Thank you for the opportunity to comment on the ICN2 Framework for Action zero draft.
We would like to share our comments in respect to question 1.
First, our principal comments relate to chapter 3.4 (International trade and investment).
· While we do appreciate that the first paragraph reflects the complex and multifaceted relationship between trade and nutrition, we find that the second paragraph almost exclusively approaches the link with trade from the negative perspective, i.e. what trade should not do, without actually spelling out the positive aspects of what trade can do to improve nutrition. We are therefore suggesting some editorial changes to this effect, as well as some clarifications in relation to indirect references to WTO Agreements (eg. TRIPS, Agriculture, SPS, TBT):
[Please see the detailled changes proposed in the text in the attachment, Ed.]
Second, we would like to add a general comment on chapter 3.3.6 (Food safety and antimicrobial resistance).
· This section has only a very brief paragraph regarding food safety and then gets into considerable detail about antimicrobial resistance (AMR). Although there is no doubt that AMR is a serious problem, in terms of the effects on global nutrition, there are much more serious food safety issues that should be flagged. Microbiological contamination, including e-coli, salmonella, and mycotoxins etc. pose much more serious health risks to malnourished people, and more needs to be done to assist governments to ensure uncontaminated food supplies. The Partnership for Aflatoxin Control in Africa (PACA) could be highlighted as an example - and many more initiatives of this kind are needed. The overwhelming focus on AMR gives the misleading impression that these other food safety issues are relatively unimportant.
Third, we have some comments regarding chapter 3.1 (Food systems).
· Our comments relate to the paragraph on page 7:
Both traditional and modern supply chains offer risks and opportunities for achieving better nutrition. Traditional supply chains are the primary channel through which most low-income consumers purchase food. Enhancing the efficiency of traditional food value chains can enable better nutritional outcomes by improving the access of low-income consumers to safe, nutrient-rich foods, such as animal-sourced foods, legumes, certain vegetables and fruits.
· By putting the word "certain" in front of vegetables, the impression is given that all animal-sources foods and legumes provide good nutrition versus only "certain" vegetables. I doubt this is the intention of the authors, who might either want to move the qualifier "certain" to before the list of food categories (… such as certain animal-sourced foods, legumes, vegetables and fruits), or delete it altogether. Nowhere else in the text are only "certain" vegetables recommended. We would also question the statement that most low-income consumers purchase food through traditional supply chains. While this may be true in most developing countries, it may not be the case in developed countries. In fact, it seems that one of the contributors to obesity among low-income consumers in developed countries is that they do not have easy access to traditional food supply chains.
These comments have been provided under the WTO Secretariat's own responsibility and are without prejudice to the positions of WTO members or to their rights and obligations under the WTO. These comments are non-exhaustive, and any absence of comments should not be construed as agreement with the concerned text.