This member participated in the following discussions
We appreciate that the opening paragraphs emphasize the right to adequate food. However, for the outcome document to help the still existing divide between food and nutrition, these opening paragraphs should ensure this gap begins to be closed in this Declaration by always referring to the right to adequate FOOD and NUTRITION.
With regard to the list of commitments which should be footnoted under Para 2, we wish to ensure that also the Global Strategy on Infant and Young Child Feeding (WHO 2003) with it protect, promote and support framework, and the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA resolutions are listed.
Rationale: In this manner the contribution of women/mothers to the attainment of the right to adequate food and nutrition and the right to health will be at least implicitly recognized. It is important to not forget that women, by providing 6 months of exclusive breastfeeding to their child are THE perfect food system feeding a population of 0-6 months old with food which is tailored to the need of the consumer, healthy, in the right quantity and quality, available on demand and environment friendly (no packaging transport and required, no discarding of rubbish, packaging etc.). Breastfeeding continues to provide an important contribution to infant’s and young child’s food security well into the second year of the child’s life and beyond. However, this ‘food system’ is also influenced by social, political, economic and environmental contexts and requires inputs in a form of policies that ensure respect, protection and promotion (facilitation). policies and programmes that support it. Today, less than 52 of 135 million children are being optimally breastfed despite the fact that breastfeeding is cited internationally as one of the most cost effective ‘interventions’ in mother and child health. Thus apart from the poor nutritional and health outcomes and thus major gap in attainment of the right to adequate food and nutrition, this alsos means an enormous waste in resources. When we use market prices to value the milk that women produce around the world each year, it highlights that women’s capacity to breastfeed is an extremely valuable national asset. Worldwide, its value is around USD 1983 billion a year based on breastfeeding rates and demographics in the UNICEF state of the world’s children report. Therefore it’s important to act on several fronts, including this political declaration, to normalise breastfeeding, ensure mothers do not suffer discrimination and are supported in their country and community, including through their own right to adequate food and nutrition being met, as they are making this enourmous contribution to the attainment of the child’s right.
[See specific comments in the attachment, Ed.]
Please find attached and below comments on the ZERO Draft of the Outcome Document I am pleased to submit on behalf of the International baby Food Action network (IBFAN).
IBFAN liaison Office
1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?
- In their present form, the first 3 paragraphs do not present a vision that would inspire action. They are not formulated as vision and do not set any clear idea of what a vision of the document is. Reading this draft against the 1992 World Declaration on Nutrition, it is concerning how non-specific and vague the document is. It seems to reflect the very short ICN2 preparatory process for ICN2 , compared to the 3 year process for ICN 1992.
- The Draft Zero is not firmly based in the human rights framework and does not even mention the right to adequate food and nutrition as protected, among others, by article 25 § 1 Universal Declaration of Human Rights, article 11 ICESCR, article 24 (c) CRC and article 12 § 2 CEDAW. The right to adequate food and nutrition for all should be the cornerstone of this document, as it was in para 1 of the 1992 World Declaration on Nutrition. In addition, the understanding formulated in 1992 that improving nutrition should be seen both as a goal of development in its own right and as a means of achieving it, is missing.
- Para 1 fails to clearly identify all key components of malnutrition, which, in addition to undernourishment, micronutrients deficiencies and unbalanced diets, also cover excessive dietary intake (overnutrition).
- Para 1 also fails to mention that each day, about 25,000 persons die because of hunger and malnutrition and that the number of those who suffer hunger is around one billion. This represents violation of basic human rights of enormous proportion that continues day after day.
· Para 2 comfortably concentrates only on some targets of the three international level commitments, leaving out other events, such as NUTRITION GOALS OF THE WORLD SUMMIT FOR CHILDREN together with a number of specific goals agreed with them. This is illustrated by omission to highlight that breastfeeding rates are stagnating or even declining while sales figures of infant formula and other baby foods are increasing annually as violations of the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA resolutions. Furthermore, these violations are not addressed at national and international levels. This omission is surprising considering the increased recognition of breastfeeding as the optimal nutrition for infants and young children and should therefore be promoted, protected and supported (1992 World Declaration and Plan for Action for Nutrition, 1999 CESCR General Comment No 12 on the right to adequate food, 2002 Global Strategy for Infant and Young Child Feeding, 2003 CRC General Comment No 15, 2003 CRC General Comment No 16, 2010 OHCHR Fact Sheet No 34 on the Right to Adequate Food). Breastfeeding is key to shape the survival, health and wellbeing of an individual during the first 1,000 days of his or her life and thus, provides a solid foundation for the respect, protection and fulfillment of the right to adequate food and nutrition.
