General Comments:
The declaration is not grounded in human rights. No reference is made to nutrition as core element of the human right to adequate food and nutrition and corresponding State obligations (to respect, protect and fulfill this right). The elimination of malnutrition is considered imperative for “ethical, political and economic reasons” and not because it is a human rights obligation (para. 4). Moreover, no link is made to human rights violations that cause malnutrition, including violations of women’s rights, child rights, and people’s access to natural resources, and those that result from malnutrition. No reference is made to women’s rights and the essential role of women in food production and nutrition (including through breastfeeding).
While the declaration acknowledges “governments’ leadership for shaping food systems” as central (para. 21 V.), it nevertheless talks about people as “consumers” as opposed to rights holders and does not mention States’ human rights obligations (for example para. 14 talks about “empowering the consumer”). In line with this, there is no mention of people being at the center of decision-making processes related to food and nutrition.
Paragraphs 3, 10 and 13 are problematic in that they seem to open the door for the argument that “more traditional” food systems/peasant farming agriculture cannot provide “safe and nutritious food for all” and thus “more nutritious food” means fortified foods, more calories and increased production. Such a view completely disregards the people and food sovereignty component, self-determination and nutritional well-being.
1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?
Paragraph 3:
This paragraph contains highly questionable assumptions regarding the positive evolution of food systems, which is said to have led to “enhanced dietary diversity” and “greater consumption of vegetables and fruits”.
International approaches to food security focused on boosting cereal production have led to significant decreases in crop and dietary diversity. The promotion of soy beans and certain grains over fruits and vegetables has moreover contributed to the shifting of diets towards unhealthy, highly processed foods and meat products (both of which have benefited from subsidized inputs) and related increases in non-communicable diseases (NCDs).
The promotion of large-scale industrial farming, based on monocultures and high levels of chemical inputs, has moreover led to the displacement of small-holder farmers, including many subsistence farmers, who produce the vast majority of food for human consumption. The agro-industrial model of food production is moreover a key driver in the loss of biodiversity, pollution of soil and water sources, and climate change - all of which threaten present and future availability of diversified and nutritious food.
The same paragraph also takes a highly uncritical view on increases in the consumption of meat and dairy products which is portrayed as something positive without considering its effect on NCDs, food and nutrition security (withover one third of total grains being used for livestock production), environmental sustainability, and so on.
While recognizing that the “food system is still unable to provide safe and nutritious food for all”, no analysis is provided as to why this is the case. No mention is made, for example, of the negative impacts of growing corporate control over the global food system, the agro-industrial model of food production or the ongoing land and natural resources grab. There is also no acknowledgement/ critical reflection on past policy/ governance failures in the food and agriculture sectors (e.g., failure of the green revolution).
2. Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?
Paragraph 7 talks about breastfeeding during the first 6 months without any mention of the importance of breastfeeding past this point, which opens the door to justifying private interests coming in after 6 months.
Paragraph 12 does not mention trade as a sector of central relevance for nutrition. As illustrated by the current negotiations for a Transatlantic Trade and Investment Agreement (TTIP) and a Transpacific Partnership Agreement (TPP), trade and investment agreements provide a useful avenue through which transnational food corporations and industry associations cancircumvent and water down national food and safety regulations in order to expand and open up new markets for unhealthy or even unsafe (including GMO-based) food products. The inclusion of investor-to-state dispute settlement mechanisms, which protect the interests of private investors over those of the public, in several trade and investment agreements, moreover effectively limits States’ ability to enact policy and legal measures required to protect and fulfil the right to adequate food and nutrition, as well as other human rights.
Apart from affecting the safety, diversity and nutritious content of the food that becomes available on local markets, the opening up of national markets to food and agricultural imports can significantly affect the livelihoods of local food producers and the food and nutrition security of the country as a whole, which becomes vulnerable to world food price fluctuations. Trade and foreign direct investment in the field of food and agriculture is hence highly relevant for nutrition.
While paragraph 14 recognizes that “governments are obliged to protect consumers, especially children, from misleading commercial messages promoting energy-dense, but nutrition poor foods (…)”, the declaration avoids engaging in any substantive discussion on the role of the food industry in malnutrition and the urgent need for regulation.
The phrase “a thriving market economy requires rules and regulations to keep it fair to all” is highly problematic given that there are different perceptions as to what is fair. States have legally binding obligations to protect the human rights, including the right to adequate food and nutrition, of persons living within or beyond their national boundaries and, therefore, must put into place effective rules and regulations that ensure private actors, including transnational corporations, do not infringe upon these rights (see Maastricht Principles 23-27).
International nutrition governance and structures are mentioned only marginally and need to be elaborated further.
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:
This section needs to emphasise that it is people, in particular small-holder farmers (including fisherfolk and livestock farmers) and other small-scale food producers as well as groups most affected by malnutrition, who must be at the centre of international and national efforts aimed at reshaping food systems - as beneficiaries as well as designers and implementers of such systems.
21.Commitment I: aligning our food systems (systems for food production, storage and distribution) to people’s health needs;
Food systems should not only be aligned to people’s health needs but should be fully grounded in respect for human rights and promote food sovereignty and the right to adequate food and nutrition.
Commitment IV: ensuring that nutritious food is accessible, affordable and acceptable through the coherent implementation of public policies throughout food value chains.
Nutritious food should be accessible, affordable, culturally acceptable, sustainable, safe and in line with people’s nutritional well-being and food sovereignty.
Commitment VI: encouraging contributions from all actors in society;
Governments must set clear rules on private sector engagement in nutrition with view to managing potential conflicts of interest.
FIAN International