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

Dear HLPE Steering Committee,

Please find attached inputs and suggestions on the present V0 Draft.

Examples provided are largely from Bioversity International research and the experience of the Biodiversity for Food and Nutrition Project.

I apologize for the last minute submission and happy to provide further inputs in subsequent versions.

Kind regards,

Teresa Borelli

Hereby I send attached the commentaries of the Ministry of Health on the Draft V0 of Nutrition and Food Systems.

Best regards,

Rafaela Batista

Office for Advisory on International Affairs

Ministry of Health of Brazil

We would like to thank the HLPE for the opportunity to comment on this draft report. The draft is comprehensive and covers many important issues and aspects.

We find it essential that the important role of fish in food security and nutrition is adequately taken on board. Both from a health and sustainability perspective an increased consumption of sustainable produced fish is desirable. This work on nutrition and food systems should include reference to relevant past work of the CFS High Level Panel of Experts (HLPE). However reference to the only HLPE report that has been focusing on sustainable fisheries and aquaculture is missing. Consumption of fish and its addition to the diets, especially of low income populations and vulnerable groups, offers important means for improving nutrition. According to the CFS HLPE report: Sustainable fisheries and aquaculture for food security and nutrition (2014), the qualities of fish are not fully recognized in global food security and nutrition, even though fish can provide important nutrients to vulnerable groups such as pregnant and lactating women and children and poor people. Reference is also made to the recommendations in the CFS Global Strategic Framework for Food Security and Nutrition (GSF) which is: to give to fish the position it deserves in food security and nutrition and to make fish a visible, integral element in food security and nutrition strategies, policies and programmes.

Fish in aquaculture systems are efficient converters of feed into protein. Aquatic animal production systems also have a lower carbon footprint per kg output compared with terrestrial animal production systems Nitrogen and phosphorous emissions from aquaculture production systems are much lower compared with beef and pork. (HLPE report: Sustainable fisheries and aquaculture for food security and nutrition, 2014). Looking at the feed conversion rate, fish farming undoubtedly is the most effective production regardless of fish species. In this aspect aquaculture is a great contributor to global food security and nutrition. The draft report should reflect this.

We believe that responsible fisheries and aquaculture development will be key in achieving the 2030 Agenda. These sectors are important for several SDGs. As stated I the report from Rio+20 outcome document "The future we want": ‘Everyone has the right to have access to safe, sufficient and nutritious food’, and: ‘Healthy marine ecosystems, sustainable fisheries and sustainable aquaculture have a crucial role for food security and nutrition and in providing for the livelihoods of millions of people.’ Hence we encourage you to make the role of sustainable fisheries and aquaculture for food security and nutrition more visible in this report.

Dear Panel,

We welcome the first draft of this important report on nutrition and food systems and are grateful for the opportunity to participate in this consultation. 

Please find our contributions attached.

With best regards,

Jennifer Dias,

UN Advocacy Manager, Brooke

Dear HLPE Members,

Please find below and in attachment our comments for your kind consideration.

Best regards,

Zoltan Kalman

The issue of food security and nutrition is very important. This is why the request of CFS to prepare a report on Nutrition and Food systems is timely and appropriate. As various recent international events concluded, the food system is broken, it is mentioned also in page 23 of the zero draft, and it needs to be urgently fixed. A paradigm shift or a new way of thinking is required, to take seriously into consideration all the 3 dimensions of sustainability, because the “business as usual” scenario would further worsen the situation.

It is highly appreciated that a zero draft is provided for first comments also through e-consultation.

The zero draft is well structured; its content is sufficiently comprehensive, although there are areas which require more specific attention or need to be supplemented.

First of all, a clearer reference to the Agenda 2030 and to the interlinkages among SDGs should be the applicable context in which the topic of nutrition and food systems is addressed. Some examples to illustrate this:

The draft provides a comprehensive overview on the various drivers of food systems, including political and economic drivers. However, under this chapter the implication of adequate, nutritious and culturally acceptable food as a human right should be betterintegrated into the Report. In particular, it should be better defined the obligations and responsibilities of states or other actors (for example food industry). Furthermore, the Voluntary Guidelines on the Right to Food and the Voluntary Guidelines on the Responsible Governance of Tenure should be considered as basic references in this regard.

