Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

Dear CFS,

So many thanks for undertaking this important and transparent policy process for the development of Voluntary Guidelines on Food Systems and Nutrition, and for providing us with this forum for feedback.

I would like to commend you on this excellent Zero Draft which not only highlights the urgency of tackling malnutrition in all its forms, but also provides several solutions for doing so along the whole “production to consumption” supply chain for food systems. Your inclusion of key issues such as equity and climate change challenges, and the need to conserve agrobiodiversity makes the guidelines relevant not just today but for many years to come.

As the CEO of HarvestPlus (https://www.harvestplus.org/), the global leader in biofortification technology and policy, and the convener of CGIAR breeding centers and 400+ other global partners working on biofortification, I was especially pleased to see your inclusion of biofortification in Part I, under (1) Production Systems paragraph (h) as one of the technologies that could result in “improvements in productivity enabling better access to healthy diets and nutrition outcomes while minimizing environmental impact.”

Biofortification is now a proven solution for improving food systems through their backbones, i.e., through the key staple(s) from which the majority of the calories consumed come – regardless of age, gender and socio-economic status of the consumer. You can see the latest evidence on the health and nutritional impact of biofortification here: https://www.harvestplus.org/evidence-document, and the availability of all of the released and about to be released, conventionally-bred (i.e., non-GMO), high-yielding, climate-smart and nutritious biofortified crops globally here: https://www.harvestplus.org/sites/default/files/publications/HP_2019_CropMap_update_v5_0515.pdf . To date 21 countries have included biofortification in their national policies, and biofortified crops are benefiting almost 40 million people globally (see our latest annual report here: https://www.harvestplus.org/knowledge-market/in-the-news/catalyzing-biofortified-food-systems-2018-annual-report ). Biofortification is an equitable intervention, since unlike other nutrient rich foods – such as animal sourced foods – which are often reserved for male members of a household – biofortification targets the staple crops consumed by all household members. Finally biofortified crops are not only bred to be climate smart/climate adaptive, but also to provide higher levels of micronutrients, which is a much needed intervention as the recent evidence (see, e.g., https://www.downtoearth.org.in/news/food/high-co2-emissions-reducing-nutrients-in-rice-wheat-66143) shows that nutrient content of our staple crops are eroding due to increasing CO2 concentrations.

Given all this evidence, I would recommend you to consider including biofortification in other sections of the guidelines, such as Part I, section(1) Production Systems (a), (b), (f), (i), (g), (k); (3) Processing and Packaging (a); (4) Retail and Markets (a) and (b); in Part II, section on Availability and Physical Access (b) and (c); Economic access/affordability (c), and under Food Quality and Safety (b).

If you have any follow up questions, please do not hesitate to contact me. We would also be delighted to participate in the forum mentioned in Paragraph 59 and to share with other stakeholders our various resources (such as the Biofortification Priority Index [ https://bpi.harvestplus.org] for identifying high impact target countries for each biofortified crop) and our know-how and lessons learned in introducing and scaling of biofortified crops and foods along the staple crop supply chains.

Sincerely yours,

Arun Baral

Dear CFS Colleagues,

So many congratulations on this comprehensive Zero Draft of the Voluntary Guidelines on Food Systems and Nutrition. Thank you very much for including biofortification in Part I, under (1) Production Systems paragraph (h) as one of the technologies that should be scaled up to improve consumer access to healthy diets and better nutrition outcomes. 

Since conventionally bred (i.e., non GMO) biofortified crops and foods made thereof are now being scaled up along the crop supply chains; biofortified foods could also be included in other parts of the guidelines, including Part I, section(1) Production Systems (a), (b), (f), (i), (g), (k); (3) Processing and Packaging (a); (4) Retail and Markets (a) and (b); in Part II, section on Availability and Physical Access (b) and (c); Economic access/affordability (c), and under Food Quality and Safety (b).

