Forum global sur la sécurité alimentaire et la nutrition (Forum FSN)

Dear HLPE Secretariat and Experts,

Thank you for the opportunity to contribute reflections on the V0 draft report on reducing inequalities for food security and nutrition. Please find attached a set of responses and recommendations from SwedBio, a programme on biodiversity and equitable development at Stockholm Resilience Centre. 

We appreciate the opportunity to provide input and welcome this progressive and comprehensive report and its emphasis on agency, intersectionality and power relations, and transformative change through human rights-based approaches for the realisation of the right to food for all.

Our reflections below respond primarily to the consultation questions 2 (does the V0 draft sufficiently cover the implications of broadening the definition of food security with regard to inequalities), 4 (gaps in the literature and data referred to), 7 (issues concerning inequalities in FSN or within food systems that have not been sufficiently covered).

In our view, the framing of the issues in the early chapters could be more coherent with the systemic drivers and actions described later in the report. The coherence and logic of the report would be improved if key cross-cutting concepts and drivers related to inequalities in food systems for food security and nutrition outcomes were more clearly integrated throughout the report and introduced in the initial chapters when framing the issue. This concerns issues such as:

- Human Rights as a general framework: a definition could be added to Table 1 to clarify as a foundation framework for addressing inequalities in FSN. The explanation should connect and emphasise the framework in line with Chapter 6, where the relation of rights perspective, FSN, and equity are more detailed. Alternatively, an opening paragraph clarifying human rights as a general framework, as stated in HLPE 14. This would pave the way for comprehension of the foundation to tackle (reducing) inequalities.

- The Right to a clean, healthy and sustainable environment is recognized as a fundamental human right and part of the international legal framework (UNGA, 2022 https://digitallibrary.un.org/record/3983329?ln=en). Human rights and a healthy planet are mutually dependent. Therefore, it is vital to acknowledge the R2HE in the debate concerning inequalities and FSN. We observe an increase in biodiversity loss, environmental degradation, and climate change, which impact the livelihoods of a large number of people and particularly the ones in vulnerability, exacerbating inequalities and causing food insecurities, among other issues. The realization of the Right to a clean, healthy and sustainable environment is fundamental to improving environmental quality and governance, which are preconditions for healthy and sustainable food production and livelihoods. See the Right to a healthy environment: good practices report of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment https://documents-ddsny.un.org/doc/UNDOC/GEN/G19/355/14/PDF/G1935514.pd… and the Right to a Healthy Environment – information Note https://www.ohchr.org/sites/default/files/documents/issues/climatechange/informationmaterials/2023-01-06/r2heinfofinalweb.pdf

- Role of nature and biodiversity in relation to multidimensional poverty, human well-being, food security and nutrition: In line with the recommendation above on the R2HE, the report could more clearly outline the interdependencies between healthy ecosystems and FSN and inequalities in this realm. Diverse and productive terrestrial and marine ecosystems, both wild and managed, provide a foundation for livelihoods, food and nutrition security and rich and varied biodiversity, both wild and cultivated, contributes to reducing malnutrition and sustaining a more nutritious diet. Consequently, the main drivers of ecosystem degradation, such as land use change, overexploitation of species, and climate change, also undermine rights to sustainable and equitable development and food security and nutrition. This is particularly true for marginalised and vulnerable people living in poverty. This was evidenced in chapter 2.1 on Status and trends - Drivers of change in the IPBES Global Assessment report, 2019.

These interdependencies could be made more clear for example by making the connection between the SDGs and food security and nutrition, e.g. as illustrated by Stockholm Resilience Centre (https://www.stockholmresilience.org/research/research-news/2016-06-14-t…) outlining how all SDGs are directly or indirectly connected to sustainable and healthy food, with the biosphere (and SDGs 6, 13, 14 and 15) providing the foundation for food security (SDG 2), but is undermined e.g. by overfishing (SDG 14), deforestation and unsustainable land use (SDG 15), freshwater shortage (SDG 6), and the climate crisis (SDG 13). These interactions and the foundational role of the biosphere-related SDGs are crucial also for SDG 1 on poverty.

Interventions that ignore nature and culture can reinforce poverty (Lade et al., 2017). The concept of poverty traps as situations characterised by persistent, undesirable and reinforcing dynamics (Haider et al., 2018) is increasingly being used to understand the relationship between persistent poverty and environmental sustainability (Lade et al., 2017). A lack of social-ecological interactions in a social-ecological system can contribute to a poverty trap. For example, a lack of diverse seeds during a drought, can impoverish a farmer (https://www.stockholmresilience.org/research/research-news/2018-01-29-broadening-thedefinition-of-a-povery-trap.html)

It might also be useful for this report to develop in parallel with and consult the IPBES process of developing the nexus and transformative change assessments, which will both provide critical insights on the relationship between biodiversity, food, health, climate change and sustainable development. This would also deepen the synergies across the IPBES knowledge base, including Indigenous and local knowledge, and the HLPE.

