The US Council for International Business (USCIB) appreciates the opportunity to submit comments to the FAO consultation on the Framework for Action for ICN2 Draft. The private sector believes it is essential that all stakeholders work together to develop holistic, impactful and sustainable solutions. We are committed to public-private partnerships that support public health strategies. We believe that collaborative multi-sectoral actions represent one of the most cost-effective ways to address public health challenges. In the past, USCIB has submitted comments to the FAO regarding the role of non-state actor, as well as regarding the ICN2 Political Outcome Document draft. As a follow up, we have a several concerns with the language in the Framework for Action Draft.
Enabling environments (Page 3): USCIB agrees with these 4 key elements, and would recommend that the comments underscore the importance of employing “knowledge and evidence-based strategies, policies and programs”, and that this reflects industry’s view as well.
“Nutrition Justice” (Page 4): This phrase is not defined and the boundaries of this concept are unclear; USCIB would recommend removing, and the document focus on the action steps on policies to achieve explicit nutrition targets.
Engage implementation partners (page 5): The language in this paragraph could be misconstrued, in particular the “subordination of interests which conflict with government policies, agreed implementation…” in a way that continues to denigrate the role and contributions of the private sector. This language speaks to a larger point within the document in that there is limited language that acknowledges the importance of the food industry and the need to engage as a full partner in deciding strategies, actions and common goals for moving forward. The private sector is noted, including on page 27, but this is an area where we think the document could be significantly enhanced.
Priority Actions for nutrition governance (page 5): In this section as well as in sections on “recommendations for follow-up” (pages 26-27), there is a lack of clarity as to how all these platforms, mechanisms, processes and reporting relate to similar activities either in place or proposed by WHO and the UN – for example, the WHO Global Coordinating Mechanism and the UN HLM periodic “Progress Reports” on the 2011 Political Declaration. There appears to be significant potential for redundant, duplicative and overly burdensome processes that could present significant obstacles to achieving real progress. At a minimum, greater clarity is required regarding roles and responsibilities among the various multi-lateral organizations.
Language on lost productivity (page 5/6): important point that could be elaborated upon further in comments as a key driver for companies to engage in nutrition/wellbeing to mitigate productivity losses and support the health and wellbeing of our consumers/communities.
Page 6 and elsewhere on incentives/taxes: Fiscal policy is complex, often has unintended consequences, and requires caution, especially as food prices continue to rise. Unintended consequences include an effect on informal and illicit products and markets, problems of tax evasion, corruption, smuggling and product switching. The introduction of a fiscal approach can very quickly become cumbersome to manage and complex to administer.
Furthermore, fiscal measures also have potentially large re-distributive effects and would most likely hurt lower-income individuals who spend a larger proportion of their income on food. Tax rates should be kept low on products that account for a relatively high proportion of spending by the poorest groups in society. In this instance, taxes on food will discriminate against low income households.
Finally, the impact on consumption patterns from implementing fiscal measures is unpredictable. Changes in consumption will depend on the price elasticity of each good (assuming the tax is passed on to consumers). How consumers’ behavior changes in light of relative price changes is not always obvious and inherently difficult to estimate. The more likely impact is that consumers will switch to alternative goods that have characteristics that are closer to the originally purchased item and that remain exempt from the new tax regime, or taxed at a lower rate.
Comments on Section: From Commitment to Action: Policy and Programme Options Role of “highly processed foods of minimal nutritional value” (page 7): There are no definitions of “highly processed foods of minimal nutritional value” in this document or by other reference and yet the conclusion is drawn that they have “contributed to obesity and diet-related NCDs”. The lack of either a definition or an evidence base linked to those definitions, should dictate that this statement is not appropriate for inclusion in the WHO/FAO Framework For Action document.
