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    • Preliminary comments from the EU on the

      “Zero Draft - CFS Voluntary Guidelines on Gender Equality and Women’s and Girls’ Empowerment in the Context of Food Security and Nutrition”

      - CFS Regional Consultations for Europe and Central Asia

      on 27./28. September 2021

      General comments:

      • A joint position of the EU & its Member States will be developed in the further process.
      • The EU welcomes the Zero Draft of the CFS Voluntary Guidelines on Gender Equality and Women’s and Girls’ Empowerment in the Context of Food Security and Nutrition.
      • In 2020, the EU adopted its third Action Plan on Gender Equality and Women’s Empowerment in external relations (GAP III) covering the 2021-2025 period, and renewed its ambitious commitment to promoting gender equality and women’s and girls’ empowerment (GEWGE).
      • These Voluntary Guidelines offer an opportunity to further the coherence of our engagement towards food security and nutrition, towards sustainable, fair and resilient food systems and towards Gender Equality and Women’s and Girls’ Empowerment.
      • We especially welcome that the Voluntary Guidelines are complementary to and support national, regional and international initiatives, which aim at addressing all forms of discrimination against women and girls and sexual and gender-based violence that undermine efforts to increase food security and improve nutrition worldwide.
      • We welcome the inclusion and reflection of the core principles in Part 2 which are all essential principles for the Voluntary Guidelines. Achieving gender equality and women’s and girls’ empowerment is fundamental to the realisation of human rights and the right to adequate food, but it is also important to stress that achieving human rights and the right to adequate food is fundamental to achieving broader gender equality and women’s and girls’ empowerment. There is a mutual condition that needs to be reflected.
      • We very much appreciate that Gender Transformative Approaches are given a high relevance in the Voluntary Guidelines and we would like to keep this ambitious text. We have to tackle root causes of all forms of discrimination against women and girls. The EU funded RBA Joint Programme for Gender Transformative Approaches for Food Security and Nutrition can be good reference and can give useful experience in this regard.
      • Also, the EU’s Action Plan on Gender Equality and Women’s empowerment in external relations (GAP III) is built, among others, on the principle of intersectionality and promotes equality for women and men in all their diversity. We therefore welcome the reference to the concept of intersectionality and believe that it is important to add in the guidelines that women and girls often experience multiple and intersecting forms of discrimination, also due to sexual orientation and gender identity.
      • Furthermore, we believe that there are significant opportunities to more systematically integrate a reference to context specific and participatory gender analysis (very much linked to the principle of intersectionality) throughout the document, by way of reflecting how fundamental it is as a tool to avoid generalisations and stereotypes that would undermine the transformative ambition of these Guidelines.
      • We suggest that the Voluntary Guidelines should be more balanced with regard to the rural and urban dimension of food security and nutrition throughout the text. For example, there are rural vs. urban/cities gaps in the provision of services such as basic infrastructure (water, sanitation, energy network, financial services), or other services (access to health care, education, long term care) and women and girls in rural areas are in more disadvantaged situations than their peers living in urban areas or cities. But also women and girls in the urban areas can be disadvantaged. A country specific gender analysis is necessary to assess each situation. Both, urban and rural areas specificities need to be reflected in the Voluntary Guidelines.
      • Also, there needs to be a balanced approach concerning not only agriculture but also reflecting on other sectors that are relevant for food security and nutrition as for ex. fisheries, aquaculture and forestry.
      • We welcome the topics and issues proposed for discussion under Part 3 and believe that there is an important opportunity to group the main issues around 6 areas: 1. Gender-based violence and discrimination; 2. Economic and social Rights; 3. Participation, Voice and Leadership; 4. Equal sharing of care and domestic work; 5. gender equality and women’s and girls’ empowerment in the context of sustainable food systems; 6. gender equality and women’s and girls’ empowerment in the context of food security and nutrition assistance in humanitarian crises.
      • We want to highlight the significance of universal social protection for the realisation of the right to food and we want to ensure that the progress in terms of food security and nutrition is adequately recognised and not narrowly interpreted in relation to shock responsive food and nutrition assistance. It is to be recalled that even prior to the COVID-19 pandemic at least 3 billion people – around 40% of the global population (and the vast majority not affected by crises) – are unable to afford the ingredients required for healthy meals (FAO 2021). We therefore suggest that social protection should be incorporated within an expanded new section on Economic and Social Rights. Currently section 3.9, while containing some valid points, places undue emphasis on shocks, F&N assistance, school feeding, discrete programmes and schemes etc. It is important that the full scope of social protection and the priority for supporting the establishment of universal social protection systems is made central, hence the need to move social protection to another section.
      • We also recommend that attention to humanitarian assistance for food and nutrition be dealt within the context of a new section on gender equality and women’s and girls’ empowerment for food security and nutrition in contexts of humanitarian emergencies, crises and conflict.
      • We believe that the agroecological transformation of agrifood systems is not limited to food production practices, but entails more balanced access to resources, more balanced relations and distribution of power. Agroecology could be a key opportunity for women to gain influence and recognition and to contribute to better nutrition/food security. We therefore believe that there is considerable scope for the guidelines to address the significance of agroecology and the promotion of territorial markets (as opposed to increased reliance on retail food outlets) for food systems transformation and the implications for integrating gender equality and women’s and girls’ empowerment into such a transformative process.