Finally, the recently adopted Kunming-Montreal Global Biodiversity Framework under the Convention on Biological Diversity is a milestone toward living in harmony with nature, seeking to stop and reverse biodiversity loss. As highlighted previously, biodiversity is essential for economic and social well-being, food security and safety, and human health. The Global Strategic Framework recently adopted, as well as the supplementary agreements to the CBD, the Cartagena Protocol on Biosafety and the Nagoya Protocol on Access and Benefit-Sharing might be helpful to pay attention to. Linking the report analysis and proposed actions for reducing inequalities in FSN with the expected outcomes, targets, and goals of the Biodiversity Convention can provide more adherence of policymakers and linked work towards a more equal and sustainable society in harmony with nature. It is important to highlight Target 10 in the newly adopted Framework, which foresees ensuring sustainable use of biodiversity through biodiversity-friendly practices which contribute to food security. See COP-15 Decision documents, particularly CBD/COP/DEC/15/4 Kunming-Montreal Global Biodiversity Framework https://www.cbd.int/conferences/2021-2022/cop-15/documents

These reflections regarding the decisions on the Convention of Biological Diversity would be suitable for Chapter 4, where the root causes for FSN inequalities are presented, and Chapter 5, where the actions to reduce inequalities are presented.

- Food sovereignty is only introduced in Chapter 6, however as a central concept related to inequalities in food systems and closely related to the aspect of agency in the broadened definition of food security it should preferably be discussed and defined already in Chapter 1, including e.g. in table 1. As elaborated in the HLPE 14 report, the food sovereignty concept seeks to ensure more equitable trade relationships; land reform; protection of intellectual and indigenous land rights; agroecological production practices; gender equity and participation in defining policies. Aspects which are all central for addressing inequalities in food systems and widely discussed in the V0 draft.

In addition, we are lacking and would like to see a clearer integration of the following areas in the report:

- The role of aquatic foods (marine and inland) – fish, shellfish, aquatic plants and algae captured or cultivated sustainably and equitably in freshwater and marine ecosystems – play a central role in food and nutrition security for billions of people; they are a cornerstone of the livelihoods, economies, and cultures of many coastal and inland communities. increasingly, studies (such as the EAT Lancet Commision report (https://eatforum.org/eatlancet-commission/eat-lancet-commission-summary…) conclude that aquatic foods must play a key role in the effort to build resilient, sustainable and healthy foods for all. It can contribute to diet-related health challenges – by reducing micronutrient deficiencies, improving heart, brain and eye health, and replacing consumption of less healthy red and processed meats – and be a part of the climate solution. Blue foods also provide much more than protein. Many blue food species are rich in nutrients such as zinc, iron, vitamin A, vitamin B12 and omega 3s. Eating more blue food can help prevent non-communicable diseases and nutrient deficiencies, especially in regions and populations where there are high burdens of malnutrition. With the right management, blue foods can be caught with reduced impacts on biodiversity or grown more sustainably than various terrestrial animal proteins, thus producing lower greenhouse gas emissions and water pollution and using fewer land and water resources. See the Blue Food Assessment report (https://bluefood.earth) and specifically the Environment Performance Paper on Blue Foods (https://bluefood.earth/science/environmental-performance/).

- In particular the role of small-scale artisanal fisheries (SSF) must be considered and highlighted in the report. They play crucial roles in employment, food security, nutrition, livelihoods, culture, and coastal communities well-being. There are major inequalities in aquatic food systems as of today. Overall, fishing communities continue facing the competition of industrial fishing fleets and other blue economy sectors, such as coastal tourism, oil and gas exploitation, struggling to access waters safely, seeing climate change impacting their activities, dying at sea in high numbers, facing challenges in financing and in equipment. For FSN, it is absolutely crucial to increase their recognition, and also create action securing their access to marine resources and markets, as promised by States under Sustainable Development Goal 14.b. In the Blue Call to Action (https://www.cffacape.org/ssfcall-to-action) - a milestone of 2022 and the year of Artisanal Fisheries and Aquaculture (IYAFA), a group of SSF organisations from around the world have come together to raises key aspects to support SSF and thereby, their invaluable contribution to FSN.

It is crucial to reflect on the role of Blue Economy discourses as a solution to food security, but also an 'instrument' that can exacerbate inequalities and directly affect coastal communities. Reference to the FAO Blue Transformation roadmap can support the reflection and recommendations. However, adding small-scale fishers, fisherfolk, and coastal communities' perspectives and reflections on the implications of the Blue Economy to exacerbate inequalities, food insecurity and rights violation is critical. See The People's Tribunal reports http://blueeconomytribunal.org/

One specific action with high potential is that of implementing Exclusive Small Scale Artisanal Fishing zones. There are studies on how to make such zones work: https://www.icsf.net/wpcontent/uploads/2022/10/930.ICSF223_Andhra_Pradesh_Tenure_Right.pdf

As States have recently committed to protect 30% of marine areas by 2030 (target 3 of Montreal agreement), we and many SSF organisations along with us insist that it cannot work if it does not have a human-rights based approach. It will be important to monitor, and valuable additions to this report stating that the 30x30 goal also needs to be achieved in a way that is compatible with SDG14B and other commitments such as the Guidelines to secure sustainable small-scale fisheries.

Connected to the appreciated highlights in the report of Farmers Organisations, we would like the authors not to forget the similarly critical role of Small-Scale Artisanal Fishers Organisations. They are much younger, but are building momentum and capacity. Some studies/articles worth looking into might be: https://doi.org/10.1080/01436597.2017.1416288 “Implicating ‘fisheries justice’ movements in food and climate politics” and “Transnational fishers’ movements: emergence, evolution, and contestation. Maritime Studies 21, 393–410 (2022) https://doi.org/10.1007/s40152-022- 00280-3 by Mills, E.N.