Given the evidence-based approach taken by the CFS in development of these important guidelines,  I would like to refer you to the latest evidence on the nutrition and health impacts, adoption, consumer acceptance and cost-effectiveness of biofortification (https://www.harvestplus.org/evidence-document).  Furthermore,  21 countries have now included biofortification in their various national policy and strategy documents (list of countries and policies/strategies are available from HarvesPlus, www.harvestplus.org). These could be highlighted as examples of policies/strategies for improving food systems and nutrition (and learnings could even be shared among member countries through the forum mentioned in Paragraph 59).

Many thanks for your consideration and warmest regards,

Ekin Birol, PhD

Director, Impact and Strategy, HarvestPlus

Girl Powered Nutrition (GPN) is a global programme run by the World Association of Girl Guides and Girl Scouts (WAGGGS) through their Member Organisations (MO) in four countries – Madagascar, the Philippines, Sri Lanka and Tanzania – chosen because of their high prevalence of adolescent malnutrition amongst girls. WAGGGS is the largest voluntary movement dedicated to girls and young women in the world with 10 million members across 150 countries.

Funded by Nutrition International, the GPN programme promotes girl led change through education on the importance of a balanced, healthy lifestyle and enabling girls to be agents of change at local, national and global levels in the fight to stop malnutrition continuing from one generation to the next.

By mid-2020, our aims are:

• For 195,000 Girl Guides across all the participating MOs to have completed the GPN badge and have improved knowledge and attitude to make healthy choices
• For 390,000 additional girls/community members to have improved knowledge and attitude to make healthy choices for girls and themselves through community actions
• For young women (Advocacy Champions) to attend and speak out at national and global events as experts in adolescent nutrition to influence decision makers that adolescent nutrition is prioritised

• As a result of the GPN programme we want a future where healthy and well-nourished girls will be able to reach their full potential and will feel confident and empowered to take actions to break the intergenerational cycle of malnutrition.

After consultation with our girl guide ‘Advocacy Champions’ around the world, we are responding to the Committee on World Food Security consultation on the development of the voluntary guidelines on food systems and nutrition because we know that girls need to be healthy and well-nourished if they are to reach their full potential. Part of the Girl Powered Nutrition programme is advocacy: influencing national and global decision-makers of the importance of making girls nutrition a global priority. WAGGGS is using programme findings to influence decision makers and create global policy changes. Please see attached file for our consultation response. 

Dear colleagues,

please kindly find attached WFO contributions to the policy process for your consideration.

With thanks and best regards,

Giulia

MARIA GIULIA DE CASTRO

Policy Officer

World Farmers’ Organisation, WFO

Below are some considerations I would like to raise on behalf of IFAD on the draft Voluntary Guidelines.

Best regards,

David Suttie

1. On the current situation and underlying problems:

- In a context of divergent narratives and approaches to developing the types of food systems that may be thought to offer the best potential for promoting better nutrition, it is surprising that the guidelines have little to offer in terms of a broad macro-level vision of food systems – both prevailing and desired. For example, as detailed in the recently published HLPE report “Agroecological and other innovative approaches for sustainable agriculture and food systems”, it would be relevant to note that smallholder farming systems make important contributions to producing nutrients in the most populous and food insecure areas of the world, and that diversity of agricultural and nutrient production has been found to diminish as farm sizes increases (p.73). These phenomena are also noted in the background paper for the Decade on Family Farming, prepared by FAO and IFAD (see pp.6-7 at: http://www.fao.org/3/ca4778en/ca4778en.pdf). While not stating that large farms do not also have a role to play – clearly they do – it should be a concern that, given the importance of smallholder farms in maintaining diversity and nutrition in food systems, policy frameworks in many contexts are creating biases towards larger-scale farms and food companies – in terms of policies related to land acquisition, marketing, trade policies, and even food and safety regulations. While some important considerations are included in the draft in terms of supporting smallholders, there would be scope for acknowledging the macro-level situation and their present and potential role therein.