· Para 3 is extremely vague, avoiding any clear analysis that would identify the negative role of TNCs in the status quo. Besides, while being available, accessible and affordable, food must be adequate which “means that the food must satisfy dietary needs, taking into account the individual’s age, living conditions, health, occupation, sex, etc. For example, if children’s food does not contain the nutrients necessary for their physical and mental development, it is not adequate […] Adequate food should also be culturally acceptable.”(2010 OHCHR Fact Sheet No 34 on the Right to Adequate Food, p. 3) According to the Special Rapporteur on the Right to Food, adequacy also means that food must be safe for human consumption and free from adverse substances (http://www.srfood.org/en/right-to-food). Adverse or harmful substances such as PCBs, BPA, melamine, pesticides etc, have been proven for their negative effect on the attainment of the right to health and must not be accepted as ‘safe food’ within the right to adequate food and nutrition. The concept of adequacy has to be, therefore, enshrined in the Outcome document as a key element of the right to food. While we recognize that evolution of food systems may have delivered on quantity of food stuffs, we question the statement that dietary diversity was enhanced through this evolution. Finally, microbial contamination of food and water is causing numbers of communicable and non-communicable diseases and therefore should also be emphasized as one of the important causes of malnutrition.
- Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?
- Para 4: The elimination of all forms of malnutrition should be an imperative for the reason of the respect, protection and fulfillment of human rights, in particular the right to adequate food and nutrition.
- Para 5 should also emphasize specifically infants and young children, considering that the 0-2 year (first 1,000 days) to be a critical window for the survival, health and development of an individual.
- Para 6 calls on renewal of 1992 commitments is appreciated. However, a new timeframe needs to be clearly determined as the objective of achieving these commitments by the end of the millennium was not reached.
- While we understand that Para 7 makes reference to the targets contained in the WHO Comprehensive Plan on Maternal, Infant and Young Child Nutrition (leaving out the specificity needed), we are wondering why would WHO and FAO like to stay with a set of such narrow targets. The exclusive breastfeeding target, while welcome, is at the same time problematic if it is taken alone, as it takes attention away from optimal infant and young child feeding practices (emphasized in the 1992 commitments) and leaves out the crucial element of continued breastfeeding for 2 years and beyond with the addition of adequat and nutritious complementary foods, with regard to food security.
- Para 8 leaves out a number of key policy instruments, all strongly relevant to nutrition and to breastfeeding, such as the Convention on the Right of the Child (in particular articles 24 (2)(c) and 27 (3)),the International Code of Marketing of Breastmilk Substitutes and its subsequent relevant WHA resolutions, the Global Strategy for Infant and Young Child Feeding. Furthermore, while recalling the International Covenant on Economic, Social and Cultural Rights, the draft doesn’t mention its article 11 on the right to adequate food nor CESCR General Comment No 12.
- Para 9-10: The somewhat noncritical focus on reshaping food systems is too narrow as it draws attention to food production only. It leaves out any notion of the well established fact that some food systems pose major challenges to environment, climate change and access to productive resources with critical consequences for health and nutrition. It is time to acknowledge clearly and strongly at the ICN2 and in its outcome document the enormous contribution breastfeeding mothers/women make to the world’s food security!
- Para 11: The Climate Smart Agriculture has not been launched yet (its launching by the UN Secretary General at the Climate Summit is currently scheduled for September 2014). Therefore, it seems problematic to include a non-existing approach in the present document without any explanation, unless it has been fully discussed at the member states level.
- In the same para, emphasis is on food waste reduction. As breastfeeding is not creating any food waste, we suggest that it is emphasized in this context as a practice which is based on a renewable natural resource and is environmentally sustainable while infant formula feeding leaves a substantial ecological foot print throughout the chain from production to consumption.
- Para 12 needs to include regulatory frameworks alongside policy packages. More importantly, it should be referring not only nutrition as a goal but to “attainment of the right to adequate food and nutrition” as a goal of all development policies.