- In general, reference to and inclusion of other food producer constituencies than farmers such as small-scale fishers and pastoralists, could be strengthened throughout the report.

- Importance of collective rights: Collective rights are primarily discussed in relation to land rights, and it can be clarified that collective rights also concerns access rights to forests and fisheries. In particular, for small-scale fisheries, it is crucial to highlight collective tenure rights and have a clear understanding that tenure can be understood as how communities secure access to natural resources, which is key to their livelihood and food security. Access to resources is the base for small-scale fishers’ and fisherfolks' social, economic, and cultural well-being (SSF Guidelines, 2014). We recommend The Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries in the Context of Food Security and Poverty Eradication (SSF Guidelines) as an important reference to the report. It is based on HRBA and was developed in an inclusive, participatory and transparent manner where SSF representatives and their support organisations played a critical role.

- Farmers rights and farmer seed systems: While the V0 draft describes adverse effects of corporate concentration of the global seed system in Chapter 4, it doesn’t recognize the negative impacts of seed policies, plant variety protection and other intellectual property laws, seed marketing laws, variety registration and certification schemes, that are largely designed to meet the needs and interests of the agricultural industry, on the agency of farmers (restricting their right to freely save, use, exchange and sell farm-saved seeds) and its implications for livelihoods and FSN outcomes. See e.g. The Right To Seeds And Intellectual Property Rights.pdf (geneva-academy.ch) For Member States to meet target 2.2 of the SDGs, the Special Rapporteur on the right to food has provided a framework to cohere and advance farmers’, Indigenous peoples’ and workers’ rights and ensure that the world’s seed systems are diverse and safe and fulfil the rights to life and food. This is elaborated in the 2021 thematic report A/HRC/49/43: Seeds, right to life and farmers’ rights - Report of the Special Rapporteur on the right to food, Michael Fakhri: https://www.ohchr.org/en/documents/thematic-reports/ahrc4943-seeds-righ…. These perspectives could be reflected in Chapter 3, e.g. p 50 or p. 51 related to Agency. Supporting Farmers rights and diverse farmer seed systems is important for FSN outcomes (See e.g. Farmer-Led Seed Systems - A Biowatch Briefing Securing food sovereignty in the face of looming ecological and social crises: https://biowatch.org.za/download/farmer-led-seedsystems/?wpdmdl=1958&re…). Also, this case demonstrates how diversification and promotion of local crop varieties has made it possible to shorten the hunger period https://afsafrica.org/wp-content/uploads/2019/11/cereal-banks-guineabis…

– The role of integrated agroecological approaches such as agroforestry for food security and nutrition: As the V0 report also demonstrates, tackling food insecurity and malnutrition requires an increased focus on food quality, which can be achieved for example by promoting diversified production systems such as agroforestry and other agroecological approaches. Scaling up agroforestry can contribute to food and nutrition security, while contributing to more sustainable and resilient food production systems. For cases and policy and practice recommendations on agroecology and agroforestry, see e.g. Agroforestry Network, 2020. Agroforestry, food security and nutrition (https://agroforestrynetwork.org/database_post/agroforestry-food-securit…) and Alliance for Food Sovereignty in Africa https://afsafrica.org/case-studies-agroecology/

- We appreciate the important recognition of valuing diverse knowledge systems in the report. In order for Indigenous and local knowledge and perspectives to be adequately included, valued and also supported in the context of this study, we recommend working with existing approaches, tools and methods and consultation with Indigenous and local knowledge holders be prioritised. Some examples of methods and tools for multi stakeholder engagements and knowledge collaborations (referred to in Chapters 5) based on equity and usefulness for all involved include methods for multi-actor dialogues such as the Multiple Evidence Base approach for connecting across knowledge systems, and the Multi-Actor Dialogue methodology (see links below). Such methodologies are also useful for transformative social learning, conflict resolution and managing power relations in global negotiations. IPBES assessments such as the Global Assessment (2019) as well as resources such as the Local Biodiversity Outlooks, provide important insights into food systems and equitable livelihoods.

○ Multiple Evidence Base approach (MEB) and Free, Prior and Informed Consent: https://swed.bio/stories/a-multiple-evidence-base-approach-for-equity-a… ; https://swed.bio/about/guiding-principles-for-knowledgecollaboration/

○ Multi-actor dialogues: https://swed.bio/focal-areas/approaches/dialogueslearning/multiactor-di… ; https://swed.bio/reports/report/the-biggest-singleopportunity-we-have-is-dialogue/

○ Local Biodiversity Outlooks (LBO) 2: website: https://lbo2.localbiodiversityoutlooks.net/ ; report: https://www.cbd.int/gbo5/local-biodiversity-outlooks-2

Additional comments on specific sections in the report:

- Given the unprecedented environmental crises we are facing, the section on Sustainability in Chapter 3 could be strengthened by broadening the discussion beyond issues of farm size and agricultural production methods to the overall threats to global food system sustainability posed by climate change and biodiversity loss. Issues such as who owns which land, and how productive is the land, should also be considered.