2. On the guiding principles and their focus: 

- Given the above, the concern of these guidelines should not only be addressing policy fragmentation (para 12) and promoting policy coherence (para 16), but in promoting policies that lead to the most equitable and inclusive outcomes in terms of advancing food systems that provide healthy nutrition for all. In many contexts, we arguably have a degree of policy coherence towards supporting food systems where (especially large, multinational) actors are enabled to make significant profits providing cheap and poor quality food to consumers, in many cases at the expense of smallholders and rural people who lose their rights to land and who are often employed under poor conditions on large plantations. So the issue is not only one of coherence, but also one of policies that promote equity and inclusion.

3. On the guidelines and policy relevant areas:

- Topics to improve consumer awareness, education and choices rightly feature in the draft. At the same time, there seems to be relatively little recognition of the working of markets and prices and how this skews consumer behaviour towards food that is not the most nutritious. Without markets that better reflect the true cost of food – taking environmental and social, as well as environmental costs into account – it is doubtful that it will be possible to change consumer behaviour to a sufficient extent, especially in the case of relatively low-income consumers. In this context, the issue of true cost accounting and reflecting how fiscal and trade policies, as well as those related to land, create inequalities and biased food markets needs to be reflected upon; on this issue, the comments provided by the Honourable Ambassador of Hungary below on true cost accounting are important and need to be taken into account.

- With rising urbanization levels shaping food systems and food demand, as recognized on p.18 of the draft, significant opportunities emerge in terms of promoting rural-urban linkages – both hard (infrastructure) and soft (institutional) – to enable local rural smallholder producers to supply nutritious food to urban residents. The resulting short value chains could reasonably be expected not only to improve nutrition outcomes in rural and urban areas – and maintain traditional healthy dies as opposed to shifting to diets comprising much highly processed goods – but to generate income among rural communities, thereby improving the purchasing power and nutrition of rural and smallholder communities, who are often among those most likely to suffer from undernutrition.

- Finally, it is slightly surprising that there is virtually no consideration of the role of indigenous peoples and indigenous food systems. Advantages of these systems in terms of diversity, nutrition, and agrobiodiversity are well-documented and have been alluded to in the comments by McGill University who provide a range of good recommendations on this topic. In particular, the fostering of indigenous knowledge, partnering with indigenous peoples’ organizations, and respecting their intellectual property rights are important considerations.

The perspective of Chapter 1 does not consider sustainability in all its three dimensions in line with the 2030 Agenda. It is mainly focused on nutrition and malnutrition, it is too narrow approach and it does not fully reflect the challenging issue of a systemic perspective on food systems. It does not sufficiently consider the conditions under which food is produced, processed, distributed, prepared and consumed, nor how food systems can be made more sustainable in order to ensure healthy and sustainable diets development.

“Sustainable” should be inserted between “healthy” and “diets” . The definition of “sustainable diets” (FAO, 2010)  should be inserted in paragraph 32 among all other definitions.

In Paragraph 16, referring to promoting policy coherence, a reference to the One Planet (10YFP) Sustainable Food Systems (SFS) Programme should be inserted.

In paragraph 26 among stakeholder groups are missed fishermen organizations, after farmers organizations.

In paragraph 61, the One Planet (10YFP) Sustainable Food Systems (SFS) Programme should be inserted as an UN Multistakeholder Platform

Please find attached the input by the UN System Standing Committee on Nutrition (UNSCN) to the Online consultation on the CFS VG on Food Systems and Nutrition.

Best regards,

Alessandra Mora

Please find attached Canada’s input to the e-consultation for the CFS Voluntary Guidelines on Food Systems and Nutrition.

Best regards,

David Cuming

Please find below the comments provided by the World Health Organization’s Department Nutrition for Health and Development (WHO/NHD) in Geneva to the Online consultation on the CFS VG on Food Systems and Nutrition.