      There are still topics that don’t find enough focus in the Zero Draft:

      • Gender responsive budgeting is only referenced once (in Part 2 with reference to principles) and there is scope to more effectively highlight the strategic significance of this agenda throughout the document.

      • While the EU Gender Equality Strategy 2020-25 and the EU Gender Action Plan III explicitly recognise the significance of trade for gender equality and women’s and girls’ empowerment, this is not evident in the Zero Draft. The Zero Draft could be strengthened by the incorporation of text to address the crucial role of gender and food security / nutrition sensitive macro-economic, finance and trade policies.

      • There is scope to further strengthen acknowledgement of the importance of healthy diets and the challenges associated with addressing all forms of malnutrition across all sections.

      • It will be especially important to ensure that the issue of breastfeeding is adequately addressed beyond reference to nutritional needs of breastfeeding mothers (current emphasis).

      • In general, justice – including basic legal and property rights (in both urban and rural areas) is inadequately dealt within the Voluntary Guidelines. We propose to include equal access to justice and legal assistance. Women’s legal capacity and equal rights with men to conclude contracts needs to be ensured as well as property and inheritance rights, and financial services, such as credit, banking and finance.

      • We believe that a reference in the Zero Draft to the phenomenon referred to as ‘feminisation of agriculture would increase the arguments in favour of setting up the Voluntary Guidelines.

      Finally, it is important that there is a reference and a link to previous CFS voluntary guidelines and recommendations and that future work will take these Voluntary Guidelines on Gender Equality and Women’s and Girls’ Empowerment in the Context of Food Security and Nutrition into account.

      We very much appreciate the transparent and inclusive policy process and look forward to the future exchange of views.

      PART 1 - INTRODUCTION

      Guiding question Nr. 1: Does the Zero Draft appropriately capture the main challenges and barriers that hinder progress in achieving gender equality and the full realisation of women’s and girls’ rights in the context of food security and nutrition in the region? If not, what do you think is missing or should be adjusted?

