Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

First of all, we would like to thank the HLPE-FSN for sharing the V0 Draft and for the possibility to comment.

Hereby we attach the official comments by Hungary.

Please allow me to start by thanking you for this quite comprehensive document. 

With regard to providing feedback in this public consultation process for the HLPE report on reducing inequalities for FSN, please find attached a series of comments and suggestions from the European Commission (DG INTPA).

Congratulations on the work so far, and looking forward to the next step in the procedure.

Here: GER position on the e-consultation on the V0 draft of the report

General remarks

 We thank the CFS and HLPE for submitting the above-mentioned V0 draft and for the possibility to provide input at an early stage. We welcome the fact that they address the important issue of reducing inequalities in food systems, particularly in the context of food security and nutrition (FSN).

 Among other things, high inequality limits development opportunities and the realization of human rights. The current multiple crises, including climate change and unprecedented biodiversity loss, are exacerbating the situation.

 Reducing inequality is one of the key tasks we face. The HLPE Report and the CFS Policy Recommendations on reducing inequalities for FSN will contribute to the achievement of Sustainable Development Goals (SDGs) 2 and 10 as well as the realization of the right to adequate food.

 The report should elaborate more clearly how the 2030 Agenda and especially the holistic approach require inequalities and inequities to be addressed.

 With a view to existing literature and research, it could help to highlight more often what evidence is generally accepted and what is more controversial.

Remarks on the individual chapters of the report

Chapter 1

 This chapter sets the scene well for engaging with equality and equity in food systems. The conceptual framework is well developed in order to capture the drivers of inequality and inequity in food systems for achieving FSN at different levels.

 On p. 9, the scope could be broader and it should not just be the 14th Amendment of the US constitution that is mentioned as an example for (racial) equality, as many states globally have similar clauses. This should be specified in the text.

 This is also the case on p. 17, when “food lobbies of the US” are named as an example for power asymmetries - many states, including the US, are experiencing this.

 Figure 1.2. (p. 26) is generally helpful in guiding readers through the conceptual framework but the readability should be improved (too small, low resolution).

 A major part of the proposed framework describes the current state. In order to provide more practical guidance to policymakers and other stakeholders on how to reduce inequalities for FSN, the descriptive chapters (Chapters 2, 3 and 4) could be shortened considerably. 

 A smaller part of the report addresses actions. To increase the practical value of the framework, a single chapter on “actions and recommendations” would be more useful than the distinction between Chapter 5 (Actions to reduce inequalities in food and other systems to improve FSN) and 6 (Transformations necessary for positive structural change to reduce inequalities in FSN).

 In addition, reference is made to a Chapter 7; it seems, however, to have been omitted. This chapter would be of interest to us. The envisaged recommendations should be directed at the global governance level to identify pathways for reducing inequality and inequity in food systems collectively.

 Finally, we welcome the fact that this introductory chapter recognizes climate change as an important additional layer of threat that particularly affects vulnerable communities. We would welcome additional general language to describe global biodiversity loss as a threat both to FSN as climate change (twin crises) - especially after the adoption of the Kunming-Montreal Global Biodiversity Framework. Biodiversity is mentioned in other chapters throughout the text but not in this important introductory chapter.

Chapter 2

 This chapter provides a sound analysis of inequalities in FSN outcomes across and within countries and regions.

Chapter 3

 We welcome the fact that the focus of Chapter 3 is broadened and that the effects are considered in a food systems approach. However, this chapter could be improved with regard to trade issues. Overall, a more balanced and differentiated point of view would provide valuable insights for reducing inequalities.

 It would be interesting to hear about the role of women in informal cross-border trade (e.g. p. 57).

 Furthermore, we would be interested to see an explanation of the comparison with self-sufficiency on p. 59. In (ii), (iii) and (iv) the comparison with self-sufficiency is not explicitly mentioned and it should thus not be mentioned in (i).

 The remarks on economic specializations should be more precise (i.e. specialization according to comparative advantages; p. 60).

 Moreover, important aspects of facilitating trade for certain groups are missing, including governmental trade facilitation initiatives by WTO and others and outgrower schemes. This would help to get a balanced overview of the current situation.