1. Does Chapter 1 adequately reflect the current situation of malnutrition and its related causes and impacts, particularly in line with the goals and targets of the 2030 Agenda? What are the underlying problems that currently hinder food systems to deliver healthy diets?

The CFS VG on food-systems and nutrition are of high importance for the UN Decade of Action on Nutrition, and for achieving food security, improved nutrition and health and other related SDG targets. The added value needs to be to go steps further with the operationalization of the agreed ICN2 Framework for Action.  Moreover, these voluntary guidelines need to build on and integrate the guidance adopted by other member state bodies of the UN system. This includes also the integration of relevant World Health Assembly guidance into the broader multisectoral context for enabling sustainable food systems supporting healthy diets and improved nutrition and health for all.

For the achievements of the global commitments and targets, we would like to underline for chapter 1, the importance of calling for an integrated approach to food systems from farm to folk. Too often, contrasting policies are observed, which are not achieving the intended outcomes of addressing all forms of malnutrition. An integrated approach from farm to folk is vital to avoid policy incoherence, and to ensure that policies included in the agricultural element are followed through in the different steps of the food supply chain, particularly around the elements of food distribution and retail and consumer policies. In addition, we would support the establishment of global policy targets in order to make that alignment; the CFS might consider establishing targets for the achievement of the overarching targets of addressing malnutrition in all its forms. (see also point 4).

For this section, an essential element is the inclusion that unhealthy diet is the top risk factor for the global burden of disease. The concept of healthy diet should be central to these voluntary guidelines. In fact, the latest analysis that looked comprehensively at the outcomes in terms of disease, the Global Burden of Disease Study, indicates that unhealthy diet is now the top risk factor for the global burden of disease. It accounts for 11 million death every year. This is a substantial element. The Global Burden of Disease Study is the most comprehensive worldwide observational epidemiological study to date, that assesses mortality and disability from major diseases, injuries, and risk factors to health. We would like to underline the importance of this study result for the CFS voluntary guidelines and suggest that it is reflected in the Introductory part 1 of the document. Furthermore, we would like to stress the importance that the Committee (CFS) looks at the concept of healthy diet as a guiding element for the discussion.

2. What should be the guiding principles to promote sustainable food systems that improve nutrition and enable healthy diets? What are your comments about the principles outlined in Chapter 2? Are they the most appropriate for your national/regional contexts?

Healthy people and healthy planet are key elements, and we do welcome the inclusion of the ‘healthy people – healthy planet’ concept among the guiding principles. In deed health objectives could be an overarching factor and an aligning factor for food and nutrition policies. Currently, food systems deliver in an inadequate way on their core-business which is to produce and provide the necessary food and nutrients for the population. Health of the population and health of the planet as key elements drive the food system transformation, and they should be placed more important than other aspects such as for example considering the food system as a production system of commodities only. We would like to suggest that this ‘healthy people- healthy planet’ element might be highlighted even more as a key driver to avoid policy incoherence.  

In Section 2, we welcome the inclusion of the definition on ‘Healthy diet’, including the healthy diet of infants and young children (page 7). Moreover, we would like to inform the CFS Secretariat that WHO is collaborating with FAO and both agencies jointly organized an expert consultation on the topic in July 2019. This consultation looked at diet from different entry points: including health, affordability and sustainability. The objective of the Consultation was to develop guiding principles around what constitutes a sustainable and healthy diet, to be further translated into clear, non-technical information that can be used by governments and other actors in communication and policy-making. The guiding principles will be shared with the CFS and will certainly contribute to the development of the CFS VG. The proceedings of the Consultation will be published as well.

3. In consideration of the policy areas identified in Chapter 3 and the enabling factors suggested in paragraph 41 of the Zero Draft, what policy entry points should be covered in Chapter 3, taking into account the need to foster policy coherence and address policy fragmentation?