- Para 13: While this para talks about more equitable access to food and water, it then focuses on agricultural productivity and on micronutrients, leaving out access to productive resources as well as protection, promotion and support of breastfeeding as key to ensuring adequate and safe diets for all, especially infants.
- Para 14 focuses on empowering consumers to make informed choices. Firstly, consumers may not be in a position to make a health food choice unless they receive full and unbiased information. Only then will they be in a position to make informed decisions about the options they have at their disposal (e.g. breastfeed versus formula feed; balanced diversified diet versus highly processed food).
- In the same para 14, the phrase “A thriving market economy requires rules and regulations to keep it fair to all” is problematic. The expression “fair to all” should be deleted and replaced by “fair to each human individual” as the current formulation risks to be interpreted by the corporate sector (TNCs) as if they are seen in this document as entitled to the same human rights as human beings. Furthermore this expression could be interpreted as protective of TNCs’ commercial and financial interests against regulations adopted by the international community or States parties. Regulation of TNCs’ marketing, creation of food monopolies and unfair trade practices and other harmful practices will be unlikely seen by them as “fair” yet it is key to achieving the right to adequate food and nutrition for all.
- We appreciate that para 14 is discussing protection of consumers. However, it needs to be further elaborated, including for protection of the youngest consumers (especially infants) and their parents targeted by unethical marketing practices in violation of the UN recommendations, such as the International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA resolutions. This para also fails to emphasize the responsibility of the corporate sector, enshrined in many human rights legal sources (such as CRC General Comment No 16), to refrain from any practices causing harm and violating human rights of consumers, and not only the commercial messages promoting energy-dense but nutrition-poor foods.
- Para 15 calls for acknowledgement that nutritional protection is provided to people who are food insecure etc. This statement is wrong, or else there would be no human being suffering/dying of starvation and hunger, non-communicable diseases, or foodborne and waterborne communicable diseases.. Moreover, the call for ‘partnership’ contained in this para needs to be clarified by stating that safeguards against conflicts of interest (CoI) are required for any collaboration which follows public-private partnership or multistakeholder initiative model. Regarding the humanitarian interventions in crises, it is critical to emphasize the government’s and UN role in ensuring emergency preparedness policies and plans are in place so that once emergency occurs, roles and responsibilities are clear, resources available or sought efficiently and nutritional needs of affected populations identified and met.
- Para 16 refers to “official” development assistance—is this term used as opposed to “unofficial” assistance?
- Para 19 is emphasizing “new modes” of involvement, an expression that needs to be clarified. If this is in reference to public-private partnerships, multistakeholder platforms and other similar hybrid models, the outcome document must be clear on the need for ensuring that prior to such type of engagement, all conflicts of interest safeguards are in place. Nutrition and food are areas where there is a major risk for CoI influencing policy making, action of the UN, governments and other civil society actors, thus affecting negatively their independence, integrity of judgment, their trustworthiness and eventually also harming their reputation.
3. Do you have any comments on the commitments proposed in the political declaration? In this connection, do you have any suggestions to contribute to a more technical elaboration to guide action and implementation on these commitments (paragraphs 21-23 of the zero draft)?
- In Para 21, we would have expected a strong commitment expressed to ensure right to adequate food and nutrition and the right to health. The reference to ”people’s health needs” is taking us decades back to the need-based discourse only.
- We suggest an additional point in this para:
Creating enabling environments for the protection, promotion and support of optimal infant and young child feeding through full implementation of the Global Strategy for Infant and Young Child Feeding to support the mother/child pair.
Unless this is included, infants, young children and their mothers fall through cracks of this commitment.
- Point IV: food value chain must emphasize all members of society as key actors in this chain with nutrition and health goals being supreme in the development of such a chain. Moreover, this point should emphasize that adequate, safe and nutritious foods should be accessible, affordable and acceptable to all.
- Point VI: encouraging contribution of all actors is in principle welcome. However, it is critical that roles of actors are delineated, safeguards against conflicts of interests in place and that it is understood that ‘contribution’ can also mean ‘refraining from unethical or illegal practices’, e.g. refraining from marketing unhealthy foods to children or violating the International Code of Marketing of Breastmilk Substitutes.