Does Chapter 1 adequately reflect the current situation of malnutrition and its related causes and impacts, particularly in line with the goals and targets of the 2030 Agenda? What are the underlying problems that currently hinder food systems to deliver healthy diets?
It perfectly reflects the current situation of malnutrition, however, we believe (point 9) that it would be necessary to say that, in addition to the food choice, consumer's behaviour is key when it comes to reducing household food waste.
On the other hand, we believe that point (10) should mention the importance of promoting food environments with less pressure and exposure to unhealthy foods (low price policies, commercial offers and advertising), especially in groups with low income and lower educational level and health and food literacy.
Among the underlying problems that currently prevent food systems to deliver healthy diets, there are the high capacity of the food industry to influence consumers' food and beverage choices, the low profile of governments in implementing comprehensive food policies as regard consumers protection such as regulations to limit access to unhealthy food in school, workplace or health settings; the application of financial incentives and disincentives in food choice; the implementation of front of pack labelling systems to facilitate healthy foods choices; initiatives to improve consumer food literacy; agricultural policies that prioritize environment and health as well as economic sustainability; inclusion of more nutrition and dietetic professionals in multidisciplinary health teams; and policies to promote small farms production.
What should be the guiding principles to promote sustainable food systems that improve nutrition and enable healthy diets? What are your comments about the principles outlined in Chapter 2? Are they the most appropriate for your national/regional contexts?
The guiding principles are adequate and relevant, we just need to mention the term "food literacy" in the principle "Knowledge and awareness on nutrition", since it is a broader and more comprehensive term than "nutrition education", and because it takes into consideration aspects that affect food systems more clearly.
On the other hand, although there is no consensus on the definition of a "healthy diet", it is important to consider key aspects such as "contribute to promote, preserve or restore health at all stages and physiological situations throughout the life span", "It must be based on safe food mainly fresh and minimally processed, with little or no presence of other highly processed low nutritional quality" and "must be sustainable, adjusted to the culture of the people, affordable and tasty."
In consideration of the policy areas identified in Chapter 3 and the enabling factors suggested in paragraph 41 of the Zero Draft, what policy entry points should be covered in Chapter 3, taking into account the need to foster policy coherence and address policy fragmentation?
We believe that the identified policy areas are adequate, but we consider it important that some aspects are collected:
PART 1: FOOD SUPPLY CHAINS
Production systems - 43, section f: we believe that linking farms to schools is positive, but they should also be linked to the community by promoting short food chains so that access to food produced in the closest geographical environment is easier, while contributing to a lower impact on the environment reducing transport and promoting and protecting small producers value chains.
Handling, storage and distribution - 44 -, section a: Until such time as social measures are in place to ensure that food banks are not required we , we believe food donation in production and distribution settings should be encouraged, as well as facilitating the task of the Food Banks to receive and distribute safe and nutritious foods that are of low commercial quality, as well as study fiscal measures and / or incentives to the food donation.
Processing and packaging - 45 - We believe it is important to differentiate the terms "sugar and sugars" from "free sugars" and suggest that "free sugars" be mentioned instead of "sugar or sugars" as a substance to be limited together with industrially produced trans fats, saturated fats and salt.
On the other hand, in section a, national or regional policies conducive to the reformulation of products and recipes high in free sugars, satured and trans fats y/or salt should take into consideration the difficulty of most small and medium-sized enterprises to develop and implement measures to reformulate their products, compared to large food and beverage operators. An idea would be to have some funds or initiatives from sectoral associations to be invested in reformulation projects of SMEs.,
Likewise, we suggest a new policy-relevant area associated with packaging that guides front of pack labelling systems to facilitate healthier choices and/or alerting to those food and beverages that can contribute to an excessive consumption of salt, saturated and trans fats, and free sugars. The use of colour code schemes such as traffic lithg, nutriscore, etc., or symbols as keyhole, or alert octagons, all of them based in accurate nutrient profiling can help consumers to quickly compare the nutrient content of a given nutrient or the nutritional value as a whole of any food in the same category.
Retail and markets - 46, section b: in addition to policies to restrict the marketing of products with a high content of fat, sugar and salt, subsidies should be promoted which would facilitate the marketing and access to healthy food, especially those produced in the closest geographic environments.