Overall, the right policy areas are highlighted in the document. A missing element is that the document does not provide sufficient reflection on how those policy areas outlined in the document should be shaped. Certain policy areas could go into complete different directions from the intended targets, and therefore, more clarity should be included on each policy area.

We would like to suggest that the policy areas could be organized around broad policy goals and the policy measures along the food supply chain.  For example, the existing challenges on enabling healthy diets could be taking as a starting point:  

Clearly one challenge is the availability and affordability of fruits and vegetables to the world population. Using an approach that addresses the question which different measures are required to address this challenge (which could be formulated as a global target), more clarity could be provided for the future user of the Voluntary Guidelines.

Another example could be the existing global problem over the supply of fats and oils for human consumption. The question to be addressed could be, what types of policies are required to increase the availability of healthier fats and oil and their production compared to the existing ones that currently are expanding; and to do this in line with the global target on the elimination of industrially produced trans fats or the target on the reduction of saturated fats in our food supply.

To address these and other challenges, which could be formulated in terms of global policy goals, clearly will require an alignment of consumer policies, industrial policies, food reformulation policies, research and agriculture policies. We would like to suggest that the CFS Secretariat considers to be more explicit about what the VG are trying to achieve. In addition, regional specific goals and targets may be considered.

4. Can you provide specific examples of new policies, interventions, initiatives, alliances and institutional arrangements which should be considered, as well as challenges, constraints, and trade-offs relevant to the three constituent elements of food systems presented in Chapter 3? In your view, what would the “ideal” food system look like, and what targets/metrics can help guide policy-making?

With regard to targets, we would like to suggest the establishment of global policy targets. In order to reach alignment between the different policy areas, the CFS might consider establishing such global policy targets that should be designed to achieve the overarching targets of addressing all forms of malnutrition. One step in that direction would be to clearly state the objectives for each policy mentioned in the document. In this way, the formulation of the policy would be more easily understood by countries for relevant implementation. CFS might help the global community and countries in providing these essentials. Without such an analysis of how a particular policy element contributes to reaching overarching targets of addressing all forms of malnutrition, the different sub-sections in Part 3 of the document, the way they are presented, could appear to be fragmented and disconnected. There is a call on countries to address this matter when they plan to use the voluntary guidelines, but CFS is well positioned to help in providing the key elements around which integrated food and nutrition policy planning might be done.

On specific policy measures we would like to share the following comments:

Regarding the food environment, WHO is currently conducting systematic policy reviews on four areas: Marketing of food to children, Labelling policies, Procurement of food in public institutions, Fiscal policies. The outcomes of this work might support the provision of evidence-base for certain policies. Moreover, some of these policies might require some broadening with reference to the current wording in the document. For example, on marketing we strongly recommend that the whole of marketing policies is considered, and that the document stays broad as it is now and is not limited to one element like the marketing to children. Equally important are the marketing of breastmilk substitutes and the marketing of foods for young children as significant public health components.

On food quality and safety: we would recommend not having a specific item but rather have it as cross cutting element that should be present in multiple policy areas. Moreover, we observe inconsistency in placing food safety in the document:  food safety is mentioned in Farm-to-school Programmes but not elsewhere in Production Systems, is mentioned in Handling/ Storage/Distribution/ Processing/ Packaging but not in Retail/Markets, and is totally absent in Consumers Behaviours section while the final preparation of food is particularly important for food safety including in informal sectors (street-vended foods). Food safety is an integral part of food security and nutrition; therefore, its actions should take place along the entire food chain.

On the food environment, and particularly on the economic access component: -  We would like to suggest more specificity around the nutrition-sensitive trade policies, and to mention the need to consider nutrition impacts of trade policies. We also would like to suggest the inclusion of import policies as a measure to shape the food environment.

Regarding the fiscal and pricing policies -  When it comes to pricing policies, we would rather suggest to use the term ‘economic measures’ and to not just consider taxation as the only measure. A broader concept would be more adequate that includes besides taxation also the management of subsidies, which is an important and critical element in the way food availability and the price of food are shaped.

