I was especially interested in reading the FFA because I am actually working at the French Food Safety Agency  (ANSES) on up-dating the recommendations of the  French National Nutriton-Health Program. As such, my comments are more orientated on malnutrition ( that is to say : unhealthy nutrition not by lack but by excess and bad quality)

1-General comment: All the important issues are covered, with taking into consideration traditional eating habits and locally produced foods to serve as a basis for nutriton recommendation. Also, the draft recognises  that food is situated at the crossing of health, environment and society.(see fig attached)

Comments on Chapter 2: the most importance sentence is : strategies should adress the  people’s dietary sources and the context in which these choices are made: this is very important because advertising and large accessibility are determinant factors in the environment

Comments on chapter 3:

  • 3: Actions  
  • 3-1 Use traditional food systems. It is important because it is difficult to modify food behaviour.
  • Education with school gardens is also important to sensitise children to food
  • and food quality.
  • 3-1-1 reduce sugar in non alcoholic beverages: sugar per se is not obesogenic, but drinking sweet or sweetened beverages only adds to the energy intake without self-restiction linked to satiety. Therefore it is also a behaviour to be changed for drinking water
  • 3-1-2 the proposed actions for sustainable healthy diet are somewhat insufficient: the word contaminant is not pronounced, when we know that several "agro-chemicals" are involved in obesity development
  • Develop local nutritous varieties and promoting locally available and affordable foods improves the food environment
  • 3-2: a transversal aspect of social protection which deserves reinforcemnt is the maximisation of the social impacts of Food environment
  • 3-3 Health: Most of the priority actions are directed to malnutriton meaning deficiency in macro or micronutrients and not to unhealthy diet, obesogenic for which bad quality and/or contaminated transformed food a prominent cause together with unbalanced energy intake. And here is a big absent in the priorities: physical activity . Most European countries uderstant food and physisvcal activity under the word "nutrition"

No comment on chapters 4-5

2-Does the Framework for Action adequately reflect the commitments of the Rome Declaration on Nutrition, and how could this be improved?

Yes but it appears somewhat insufficient with regard to the developpment of obesity and NTDs in some developping countries. The need to access to physical activy and practice it has been mentionned in my comment on 3-3

3-Does the Framework for Action provide sufficient guidance to realize the commitments made?

Yes, but some might be difficult to realise

4-Are there any issues which are missing in the draft Framework for Action to ensure the effective implementation of the commitments and action to achieve the objectives of the ICN2 and its Declaration? 

Missing issues pertain to the development of obesity and NTDs: Physical activity is absent. Sustainable agriculture and healthy food processing and transformation by food industry is insufficient