 This also applies to the examples given of certain groups that are disadvantaged by trade (p. 61 and following). It would be more constructive to also give examples where marginalized groups could benefit from trade and trade liberalisation, by clearly pointing out the conditions under which benefits are possible.

 Furthermore, the section on “Power and policy space for developing FSN-relevant policies” should be carefully reviewed with regard to the WTO rules that are mentioned. It may be helpful to not only refer to the TBT agreement, but also to trade costs in general.

 The line of thought about the “regulatory chill” should be explained more clearly by presenting more details and being more specific. For example, regulatory traditions would need to be mentioned as an additional factor. It would be helpful to name the relevant factors that cause the “regulatory chill”, while making reference to domestic policy-making. It would be interesting to see the recent evidence base as well as more and especially positive examples.

 Finally, with a view to reproductive systems and time use (p. 72), the text should look beyond agriculture, in particular towards women’s and men’s contributions to care work and other activities.

Chapter 4

 The chapter’s section on “Global political architecture, geopolitics and food regimes” (p. 82 and following) should be carefully reviewed and be made more specific with regard to the WTO negotiations, especially the Doha Development Agenda round.

 Moreover, relevant agreements from the WTO Ministerial Conferences (e.g. the Trade Facilitation Agreement (TFA) adopted at the Bali Ministerial Conference in 2013) as well as Special and Differential Treatment (SDT) and measures to support developing countries in engaging in negotiations and trade should be added.

 Furthermore, the role of trade in inputs, and thus trade of technology, is missing in the chapter.

 The chapter’s section on the conflict between nature conservation and land rights correctly identifies possible trade-offs relating to social inequalities. However, given the newly adopted Kunming-Montreal Global Biodiversity Framework, this section must be reviewed to adequately reflect the international agreement on the 30x30 target (target 3), which includes the important role of Indigenous Peoples and Local Communities (IPLCs). Furthermore, the report could also elaborate on how conflicts between nature conservation and land rights should be or have been successfully resolved or managed.

 Finally, the cited source “Wittmann et al, 2010” is missing in the list of sources and should be added. Overall, the statement on the influence of the seed industry on movements for the rights of local populations should be revised as it seems sweeping. In this regard, the OECD report on “Concentration in Seed Markets – potential effects and policy responses” could be consulted. 

Chapter 5

 As an action to address inequalities, partnerships and the exchange of accumulated information are important tools. As stated in the previous chapters, the contexts in which inequalities arise can vary widely. Nevertheless, the lessons learned by one actor can help another to move forward, and vice versa. This should be seen against the backdrop of strong partnerships and cooperation as laid out in SDG 17.

 We welcome the approach of developing inclusive farmers’ organizations. This should be considered as a broad concept, involving stakeholders throughout the value chain and focusing on living conditions in rural areas. The governance level could assist in setting up these organizations and implement ways for political consulting in multi-stakeholder processes.

 While food safety is mentioned and the report acknowledges that it “has not historically been well-integrated into food system and food security research and action”, little effort is made to overcome this issue in the present framework. Food safety is linked to the food security dimensions of availability, utilization and stability. Yet this is currently only highlighted under “utilization” on p. 68.

 We suggest considering whether the establishment/strengthening of food control systems could be embedded in the “actions” part of the framework (currently chapters 5 and 6). Such action would constitute a concrete structural change to reduce inequalities in some countries.

 Furthermore, we note that a recent publication by FAO offers a concrete case study that underlines the links between food safety and food security (https://www.fao.org/3/cb8715en/cb8715en.pdf).

 Finally, the aspect of consumer behavior (cf. Figure 1.2, p. 26) is underrepresented in this chapter and could be further highlighted, e.g. with a view to nutrition knowledge.

Chapter 6

 We welcome and support the fact that this chapter emphasizes the human right to adequate food and rights-based approaches for the transformation of food systems.

 In this regard, we particularly welcome the focus on marginalized groups and their participation, as well as the sections on social protection and universal access to services and infrastructure. It is important to highlight the multisectoral nature of the required transformative actions and that this is one of the key challenges in making progress in the transformation of food systems.

 We emphasize that sustainable food systems must be equitable and inclusive and, without exception, based on a human rights approach. Safeguarding all human rights is an integral and indispensable element of sustainable development worldwide and consequently one of Germany’s key concerns. 