- We welcome Chapter 5, which highlights the need for equity-sensitive policy processes and mentions making nutrition-sensitive policies. Awareness of inequities, inequalities, and nutrition in relevant policies across sectors is critical. In addition, sensitive policies seek to do no harm. However, we would like to suggest drawing lessons from gender-responsive and - sensitive approaches. For a truly transformative change and to reduce inequalities for FSN, we see it is essential also to have responsive policies which recognize and react to inequities and inequalities in implementation. In addition, the section would gain in clarity if the discussion distinguished between the content of the formulated policies vs the process for policy formulation.

- Table 5.1: We lack framing these actions within a HRBA. As an example, instead of ‘Develop farmers’ organisations’ (which has a top-down connotation and raises questions about who develops them) the action should rather be about supporting constituencies’ own social movements and organisations based on their priorities, needs and rights.

- Chapter 6, p. 125-126 Agroecology and food sovereignty: We welcome the clear reference to agroecology as a structural reformation approach and the emphasis on maintaining the holistic perspective of agroecology as a rights-based, justice-centred approach. However, the section could be developed with regards to how to support a just transition to agroecology within food systems, such as supporting social movements in their struggles to advance agroecology and food sovereignty and maintaining the momentum that currently exists (e.g. through ongoing social movement processes such as the Nyeleni process Nyéléni Process - International Planning Committee for Food Sovereignty (IPC)) and by supporting IPLCs in their efforts to maintain and revitalise indigenous and local food systems in support of local food security, food sovereignty and agroecology. Also, reference could be made e.g. to the FAO Scaling-up agroecology initiative or the application of the CFS Policy Recommendations on Agroecological and Other Innovative Approaches and how these initiatives and instruments effectively can contribute to reducing inequalities for FSN outcomes.

Other relevant references:

- Haider, L.J, Boonstra, W.J., Peterson, W.J., Schluter, M., 2018. Traps and sustainable development in rural areas: a review. World Dev., 10, pp. 311-321. Poverty arises from complex interactions between social and environmental factors that are rarely considered in development economics. A more integrated understanding of poverty traps can help to understand the interrelations between persistent poverty and key social and ecological factors, facilitating more effective development interventions.

- Lade, S, Haider, L.J, Engström, G., and Schlüter, M. 2017. Resilience offers escape from trapped thinking on poverty alleviation. Science Advances 3 (5) DOI: 10.1126/sciadv.1603043 The poverty trap concept strongly influences current research and policy on poverty alleviation. Financial or technological inputs intended to “push” the rural poor out of a poverty trap have had many successes but have also failed unexpectedly with serious ecological and social consequences that can reinforce poverty. Resilience thinking can help to (i) understand how these failures emerge from the complex relationships between humans and the ecosystems on which they depend and (ii) navigate diverse poverty alleviation strategies, such as transformative change, that may instead be required.

- FAO. 2022. The State of World Fisheries and Aquaculture 2022. Towards Blue Transformation. Rome, FAO. https://doi.org/10.4060/cc0461en

- https://www.stockholmresilience.org/research/research-news/2021-10-20-w… Main points: 1) Private and public investors must collaborate with coastal communities and support locally led investable products and projects. 2) The ocean economy must be equitable, sustainable and diverse if it is to create true economic potential for Small Island States (SIDS) and those coastal Least Developed Countries (LDCs), which depend on the ocean for their lives and livelihoods, 3) Women hold the key to supporting coastal communities to adapt to the impacts of climate change and other ocean risks

- A Policy and legal diagnostic tool for sustainable small-scale fisheries: In support of the implementation of the voluntary guidelines for securing sustainable small-scale fisheries in the context of food security and poverty eradication: https://www.fao.org/3/cb8234en/cb8234en.pdf

- SSF People-centred methodology to assess the voluntary guidelines for securing sustainable small scale fisheries in the context of food security and poverty eradication https://www.foodsovereignty.org/wp-content/uploads/2022/07/EN_People-centredmonitoring-of-the-implementation-of-the-SSF-Guidelines.pdf

- People-Centred assessment of the Implementation of the Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries: https://www.foodsovereignty.org/wp-content/uploads/2022/10/TNI_report-EN_web.pdf

- IPBES (2019): Global assessment report on biodiversity and ecosystem services of the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services. E. S. Brondizio, J. Settele, S. Díaz, and H. T. Ngo (editors). IPBES secretariat, Bonn, Germany. 1148 pages. https://doi.org/10.5281/zenodo.3831673

- Forest Peoples Programme, International Indigenous Forum on Biodiversity, Indigenous Women’s Biodiversity Network, Centres of Distinction on Indigenous and Local Knowledge and Secretariat of the Convention on Biological Diversity (2020) Local Biodiversity Outlooks 2: The contributions of indigenous peoples and local communities to the implementation of the Strategic Plan for Biodiversity 2011–2020 and to renewing nature and cultures. A complement to the fifth edition of Global Biodiversity Outlook. Moreton-in-Marsh, England: Forest Peoples Programme. Available at: www.localbiodiversityoutlooks.net

This report elaborates on governance transitions towards inclusive decision-making and selfdetermined development, relevant e.g. for the section on addressing agency and power through inclusive governance in Chapter 6, and on revitalization of indigenous and local food systems for local food security, food sovereignty and agroecology as part of a just agricultural transition.

Thanks to FSN team for this open consultation. FSN team prepared a detailed document on a complex subject covering important points. Inputs from professionals with diverse backgrounds and lateral thinking will enrich the contents. Framework based on the Gini coefficients has limitations.