Characterization of WHO recommendation on “free sugars” (page 8): The document appears to misstate WHO recommendations on free sugars –specifically with respect to the “5%” language. It is our understanding that the WHO is currently conducting a peer-review of proposed recommendations and in March 2014 requested public comments on those recommendations. With regard to a recommendation of intake below 10%, the authors of the WHO review noted that the relationship observed between free sugar intake and dental caries was based on evidence that was judged to be of very low quality. At that time, the Grocery Manufacturers Association (GMA), a USCIB member, commented on the proposed recommendations and concurred with WHO that more scientific substantiation and full engagement and collaboration of the many concerned stakeholders is required before a conditional recommendation of reducing sugar intake to 5% can be considered for adoption as policy. Furthermore, since the request for comments in March, WHO has issued no public statement with regard to its proposed sugar recommendations and the results of its peer-review process, so the statement in the Framework for Action seems premature at best.
Additionally, the private sector understands that many consumers are increasingly seeking ways to improve their dietary quality and manage their calorie intake, including reducing sugar consumption. For example, to meet these needs, members of the International Food and Beverage Alliance (IFBA) have been formulating products with less added sugar, using alternative sweeteners and other ingredients as alternatives to sugars and reducing calories by offering smaller portion sizes and providing portion guidance. Reducing sugar levels is complex and challenging, both technically and in terms of consumer acceptance.
Empowering Consumers to make healthy dietary choices (page 9): We agree that nutrition education is key, and that we need to collectively work to effectively educate consumers through labeling and nutrition programs about food, how to combine them into diets (quality and quantity) that fit their needs as well as address other aspects of a healthy and productive lifestyle including physical activity, energy balance, etc.
Role of women in food systems (Page 9): Another crucial issue includes ensuring the empowerment of women and girls both economically and socially. These members of society have an important role in the decisions made at the household level with regards to food and nutrition. Therefore, we believe that it is important to promote policies that help women become farmers, traders and business owners. Equally important is that these members of society are educated and properly informed to make healthy choices for their households. The private sector can play a crucial role in empowering women and girls.
Backyard farming/gardens (Page 10): This is certainly one small element to the overall approach, but recommend that we provide a caution given huge global demands on food, increased production/yields, change in diets, demographic shifts (move to cities) that will all require a more robust approach.
Regulating marketing and financial incentives/disincentives (pages 11-12): It is not clear what the evidence base is for the specific strategies noted in this section, raising the question of why national governments should rely upon this analysis. This section references the WHO Set of Recommendations on Marketing Food and Non-alcoholic Beverages to Children in the context of “Regulating Marketing” despite the fact that these WHO recommendations also note the role that industry self-regulation can and has played in this arena.
Priority actions to improve the food environment (Page 12): USCIB is concerned about the language on Priority Actions to Improve the Food Environment; the Framework for Action document should highlight how the food and beverage industry is already responding to the WHO‘s 2004 Global Strategy by:
--Offering healthier products through product innovation and reformulation
--Providing more information to consumers through nutrition labeling so that they can make informed choices
--Adopting responsible marketing policies, particularly with respect to children
--Working with other stakeholders to promote physical activity and nutrition education
Page 22, access to safe water: USCIB strongly supports work in access to safe water and would like to highlight some of the efforts that industry/TCCC are already undertaking to ensure access to clean water: http://www.coca-colacompany.com/water-stewardship-replenish-report/
International trade and investment (page 24): There appears to be a presumption underlying this section that the impact of trade and investment is primarily negative, despite the fact that no evidence is offered to support this presumption and despite significant evidence to the contrary, including FAO and WTO reports, indicating that increased trade, particularly in agriculture and food, increases the standard of living in developing countries and improves the performance of national economies. This section continues this presumption with respect to trade and nutrition specifically, not by providing any evidence of harm, but by implication simply constructing each proposition in the negative. Without any science or evidence basis, this entire section should be reconsidered.
Providing evidence for the definition of a healthy diet (Page 26): This is an area in which the private sector could contribute. USCIB would like to recommend and welcome a dialogue between the private sector and FAO and WHO on the subject.
Intergovernmental Panel on Nutrition (Page 28): USCIB would support such a panel and would like to recommend inclusion of representatives with substantial expertise from the food and beverage industry.