 In addition, we underline the challenges listed that more equality data and research is needed to gain further insights and to identify global connections

Recommendations from the International Collective in Support of Fishworkers (ICSF) www.icsf.net

Question 1

• Considering the importance of the fisheries sector to food security and nutrition globally, it is important that this framework also be able to provide practical guidance to policymakers working on fisheries, rural and social development. Information and examples of social inequality in the context of fisheries – particularly within the small-scale sector – should be included in the framework, especially in relation to intersections with gender, ethnicity, class, caste, age, etc.). Such examples would be especially useful to include on pages 12-17 of the draft report.
  • The accompanying list of recent ICSF resources on fisheries and food security and nutrition provides numerous concrete examples which can be drawn upon in the report.  

• Specific reference should be made to the international Guidelines for Securing Sustainable Small-Scale Fisheries in the Context of Food Security and Poverty Eradication (SSF Guidelines) and their core principles. These Guidelines are the cornerstone of equitable and sustainable small-scale fisheries governance globally. See: https://www.fao.org/voluntary-guidelines-small-scale-fisheries/guidelines/en/
• The framework should also make a connection between small-scale fisheries and the human right to adequate food, such as through exploring synergies in the implementation of the SSF Guidelines and the Right to Food Guidelines. See:  http://www.fao.org/3/cb4939en/cb4939en.pdf 

• The framework should make more reference to gender-equitable food production systems, such as in the context of small-scale fisheries governance and development. Insights can be drawn from this handbook: https://www.fao.org/voluntary-guidelines-small-scale-fisheries/resources/detail/en/c/1095418/

Questions 4, 6 and 7

• Chapter 2 deals with inequalities in food security and nutrition across regions and groups. When discussing such inequalities, it is recommended to also explore and highlight inequalities within and between specific food producer groups across the food chain – including agriculture, fisheries, livestock, aquaculture and forestry. Inequalities and the obstacles these create are very different between and within these diverse groups, and cannot be adequately addressed without a clearer understanding of their causes and consequences.

• In Chapter 2, no distinction is made between different types of animal-based protein, while fish has a very different nutritional value than red meat, and provides key long-chain fatty acids that are crucial for the health of pregnant and lactating women, and the mental and physical development of young children. Data should be included on the nutritional importance of fish. Key data can be found here:   https://www.worldfishcenter.org/strategy-2030/index.html#bigfacts

• • Example to include: 800 million people globally (of which 50% are women), depend on small-scale fisheries and aquaculture for their livelihoods.

• Chapter 3 deals with inequalities in food and other systems and FSN implications. This chapter has a strong focus on inequalities in agricultural food systems, however inequalities in aquatic food systems (including fisheries and aquaculture) are not included. Such inequalities should be highlighted, in particular regarding: tenure rights; access to markets and trade; access to information and technology; finance opportunities; participation in decision-making spaces and processes; opportunities to engage in decent work; and access to social development, social security and safety.

• Include some of the key findings from FAO’s Illuminating Hidden Harvests (IHH) report on small-scale fisheries and sustainable development (available here: https://www.fao.org/3/cc0386en/cc0386en.pdf ). Examples include:

• Small-scale fisheries account for at least 40 percent of global fisheries catch.

• 90 percent of the people employed along capture fisheries value chains operate in small-scale fisheries.
• 45 million women participate in small-scale fisheries, including for subsistence purposes.
• Small fish and midwater fish are especially nutritious and found abundantly in small-scale fisheries landings.
• Co-management is likely implemented for about 20 percent of the catch from small-scale fisheries.
• For each fisher in the small-scale sector, at least four other people are engaged in related land-based activities, such as the preparation of equipment, fish processing, and marketing.
• As a family-based activity, fishing makes a direct contribution to household food security, where women play a particularly important role – both as the link with markets and as the household provider of food. These roles are of course in addition to their reproductive and caregiving roles.

