Thank you for the opportunity to make a contribution on behalf of the International Agri-Food Netork and the Private Sector Mechanism
Do you have any general comments on the draft Framework for Action?
The draft document tackles a huge number of action areas directly and indirectly impacting on nutrition. Work needs to be done to make the Framework clearer and more focussed so that governments and stakeholders can look forward to partnering in a successful implementation period post-ICN2.
Members of our network would welcome the fact that, woven throughout the Framework for Action there are references to priority actions that seek to: (1) promote good practices for improving nutrition enhancing food and agriculture; (2) address micronutrient deficiencies; (3) improve micronutrient intake through food fortification; (4) strengthen facilities for local food production and processing; (5) promote the consumption of affordable nutritionally enhanced foods; and (6) increase incentives to achieve these and other priority actions.
The private sector is where most people access the products and services to meet their needs. This is the same for food and nutrition, where diverse diets from a range of agricultural systems are key. Business has a direct and indirect impact on nutrition through agriculture, food fortification; promoting safe infant and young child feeding practices; improving access to clean water and improved sanitation and hygiene; changing consumer behaviour and offering insights in how to promote healthier choices. This is why business needs to be part of these ICN2 discussions.
The private sector consists of farmers who regardless of their geographical location, gender, age, or size are subsistence, small, middle or large-scale holders. Farmers produce the food that people consume. Farmers and their fisherman and livestock counterparts provide the continuous, ongoing linkages to the social, economic and environmental development of the planet. These food producers are the backbone of our local, national and global food systems and take the first step in food security.
Post-agriculture production, the private sector consists of an additional tens of millions of harvesting, processors, manufacturers, packagers, transportation, marketers and distributors and retailers who can also be categorized as small and medium enterprises, large national businesses and multinationals.
These private sector entrepreneurs —individually and collectively—constitute the global interconnected food systems that forge the essential roles in feeding the world. Through these efforts they have had, and will continue to play a critical role in addressing hunger and malnutrition.
Business is prepared to, and recognizes, its responsibility to play even larger roles to help achieve zero hunger and malnutrition in our lifetime. Without these committed businesses and entrepreneurs there would be even greater hunger, malnutrition and pervasive famines, disease and pre-mature deaths in the world.
The world is in a different and a better place today than 40 years ago when the 1974 World Food Conference was held to address concerns about famine. ICN2 in November, offers us the opportunity to create a new framework, for all actors to find and implement the solutions to malnutrition. This would improve health conditions and reverse the negative impacts on the cognitive, social and economic capabilities among hundreds of millions of people, mostly women and children.
Do you have any comments on chapter 1-2?
Chapters 1-2 have largely been welcomed by the members of our constituency who have read this document. This is because of the emphasis on enabling environments for improving nutrition, knowledge and evidence based strategies, and the need for public-private partnerships.
Do you have any comments on chapter 3 (3.1 Food systems, 3.2 Social Protection; 3.3 Health; 3.4 International trade and investment)?
The aims of section 3 are commendable and contain crucial acknowledge of the role of modern supply chains, productivity, technology and diversity in food production, as well as diverse diets.
As mentioned by members of our constituency, the value chain approach in 3.1 is welcome, particularly with reference to the powerful role of micronutrients. Partnerships already exist in some countries, for example, the HarvestZinc initiative.
The section is extremely ambitious, aiming to tackle many complex issues, from public procurement, to NCDs, to environmental sustainability and social protection. The way it is currently drafted, not all of these areas are tackled in all of their complexity and as a result certain paragraphs run the risk of being imbalanced and open to misinterpretation.
Suggestions for improvement in section 3 may include:
· “nutritional justice” and “ “highly processed foods” – are there global definitions of these terms? If not, how would stakeholders and governments be able to coordinate action?
· “free sugars” – current WHO work on this matter must be reflected and the Framework for Action must not pre-empt any conclusions of consultations that are underway with the global health community, which includes businesses as key stakeholders.
· The “Priority actions” on page 10 merit further attention. “backyard gardening” and “small animal management” are important and effective ways to communicate food production to the public, however it does not make sense to omit the crucial role of the world’s farmers, in all of their diversity and agricultural systems, in providing nutrition for the global population.
· The sections on “traditional foods” and “cultural preferences” could be merged and shortened. The term “appropriate traditional foods” may need to be modified in order to encapsulate consumer choice, likewise the term “acceptability…of diets”.
· Pages 11 &12 – private sector models on action on NCDs and incentives for healthy diets could be taken into account.
· Those among our constituency such as the International Dairy Federation would like to challenge the recommendation for Saturated Fatty Acids, stating that the type of Trans-Fat should be specified.
· 3.1.1. Loosely refers to fiscal incentives, whereas experiments with “food taxes”, without any proper scientific evidence, would unfairly discriminate certain types of foods. 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.
· 3.1.2 on “Sustainable healthy diets” aims to tackle a hugely complex issue in just ½ a page.
· 3.3.6 is likewise complex and cannot be discussed fully in a document about nutrition. WHO, FAO and OIE are already undertaking an enormous amount of work on antimicrobial resistance, for example the multistakeholder platform EPRUMA. One recommendation would be to omit this section.
· 3.4 on international trade – another complex issue that cannot be fully characterised in just ½ a page. The current tone is overly negative, a recommendation would either be expansion or deletion.
Do you have any comments on chapter 4-5?
Does the Framework for Action adequately reflect the commitments of the Rome Declaration on Nutrition, and how could this be improved?
The private sector remains committed and fully engaged in its own efforts to improve global nutrition, as well as partnering in the commitments of the Rome Declaration.
A commitment from governments and international institutions is urgent. However, in this part of the document 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.
Does the Framework for Action provide sufficient guidance to realize the commitments made?
The Framework for Action has laudable aims but it must become more focussed and concise if it is to clearly set out ways to realize the commitments in the Rome Declaration.