A system’s engineering approach to reduce unequal experiences of FSN would be to slow down the ‘engine of inequity’ such that it halts in a reasonable time. Framework proposed in the draft may take much longer time and may not give the expected outcome. Other approaches like stopping the engine immediately might result in unforeseen consequences.  Suggestion is to identify the determinants leading to unequal experiences of FSN and carry out ‘causal analysis’ to the systemic drivers and the corresponding root causes of FSN inequities. The current framework is very complex, it is better to delink inequities within food system from inequities in other systems.  In the first phase, develop solution(s) to FSN inequities by the year 2030.  In the second phase consider the inequities in other system impacting FSN equity and solve by 2050.

Data collection and report by itself does not provide leads to solution(s). It only adds confusion due to lack of clarification. Pursuing ‘further research needs’ in (PROTEIN AND AMINO ACID REQUIREMENTS IN HUMAN NUTRITION, WHO technical reports series no 935) is necessary. Current report focus should be on ‘scientific progress’ on the globally valid nutrition issues published across the world. Necessary modifications to a member nation should be left to the ‘scientific community’ in the respective member nation. This reduces the possibility of applying dietary guidelines of high income countries in low income countries without understanding the consequences. Local scientific community is best equipped to modify the global guidelines to local and indigenous population (IP) traditions and food preparation practices.  

Consider adding FSN standards or guidelines in the document (SOFI 2022 report on protein in diet does not cover this point). This will help those countries lacking their own standards and guidelines. In general, citizen’s tendency is to follow standards and guidelines laid down by global bodies ratified by local authorities.

 Some of the solutions for addressing FSN inequalities are given below. Documents giving details and references are attached.

1. Exclusion of agriculture from GDP computation pushes the agriculture-based economies into low and low middle income countries. It is necessary to include monetary value of biofuel products like ethanol, biodiesel along with industry produced goods in computing GDP. Participation in cassava fuel ethanol production helps small farmers and landless laborers in reaching GDP per capita level by 2030. Cassava based biofuels will play an important role in poverty elevation and food security issues in low- and low-middle income countries. One tonne of cassava, produces about 350 litres ethanol. Globally, cassava production in 2020 is 303 million tonnes, which gives more than100 billion litre ethanol for blending with fossil fuel.
2. Cassava fuel ethanol is (1) 98% pollution free, (2) biodegradable, (3) renewable, (4) there is no carbon left when ethanol burns in automobiles, (5) ethanol does not cause climate change, and (6) all the by-products in the production of ethanol are edible and non-toxic, providing a very good source for animal feedstock.
3. Cassava is one of the most drought-tolerant crops, can be successfully grown on marginal soils, and gives reasonable yields where many other crops do not grow well. Cassava is well adapted within latitudes 30° north and south of the equator, at elevations between sea level and 2,000 m  above sea level, in equatorial temperatures, with rainfalls from 50 to 5,000 mm annually, and to poor soils with a pH ranging from acidic to alkaline. These conditions are common in certain parts of Africa and South America. Cassava plays a particularly important role in agriculture in developing countries, especially in sub-Saharan Africa, because it does well on poor soils and with low rainfall, and because it is a perennial that can be harvested as required.
4. There are two aspects of cassava that are useful in meeting UN SDG’s.

• If value of fuel ethanol produced from cassava is included in GDP calculation. Cassava fuel ethanol price varies with fossil fuel price in the global trade, synchronising farmer’s economic status with global trends. Contribution of agricultural worker in countries with large percentage of small farmers and landless workers will approach other sector workers leaving no one behind.
• Exchanging fuel ethanol with nutritious food from other countries having surplus nutritious food and in need of fuel ethanol for blending fossil fuel with ethanol will address the food security and nutrition of vulnerable groups in cassava fuel ethanol producing countries.

1. Review the daily intake suggestion of including ‘500gms’ vegetables and fruits is needed. Leaves and stem in vegetables and pulp in fruits are intermediate products in plant growth. Nuts and seeds are the end products that have large quantities of all micronutrients present in vegetables and fruits. Maintaining the current level of vegetables and fruits (200 grams in total) production and consumption is necessary to limit global greenhouse gas emissions and fresh water use. It is necessary to review the emphasis on increasing the global consumption of fruits and vegetables to double by 2050 to meet global nutrition targets. Many nutritionists encourage people to consume plenty of fruit and vegetables, five or more portions a day often being recommended. Vegetables and fruits consumption should be based on palatability and taste of individual, not driven by nutrition.

There is no scientific evidence to support doubling the consumption of vegetables and fruits. Indians mostly vegetarians are also susceptible to Vitamin B12 deficiency. Moreover, there is insufficient evidence to support reduced vegetables and fruits increases health risks. In 14 of the 20 G20 countries, consumption of vegetables is less than 200 grams per day. Health risk due to low vegetables and fruits intake is not in the top 10 of reasons of death in the world and low income countries. It is ranked 8 and 7 for middle income and high income countries respectively.