• Chapter 4 deals with the systemic drivers and root causes of FSN inequalities. On page 79, there is a discussion on fisheries policy and investment. In this section, more information should be included on small-scale fisheries and the impact of global trends such as blue economy / blue growth and conservation agendas. Although the international community has endorsed the SSF Guidelines, their widespread implementation still faces major obstacles.  The growing pressures of the blue economy and conservation, including the rapid expansion of aquaculture, wind farms, marine protected areas and the 30x30 agenda, deep sea mining, etc., pose multiple threats to small-scale fisheries – particularly at the level of tenure rights, and access to resources and markets. Climate change and global environmental policies too are impacting small-scale fisheries in a major way. The framework should include references to how the blue economy, conservation agendas, environmental and climate politics impact small-scale fisheries, including in relation to gender inequality and access to resources, markets and fishing areas. Examples can be found in this collective statement: https://www.cffacape.org/publications-blog/joint-statement-financing-the-30x-30-agenda-for-the-oceans-debt-for-nature-swaps-should-be-rejected

We are also including a list of recent ICSF resources (reports, articles and films) on food security and nutrition in the context of fisheries which you may wish to draw examples from for your report. Please see it in the attachment. 

We thank the HLPE-FSN for sharing the VO Draft and for the possibility to comment.

We support the use of the definition of food security, including agency and sustainability. These two dimensions are particularly important in the context of inequality, poverty and food insecurity, as well as for long-term solutions based on comprehensive and transformational approaches. The guiding principle of Leave no one behind is central for this report. Switzerland welcomes the human rights based approach, including the focus on the transformative action with regard to the human right to food. Furthermore we suggest to shorten Chapter 1 and to put some of the information into an annex.

Christina Blank, Permanent Mission of Switzerland to the UN Organisations in Rome

On behalf of We Effect,

We Effect, a cooperative, Swedish development cooperation organisation, is focusing its contribution on two thematic areas: environment & climate change and gender equality.

Environment and climate change

• Pollution and biodiversity loss as drivers of inequalities in FSN outcomes and its link to climate change is largely missing. Biodiversity in general requires more attention in the report as it is the basis for food production. Pollution, biodiversity loss and climate change must be viewed together as they are reinforcing and interlinked trends. For example, regarding pollution - when talking about trade (esp. global trade), this has a polluting aspect, especially emissions which we know are contributing to climate change, having unequal impacts on different groups and widens inequalities. For instance, as it leads to lost harvests with droughts and floods increasing in frequency and magnitude (and the droughts and floods harm biodiversity), where usually smallholder farmers are more vulnerable than large food producers. 
• The paper often refers to caste - but it could also mention clans and tribes to make it more globally appropriate.
• Disasters and natural hazards as drivers of inequalities in FSN outcomes is largely missing and deserve more attention - there are wide differences among groups and individuals’ capacities to cope, absorb, adapt, and transform in the face of shocks and stresses. These in turn influence their FSN outcomes, as their livelihoods, crops and harvests are damaged, as well as the economic impacts which affects the ability to access healthy and nutritious food and safe and clean water.
• Food waste, vegetarian/vegan food trends and their influence on FSN outcomes is missing - the link between emissions and food more could be highlighted more.
• P.50 when referring to availability of land and scale of production, this should mention biodiversity loss as a negative consequence of monocultures as this could also harm food diversity as well as ability to grow food.
• The climate section, p.85-87, could be strengthened. There is no explicit mention of gender and other intersections, except poverty. It also does not reflect on the vulnerability of agriculture in general and smallholder farmers to climate change and their relatively limited capacity to adapt and manage changes vis-a-vis large corporations. It is also missing how climate change alter the types of crops that farmers can grow and harvest as well as how it alters the seasons of harvest - which all affect availability, access, utilisation, stability, sustainability, and agency. It should also mention that climate change can alter the nutritional value of certain crops. It should also mention that very little of climate finance is targeting agriculture, and smallholder farmers in particular (less than 2%) - which is deepening the already existing inequalities. Climate change is also affecting soil fertility which is making it more difficult to make a living as a farmer and reach FSN outcomes. Climate change, for example, is increasing the risk of cyclones and hurricanes, and these tend to cause saltwater and/or sand intrusion in farmland making it impossible to grow food where it has been traditionally grown (unless you have a lot of money and can recover the land--> increasing inequalities).  