      • As mentioned in our general comments, we welcome that the Voluntary Guidelines aim at addressing all forms of discrimination against women and girls as well as sexual and gender-based violence that negatively impact upon food security and nutrition. Gender transformative approaches are a prerequisite to tackle root causes of all forms of discrimination against rural women and girls and this should stay as highlighted throughout the text as it is reflected in the Zero Draft.
      • We believe that it is important to highlight from the outset that the right to adequate food and gender equality and women’s and girls’ empowerment are mutually reinforcing and to avoid implying (as is currently the case) that gender equality and women’s and girls’ empowerment is (merely) instrumental in achieving food security and good nutrition (this also comes up in Part 2).
      • Furthermore, a reference needs to be made more to healthy diets as central to food security and nutrition objectives.
      • We propose that also other economic sectors (as aquaculture, fishery, forestry, etc., for ex. in paragraph 7) will be more balanced .
      • At the moment fisheries and aquaculture are left out of discussions, research, decisions, solutions and resource allocations regarding food security and nutrition, despite being a critical component of strategies to deliver healthy, sustainable and equitable food systems. It’s important to single them out, for ex. in paragraph 13 and make a reference to the FAO “Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries in the Context of Food Security and Poverty Eradication – SSF Guidelines”.
      • There are rural vs. urban/cities gaps in the provision of services and broadband. The girls and women who live in rural/remote areas where there is inadequate access to essential services such as basic infrastructure (water, sanitation, energy network, financial services), or other services (access to health care, education, long term care) are in more disadvantaged situations than their peers living in urban areas or cities. The COVID 19-Pandemic has shed the light on the problems some regions faced when it comes to the access to broadband and IT infrastructure. Some children and youth, including girls and young women, could not participate in online education in those regions with inadequate access to broadband or insufficient IT equipment in the households living under poverty lines. This needs to be reflected in the Voluntary Guidelines.
      • The Zero Draft should better drawn on the linkages of the concepts of food security and nutrition.

      PART 2 – CORE PRINCIPLES THAT UNDERPIN THE GUIDELINES

      Guiding question Nr. 2:Does Part 2 of the Zero Draft satisfactorily reflect the core principles which should underpin the Guidelines? If not, how do you propose to improve these principles?

      • We welcome the inclusion and reflection of the core principles in Part 2 which are all essential principles for the Voluntary Guidelines.
      • Achieving gender equality and women’s and girls’ empowerment is fundamental to the realisation of human rights and the right to adequate food, but it is also important to stress that achieving human rights and the right to adequate food is fundamental to achieving broader gender equality and women’s and girls’ empowerment. There is a mutual condition that needs to be reflected.
      • We very much appreciate that Gender Transformative Approaches (paragraph 21) are given a high relevance in the Voluntary Guidelines. We have to tackle root causes of all forms of discrimination against rural women and girls. The EU funded RBA Joint Programme for Gender Transformative Approaches for Food Security and Nutrition can be good reference and can give useful experience in this regard. However, the gender transformative approach, while recognised as a key principle, requires strengthening in terms of application via not only the inclusion of men and boys, but also the active promotion of engagement of young people and the systematic commitment to strengthen engagement at local level on a sustainable basis.
      • We very much appreciate the inclusion of context-specific gender analysis and approaches (paragraph 23). It is important to build interventions on gender sector analysis which are specific to a country/local context in order to understand from the start the constraints and opportunities. However, we believe that there are significant opportunities to more systematically integrate references to context specific and participatory gender analysis (very much linked to the principle of intersectionality) throughout the document, by way of reflecting how fundamental it is as a cross-cutting issue.
      • Concerning the “Reinforcing the collection and use of gender-disaggregated data” (paragraph 25) it is very important that the perspectives of children and young people are included. Children and youth make up 3.2 billion people (42% of the global population). At the same moment it reads as if qualitative data is associated with ‘traditional’, ‘indigenous’ and ‘local’ knowledge and only to be used to complement ‘real’ scientific data. This should be clarified.
      • We believe that the intersectionality and multidimensional approach (paragraph 27) is key and we suggest to move it up after the principle of gender transformative approaches (paragraph 22). The reference to intersectionality would benefit from being more explicit (both here and across the document) that generic measures to assist “women and girls”, will, besides being equal, tend to assist the best off and least disadvantaged women and girls, whose interests are not necessarily the same as those of the most disadvantaged women.
      • The EU’s Action Plan on gender equality and women’s empowerment in external relations (GAP III) is built, among others, on the principle of intersectionality and promotes equality for women and men in all their diversity. That is why it is important to add that women and girls often experience multiple and intersecting forms of discrimination, due to also sexual orientation and gender identity.
      • For the principle on Multi-stakeholder collaboration and partnership (paragraph 28) we suggest that in addition to recognising opportunities, also risks associated with private sector engagement and conflicts of interest should be highlighted.
      • We would like to propose that the 11 principles be listed with the order suggested here below, which will help increase the coherence of the guidelines. In order to make clearer the reasons for this request, we have highlighted the area to which each principle pertains. Listing principles pertaining to the same area in an orderly manner helps maintaining focus and coherence.