1. Gender inequality is created by us over the centuries. In several countries, communities have preferred boy over girl right from the childhood. There is significant difference in food energy and protein given to boys and girls in all age groups, nearly 40% more food energy is given to boys at 18 years age. Any sustainable solution to gender inequality should start with gradual reduction of difference in food energy intake of male and female. The food energy intake plays key role in physique, strength and confidence of a female. Male with higher food energy intake will dominate female. Increase in food energy intake by female in the age group 13-30 years will boost the physical strength and confidence levels of female in facing the domestic violence, household and child-care responsibilities, mental health, and economic impacts.
2. Increase soya protein products for human consumption to reduce protein energy malnutrition. Globally, about 98 percent of soybean meal is used as animal feed. Increase human consumption of soybean meal, soy flour and other soybean products from current 2 percent.
3. Integrate long shelf -life food products with fresh local food items to meet special dietary requirement of aged and vulnerable.
4. FAO 2019 statistics indicates that there is nearly 8% increase in per capita consumption of dietary energy in the world between 1997 and 2017. There is more than 50% increase in the adult obesity rate during the same period. 
5. Locally produced food can contribute to resilience of the vulnerable and resource-poor by increasing food availability, enhancing nutrition, improving farmers’ livelihoods and creating job opportunities for other disadvantaged groups. By adding value within local supply chains and markets, this approach contributes to improved local revenues.  Farmer’s forum of India emphasised ‘Nutritional resilience and production for self-consumption of rural communities with backyard poultry, home gardens & farmers’ & community markets.
6. Income generating activities in villages improves standard of living that in turn leads to small farmer, landless agricultural workers income reaching national GDP (PPP). Food is a potential sector of income generating activities in villages. Village cottage industry producing farm fresh products with local flavor and food quality matching high volume big industry produced food goods at a comparable price will improve the availability of variety of food goods and services in the villages.
7. Rural transformation leading to vibrant village atmosphere is necessary to bridge the urban- rural development gap. In several middle, low- income countries including India, the economic development is varying and is not uniform across the country, regions and states. There is a large disparity between urban and rural development. MPCE-Monthly Per capita Consumption Expenditure has increased in both rural and urban areas over the years. However, the increase in expenditure has been greater in urban areas compared to rural areas. This shows a wide rural-urban disparity in the MPCE.  During 2011-12 average urban MPCE at ₹2,630 was about 84% higher than average rural MPCE ₹1,430 for the country as a whole.
8. Agriculture value added per worker in India is 1669(constant USD), GDP per capita is 6516(USD, PPP). Agriculture produce is priced at international market price, whereas the GDP per capita is based on country inflation. The agricultural worker / marginal farmer gets paid less for produce, where as they have to pay higher price for the food they consume.
9. ‘Sustainability’ and ‘resilience’ are often misused terms. Currently there are no sustainable systems, there are no energy efficient resilient systems. Sustainability requires adaptation to evolution process which in turn depends on migration during adverse climate conditions. Resilience requires expensive energy to develop or maintain existing system under severe weather conditions like global warming.

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.

Inequality is one of the root causes of hunger and food insecurity, therefore, we consider this topic relevant and timely, reminding that Hungary was one of the sponsor countries proposing this issue to be included in the CFS Multi Year Programme of Work (MYPOW).

We appreciate the open, transparent and inclusive process, providing opportunity for all stakeholders to submit comments in the framework of this online consultation.

We wish to start by congratulating the HLPE, its Steering Committee and the Drafting Team for the high quality of the V0 Draft, commending their efforts to rely also on previous HLPE reports and CFS policy papers.

We agree with the concept outlined in the V0 Draft, seeking to address inequalities and inequities as main drivers of food insecurity. In this regard, we appreciate that the definition of food security is used in a broader sense, acknowledging that in addition to availability, access, stability and utilisation, the two new dimensions (agency and sustainability) play an essential role in the fight against food insecurity. Among the definitions, we appreciate and find helpful the clearly explained distinction between inequity and inequality.

We very much welcome the human rights approach throughout the document, putting in evidence the universality and the interlinkages among the various human rights, but the rights’ based approach of the document most detailed in Chapter 6 does not differentiate between levels of fulfilling the right to food, and not even calls upon to define a minimum level. Without this the responsibility of communities/states cannot be framed.

Similarly, we appreciate references to a number of SDGs as well. We would suggest to include also SDG 8 (Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all), considering the high number of food workers and other employees in the food systems and their labour rights. Furthermore, we would suggest including explicit reference to the right to decent work (including decent rural employment[1]) and consider it appropriate to make clear reference to the respective UN resolutions, for example when it comes to decent livelihood[2] or clean environment[3], on page 19. of this document mentioned only in brackets.

Regarding the "Systemic Drivers" in page 21, we find it not sufficiently comprehensive and exhaustive. We miss in particular the following important drivers of inequalities.

1. Lack of sustainability assessments of food systems, based on independent and neutral science. Outcomes of these assessments could help policy makers take the right decisions aiming to reduce inequalities. Science-based sustainability assessments should give due consideration to all environmental and particularly social externalities, including the „hidden costs”, applying the principles of true costs accounting[4].
2. Lack of appropriate policy environment (due to lack of appropriate sustainability assessments of food systems), with consequences listed below:

1. In general, incorrect distribution of subsidies, (favouring mainly large entities) which further aggravate the existing inequalities. It should be noted that the new agricultural policy maintains its main features that the basic income support tends to favour farms with larger areas, though new redistributive support for smaller farms can correct this disparity. Another important fact is that the agricultural policy of EU member states, like Hungarian agricultural policy should meet the EU requirements, thus will respond to environmental needs and challenges, such as soil, landscape, biodiversity, water protection, etc., in a much more comprehensive way than before.
2. Limited access for smallholders and other marginalized groups (women, indigenous people, etc.) to

- land and other natural resources,

- loans or credits

- inputs and technologies

- markets,

- research and innovation (The main focus of research is mainly industrial farming and corporations…)

We wish to draw attention to the indicator Inability to afford a meal with meat,

chicken, fish (or vegetarian equivalent) every second day available from the EU-SILC  survey as a major source of comparable information on access to food in the EU.

