism that decreases access to and availability of a variety of foods, including dairy products;
- Ensure environmental sustainability considerations are science-based and reflect the relative and absolute nutritional benefits of dairy foods.
- Carefully consider whether the voluntary guidelines as currently drafted will duplicate work or overlap with the mandates of other international organizations.
- Provide mechanism to revisit guidelines/set timeframe for update of global progress towards reduction in malnutrition.
- Acknowledge that due to regional and population differences that affect the HLPE five main categories of food system functionality, there is no single universal diet that combats malnutrition and ensures sustainable practices.
- Importantly, they should allow for the definition of “healthy diets” to include countries’ own national dietary guidelines instead of solely being defined by WHO indications.
- Acknowledge that trade-offs will exist within a food system in order to sustainably achieve a reduction in malnutrition and that countries should make these trade-off decisions based on regional and population relevant science-based information.
- Recognize that while smallholder farmers are necessary to help combat malnutrition, large holder farmers also play a significant role in sustainably reducing global malnutrition.
Milk and dairy foods are well-known for being naturally nutrient rich, providing an abundant supply high quality protein, calcium, phosphorus, potassium, iodine, and vitamins B2 and B12. This unique package of essential nutrients contribute to address all forms of malnutrition; it is associated with better growth, micronutrient status, cognitive performance and motor function development. In addition, several dairy products are scientifically proven to protect against some non-communicable diseases. There is an inverse association between dairy intake and colorectal cancer as well as between yogurt intake and risk of type 2 diabetes and between milk and stroke.
Dairy is then part of healthy diet and a major contributor to helping achieve many of the UN Sustainable Development Goals (SDGs) such as zero hunger and health and well-being as well as providing reliable livelihoods, helping to lift people out of poverty, empowering women, caring for the land, and much more.
The dairy community supports the CFS work to develop these voluntary guidelines on food systems and nutrition but wants to ensure that the role dairy products in making whole diets healthy is recognized.
Please find in attached documents our detailed comments on the draft voluntary guidelines on food system and nutrition.
The International Dairy Federation is thankfull for the oppourtunity to participate to this e-consultation. Please find our contribution below.
We stay at your disposal if you would need more information.
The International Dairy Federation represents the global dairy sector covering over 75% of global milk production and engages all stakeholders of the dairy chain in primary production, milk processing and related research and innovation. Collectively, this is an enormous amount of knowledge, resources and networks.
Date/Timeframe and location
Continuous and worldwide
Main responsible entity
Livestock is vital for ensuring food and nutrition security and to achieving the sustainable developments goals.
Good nutrition is important for people of all ages. During childhood, good nutrition promotes normal growth and development. In the longer term, it is believed that establishing healthy eating habits in childhood can help to reduce the development of chronic diseases such as diabetes, heart disease and some cancers. Promoting a healthy diet to children can help them form healthy habits that extend into later life. Micronutrient deficiencies arising from poor-quality diets remain widely prevalent. Milk is rich in bio-available nutrients and an efficient vehicle for delivering several critical micronutrients and improving growth of young children.
As school feeding programs provide valuable settings to promote access to healthy, diversified diets. IDF with its large member basis provided the ideal platform to conduct together with the FAO the largest global review to date of school milk programme implementation, administration, promotion and nutritional importance.
The survey held in 2014 gives an in-depth look at 60 different school milk programmes in the Americas, Asia, Africa, Oceania and Europe. 140 million children were reached with these programs, with around 57% of those receiving it at least 5 days per week. In 58% of the programmes, children were provided with free milk. In 27% it was provided to them subsidised. Comparison with a survey carried out in 1998 by FAO shows that milk and dairy foods are still as popular as ever and are widely recognised as essential to healthy eating. The survey provides much more detailed information on these school milk schemes and provides guidance for those who are implementing or considering implementing such programmes (http://store.fil-idf.org/product/the-contribution-of-school-milk-programmes-to-the-nutrition-of-children-worldwide/) .