      19. Commitment to Human Rights and Realization of the Right to Adequate Food (Rights)

      20. Empowerment of women and girls (Rights)

      21. Gender transformative approaches (Approaches)

      22./ex. 27 Intersectionality and multidimensional approach (Approaches)

      23. Context-specific gender analysis and approaches (Approaches)

      24. Gender mainstreaming combined with targeted actions (Approaches)

      25. Reinforcing the collection and use of gender-disaggregated data (Approaches)

      26. Inclusiveness and participation in policy-making (Policy)

      27./ex. 22 Strengthening policy coherence (Policy)

      28. Multi-stakeholder collaboration and partnership (Policy)

      29. Adequate financial, technical and human resources, supported by political commitment and public policies (Resources and actions)

      Additional comment for Part 2:

      Para 17: We welcome the reference to existing international legal frameworks and guidance. We suggest to also include a reference to the CFS Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests (VGGT, 2012) which also focuses on gender equality and gender sensitive analysis etc.

      PART 3 – THE VOLUNTARY GUIDELINES ON GENDER EQUALITY AND WOMEN’S AND GIRLS’ EMPOWERMENT IN THE CONTEXT OF FOOD SECURITY AND NUTRITION

      Guiding question Nr. 3: Do the nine sections of Part 3 of the Zero Draft comprehensively cover the policy areas to be addressed to achieve gender equality and the full realization of women’s and girls’ rights in the context of food security and nutrition? If not, what do you think is missing?

      General comments Part 3:

      • We welcome the topics and issues proposed for discussion under Part 3 and believe that there is an important opportunity to group the main issues around 6 areas: 1. Gender-based violence and discrimination; 2. Economic and social Rights; 3. Participation, Voice and Leadership; 4. Equal sharing of care and domestic work; 5. gender equality and women’s and girls’ empowerment in the context of sustainable food systems; 6. gender equality and women’s and girls’ empowerment in the context of food security and nutrition assistance in humanitarian crises.
      • We believe that such a restructuring would increase the coherence of the Voluntary Guidelines on various levels:
      • The first 4 themes (violence, rights, voice, domestic care and work) are challenges and barriers to gender equality that affect food security and nutrition, but whose solution / overcoming requires policies and actions of a general nature which requires mobilization of a number of stakeholders which are not exclusively dealing with food security and nutrition issues. Such mobilization will require authentic adherence to the principles of ‘commitment to human rights’, of ‘empowerment of women and girls’, of ‘strengthening policy coherence’, of ‘multi-stakeholders collaboration and partnership’ and of ‘inclusive participation in policy making’.
      • The last two themes (GEWGE in Food security and Nutrition in specific contexts 5. Sustainable food systems and 6. humanitarian action) would allow to address the specificities of these two contexts and to mobilise the various stakeholders for the design and implementation of specific policies.
      • The six areas proposed include all 9 sections proposed in the Zero Draft.
      • This restructuring would be the opportunity to rebalance language in relation to rural and urban areas, and in relation to various productive activities (not only agriculture, but also fishery, food preparation, trade, care etc.), as well as an opportunity to not confine the concept of social protection only to the humanitarian action.
      • Last but not least this proposal would make it easier to identify the institutions and stakeholders involved / in charge of / responsible for developing or implementing the policy recommendations of the Voluntary Guidelines.

      Section 3.1Women’s participation, voice and leadership in policy- and decision-making at all levels:

      General comments:

      • This section spans both high level decision making and decision making at the level of the household. It is suggested that the section is more clearly divided to better address these two very different agendas. It would also be useful to reference for example civil society, trade unions and media when discussing participation, voice and leadership.
      • We suggest to reference intersectionality in this section. The greatest challenge lies with those women and girls most marginalised and excluded. It is also important to include girls and youth in this section by acknowledging not only the important contribution they can make but the contribution that a ‘new vocal generation of young women and girl activists’ is already making.
      • Paragraph 32: We suggest to add the perspective of fisheries: Policies have tended to concentrate on the harvesting sector, where men dominate. Fishing development programmes have focused on men’s needs and priorities paying little attention to the important role of women in the sector. Women are still often excluded from policy, decision-making in the fisheries/aquaculture sector, and many countries still have gender-blind fisheries policies. In post-harvest activities, policy initiatives mainly support larger or urban traders rather than considering the livelihood interests of all stakeholders throughout the value chain.
      • Paragraph 34: This should not only apply to children but also to women’s own nutrition outcomes and nutrition outcomes in general.