The informal food sector -  has a role to play in many parts in Asia and also in urban areas in Africa and elsewhere. In many low-income countries, the informal food sector is comprised of street and market food vending. Given its importance for a huge number of people in the world and often the most vulnerable, we suggest including policies that address the nutritional value and safety of food produced in the informal sector, under the section on food environments – availability and physical access.

5. How would these Voluntary Guidelines be most useful for different stakeholders, especially at national and regional levels, once endorsed by CFS? 

There are multiple actors involved in food systems at all levels.  Under this point, we would like to suggest including the need for setting up rules of engagement to strengthen transparency and accountability. As addressed in the HLPE report on Multistakeholder Partnerships, this includes identifying and acknowledging possible tensions, power asymmetries and conflict of interest among partners; developing appropriate support tools to address these, and defining clear roles and responsibilities of the different partners. We consider it important to address the rules of engagement in chapter 4 of the document.

The UN Decade of Action on Nutrition as an implementation mechanism for the VG. The discussion of the VG might inform the workprogramme and the commitments for the second half of the Nutrition Decade. We would like to suggest that the Nutrition Decade is mentioned as a means to follow up and implement the VG.

FAO and WHO are preparing for the Mid-term Review of the Nutrition Decade to lead to an event in 2020. The main objective of the Mid-term Review will be to identify existing gaps and set priorities for the second half of the Nutrition Decade. The CFS VG play an important role in identifying these priorities with regard to food system action and guiding countries in further operationalising the relevant ICN2 Framework for Action recommendations. More information on the Mid-term Review are available at this link https://www.un.org/nutrition/sites/www.un.org.nutrition/files/general/pdf/concept_note_for_nutrition_decade_mid-term_review_rev_130619.pdf

WHO looks forward to continuing working closely with the CFS Secretariat and all partners involved in this process.

Global Dairy Platform (GDP) appreciates the opportunity to submit inputs for consideration by the Committee on World Food Security (CFS) in response to the call for comments on the “Voluntary Guidelines on Food Systems and Nutrition” Zero Draft.

GDP, a collaboration of dairy companies, associations, scientific bodies, and other global partners is committed to demonstrating dairy’s positive contribution to global food systems, healthy diets, and sustainable livelihoods.

The following responses are offered regarding the Zero Draft and highlight three main topics of importance within food systems: (i) access and affordability for all; (ii) regionally based, culturally informed solutions; and (iii) the importance of both animal and plant-sourced foods in a healthy diet.

1) Does Chapter 1 adequately reflect the current situation of malnutrition and its related causes and impacts, particularly in line with the goals and targets of the 2030 Agenda? What are the underlying problems that currently hinder food systems to deliver healthy diets?

Overall this chapter captures the majority of the issues that promote/lead to malnutrition. However, there are a couple of issues that could be more fully addressed concerning governmental roles in:

• improving infrastructure that will allow agricultural products to more effectively reach all people in a region, a country, a continent. In regions where poor roads hinder transportation of goods, the best agricultural practices might still not be able to aid the majority of the people in that region.
• taxation and regulation of both domestically produced and imported food stuffs. Government policies on these issues can greatly impact accessibility and affordability, which in turn can influence nutrition/malnutrition status, particularly in many developing countries.
• The chapter focuses primarily on malnutrition from the perspective of the consumer/individual. Very little is mentioned about other aspects of the food system, and the roles they can play in battling malnutrition (as well as addressing other SDGs besides hunger/malnutrition alleviation). For example, there are strong data indicating that livestock/dairy production plays a role in poverty alleviation, and that livestock ownership in developing countries improves nutritional outcomes for individual owners and those with whom they work.