Gender equality

• Agency should reflect collective agency and not merely individual agency, especially for women, as change and claims occurs when they mobilise and become stronger together. Research has proven that women rights organisation/mobilisation is the main factor for advancing gender equal policies which is a prerequisite for advancing gender equality within a society.
• There is a lack in the draft to fully recognising gender-based violence, including economic violence and simply not sexual harassment and exploitation, as part of the deep-rooted discrimination towards various gender identities and the interlinkage to all aspects of the value chain and in relation to all six dimensions of FNS.
• Addressing social norms also need to reflect gender-based violence risk mitigation approaches to materialise positive change, as changes in power dynamics may increase the prevalence of gender-based violence. Also, increase focus on that the programming itself is not reenforcing gender-based violence.
• The report tends to lean towards a binary on take – and subsequently lack addressing how to strategise bringing sexual orientation and gender identity (SOGI) on board in a context where this is more of a risk living as a SOGI person.
• The concept gender needs to move away from drawing a parallel to gender and women in the report – and recognise how the gender power dynamics between gender roles within societies (non-binary) plays out and create inequalities.  
• Universal protection needs to be problematised as it tends to be more about poverty reduction that ensure solid governmental structures for care work and other types of social protection.

With kind regards,

Hanna Sjölund

Head of Policy

We Effect

The Private Sector Mechanism would like to thank the HLPE and CFS for this opportunity and their consideration of the present input on the V0 of the Report for purposes of improving the final report.

We look forward to participating in the CFS Reducing Inequalities Workstream in collaboration with all CFS multi-stakeholders to promote effective CFS outputs and outcomes. Please find attached input on the V0 draft and concrete suggestions for improvement.

Sincerely

Secretariat, Private Sector Mechanism of the Committee on World Food Security

The report represents an impressive, comprehensive, and nuanced account of the way in which socio-economic inequalities interact with food security and nutrition. It is undoubtedly successful at conveying both the vastness and the specificity of the problems that inequalities pose for the improvement of global food and nutrition security. The effort is commendable, necessary, and welcomed. With regards to some of the feedback questions, these are our inputs:

1) The Framework is a good encapsulation of the mechanism underlying the impact of inequities and inequalities on the six dimensions of food security. If the authors of the report might seek to expand on it and increase its descriptiveness, my suggestion would be to distinguish more explicitly which form of inequality impacts which dimension of FSN, and how. For instance, gender-based discrimination has several ways in which it can be detrimental to FSN, and these pathways go through the different dimensions of FSN. Sexism means reduced female-led agricultural and economic activity (availability), unequal access to food, suboptimal food choices because of lack of educational resources (utilisation), and reduced human capital development (stability), etc. These are discussed in Chapter 2 of the report, but that could benefit from further formalisation in terms of clarity.

7) The report covers a lot of ground, managing to both provide a clear description of its individual pieces and an insightful analysis of how they interrelate. One aspect that could be expanded is double- and triple-burdens of malnutrition (page 34), due to its increasing relevance (and incidence) in the context of contemporary global development trends. Perhaps its definition can be expanded, and issues related to it better represented throughout the rest of the report (especially in the action section).

Similarly, the increasing relevance of double-duty actions is briefly mentioned in the final conclusion, alongside an introduction of multiple-duty actions. As the importance of these concepts is emphasised and common use of the terms sparse, we believe the report could benefit from an expansion of these ideas in the actions section. Further, the term ‘syndemic’ is briefly mentioned, yet could use a slightly more in-depth explanation before being mentioned in passing in the conclusion.

Overall, the report addresses issues of fundamental importance, and it does so clearly and effectively. Our most sincere congratulations, and thanks, for the impressive and insightful analysis.

On behalf of Andrea Moreschi and Caitlin Mahoney, at WFP Social Protection.