PART 2: FOOD ENVIRONMENTS
Economic access - 49, section d: we believe that it is important to facilitate, from the legal and regulatory point of view, the donation of food in the different phases of the food value chain, as well as to facilitate the task to the Food Banks to receive and distribute safe and nutritious foods that have reduced commercial quality, as well as assess the application of fiscal measures and / or incentives for food donation. However, we believe that food banks should be a temporary measure until such time as governments introduce adequate social funding to ensure that people can purchase their own food.
Promotion and publicity. 51, section a: We believe that in addition to improving the school food environment, regulations and policies should be established to avoid food swamps in the immediate vicinity of schools.
On the other hand, we suggest a new policy-relevant area related to food waste, to review in depth the labelling rules that govern the use of “preferred consumption date” and “expiration date” as well as make an effort to train consumers in its correct interpretation in order to improve food safety and reduce food waste.
Quality and safety - 52, section b: national or regional policies conducive to the reformulation of products and recipes high in free sugars, satured and trans fats y/or salt should take into consideration the difficulty of most small and medium-sized enterprises to develop and implement measures to reformulate their products. Larger operators can more easily apply changes in the composition of food and beverages.An idea would be to have some funds or initiatives from sectoral associations to be invested in reformulation projects of SMEs.,
ART 3: CONSUMER BEHAVIOR
Education and information on food and nutrition - 55. In addition to nutrition training for health professionals and others involved in the provision of health services, it is essential that health systems have professionals with specific training in nutrition and dietetics, within the framework of multidisciplinary teams, since it has been proven to be cost-efficient. Dietitians are the key health professional to translate the science of nutrition and dietetics into practice, providing people with the most appropriate choice for their health and well-being, considering their culture socio-economic status and education.
Likewise, as mentioned above, it is important to incorporate the term "food literacy" as a key element in training consumers to make responsible health decisions associated with food consumption. Dietitians are key players in the food literacy of the people as well as in the development and implementation of public policies that facilitate access to healthy foods and ensure sustainable food systems.
Section b, on food-based dietary guidelines: - sustainability should be a criterion to be considered when establishing food-based dietary guidelines, not only for the promotion of consumption of food with a lower ecological, water, carbon and environmental footprint, such as fresh plant foods especially highlighting fruits, vegetables and pulses, but also incorporating tools to reduce household food waste.
Social norms, values and traditions - 56, section b: - traditional food culture should be the backbone of the development of food-based dietary guidelines, so as to promote traditional diets, popular gastronomy and to encourage the recovery of traditional varieties of foods which have lost market share to more commercial varieties
Can you provide specific examples of new policies, interventions, initiatives, alliances and institutional arrangements which should be considered, as well as challenges, constraints, and trade-offs relevant to the three constituent elements of food systems presented in Chapter 3? In your view, what would the “ideal” food system look like, and what targets/metrics can help guide policy-making?
Some examples of initiatives to facilitate compliance with the proposed policies:
- Civil society movements promoting food system based on new relations between consumers, small local food producers and rural communities, such as Slow Food.
- Urban farming initiatives integrated in most of the main municipalities’ strategic actions.
- Actions to improve soil health incentivizing the involvement of small farmers using soil-conservation agriculture methods.
- Awareness of food retailers and wholesalers to reduce GHG by promoting local products, improving access to organics, reducing plastics and promoting buying in bulk, providing eco and fair-trade food stuffs, etc.
- Making food chain shorter by promoting street markets where local farmers can sell their products.
- Reducing food waste and losses - Donation of food surpluses to social supermarkets to be given to people in need or selling them at low prices to general population, APPs to share food or selling "ugly foods" at affordable prices.
- Provision of sustainable diets by using green public procurement for school meals programs or hospital food services.
- Integrating sustainability as transversal topic in food based dietary guidelines as the Swedish Government does.
- National regulations to make food systems healthier, fairer and more sustainable, such as the newly French Food Bill also known as Egalim Bill which establishes comprehensive objectives for achieving sustainable food systems, including ambitious targets for the provision of organic food in public canteens, reducing plastics, a more robust legislation on animal welfare and regulation of the minimum prices and limiting mass-discount promotions in supermarkets, to avoid large distributors of foods setting prices that penalize producers.