Beyond ensuring access to milk and dairy foods in schools, many of our members deliver nutrition education programs to foster healthy food and physical activity habits. Through the dairy nutrition initiative IDF collects exemplary practices of effective education programs from around the world. The initiative has collected examples from around several countries, reaching different age groups, engaging multiple partnerships but with the same goal to connect children with the source of their foods and educate them about healthy lifestyles.
Key characteristics of the food system(s) considered
(Re)-connect the youth with the source of their foods and educate them about healthy lifestyles
Key characteristics of the investment made
School feeding programmes can have a positive influence on food choices and can be funded and supported in a number of different ways.
Key actors and stakeholders involved (including through south-south/triangular exchanges, if any)
Considering all data compiled many programmes were organized through a collaboration of different organizations. Some key actors were dairies, government, communities and schools. But also parents and teachers can be the initiators of the programs.
Key changes (intended and unintended) as a result of the investment/s
The impact of school milk programmes, in terms of number of children reached, varied significantly from country to country. Of all the countries responding, a total of 139 977 649 children were benefiting from school milk, an average of 54%. But variation are huge amongst different countries, the US for example is able to reach 80%, however there are countries were only 20% or less of the children were receiving school milk.
The biggest challenge identified in the survey was the funding of the programmes.
Other challenges included an expectation that school milk programmes should be free or highly subsidized; the administrative and resourcing burden for school staff; and competition from other foods.
These programs are at the nexus of agriculture, nutrition and education. Aligning resources and funding through public-private partnerships will not only improve reach and impact, it will also ensure the target audience receives a consistent message at critical touch points.
The International Dairy Federation (IDF) is grateful for the opportunity to comment on the First Draft of the Work Programme of the UN Decade of Action on Nutrition, 2016-2025 (dated 27 January 2017). Since 1903, IDF is the pre-eminent source of scientific and technical expertise for all stakeholders of the dairy chain. IDF commits to help nourish the world with safe and sustainable dairy.
We congratulate the UN for drafting such an ambitious working program. As clearly addressed in the document, the solution to achieve this work program is by combined and coordinated efforts across all actors. International federations such as the IDF through the broad membership they represent can play an essential role in facilitating these partnerships. Industry can help through its expertise by knowledge sharing of social responsibility programmes, technical expertise for cost-effective product development, processing and distribution, as well as providing platforms for advocacy and education. We therefore strongly urge for that open and inclusive dialogue amongst all stakeholders.
We continue to advocate for a focus on foods and diets rather than single nutrients in any policy development and activities, other than where specific micronutrient deficiencies need to be addressed through targeted food fortification and/or supplements. Foods and diets are far more than the sum of their individual nutrients. Nutrients are not consumed in isolation and it is inaccurate to generalize about the effects of a single nutrient without considering the food matrix in which it is present. In some countries, dietary guidelines are shifting away from recommendations based on nutrients or foods in isolation and now focus primarily on healthy eating patterns. Overall, no single food or nutrient creates a healthy dietary pattern, but instead, it is the combination of nutrient-dense foods that is emphasized: “…dietary components of an eating pattern can have interactive, synergistic, and potentially cumulative relationships, such that the eating pattern may be more predictive of overall health status and disease risk than individual foods or nutrients[i]”.
Nutrition science has moved on from just focusing on nutrients in isolation – it also considers foods and dietary patterns that are associated with good health. Nutrition policies need to take this into account[ii].
We note that Point 21 suggests that a healthy diet is one that contains adequate macronutrients, fibre and essential micronutrients. This is too reductionist a view as food is much more than this.
- We suggest that the text is amended to reflect these points.
Table 1 suggests establishing an action network focused on food reformulation. The danger with this is that there is too much focus on single nutrients and too little on the overall impact of a food. Focusing on reformulation can lead to the use of oversimplified paradigms which in turn may undermine minimally processed, naturally nutritious foods. Nutrition policies that target the decrease or increase of the consumption of single nutrients will result in a modification of the effects of the food and even the diet itself. Food reformulation can be complex, and simply taking out a nutrient is often not feasible. Typically, the nutrient that is removed provides properties that are important for food safety and/or acceptability of a product. In products where fat is removed to produce a low fat or fat free product, carbohydrates (mostly refined) are often added to maintain an acceptable flavour or texture profile[iii]. This could be counterproductive to reducing levels of obesity and risk of non-communicable disease. As addressed in the FAO/WHO report replacing SFA largely with refined carbohydrate has no benefit on CHD and may even increase the risk of CHD and favour the development of metabolic syndrome [iv] [v].
