This member participated in the following discussions
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.
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.
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
Protection of biodiversity
Protection of native seeds and centers of origin
Invitation to an open discussion
on the political outcome document of the ICN2
Name: Xaviera Cabada
Organization: El Poder del Consumidor- NGO
1. General comments on the Draft of the Rome Declaration on Nutrition.
· The importance of sovereignty and sustainability regarding agricultural practices is needed to be more emphasised as well as the emergency need for the protection of biodiversity.
· As part of the right of everyone to have access to sufficient, safe, healthy, and nutritious foods, there needs to be the reaffirming of the importance of traditional diets from the world.
· There needs to be more emphasis on human rights approach and the urgent need for the protection of breastfeeding as the first way to guarantee the right to adequate food among population.
· As part of the root causes of malnutrition, the intake of ultraprocessed foods high on sugar, fat, saturated fat, trans-fats, and salt/sodium has become one element that is directly linked to malnutrition as a cause, it would be proper to integrate it as such.
· Regarding trade practices, there needs to be recognized the need for fair trade practices.
· Importance of participation of civil society organizations for the public interest needs to be integrated in the document.
· Among agricultural practices there needs to be the exclusion of genetically modified organisms, especially in those countries where they represent a severe threat to their sovereignty.
· In commitment to action, conflict of interest needs to be approached.
2. Specific comments on the paragraphs related to the multiple threats that malnutrition poses to sustainable development (paragraphs 4-10).
· Paragraph 4, instead of unbalanced diets- unhealthy diets.
· Paragraph 5, as part of the root causes, point one would need to integrate in line 3, where … “vicious cycle, by lack of breastfeeding, non-potable water, poor sanitation, food borne and parasitic infection, and ingestion of ultraprocessed foods high on sugar, fat, especially saturated and trans-fats, and salt/sodium.
· Paragraph 7. “Recognize that environmental, societal changes, and marketing practices of unhealthy foods, especially those directed to children often have an impact on dietary and physical activity patterns….
3. Specific comments on the vision for global action to end all forms of malnutrition (paragraphs 11-12).
· Paragraph 11, subsection a)… “paying particular attention to the special needs of children, women, elderly and disabled people; emphasizing the human rights approach.
· Paragraph 11, subsection b)… “a coordinated action of different actors, where civil society is a key actor, at international…. as well as health, breastfeeding, ….
· Paragraph 11, subsection c)… “including in fair trade and investment agreements…”
· Paragraph 12, subsection a)… “support and complement nutritional effective initiatives and measures”
· Paragraph 12, subsection c)… at the end of the subsection, after consumed add the following; “assuring local agricultural practices, promoting sustainable practices, and the exclusion of genetically modified organisms, especially in those countries where they represent a severe threat to their sovereignty.
· Paragraph 12, subsection d)… “appropriate market and price regulations in food”…
· Paragraph 12, subsection f)… “while limiting the consumption of processed foods that negatively affect nutrition and health, including breastmilk substitutes for infants”
· Paragraph 12, subsection h)… “food systems should be self-sustainable…”
4. Specific comments in the appropriate fields relating to these commitments (paragraph 13):
Commitment a): eradicate hunger and all forms of malnutrition, particularly to eliminate stunting, wasting and overweight in children under 5 and anemia in women; eliminating undernourishment and reversing rising trends in obesity
Add “and diabetes and other chronic diseases”
Commitment b): reshape food systems through coherent implementation of public policies and investment plans throughout food value chains to serve the health and nutrition needs of the growing world population by providing access to safe, nutritious and healthy foods in a sustainable and resilient way;
Add after public policies “free from conflict of interest”
Commitment c): take leadership to shape and manage food systems and improve nutrition by strengthening institutional capacity, ensuring adequate resourcing and coordinating effectively across sectors;
Add “with the full support to small and medium local producers”
Commitment d): encourage and facilitate contributions by all stakeholders in society and promote collaboration within and across countries, including North-South, South-South and triangular cooperation;
Add “adequate collaboration”
Commitment e): enhance people’s nutrition, including people with special needs, through policies and initiatives for healthy diets throughout the life course, starting from the early stages of life, before and during pregnancy, promoting and supporting adequate breast feeding and appropriate complementary feeding, healthy eating by families, and at school during childhood;
Commitment f): adopt and implement a Framework for Action that should be used to monitor progress in achieving targets and fulfilling commitments;
Commitment g): integrate the objectives of the Framework for Action into the post-2015 development agenda including a possible global goal on food security and nutrition.