Although many actions are currently carried out in order to lead us forward to a healthier and more sustainable eating, making a step forward is needed:
- There are many actions that are in our hands as reducing food waste, adopting healthier diets or supporting businesses with sustainable practices.
- There is robust evidence to integrate sustainability in national food based dietary guidelines. This could nudge governments to play a more active role to implement sustainable and greener public procurement, which have a strong power.
- Policymakers and government should be bold when introducing integrate sectoral policies that affect food production, processing, distribution, and consumption. They should regulate food systems not only to halt its impact on the environment but also to prevent obesity and other NCDs.
- Investing in Agri Technology is necessary to address climate changes and make farming viable for the next generations.
Consumer have the power to change food systems and dietitians are key agents to help and lead them towards a healthier diet and a more sustainable eating pattern by raising food literacy among population.
Ideal sustainable food system:
- Important aspects are the reduction in non-communicable diseases and financial burden of health care, protection of the environment, animal welfare and food security of the people, which will revert on the economy, equity and protection of culture, including food culture, especially of the minority and most vulnerable groups . The food sovereignty of the people is assured.
- In the environment, the use of renewable energies and the protection and recovery of the quality and safety of soil, water and air should guide actions in all policies, including infrastructure
- In health, it is important to focus on a diet based on fresh and no/ minimally processed vegetable foods, where foods of animal origin are incorporated considering their well-being. The reduction of food waste is a key pillar to ensure food security and food sovereignty.
- Equity is important in society to ensure the well-being through access to fair, environmentally friendly and healthy food systems. It should highlight the democratic participation of people in the social, economic and political system. Consumers have the ability and capability to change the food systems and they should be empowered to do it.
- The necessary infrastructure must be ensured for the welfare of people and access to healthy foods and health services, regardless of their economic and educational level. Infrastructures should facilitate global trade, but it is very important that the food systems have a local / regional approach, as this will be more aligned with the reduction of greenhouse gas emissions, the protection of local / regional economies and the maintenance of the food culture.
- The cultures and traditions of the peoples of the world in all their religious, food, gastronomy, etc., diversity, must be respected, even in a globalized world.
- Regarding health, the level of food processing should be considered as a key point directly related to the nutritional quality of food as well as equity in the economy and protection of the environment.
We do not believe that the focus of a sustainable food system should be the production of organic foods, since much more can be achieved by changing the food habits of consumers towards more moderate diets and based mainly on fresh and no/minimally processed vegetables foods, reducing consumption of meats and animal foods and reducing waste food. While it is true that food production systems must seek a balance between productive capacity and protection of the environment (water quality, soil, air and maintenance of biodiversity)
How would these Voluntary Guidelines be most useful for different stakeholders, especially at national and regional levels, once endorsed by CFS?
The key is the commitment of governments to adopt these guidelines gradually, but as quickly as possible, but we also believe that it is more important that civil society is empowered to motivate changes so organizations and stakeholders embrace these guidelines in their strategic plans and take measures to mobilize governments to achieve them.
Civil society has the capacity to change systems, but public policies (governments, public sector) are responsible for facilitating the implementation of sustainable and healthy food systems. We must aspire to a society in which citizens have sufficient health and food literacy and are exposed to environments where it is easier to follow healthy behaviours that enable them to reach the highest levels of health, regardless of their educational and economic level.
All the links in the food chain must work collaboratively and fairly, and the primary sector must be strengthened, be specially protected and its actors suitably trained to facilitate an adequate impact on small economies, social justice, the environment, biodiversity and culture of the people.
Thus, support to families, retailers and small and medium-sized companies, will facilitate fairer systems, which is fundamental to a more sustainable food system. Regulation must be a tool in the promotion of sustainable systems, but primary sector needs investments, public policies and training in advance, which would allow them to make a fair profit from their work.
Undoubtedly, it is a matter of food literacy, but there is no point in having the capability and willingness to act in a sustainable way, whether on the part of consumers, farmers, fishermen, etc., if the social, political and economic environment, does not facilitate easy to access to the tools to put into practice what we know is better for a more sustainable food system: affordable fresh and no/minimally processed food, evaluative labelling, healthier portion sizes, pricing policy for non-sustainable or unhealthy foods, affordable environmentally friendly supplies, promotion of non-harmful natural resources and techniques in agriculture, livestock, fishing, food industry, etc.
Mr. MANUEL MOÑINO GÓMEZ