(Reference “Dairy Developments Impact on Poverty Reduction” http://www.fao.org/3/CA0289EN/ca0289en.pdf)

2. What should be the guiding principles to promote sustainable food systems that improve nutrition and enable healthy diets? What are your comments about the principles outlined in Chapter 2? Are they the most appropriate for your national/regional contexts?

• The document indicates that guidelines need to conform to regional customs, beliefs, cultures, etc. In that regard, more can be said to differentiate the health/nutrition needs of people in developed vs. developing regions. Animal proteins (like most foods) may be overeaten in certain developed countries but the nutritional value they offer can help in the reduction of malnutrition in the developing world. The need for a more localized approach to nutritional practices should be accentuated more in the document.
• The Guidelines point to the need to provide evidence-based information to stakeholders. It would be helpful if the committee outlined what constitutes “evidence-based”; will all published scientific data be considered as adequate evidence? Will certain types of research be stressed? Will research carried out in one geographic region be used as evidence that drives guidance in other regions? Who gets to choose the validity/suitability of studies used to generate guidance? What happens when there is a lack of scientific evidence? Finally, sustainable food system guidance is sometimes driven by emotional/anecdotal information, rather than science-based data. To what extent, if any, will this sort of information be viewed as “evidence?” It is imperative that policy-driven decisions be based on sound science and data gathering.

• The Guidelines acknowledge the complexity of food systems (paragraph 20). However, per the HLPE Report of Food Security and Nutrition (Oct 2017), food systems encompass a broad set of activities including the production, processing, distribution, preparation and consumption of foods; the Guidelines barely address a number of these issues, focusing primarily on the consumption of foods at the individual level. We encourage the committee to expand the coverage of these important issues.
• In paragraph 24, innovation, technology and infrastructure are listed as three main drivers that will aid in implementation of the Guidelines. All these functions require financing. Who will pay for this? Consideration of the financial aspects of the Guidelines and how governments as well as the private sector can be integral seem warranted.
• The definition of a healthy diet (paragraph 32) has a Western/developed world slant:
  
  - Such guidelines have long stressed reduced consumption of dietary fat, sugar, and salt, and more fruits, vegetables and whole grains. Some data support this guidance (though not universally), particularly in Western populations. But what about in countries that for various reasons struggle to produce enough nutrient dense foods to satisfy their population demands, and those that import agricultural products, making animal proteins, fruits, vegetables, etc. less available or less affordable? What about people in hot regions who perspire more and may benefit from an increase in electrolytes (sodium, potassium) in their diet, or people who receive inadequate calories to support their energy needs who can benefit from added fat (and, yes, maybe some added sugar as well) in their diets? In this regard, more and more health experts are stressing the need for healthy dietary patterns, rather than focusing on individual nutrient targets.

(Reference: Astrup, A et al. BMJ 2019;366:4137 doi: 10.1136/bmj.l4137 (Published 3 July 2019)

• It is understood that these Guidelines are meant to be somewhat general and cannot cover the specific needs of individual demographic groups. However, by “laying down a marker” as to what constitutes a healthy diet, the Guidelines do not fully acknowledge the diversity of needs of people around the world based on economics, availability, lifestyle and cultural norms. Ideally, the Guidelines will allow for and encourage the definition of “healthy diets” to include countries’ own national dietary guidelines instead of solely being defined by a narrow set of indicators.
• The document largely omits the need for potable drinking water/fluids globally. The committee highlights daily needs for energy, vitamins, and minerals. But in many regions, one of the most pressing nutritional need is adequate, safe, fluid intake. Beverages such as fluid milk can serve numerous nutritional needs (energy, fluids, vitamins, minerals, protein) and should be acknowledged in the document.

3. In consideration of the policy areas identified in Chapter 3 and the enabling factors suggested in paragraph 41 of the Zero Draft, what policy entry points should be covered in Chapter 3, taking into account the need to foster policy coherence and address policy fragmentation?