On behalf of Global Dairy Platform:

In response to the request for feedback on V0 draft of the HLPE report on Reducing inequalities for food security and nutrition, we respectfully submit the following:

This report will make an important contribution to the work of the CFS. It is good that the report recognizes that food security and Nutrition (FSN) is context-specific and requires diverse solutions operating at a range of scales. The report examines agri-food systems generally, which assumes uniformity of impact across all forms of agriculture. However, specific agricultural systems may have very different impacts than others (i.e., dairy, soybean, chickens, lamb, corn, etc.). Although an in-depth discussion on differing effects of various foods and food production systems on FSN in the context of inequalities and inequities may not be suitable for this report, it should at least be recognized with some discussion or examples. There is some recognition of the impact that livestock may have on improving FSN and reducing some inequities. The role of dairying in providing FSN and reducing inequalities may provide a good example to highlight. Dairy is relevant, according to the FAO (http://www.fao.org/3/cb2992en/cb2992en.pdf), there are approximately 133 million dairy farms globally, with 600 million people living on these farms deriving their livelihood from dairying. The livelihood of an additional 400 million people are supported by the jobs created up and downstream from the farm. There are approximately 240 million jobs created by the dairy sector. Of the 133 million farms, 37 million are female headed, with 80 million women engaged in dairy farming to some extent. An FAO report on Dairy Developments Impact on Poverty Reduction (https://www.fao.org/3/ca2185en/CA2185EN.pdf) provides evidence of the relationship between dairy development and improvements in human welfare. This report showed that dairy provides a pathway out of poverty for individuals, families, and communities. Women empowered by dairy have increased income and influence.

Another FAO report, Dairy’s Impact on Reducing Global Hunger: research summary (https://www.fao.org/publications/card/en/c/CB1198EN/), provides quantitative evidence on the positive impact dairying can have on eradicating hunger globally. It was found that increasing household production of dairy increased dairy consumption which was associated with child linear growth and reduced stunting.

Dairy foods are nutrient rich and intake has been associated with reduced risk of several chronic diseases (diabetes, high blood pressure, stroke, osteoporosis/fractures, over weight). It has been shown that adequate dairy intake as part of a healthy diet can reduce health care costs (Scrafford et al. Nutrients 2020, 12, 233; doi:10.3390/nu12010233).

The impact of dairying is a good example of how production and consumption of a specific food type can impact FSN and improve inequalities.

Additional Comments on the report:

In this report, it seems some inequality issues (i.e., gender) may have a larger impact in LMIC, I believe it would strengthen this report if it was made clearer when the impact of this issue (or others) is occurring mainly in LMIC or HIC as was done with stigma related to obesity (mainly wealthy countries)

In chapter 2 it would be good to reference Ty Beal paper recently published in Lancet (Micronutrient deficiencies among preschool-aged children and women of reproductive age worldwide: a pooled analysis of individual-level data from population-representative surveys https://www.thelancet.com/journals/langlo/article/PIIS2214-109X(22)00367-9/fulltext#.Y7XuwoJe6bs.twitter), as it provides the most recent data on micronutrient deficiencies globally and shows HICs have more deficiencies than previously thought.

In chapter 3, pg. 62., it states: “A high proportion of such challenges in the health and nutrition arena related to aspects such as labelling, and regulatory chill compromises nutritional quality of diets and the utilization dimension of food security.” However, it should be recognized that the data on the value of nutrition and FOP labeling in changing dietary patterns seems to be small and the data is inconsistent ( Are Front-of-Pack Nutrition Labels Influencing Food Choices and Purchases, Diet Quality, and Modeled Health Outcomes? A Narrative Review of Four Systems https://www.mdpi.com/2043952 #mdpinutrients via @Nutrients_MDPI Dec. 2022).

Gregory D. Miller, Ph.D., F.A.S.N.

Global Chief Science Officer, National Dairy Council

Executive Vice President, Dairy Management, Inc.

Nutritional Security, Sector Lead, Global Dairy Platform

Solutions from the Land is pleased to provide the following response to the invitation to review, comment and make recommendations for strengthening CFS HLPE Vo Draft Report on reducing inequalities for food security and nutrition. The mission of Solutions from the Land, a farmer-led organization, is to inspire, mobilize and equip agricultural, forestry and fishery leaders to advance pragmatic, proven and innovative agricultural solutions that benefit producers, the public and the planet in a new era where sustainably managed farms, ranches, fisheries and forests are at the forefront of resolving food system, food and nutrition security, energy, environmental and climate challenges to concurrently achieve global sustainable development goals (SDGs).

Ernie Shea, President

Solutions from the Land