Dear all,
I welcome the initiative for those guidelines.
My first comment is about the name: guidelines are by definition voluntary, so it is not neccessary to include 'voluntary' in the title.
Background and rationale.
The focus is on health, missing in 9. a delivering of helathy diets and reduce their impact on the planet, and in 10. diets that meet the planetary boundaries.
One of the objectives (18.) should include the discourage of overconsumption and the prevention of obesity.
21. Not only issues on genetic resources, but also natural resources and minerals.
Key concepts: please add the FAO (2010) definition on sustainable diets.
Overall add healthy and sustainable diets (36e, 41, 43b)
43b: minimizing the inputs, but also the outputs (pollution, greenhouse gass emission, etc).
43c: Sustainable use of agrodiversity, does also mean fitting into local climate, soil and water resources. Missing the issue of soil degradation,
43i: Climate change also affects the harvests and yields.
44. About food waste. For consumers proper cooking, preparationg and shopping is also crucial. Policy relevance in more higher income countries has to focus on the issue of food waste in households (as main waster) by policies on smart shopping, storing and preparing.
45. Packaging should also refer to the importance to reduce the impact on the environment and the promotion of recycling.
46b focuses on the production of local foods. This should include foods in season accomplished with some food from other regions with the lowest impact on the environment.
Restrict the marketing of products high in saturated fats, added sugar and salt. Essential fatty acids should be promoted, as wel as fruits with natural sugars.
51b. There should also be transparancy on environmental labels, including independent audits and high standards.
55b. Please add as example onfood based dietary guidelines, that more and more countries include guidelines on sustainability issues, i.e. promoting fresh, local and seasonal products and not ultraprocessed foods and promoting a balance between protein from plant-based sources and animal-based sources.
55.c Nutritional education could include production methods, school gardens and increasing connections between producers and cosumers.
M. Corné van Dooren