• The three primary entry points: supply chains, food environments, and consumer behavior seem all-encompassing. However, the factors outlined to help improve nutrition should be more balanced; there seems to be an undercurrent that favors plant-based rather than animal-based agriculture. For example, in paragraph H (Food Supply Chains), the document reads as follows:
• “Investment in research and innovation for commercial development of nutrient-dense foods and crops, such as fruits, vegetables and legumes, and bio fortified crops, could lead to improvements in productivity enabling better access to healthy diets and nutrition while minimizing their environmental impact.”
• Research on animal production practices is clearly omitted. Why is that? If developing nutrient-dense diets is truly the aim here, more research on livestock production seems warranted as well.
• The document also neglects to consider the important role of livestock in a circular economy. In many countries Livestock provide draft power and are the primary source of fertilizer for crop production. Livestock also consume the byproducts from crop production and from the processing of plant produce for human edible foods. Additionally, livestock can graze and consume grass, straw and other biomass from marginal lands which is inedible by humans and as such convert this to highly nutritious human edible food stuffs.
• While the document does mention that diverse food production (animal and plant) can serve as a hedge against global disasters (drought, famine, conflict, etc.), it could more definitively discuss the resilience of livestock against storms, floods, etc. While severe weather can potentially wipe out a crop for a season or longer, animals can be moved to shelter, fed alternative feed, etc., and better withstand climatic hazards that can devastate crops. Further, in times of conflict livestock are mobile and can be moved with their owners.
• Finally, seeking ways to incentivize farmers to adopt new innovations and technologies should be highlighted as a means of increasing productivity and promoting more sustainable food production. 

4. Can you provide specific examples of new policies, interventions, initiatives, alliances and institutional arrangements which should be considered, as well as challenges, constraints, and trade-offs relevant to the three constituent elements of food systems presented in Chapter 3? In your view, what would the “ideal” food system look like, and what targets/metrics can help guide policymaking?

• Encouraging an environment where all stakeholders, including farmers, the private sector, government, and academia have a seat at the policy table to assist in the development of a nation’s guidelines will help to strengthen the final product in most cases.
• Enhancing outreach and extension services to farmers, providing them with information and access to innovative production techniques and education about best practices, will enable farmers to improve yield and the environmental and economic sustainability of their farms.
• More public/private initiatives should be considered. Engaging industry as a part of the solution rather than viewing it as a part of the problem would spur more investments in research and technology, among other things, and hasten progress.
• Seeking alliances between government agriculture departments, universities, and industry can provide opportunities for more, larger grants to students and faculty to conduct targeted research on healthy crop and livestock production. Some programs like this do exist, but not enough.
• Alliances with companies working on technological solutions to global health problems should be considered. Local solutions to various food production-related issues is invaluable, but an acknowledgement that high tech, futuristic solutions are and can be developed to solved large scale undernutrition problems should be sought as well.
• Encourage collaboration globally among policy makers by proposing not only set topics for guidelines to consider but also set goals for these guidelines to achieve.

5. How would these Voluntary Guidelines be most useful for different stakeholders, especially at national and regional levels, once endorsed by CFS?

The document can more clearly highlight the complexity of the global food system, and the potential for unintended consequences when we generate policy changes without a complete understanding of the resultant outcomes.

For example,

• In a nutritionally challenged community which depends on animal protein sources, what would the consequences be if we enact guidelines that would scale back such high-quality protein and replace it with a lower quality source derived from plants?
• What would replace staple foods like potatoes in countries like Peru with a rich heritage of tuber consumption?
• What are the long-term consequences (good and bad) of growing crops organically in regions that have traditionally used pesticides?

Every action with respect to global nutrition change can produce another, often unforeseen or unintended outcome. We need to think these issues through carefully before enacting sweeping policy changes. Ideally, countries will make these trade-off decisions based on regional and population relevant science-based information.

Lastly, governments should be encouraged to monitor and measure the impact of voluntary guideline implementation to ensure they deliver intended outcomes, and not produce unintended consequences