Overall Consumers International welcomes this Framework. Having said that we feel that it is missing specific recommendations on:
- targets for reformulation to lower levels of salt, saturated fat and sugar (we could only see reference to removal of trans fats).
- actions on nutrition information/ labelling - although there is a section headed 'nutrition education for behavioural change' which includes reference to nutrition information, this does not have a list of 'priority actions' like the other sections. It would therefore be good to include reference to nutrition information, but specifically front of pack; information out of home (eg. calorie labelling) and the importance of regulation of claims (particularly with the earlier emphasis on fortification for example).
Under sustainable healthy diets (3.1.2), it would also be useful to make reference to the need to provide clear, integrated advice for consumers on healthy and sustainable diets.
We also think it would be good to get a stronger emphasis on the importance of consumer acceptability of food production methods under food systems, particularly in relation to things like biofortification.
In section 3.3.6 where reference is made to the antimicrobial resistance we recommend tightening up the language so that the priority actions include:
-Establish and enforce targets to end the use of antimicrobials for growth promotion
and phase out use for routine disease prevention in livestock production.
-Establish a regulatory framework for authorisation and control of the quality of veterinary
medicines, ensuring a separation between the selling and the prescribing of veterinary