        Suggested to refer to HLPE Food Security and Nutrition (Building a Global Narrative http://www.fao.org/3/ca9731en/ca9731en.pdf).

      • Paragraph 37: It would be key to emphasise that the participation of women needs to take place in finance, economics and planning (which often tend to be more male dominated) which have perhaps the most significant implications for food security and nutrition outcomes.
      • Concerning fisheries it is essential to identify and target the needs and interests of both women and men. Strategies that promote more diversified and independent roles for women should be developed and formulate and implement fisheries policies and initiatives that adequately address women’s interests and priorities.

      Section 3.2 Elimination of violence and discrimination against women for improved food security and nutrition:

      General comments:

      • We welcome the fact that this section has been brought forward. We suggest to refer to sexual and gender based violence (GBV) in the title of this sub-section and include a footnote definition to explain that sexual violence is a subset of GBV.
      • We recommend to acknowledge harassment and micro-aggressions (for instance verbal or online abuse) that affect so many on a daily basis as well as the impact pervasive fear of sexual and gender based violence has on all aspects of life.
      • According to the EU’s Action Plan on Gender Equality and Women’s empowerment in external relations (GAP III) for 2021-2025 which is built, among others, on the principle of intersectionality and promotes equality for women and men in all their diversity, we believe that it is important to add that women and girls often experience multiple and intersecting forms of discrimination, also due to sexual orientation and gender identity.
      • Paragraph 40: We also suggest to consider that there are fish-for-sex practices between male fishers and local female buyers seeking access to fish: linked to scarce resources and increased competition for fish.
      • Paragraph 44: In many places, the violence (including sexual exploitation) that women face in employment situations across both rural and urban populations is a huge barrier/disincentive to their being able to work, so we recommend to avoid reference to rural environments.
      • Paragraph 47:Policy areas for discussion: "Changes in social norms and stereotypes" isn't a policy area – it's an objective, and the VGs need to suggest which the policy areas are that might be able to effect this. Social norms cannot simply be legislated for (though legislation can help bring about change). Social norms will surely change with: more women in leadership positions (in government at all levels, and in all the other stakeholders to whom the VGs are addressed); equality in access to education; equality in access to economic opportunities; as well as legislation against discrimination.

      Section 3.3 Access to education, capacity building, training, knowledge and information services:

      General comment: We suggest, according to our proposed restructuring, to integrate education into the section which covers economic and social rights. In addition, with respect to formal education, we suggest that ‘a shift is needed to move beyond gender parity in numbers and focus on how the education system can advance.

      Section 3.3.1. Access to formal education:

      • Paragraph 51: Eliminating gender disparities in school attendance leads to improvements in female education and reproductive health. There is a negative relationship between levels of literacy and total fertility rates in females which may contribute to improvements in maternal and child health. We suggest to include this here.
      • Paragraph 53: We propose to add to train women in the sustainable management of fishing resources and to improve their formal and informal education in improved technologies, entrepreneurial skills, health practices, sanitation and nutrition, adult literacy, and extension services.

      Section 3.3.2 Access to advisory and extension services:

      • Paragraph 55: We see an emphasis on extension services and a neglect of other vocational and entrepreneurial support. We suggest to have a better balance on that.
      • Paragraph 56: We suggest to include women working in small-scale fisheries and aquaculture.
      • Paragraph 57: Also include that there are extension services in fisheries and aquaculture.

      Section 3.3.3 Access to financial services and social capital:

      • Paragraph 59: We suggest that financial services will not be included in the same section as education.
      • Paragraph 61: This paragraph is an example of generalising to all women which is not useful as every situation needs to be assessed specifically.
      • Paragraph 65: There is the need to include urban as well as rural female entrepreneurs.