Among the political and economic drivers the role of food prices is analysed from various points of views, including the impacts of price volatilities on food security and nutrition. Not sufficiently addressed, however, the impacts of low food prices on certain segments of the population in some countries. More specifically, there is no reference to the sometimes existing link between low prices and low quality of food. It is a matter of fact that, as an immediate impact, low food prices are advantageous for the poor people. On the other hand, it needs to be considered that low priced food generally means less nutritious, lower qualityfood. This might have serious health impacts, worsening the food security and nutrition situation of affected population. As the UN Special Representative on the Right to Food properly said, “cheap (junk) food products are violating the human right to healthy food”. Low food price policies, in an indirect way, can lead to increased financial burden for thepublic health care. These (and other) externalities should be taken into due consideration and the Report should draw attention to the need for calculating the real costs of food and for more transparency in the whole food value chain. The Report could also refer to the positive social impacts of decent food prices paid to farmers. Furthermore, higher food priceswould help recognising the real value of food and having more respect for it, providing incentives for reducing food waste as well.

Another economic driver could be included as well, namely the profit-orientation. It is a matter of fact that in market economies profit is the main driving force. It is natural that farmers and all stakeholders of the food value chain are and should be interested inmaximizing their profits. However, it is the responsibility of national governments andregional economic integrations to create the appropriate economic environment to provide (positive and negative) incentives. To put it in a simple way, such environment should make food producers interested in fully respecting the environmental and social dimensions of sustainability and in producing healthy food at affordable prices. (Affordability does not necessarily mean cheap food but rather mean decent employment and wages. This is again an example of interlinkages of SDGs.) As part of this “appropriate economic environment” measures such as junk food taxes, bans for advertising unhealthy food for children, promotion of healthy, organic and local food could be recommended for consideration. Local food production and consumption are important elements of a renewed food system. Short food supply chains can assure full transparency and offer a win-win-win-win situation: good for producers (stable market, higher prices), advantageous for consumers (healthy food, affordable prices), beneficial for the environment (zero km, less use of chemicals) and for the whole society (healthier population, more local employment). 

In the process described above the international organisations (UN and others) should have a role as well, including through providing appropriate policy advice.

Finally, it is very much appreciated that documents and reports on nutrition and diets that have recently been released (such as the GloPan Foresight Report,) are being kept in consideration. It would be a value added if related documents prepared by the UNSCN, FAO, IFAD, WFP and WHO or others are considered as well.

More and more specific comments might be submitted at a later stage.

There have been several relevant and competent comments. My suggestion would be to follow the actions as recommended in the excellent and recent article by Haddad et al in Nature on the needed changes in food systems.

Everything is there, except perhaps that emphasis on capacity building is needed: nutrition capacity for food system people and food system capacity for nutrition people.

Dear Panel,

Please find my personal comments (not from my institute) below. I will be happy to clarify these if needed. And if needed, I will also be willing to contribute more to a next draft.

General

This is a very important and timely report. It is very relevant to assess present (and past and future) consumption patterns in the light of ‘food systems’ and the food environment. This having said, the report could gain strength by providing more evidence, be more conclusive, while avoiding to be biased. Please find below some quick comments, as unfortunately I did have time for a full review.

The report could even stress more that there are large differences in types of food systems, with huge implications for nutrition. While the notion of ‘food environment’ is important, it should be noted that there is a large difference between the implications of what a food environment means certain rural areas in developing countries where food production sometimes is largely based on subsistence farming, compared to an urban environment.  And within an urban environment, there is a large difference between richer and poorer countries, and also between richer and poorer neighborhoods. In case of regions with are still largely based on traditional food systems, the notion and large body of work around ‘farming systems’  might be of larger relevance.

While the report at one hand would need to take into account this notion of large differences, on the other hand the report cannot give ready answers for all situations. It is therefore more important to provide the readers/users of the report with some kind of relevant framework how to analyze their own situation (local or national food system), and identify potential points of intervention, than to try to cover everything. See for example the draft framework in the UNEP IRP report on Food systems and natural resources (Chapter 8).

1. Are those major objective(s) clearly reflected in the V0 draft?

I do not see yet a clean line of (evidence based) argument yet how food systems (and actors within food systems) influence dietary patterns. I would say that two lines of thought are important in doing so:

1) to acknowledge that food systems vary widely globally, implying that the analysis should also be specific per type of food system / region and 2) assess the business logic of actors within food systems (taking into account the diversity of food systems).

The sustainability issues are treated only quite briefly. For the sustainability / resource aspect, I would suggest to use the UNEP-IRP report Food systems and natural resources (2016).

I would be careful to explore to the question “what an ideal food system would look like” (p. 21, l. 15). The type of food system is largely determined by societal developments, and is hard to change. I would suggest to look within current food systems how nutritional (and environmental) outcomes can be improved.

