Comments on the draft ICN2 Zero Outcomes document
Organizations:  World Cancer Research Fund International (WCRF International) and The Non-Communicable Disease Alliance (The NCD Alliance)
 
Name: Corinna Hawkes
Organization: WCRF International
Location: London, United Kingdom
 
Name: Katie Dain
Organization: The NCD Alliance
Location: Geneva, Switzerland
 
World Cancer Research Fund International is an umbrella organisation that leads a network of cancer charities and has a global reach. The network funds scientific research and updates and interprets the evidence on the relationship of food, nutrition, body weight, physical activity and alcohol to cancer risk. WCRF International advocates the wider implementation of effective policies to prevent cancer and other non-communicable diseases.
 
The NCD Alliance is a unique civil society network of over 2,000 organizations in more than 170 countries focused on raising the profile of non-communicable diseases (NCDs) on the global development agenda. Founded in 2009, the NCD Alliance unites five international NGO federations and a network of global and national NGOs, scientific and professional associations, academic and research institutions, private sector entities, and dedicated individuals. The NCD Alliance works closely with key partners, including the World Health Organization and Member States, to catalyze action on NCDs at all levels.
 
 
1. Do you have any general comments on the draft political declaration and its vision (paragraphs 1-3 of the zero draft)?
 
While we applaud the inclusion of malnutrition in all its forms, the term “unbalanced diets” is insufficient without also an explicit mention of excess energy intake.
 
Under paragraph 2, the bullet point on obesity is misleading in the way it is written. As it is written it could be understood that rising NCDs are causing a rise in obesity. We recommend changing the sentence to: “obesity in children and adults has been going up quickly all over the world, as has the incidence of diet-related non-communicable diseases. ” It is also recommended to specifically highlight the burden of NCDs in low- and middle- income countries, as the assumption that NCDs remain a problem of high-income countries remains pervasive. 
 
The following examples of progress under paragraph 2 require data to reinforce the statements:
- “micronutrient deficiencies have not improved…”
- “obesity in children and adults has been going up quickly…”
- “the incidence of non-communicable diseases related to diet has been rising rapidly all over the world.”
We recommend the following amendments to the examples under paragraph 2:
- change “large socio-economic differences” to large socio-economic inequalities, and at the end of this bullet point add “and many sections of the population are particularly vulnerable to risk.
 
2. Do you have any comments on the background and analysis provided in the political declaration (paragraphs 4-20 of the zero draft)?
 
We propose that paragraphs 3 – 21 are reorganized in the following way to improve the flow, focus and clarity of the document.
 
A vision for global action to end all forms of malnutrition. 
3) Reaffirm that the elimination of malnutrition in all its forms is an imperative for ethical, political and economic reasons. 
 
4) Renew the commitments made at the first International Conference on Nutrition and at the World Food Summit, and pledge to increase efforts to support initiatives such as the UN Secretary-General’s Zero Hunger Challenge. 
 
5) Renew the commitment to reduce the number of children under 5 who are stunted; reduce anaemia in women of reproductive age; reduce low birth weight; halt the increase in the prevalence of overweight and obesity in children under 5; increase the rate of exclusive breastfeeding in the first six months; reduce and maintain the prevalence of wasting in children under 5; as well as halt the rise in obesity and diabetes, as part of the effort to achieve a 25% reduction in NCD mortality by 2025. 
 
6) Recall the International Covenant on Economic, Social and Cultural Rights and the Voluntary Guidelines to support the Progressive Realization of the Right to Adequate Food in the Context of National Food Security; the Global Strategic Framework on Food Security and Nutrition of the Committee of Food Security and the commitments of the Political Declaration of the High-level Meeting of the General Assembly on the Prevention and Control of Non-communicable Diseases. 
 
The multiple determinants of malnutrition
7) Recognize that the causes of malnutrition are complex and multidimensional. Determinants include immediate causes (inadequate dietary intake and illness); underlying causes (inadequate access to food in a household; insufficient health services and an unhealthful environment; and inadequate care for children and women) and more distal causes.
 
8) Food availability, affordability and accessibility remain key determinants of malnutrition in all its forms. The evolution of food (including agricultural) systems -- with innovations in production, manufacturing, storage and distribution -- has led to enhanced dietary diversity, greater consumption of vegetables and fruit, as well as meat and dairy, in developing countries, although benefits have been uneven. The consumption of processed foods, sugars and fats, particularly saturated and trans-fats, as well as salt, have also increased globally, fuelling the global epidemic of NCDs, in particular in low- and middle- income countries. The food system is still unable to provide safe and nutritious food for all and is increasingly challenged to do so, in view of the constraints posed to food production by resource and ecological sustainability concerns, especially climate change. 
 
 
Reshaping the food system to improve people’s nutrition 
9) Recognize that food systems – the resources, environment, people, institutions and processes with which food is produced, processed, stored, distributed, prepared and consumed – determine the quantity as well as quality of the food supply in terms of nutritional content, diversity, safety, accessibility and utilization. 
 
10) Reaffirm that agriculture (including livestock), fisheries and potable water are at the basis of food systems, but that the way that food is stored, distributed, processed, retailed, prepared and consumed throughout the food system plays a critical role in the quality and quantity of the food supply as it reaches consumers. 
 
11) Acknowledge that food systems are a critical factor in influencing access to sufficient food, to nutritious foods and to unbalanced diets, by populations at risk of malnutrition in all its forms. 
12) Recognize that the food system is influenced by policies and incentives across a wide range of sectors. 
 