      Section 3.3.4 Access to appropriate ICT-based, digital and innovative technologies:

      • Paragraph 67: ICT can help women not only in rural and remote communities but also in urban areas to achieve access to new markets and consumers, to sell their produce. The context-specific situation needs to be assessed if ICT can really help women to achieve access to new markets and consumers.

      Section 3.4 Women’s economic empowerment in the context of sustainable food systems:

      • Paragraph 74: We propose that a food system section should start with the recognition that a transformative approach is urgently required with respect not only to gender but also to food systems.
      • There is scope for this section to be more centred around the green transition, agroecology and the linkage with gender equality and women’s and girls’ empowerment.
      • We believe that the agroecological transformation of agrifood systems is not limited to food production practices, but entails more balanced access to resources, more balanced relations and distribution of power. Agroecology could be a key opportunity for women to gain influence and recognition and to contribute to better nutrition/food security. We therefore believe that there is considerable scope for the guidelines to address the significance of agroecology and the promotion of territorial markets (as opposed to increased reliance on retail food outlets) for food systems transformation and the implications for integrating gender equality and women’s and girls’ empowerment into such a transformative process.
      • Paragraph 76: This paragraph reflects a rare example of a call for specific gender context analysis. It needs to be applied to all other sectors throughout the VGs.
      • Coastal areas are highly vulnerable to natural disasters caused by climate change; the degradation of coastal marine resources (i.e. reduced fish stock; water bodies contamination) affect the livelihood systems of men and women. We suggest to add that it is necessary to invest in women’s networks, as they can play important roles in mobilizing and redistributing resources, promoting labour opportunities, providing information, and in creating new coping strategies for households and communities.
      • Paragraph 78: Concerning fisheries, men often have greater access and connections to national and even global value chains and greater bargaining power over intermediaries; while women sell fish at the retail level, mainly in local markets, where intermediaries tend to control the demand. Besides, women often work in low-status, less-skilled and low-paid jobs, and on informal, casual and temporary contracts that disqualify them from receiving social benefits. It is urgent to give women equal control in the value chain and profit margins and this needs to be reflected in the Voluntary Guidelines.
      • Paragraph 81: This important overarching recognition of legal rights and systems seems rather out of place in this section and should be moved.
      • Paragraph 82: Land and property rights are important for gender equality and women’s and girls’ empowerment in rural as well as urban areas.
      • Concerning fisheries, it is important to improve women positions in the value chain, female traders must be provided with the know-how and access to education and information on fish preservation and marketing so they can receive better quality fish and keep it fresh. It is also necessary to mobilize women’s organizations and groups to promote gender equality along the aquatic food systems.

      Section 3.5 Access to and control over natural and productive resources:

      General comment:This section overlaps significantly with section 3.4 (as seen for example in the first policy area for discussion under 3.4 and it is therefore recommended that they be combined.

      • There is scope to strengthen references to agroecology – including definition and implications of guiding principles for gender equality and women’s and girls’ empowerment.

        We believe that the agroecological transformation of agrifood systems is not limited to food production practices, but entails more balanced access to resources, more balanced relations and distribution of power. Agroecology could be a key opportunity for women to gain influence and recognition and to contribute to better nutrition/food security. We therefore believe that there is considerable scope for the guidelines to address the significance of agroecology and the promotion of territorial markets (as opposed to increased reliance on retail food outlets) for food systems transformation and the implications for integrating gender equality and women’s and girls’ empowerment into such a transformative process.