5. We would also appreciate your vision on policies, programmes and investment that might help translate such commitments into action.
Policies and investment must be implemented entirely for the public interest, without conflict of interest.
It is crucial agricultural systems to be exempt from genetically modified organisms, especially in those countries where their presence implies a severe threat to the sovereignty of the country. Countries need FAO support.
Small and medium local producers need full support from governments and international entities like FAO and WHO.
Documentation that may be of support: WHO Recommendations on the marketing of foods and non-alcoholic beverages to children and the marketing of feeding products for infants and young children,
International Code of Marketing of Breastmilk Substitutes and subsequent relevant WHA resolutions,
Convention on the Rights of the Child from the Committee on the Rights of the Child, General Comment No. 16 (2013) on State obligations regarding the impact of the business sector on children´s rights.
1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?
We believe this is a great effort that is being made and we are very pleased to be able to make contributions.
In general, we observed that there is many valuable aspects in the document, but overall it is ambiguous in many ways, many definitions are not well established. Examples: malnutrition-it is not clear and it does not exactly define that overweight and obesity is part of malnutrition, it refers only to “overconsumption”; safe food- leads to think it is regarding to only processed foods and that traditional fresh grown foods from the different localities do not meet in this concept).
It is not based on the best interest of the child nor children´s rights; children are even mentioned as “consumers” but not as right holders. Overall human rights are not mentioned, only economic, social and cultural rights; which is very important but it is also important to mention and to base all the proposals and policies regarding human rights.
Breastfeeding is only mentioned once in the whole paper when it is one of the most effective measures for malnutrition; we believe it needs to be reinforced.
Accountability of private sector is not mentioned at all, nor the importance of conflict of interest when regarding industry involvement and partnerships, industry is only partially mentioned as part of the problem when it has been a big part of the problem for NCD´s and for undernutrition as well.
Marketing to children is not mentioned and it needs to be very clear that is a very strong issue regarding nutrition in children.
Some words can be complemented: sugars- for free sugars or added sugars; safe food- for safe nutritious food; regulations- for strong regulations; healthy food- for healthy, natural and fresh food.
In the commitments part VI, it does not establish if it is including private sector and what would the role be.
2. Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?
Paragraph 4 establishes elimination of malnutrition is imperative for ethical, political and economic reasons but not for the best interest of the child, nor for the child´s rights, nor for human rights.
Paragraph 5 does not recognize the importance of the protection of women and children particularly when breastfeeding. Instead of using word “including” it can be “specially” women and children. Breastfeeding is only mentioned in paragraph 7, when it is one of the most important effective measures for malnutrition.
Paragraph 8 only mentions Economic, Social and Cultural Rights; Human rights need to be mentioned too.
Paragraph 13 mentions safe food, it can be substituted for “safe nutritious food”.
Paragraph 14 where it says “Reliable and relevant nutrition information, sensitive to cultural norms and preferences, needs to be effectively disseminated to improve behaviour and practices”, the idea is confusing. The food that needs nutrition information is usually processed food, then the sentence is followed by sensitive to cultural norms and preferences… it leads to think that processed food´s nutrition information needs to be sensitive to cultural norms and preferences, when what it needs is to warn about the risks of intake and inform consumers of the real contents of it, allowing the population to make real informed decisions. On the same paragraph, when it talks about regulation, it can say “strong regulation” instead. On the last part, where it talks about local food cultures, it is better if it establishes “local foods and cultures”.
Paragraph 15 must establish that the “partnerships” must be without conflict of interest and it must clarify that these “partnerships” must be for the public interest.
Paragraph 19 must specify the role of private sector, the importance of the public interest and the conflict of interest.
Paragraph 20 must include monitoring on programmes and policies. Also it must include industry´s form of accountability.
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)?
Please provide your comments in the appropriate fields relating to these commitments:
21.Commitment I: aligning our food systems (systems for food production, storage and distribution) to people’s health needs;
Food production that allows countries their own sustainability and sovereignity, coming from small and medium producers.
Commitment II: making our food systems equitable, enabling all to access nutritious foods.
Nutritious fresh, natural foods.
Commitment VI: encouraging contributions from all actors in society;
Is not clear is all actors include private sector. If it does, what would the role be of private sector and the regulations they need to follow on, as well as the forms of accountability.