13) Acknowledge that food systems should produce more nutritious food, not just more food, and guarantee adequate supply of fruit and vegetables, unsaturated fat and animal source foods while avoiding excess of sugars, saturated and trans-fats, salt and, where applicable, excess energy; food systems should enhance nutrition by providing year-round access to macro and micronutrients, promoting food safety and balanced diets, and avoiding food processing that reduces or adversely affects nutrition. 
 
 
14) Reaffirm that all systems for food production (soil, seeds, land, water, transport) and processing should be sustainably managed to ensure food and nutrition security for all by adopting ecologically sensitive farming practices. Climate change poses a major threat to sustainable food systems, and hence, to food and nutrition security. Good nutrition requires more sustainable, equitable and resilient food systems.
15) Acknowledging that creating consumer demand for sufficient food, nutritious foods and balanced diets is part of the process of creating a healthy food system. Empowering the consumer to make healthy food choices is essential. 
16) Further acknowledging that nutrition policy and programme implementation is poorly developed, coordinated and monitored at both national and international levels. Government responsibility for and leadership on nutrition is often partial and fragmented, or even non-existent. National nutrition strategies should involve and coordinate all relevant ministries and departments in complementary interventions, supported by the necessary financial, human and other resources.
17) Convinced that food systems, and the policies and incentives which affect them, can play a significant role in alleviating malnutrition in all its forms and related health outcomes. There are opportunities for enhancing nutrition throughout the food system which can support and augment existing efforts to attain better nutrition, such as through the SUN and the Global NCD Action Plan 2013-2020, etc. Continued efforts are needed, not only to raise agricultural productivity to meet the dietary energy needs of a growing population, but also to improve access to more nutritious foods to provide other essential nutrients, especially micronutrients, i.e. vitamins and minerals, while curbing the excessive consumption of sugars and saturated fats. 
 
 
 
 
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)?
 
The currently proposed commitments are insufficiently clear. In order that the commitments add value, we propose the following alternative commitments for the zero draft: 
 
Recognizing that a framework for collective commitment, action and results is needed to reshape the global food system to improve people’s nutrition:
 
1. We declare our commitment to identifying and implementing effective food systems solutions to poor quality diets and malnutrition in all its forms.  This should include finding solutions to underweight, stunting, micronutrient deficiencies, overweight/obesity and diet-related non-communicable diseases, including heart disease, diabetes and some cancers. We consider all of these conditions to be part of malnutrition in all its forms. 
 
2. We commit to establishing cross-government and multi-sectoral governance structures with the mandate of identifying and encouraging effective food systems solutions to malnutrition. Governments should play a lead role.
 
3. We commit to improving the opportunities for our populations, especially vulnerable populations, to access safe and nutritious foods. We will identify and remove constraints to an available and affordable supply of nutritious foods so that all populations can access a diverse and healthy diet. Constraints can occur throughout the food system, and may include soil, water and land management, agricultural research, agricultural production, transportation, distribution networks, procurement logistics, transmission of price information and retailing.  Focusing on increasing access to nutritious food has co-benefits for climate, resilience, and gender.
 
4. We commit to leveraging local food systems and engaging local populations to support the adoption of sustainable and nutritious diets, including by establishing markets for smallholder and family farmers, developing urban food systems to meet the needs of the local population, leveraging traditional/indigenous crops, and supporting women engaged in local and smallholder food production systems. 
 
5. We commit to reviewing the coherence between national and international policies that influence food systems and the food supply and programmes and policies designed to achieve nutritional outcomes, including those associated with food safety.  This will include reviewing bilateral, regional and international trade and investment agreements, investments in agricultural research, and incentives we provide to food processors and retailers. We will address policy incoherence to ensure investments and incentives that provide an enabling environment for the effective implementation of nutrition policies and programmes.
 
6. We commit to accelerating the implementation of population-wide interventions that enable and empower individuals, women and families to make healthy, nutritious food choices, which will create demand for healthy food systems. These should include the measures contained in the WHO Comprehensive implementation plan on maternal, infant and young child nutrition and the WHO Global Action Plan for the Prevention and Control of NCDs 2013-2020, including the implementation of the WHO Set of Recommendations on the Marketing of Food and Non-Alcoholic Beverages to Children.
 
7. We commit to advancing the data revolution in nutrition. Data systems and metrics are needed to monitor progress and drive commitment and accountability for achieving nutrition outcomes, and the relationship between food systems and nutrition. We commit to focusing on creating and improving systems and tools for gathering better and more frequent data, particularly on undernutrition rates, micronutrients, diet quality (including metrics relevant to obesity and non-communicable diseases) and local availability and affordability of diverse nutritious foods. Achieving this may require improved data sharing and use between the private and public sectors. Data should also be disaggregated by gender, age, ethnicity, geography and other key targets essential for reaching the most vulnerable and marginalised. 
 
8. We commit to engaging all actors in our efforts to identify and implement effective food system solutions to malnutrition in all its form including civil society. We recognize that engagement with the private sector should be conducted within a clear and transparent framework for engagement which is supported by appropriate rules, regulations and safeguarding against conflicts of interest. 
 
9. We call for food and nutrition security to be included as a standalone goal, with relevant targets and indicators, and mainstreamed in the post-2015 development agenda. Food and nutrition security represent the cornerstone for progress on other development fronts such as employment, education, the environment and health and in achieving a quality future for humankind. The sustainable development goals should strongly complement poverty eradication efforts when it comes to food and nutrition security, and include universal targets on eliminating malnutrition in all its forms. 
 
10. We call for official development assistance, including climate mitigation and adaptation finance, philanthropic transfers and other foreign assistance, to support capacity building in identifying and implementing effective food systems solutions to improve malnutrition in all its forms. 
 
 
We welcome, as an Annex to this document, the development of a framework for action that will report biennially on its implementation to FAO, WHO and ECOSOC.