      Section 3.5.1 Access to and control over natural resources, including land, water, fisheries and forestry:

      • Paragraph 84: Tenure rights for fisheries stakeholders, especially informal and indigenous rights, are far less developed or recognized than in other sectors. We suggest to include that advancing knowledge on tenure and user rights in fisheries is a crucial step towards achieving gender equitable governance of fisheries and attaining food and nutrition security and livelihood benefits.
      • Paragraph 85: There is the need for a stronger focus on access to justice in the Voluntary Guidelines. In general, justice – including basic legal and property rights (in both urban and rural areas) is inadequately dealt within the Zero Draft. We propose to include equal access to justice and legal assistance. Women’s legal capacity and equal rights with men to conclude contracts needs to be ensured as well as property and inheritance rights, and financial services, such as credit, banking and finance.
      • Paragraph 86: Women accounted for about 50 percent of the workforce in fisheries and aquaculture, when the secondary elements such as processing and trading are included. The sectors support the livelihoods of approximately 10–12 percent of the world’s population and are central to global food and nutrition security. The challenges are limited access to and control over assets and resources, constraining gender norms, time and labour burdens of unpaid work, and barriers to sustaining entrepreneurship. Gender equality in fisheries and aquaculture can bring many potential benefits including higher fish productivity and household incomes, as well as positive nutritional outcomes.
      • Paragraph 94: Concerning also fisheries it is essential to consider the livelihood interests of all stakeholders throughout the aquatic food system when addressing resource management. New institutional arrangements are needed for the equal participation of capture and post-harvest actors in governance decision-making.

      Section 3.5.2 Access to and control over productive resources:

      • Paragraph 96: This paragraph considers that “Typically, breeding and crop management programmes largely work with male farmers”. There might be the bigger problem that typically breeding and crop management programmes largely work with the commercial sector, with big farmers, and ignore the needs of farmers in more marginal areas, the needs of rural people living in conflict areas, crop traits needed by the poor and the labour poor - gender is a part of this power imbalance. This needs to be reflected here.

      Section 3.6 Access to labour markets and decent work:

      General comment: It is important to incorporate social protection in the title (also referenced several times in the text under this section) as it is an integral component and currently problematically side-lined in the final section.

      • This should be ideally integrated within a new Section on Economic and Social Rights – Empowering Women and Girls.
      • Paragraph 106 (i): Concerning the “Legal framework to prevent and address violence and harassment in the workplace”. It should be highlighted that even in contexts when there is a legal framework in place, the justice sector often remains unable to effectively implement.
      • Concerning the “Redistribution of unpaid domestic and care work”: We usually refer to “equal sharing of care and domestic work between women and men”.
      • Paragraph 106 (i) and (iv): We note an overlap with Section 3.7, needs to be better combined.
      • Paragraph 106: Fisheries and aquaculture strategies should take the gender-specific divisions of labour into account (harvest and post-harvest). To avoid placing additional time burdens on women, the opportunities offered by aquaculture should be assessed from a gender perspective. Strategies must ensure that aquaculture can contribute to women’s empowerment.

      Section 3.7 Recognition, reduction and redistribution of unpaid care and domestic work:

      General comments: This section should be moved upfront since it is a fundamental precondition for a broader gender transformative approach, access to education, participation, economic empowerment etc. (See for example paragraph 113 (iii).)

      • In this section, a reference needs to be made to sexual and reproductive health and rights.Furthermore, there should be more emphasis on the linkage to social security here.
      • Paragraph 107: It is suggested that a reference should be made to the impact that the pressure on women to undertake paid work in addition to significant unpaid care and domestic work, is a key driver of the shift away from traditional and often relatively more healthy diets, to more convenient but highly processed food due to their non-perishability and cutting of food preparation time. This transition can have disastrous consequences for diets and nutrition.
      • Paragraph 111: We suggest to refer to “equal sharing of care and domestic work between women and men” instead of “equal redistribution of unpaid work between women and men”.
      • Paragraph 113: Concerning fisheries, we suggest to provide labour-saving technologies for domestic and fisheries work (i.e. ovens for fish processing, and more efficient processing and storage equipment); provide better infrastructure (electricity, refrigeration, running water, etc.) and services (transportation, health, extension, credit, child care arrangements at fish processing factories); in order to free up women’s time for taking advantage of new opportunities and for girls to attend school.
      • Paragraph 115: Aquatic food is important for both sexes and all ages, but particularly so for young children, pregnant women and women of childbearing age, due to the critical role of micronutrients and DHA+EPA in fetal and child growth and development. There is also growing evidence on the vital potential of aquatic foods to meet protein needs and reduce micronutrient and other nutrition deficiencies, improve heart, brain and eye health, and the important role of sustainable aquatic food system as part of the solution to current environmental and climate emergency. 