I would suggest to put much more emphasis on food processors, retailers and food service. What is their business logic? A very important aspect is the processing of food: in general, the industry earns more many with more processed foods, which has led to a vast increase in the consumption of ultra-processed foods, starting in richer countries, now also in middle-income countries and more and more in LIC. The high consumption rates of processed and ultra-processed foods has an enormous impact on both human health as well as on the environment. In many cases (oil crops, cereals, etc) the best parts of the crop (minerals, proteins, fibers) are fed to animals, and human only consume the carbohydrates (oil, white bread and rice, beer, sugar, refined juices etc.).

2.

Do you think that the overall structure of the draft is comprehensive enough, and adequately considered and articulated? Does the draft strike the right balance of coverage across the various chapters? Are there important aspects that are missing? Does the report correctly focus on the links between nutrition and food systems without straying beyond that?

Chapter 2 (The Burden) is framed quite negatively. Maybe this could be framed more neutral, without of course understating this burden. But for many people the nutritional status has improved over the last 20-40 years. While large famines were more a less normal in the previous centuries, there are now many regions in the world were food security is not really an issue anymore.

3.

Does the conceptual framework need to be edited? Simplified? Should “the food environment” as defined in the draft be central to the framework?

No, I would suggest to put the idea of ‘food systems’  central in the report, with food environment being an important aspect. Maybe the conceptual framework of the UNEP IRP could be combined with the present framework.

Some other points:

• In chapter 2 other food related NCDs seem to be largely missing, as CVDs but also colon cancer and other diseases (for example alcohol related).
• Alcoholic beverages are largely missing: what is their effect on health, family incomes etc? Take for example the aggressive marketing of beer, and high pressure in some groups to drink beer in many countries.
• Paragraph 3.2 needs more elaboration
• Future developments seem to be a bit scattered over the report.
• The food service sector is largely missing (restaurants (from large chains to street vendors), caterers, food in institutions as schools, hospitals, work, prisons etc.). In many countries, the out-of-home consumption is more than 50%.
• Typologies of food systems: see the UNEP IRP report. On Food systems. It is also important to note that food systems are interlinked, by trade, cultural exchange etc.
• The trade section seems to be a bit biased. Trade is important for countries with limited production potential, it can help to mitigate production shocks, it can help to diversify diets etc.
• The food system is depicted (see for example page 69) as a linear one-way system, while in reality it is a two-way system, with many feedback loops.

With kind regards,

Henk Westhoek 

Program manager Agriculture and Food

The draft report provides an excellent starting point and is comprehensive in it's scope.  we have made detailed comments and suggestions in the attachment 

The importance of increasing yield both quantitatively in kilograms (or calories) and qualitatively (in nutritious value, providing not just calories but essential proteins, micronutrients and vitamins) deserves more attention. Supporting farmers to encourage implementation of innovations to improve current agricultural production systems is imperative.

Providing farmers with access to quality inputs, in particular fertilizers, and the knowledge to apply them efficiently and effectively over a long period of time is the first step enhancing economic and environmental sustainable food security.

The report was reviewed with high interest. It is very well structured and informative. It is not too technical or to simple.

Nevertheless the Austrian Federal Ministry of Health and Womens´s Affairs (Departement III/8) wants to highlight some very important points which need further consideration.

The links between environment and nutrition are of high importance for present and future measures which try to improve nutritional status and behaviour. For this reasons it would be important that this report does contains more information and scientific data about:

- Marketing to children and the different approaches how it could be limited

- The role of producers and enterprises. They also have to contribute to a healthy nutrition in the context of under AND overnutrition. Different approaches of how they could contribute (e.g reformulation initiatives, stop marketing to children respective stop marketing for HFSS) should be highlighted.

- The role of environments which contribute to healthy and adequate nutrition (e.g healthy school lunches, food in hospitals and retirement homes).

This report contains of course a big section about undernutrition. Austria highly recommends to also focus on mechanisms which contribute to undernutrition in western countries. E.g inadequate nutrition in hospitals and retirement homes.

We are pleased to contribute by sending the draft White Paper of the Animal Task Force that will be published next Dec 19. This consists in a strategic research and innovation agenda for a sustainable livestock sector in Europe, including suggested priorities for research for Horizon2020 2018-2020 Work Programme, to enhance innovation and sustainability in the livestock production sector of Europe's food supply chains.

It includes an introduction summarizing i) current challenges faced by animal productions in Europe, ii) the livestock's role in realising a sustainable circular bio-economy for Europe and iii) the importance of supporting innovation, sustainability and competitiveness in Europe's livestock sector.

Please find attached short and full versions.