We welcome the references to power imbalances along the food supply change, often creating conflicts of interest situations, which are the major obstacles to transformative changes of food systems. We would find it indispensable to make a clear distinction of roles and responsibilities of the various stakeholders. Contrary to the present practice, multinational corporations and other lobby groups could be consulted but they are NOT supposed to be involved in decision making and they should not be allowed to use their strong power to influence policy decisions[5]. Decision making is the competence of governments. Furthermore, we consider it essential to draw attention to and duly address in the report the greenwashing attempts by many corporate stakeholders, including their Corporate Social Responsibility (CSR) measures[6]. Although CSR activities are generally welcome, the CSR messages are regularly positive, they cannot be considered in any way sufficient for the necessary transformative changes.

Finally, there is reference to Chapter 7 that summarises FSN recommendations. We are looking forward to the possibility to see and to form an opinion also on this chapter. This is even more underlined by the fact that the rights’ based approach to the topic implies global action and mutual responsibility of actors and nations in providing FSN solutions.

Overall, the study is well balanced, covering basically all aspects relevant to our field (children, the underprivileged, cultural aspects, regionalism, food sovereignty, legal approach, etc.).

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

Food and agriculture face a multitude of recent and long-standing challenges that have all led to increasing inequalities within the agrifood sector. To respond effectively, all stakeholders, including the private sector, must form alliances and partnerships that drive innovation, create jobs and advance equitable growth. With respect to SDG 10: Reduce inequality within and among countries, the Private Sector Mechanism (PSM) acknowledges the crucial role businesses can play as engines for economic growth, the creation of jobs, and promoting of economic activity throughout the value chain that does not contribute to inequality.

General observations on the Zero Draft

The PSM supports efforts to reduce inequalities in food security and nutrition and the work of the HLPE to inform us on how to do so. While there are inequalities in food security and nutrition, having enough food supply and access to it, should not be overlooked. We urge the HLPE to ensure the Report includes information based on robust science and provides an unbiased view of the issues at hand to effectively contribute to policy-making decisions. Currently the conceptual framework provided does not explain how policymakers can use the framework in practice. It would benefit from including examples that successfully showcase the use of the framework and that address all aspects of “engine of inequity”.

Furthermore, considerable research has already been done on this topic that should be reflected in the Report, including the following relevant research by the OECD https://www.oecd-ilibrary.org/agriculture-and-food/making-better-policies-for-foodsystems_ddfba4de-en. In order to avoid duplication of resources and provide value to this work, please consider the OECD study on the functioning of the world’s food and agriculture system and how it can contribute to reduced hunger and the attainment of global food security. https://www.oecd-ilibrary.org/agriculture-and-food/global-food-security_9789264195363-en.

The PSM would also share a more general concern regarding the way the role of the private sector is portrayed throughout the V0. The text seems overly pessimistic about the role of food manufacturers – who are mentioned as profiteering from inequalities (p.64 “It is important to note that these conditions of multidimensional poverty have provided opportunities …”) and proliferating non-nutritious food (p.109: “Big Food’s influence on market proliferation with non-nutritious foods”).

We believe the paper should acknowledge the positive work done by food manufacturers as well that can be gleaned throughout the value-chain and scaled up. For example, on improving nutrition through micronutrients and fortification, see reports from the WFP “Food fortification — enhancing the micronutrient content of commonly eaten foods — provides a cost effective and life changing solution until we can ensure healthy and nutritious diets for all.” https://www.wfp.org/publications/food-fortification. As for improvements in the healthiness of products, see https://accesstonutrition.org/app/uploads/2021/06/Global-Index-2021- Executive-Summary.pdf. There are numerous examples that can be shared on improving access to food in remote areas and ensuring food quality and safety for all consumers.

Specific references to missing concepts and issues insufficiently addressed

• Innovation and Technology:

o A more balanced view of innovation and technology is needed, as reflected by the FAO Science and Innovation Forum, which highlighted how it could address the various challenges the agrifood sector currently faces. Furthermore, food science and technology should be seen as part of the solution in achieving greater equity in food and nutrition security.

o Food science and technology has made significant contributions in reducing the cost of food through packaging and processing technologies that allow foods to be safe and stable for longer periods of time, which is acknowledged in the report, but positioned as a disadvantage for healthy diets.

o Currently, innovation and technology are listed as one of the systemic drivers and root causes of inequalities, which is a narrow and overly negative perception that does not acknowledge the potential and reality of food science and technology, among other innovations.

• Diet Quality

o P.34 – measures of diet quality at a global level could benefit from highlighting the need for harmonized diet quality assessment methods and data frameworks.

o It would be relevant to include a link to the CFS data workstream in this section.

o Certain sections referring to diet quality (page 34) use indicators such as AHEI and Global Diet Quality may not be the most suitable to reflect the global diet quality. They oversimplify by categorizing ‘(un)healthy diets’ based on adherence to dietary guidelines, especially when based on Western diets and subsequently used to assess diets in other areas of the world.

o It is also recommendable to make the distinction in diet assessments between nutrient (in)sufficiency and dietary risk factors in relation to non-communicable diseases.

o The data available from the Global Burden of Disease (https://www.healthdata.org/gbd/2019) on population health and how it varies by different regions, socioeconomic status, or ethnic groups in their country, could improve the content of this section.