Reformulation is also a way for highly processed unhealthy foods to be positioned as being healthy.
- We suggest that all action networks should take a whole of food/dietary pattern approach rather than focusing on single nutrients in isolation.
It is essential that before implementing any new policies or activities there should be clear evidence for a positive impact and a risk based assessment should be considered to identify any potential negative consequences.
We also note that table 1 reference sustainable livestock production. While the concept of sustainable food systems is not new, much more research is needed to establish the scientific foundation on which informed recommendations for sustainable, healthy diets can be made.
A sustainable food system must meet the nutritional needs of the human population while not depleting or degrading the natural resources upon which life depends, as indicated in this definition by the United Nations Environmental Program:
“Sustainable food systems enable the production of sufficient, nutritious food, while conserving the resources that the food system depends on and lowering its environmental impacts. Such systems are based on the idea that all activities related to food (producing, processing, transporting, storing, marketing and consuming) are interconnected and interactive.[vi]”
The concept of sustainable diets contains additional aspects of sustainability related to the human population, as described in the Food and Agriculture Organization’s definition of sustainable diets:
“Sustainable diets are those diets with low environmental impacts which contribute to food and nutrition security and to healthy life for present and future generations. Sustainable diets are protective and respectful of biodiversity and ecosystems, culturally acceptable, accessible, economically fair and affordable, nutritionally adequate, safe and healthy; while optimizing natural and human resources.[vii]”
Whether framed as sustainable food systems, sustainable healthy diets, or nutrition security, the underlying systems - agricultural, environmental, social, and economic - are connected to one another in ways that are only recently being understood and appreciated by scientists and policymakers. A coordinated, interdisciplinary approach is needed to gain vital insights on interrelated dynamic and adaptive processes within and across these systems. Dietary guidance based on an incomplete research base could lead to unintended consequences for both human health and the long-term sustainability of the food system.
Finally, we continue to support policy development that acknowledges the important and valuable role that dairy plays in balanced and varied diets. Dairy products are nutrient-dense foods that can help reduce malnutrition throughout the world, with increasing evidence that diets containing dairy help reduce the risk of obesity and NCDs.
[i] The Dietary Guidelines for Americans 2015-2020. 8th Edition https://health.gov/dietaryguidelines/2015/guidelines/
[ii] Mozaffarian D (2017) Foods, nutrients, and health: when will our policies catch up with nutrition science? The Lancet Diabetes & Endocrinology 5, 85-8.
[iii] Sandrou DK, et al (2000). Low-fat/calorie foods: current state and perspectives. Crit Rev Food Sci Nutr. , 40(5):427-47.
[iv] Jakobsen MU, O. E. (2009). Major types of dietary fat and risk of coronary heart disease: a pooled analysis of 11 cohort studies. Am J Clin Nutr. ,89(5):1425-32.
[v] Fats and fatty acids in human nutrition. Proceedings of the Joint FAO/WHO Expert Consultation. November 10-14, 2008. Geneva, Switzerland. (2009). Ann Nutr Metab., 55(1-3):5-300.
[vi] UNEP. Avoiding Future Famines: Strengthening the Ecological Foundation of Food Security through
Sustainable Food Systems. United Nations Environment Programme (UNEP), Nairobi, Kenya 2012.
[vii] Burlingame B, Drnini, S. Sustainable diets and biodiversity: Directions and solutions for policy, research and action. Proceedings of the International Scientific Symposium, BIODIVERSITY AND SUSTAINABLE DIETS UNITED AGAINST HUNGER, 3 – 5 November 2010, FAO Headquarters, Rome 2012.