        Women’s participation as equal and productive partners in fisheries has significant impacts on household and community nutrition.

      Section 3.8 Women and men’s ability to make strategic choices for healthy diets and good nutrition:

      General comments: We welcome the incorporation of healthy diets in the title of this section.

      • We are concerned that this section works to frame healthy diets and good nutrition as standalone issues – when in fact these are outcomes that are fundamental to food security and nutrition and therefore the entire document. We suggest to consider this section incorporating in an expanded Food Systems section. The ability to make strategic choices for healthy diets is also undermined by food poverty and aggressive marketing.
      • Paragraph 114:The text in the problem statement of this section would provide important background and rationale in Part 1 of the VGs. A reference to girls and boys needs to be included.
      • Paragraph 115:The statement that “women and girls are more likely to suffer from different forms of malnutrition than men and boys” is misleading and requires reference to specific data regarding different forms of malnutrition. Interestingly, at no point does the current draft reference a gender analysis of poverty and food poverty in particular as a driver of food insecurity / unhealthy diets / malnutrition. According to World Bank, since poverty is generally measured at the household level, ‘what we know from existing data is that women account for about 50 percent, of the world’s extreme poor—although, this does not mean poverty is gender neutral’.
      • Paragraph 123: We suggest to incorporate sustainable aquatic food in food security and nutrition policies and food system strategies to address the triple burden of malnutrition (food insecurity, undernutrition and overweight) and to mainstream aquatic foods in healthy diets for children and women of reproductive age.

      Section 3.9 Social protection and food and nutrition assistance:

      General comment: We suggest that social protection should be incorporated within an expanded Section 3 on Economic and Social Rights. Currently this section, while containing some valid points, places undue emphasis on shocks, F&N assistance, school feeding, discrete programmes and schemes etc. It is important that the full scope of social protection and the priority for supporting the establishment of universal social protection systems is made central.

      • We recommend that attention to humanitarian assistance for food and nutrition be dealt within the context of a new section on gender equality and women’s and girls’ empowerment for FSN in contexts of humanitarian emergencies, crises and conflict.
      • Paragraph 128: This paragraph makes reference to breastfeeding in passing but given the significance of this agenda for food security and nutrition a more robust statement would be warranted. For example in the Voluntary Guidelines on Food Systems and Nutrition it is mentioned: “Governments should create an enabling policy framework, as appropriate, and supportive practices to protect and support breastfeeding, ensuring that decisions to breastfeed do not result in women losing their economic security or any of their rights. This should include promoting and implementing policies and programmes ensuring maternity protection and paid parental leave and removing workplace-related barriers to optimal breastfeeding (lack of breaks, facilities, and services).” (p. 23)
      • Paragraph 129: With respect to school meals in the context of external action, the importance of contextual analysis and broader consideration of ways to address multiple barriers to girls’ attendance should be promoted. In many contexts, the reality of education provision simply does not allow for effective and reliable provision of healthy school meals, and many of the most vulnerable who are unable to attend / regularly attend will be excluded. Crucially, school meals do not address the fundamental drivers of food poverty among families.
      • Paragraph 130:We suggest to also add nutrition-sensitive social protection (e.g. targeting nutritionally vulnerable population such as pregnant women and children under two) that mainstream aquatic food.

      PART 4 - IMPLEMENTATION AND MONITORING OF THE USE AND APPLICATION OF THE VOLUNTARY GUIDELINES

      Guiding question Nr. 4: Does Part 4 of the Zero Draft provide all the elements necessary for effective implementation and monitoring of the use and application of the Guidelines? If not, what do you propose to add or change?

      • More generally, it would be valuable to have an assessment of previous CFS Voluntary Guidelines and Policy Recommendations regarding uptake and value added, to strengthening lessons being learned and to inform this section accordingly.
      • Paragraph 131:It is suggested that this paragraph should make explicit reference to the progressive realisation of the right to adequate food as established in the fundamental statement of objectives of the guidelines in Part 1, paragraph 10.