• Obesity

o References to adult obesity prevalence needs a closer look and could benefit from looking at the following links. Prevalence is higher in advanced countries, but is rising faster in developing ones: https://www.worldobesity.org/resources/resource-library/world-obesity-a….

o Also worth checking if prevalence indeed is higher in “wealthier households” as papers draw different conclusions "Women and men with lower incomes are more likely to be obese, entrenching inequality" https://www.oecdilibrary.org/docserver/0f705cf8- en.pdf?expires=1671700345&id=id&accname=guest&checksum=46CE0FC9 08CC32041799611FFFB294CA.

o There is concern that solutions mentioned, such as on page 109 (2009 South Korean example) may be outdated and worth analyzing more closely before presenting as solutions that are replicable and efficient, considering they do not seem to be linked to output results.

• Only 12 uses of the term ‘maternal’ in the entire document/some of those in the references.

o Importance of specific nutrients for women trying to conceive/no mention of pre-conception/taking into consideration and supporting the health and nutrition requirements of those trying to conceive.

o Importance of access to a balanced and nutrient-rich diet for breastfeeding mothers to ensure their babies also get the nutrients they require.

• No reference to premature babies yet 1 in every 10 children in the world is born premature/prematurity is the world’s single biggest cause of newborn death, and the second leading cause of all child deaths, after pneumonia.

o Nutrition is an important factor in ensuring optimum long-term growth, neurodevelopment, and other health outcomes for premature babies.

o Climate change and premature births: emerging evidence suggests that climate change is also associated with a multitude of maternal and birth outcomes, such as the risk of infertility, miscarriage, Caesarean-section, premature birth, low birth weight, stillbirth, and poor infant development.

o New studies from across the globe have found that the climate crisis is damaging the health of fetuses, babies, and children – from higher climate temperatures linked to preterm birth, and wildfires doubling the risk of birth defects, to the reduction of fertility linked to air pollution. Climate change is also accelerating mosquito-borne infectious diseases, like malaria and Zika, which affect fetal health and development.

• Breast Milk Substitute (BMS)

o P.34 refers to “Breastfeeding’s inherent relationship with commerciallyproduced infant formula.” What is meant by 'inherent relationship,' and is this backed by science.

o There is little evidence to support the usual conflation made between so-called aggressive BMS marketing practices and low breastfeeding.

o References to improved breastfeeding rates in certain countries (e.g., pg.35) needs additional context, as well as references to lower rates elsewhere in order to help people understand the factors that influence breastfeeding rates.

o Practices vary significantly between food manufacturers (see page 66) which is not taken into account- as all are lumped together.

o There is no recognition of the fact that infant formula is the only safe and suitable breastmilk substitute recognized by the WHO and other governing bodies when breastfeeding is not possible or an option.

• Land inequality and resilience

o P.46 – on land inequality surprisingly notes that large scale acquisition is only linked to ‘corporate entities and international investors’. As the cited source shows, some deals are done through governments, governmental agencies or entities controlled by states.

• Agroecology o Agroecology is one approach, among others, to contribute to feeding sustainably a growing population and support countries in achieving SDGs and as such, it is startling to see it is the only agriculture approach mentioned as a structural reformation approach with implications for equity.

o This assumption is not well aligned with CFS Policy Recommendations on Agroecological and Other Innovative Approaches for Sustainable Agriculture and Food Systems that Enhance Food Security and Nutrition, nor with reality. As such, we trust this view will not be included in the subsequent drafts.

o This report should consider the work that the FAO has done on climate-smart agriculture, among other approaches. https://www.fao.org/climate-smartagriculture/en/ and the World Bank https://www.worldbank.org/en/topic/climate-smart-agriculture.

• Informal sector

This section would benefit from the CFS work on linking smallholders to markets; namely, supporting value chain development that links smallholder farmers, and the informal food production sector, directly to the formal food processing and packaging sector thus providing smallholder farmers’ increased income, improving the accessibility of local & traditional food supply whilst improving and safeguarding food safety and nutritional value of foods. While it is important to acknowledge the informal sector as a reality within the agrifood system, its limits and challenges should also be explored. The text currently seems to only highlight the positive aspects.

o On page 57, it is said that research has found that women farmers lost control when milk was sold to chilling plants, however, this should not be the rationale to discourage farmers to sell milk to formal processors if they can.

o On page 65, informal markets are described as very good solutions for the poor, however, it is more beneficial to discuss the sustainable market models we should work towards, rather than concluding that the present situation works for the poor. All consumers should have access to safe, quality foods at prices they can afford, both poor and not so poor, and we have to find ways of including all informal smallholder producers into such formal systems.

o Smallholder farmers that are not connected to or have access to the formal market, will always have challenges and remain small, not knowing if they can sell their produce from one day to the next.

o Inequalities between farmers that are part of formal value chains and farmers that are not, can be reduced by linking producers in the informal market to processors, retailers, aggregators and markets in the formal sector.

Concluding Remarks

The PSM thanks 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 multistakeholders to promote effective CFS outputs and outcomes.

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.