The International Dairy Federation (IDF) is grateful for the opportunity to comment on the ICN2 Framework for Action zero draft. Our comments relate to Question 1 addressing general aspects of the draft FfA, chapter 3.1 Food systems and chapter 3.3. Health, section 3.3.6 Food safety and antimicrobial resistance.
Dear Sir, Dear Madam,
The International Dairy Federation (IDF) is grateful for the opportunity to be able to comment again on the revised draft political outcome document of the ICN2. Please find in attachement the comments I am submitting on behalf of the IDF.
Firstly the International Dairy Federation (IDF) would like to thank the CFS Secretariat for opening this important topic for discussion. Since 1903, IDF is the pre-eminent source of scientific and technical expertise for all stakeholders of the dairy chain. IDF commits to help nourish the world with safe and sustainable dairy.
1. What issues should be addressed by the Committee in the biennium 2016-2017?
Discussion on the role and importance of a diverse diet to support growth and development, including pregnancy.
2. Explain the issue and describe why you are proposing it;
FAO states that “the only sustainable means of addressing malnutrition is through the consumption of a high-quality, diverse diet that provides adequate but not excessive energy.”1 Access to better and more diversified diets is key for combating problems of micronutrient malnutrition or “hidden hunger”2. Research on the consumption of animal-based foods by children has convincingly demonstrated improved growth, micronutrient status, cognitive performance and level of physical activity3. Animal foods are often disregarded in discussions of food security due to cost, however their role should be considered in a wider context of nutrient richness, protein/energy balance, and overall cost effectiveness to complement poorer quality protein and energy sources. Policy-makers should consider the protection of the nutritional quality of diets, not only the adequacy of staple foods1.
1 FAO 2013. The state of food and agriculture. Food systems for better nutrition. http://www.fao.org/docrep/018/i3300e/i3300e00.htm (Accessed on 6 May 2014)
2 FAO.2013. Milk and Dairy Products in Human Nutrition. http://www.fao.org/docrep/018/i3396e/i3396e.pdf (Accessed on 6 May 2014)
3 Dror DK, Allen LH. The importance of milk and other animal-source foods for children in low-income countries. Food & Nutrition Bulletin. 2011; 32:227-43.
Dear Sir, Madam,
Please find attached comments on the Zero draft of the political outcome document I am pleased to submit on behalf of the International Dairy Federation.
The International Dairy Federation (IDF) appreciates the opportunity to contribute to this online discussion on “The contribution of the private sector and civil society to improve nutrition”. Founded in 1903, IDF is the leading source of scientific and technical expertise for all stakeholders of the dairy chain. IDF is committed to furthering current knowledge and science on a wide range of issues by triggering state of the art projects across the dairy chain.
One of the questions posed is to comment on the core background and expert papers and materials for the ICN2. Although mostly excellent, we have some concerns about one of the conclusions/statements in 'Leveraging agriculture and food systems for healthier diets and non-communicable disease prevention: the need for policy coherence' by Hawkes C and colleagues. On page 22 it states that in relation to dairy products (along with highly processed foods and meats) 'Increasing consumption of these foods has been associated with Non-Communicable Diseases.'
We believe this is not fully representative of the available scientific evidence for dairy foods and NCDs. For example the 2013 Australian Dietary Guidelines acknowledge the evidence for the health benefits of consumption of milk, yogurt and cheese has strengthened since the 2003 edition of the dietary guidelines and states that:
“Consumption of milk, yogurt and cheese can protect us against heart disease and stroke, can reduce our risk of high blood pressure and some cancers, may reduce our risk of type 2 diabetes and may contribute to stronger bones”
In relation to the question ‘What role can the private sector and civil society play in designing and implementing policies that make agriculture and food systems more nutrition-enhancing?’ we would like to say that international dairy organisations such as IDF and national dairy food organisations can play a role in the development of nutrition policy, such as dietary guidelines. Their staff has the specialist expertise required to assist policy makers in using the latest scientific literature on dairy foods and health. Also, many national dairy organisations fund research to fill gaps in knowledge relating to the impact of dairy consumption on health.
 National Health and Medical Research Council (2013) Australian Dietary Guidelines Summary, Pg 23. Canberra: National Health and Medical Research Council.