Below are some considerations I would like to raise on behalf of IFAD on the draft Voluntary Guidelines.

Best regards,

David Suttie

 

1. On the current situation and underlying problems:

- In a context of divergent narratives and approaches to developing the types of food systems that may be thought to offer the best potential for promoting better nutrition, it is surprising that the guidelines have little to offer in terms of a broad macro-level vision of food systems – both prevailing and desired. For example, as detailed in the recently published HLPE report “Agroecological and other innovative approaches for sustainable agriculture and food systems”, it would be relevant to note that smallholder farming systems make important contributions to producing nutrients in the most populous and food insecure areas of the world, and that diversity of agricultural and nutrient production has been found to diminish as farm sizes increases (p.73). These phenomena are also noted in the background paper for the Decade on Family Farming, prepared by FAO and IFAD (see pp.6-7 at: http://www.fao.org/3/ca4778en/ca4778en.pdf). While not stating that large farms do not also have a role to play – clearly they do – it should be a concern that, given the importance of smallholder farms in maintaining diversity and nutrition in food systems, policy frameworks in many contexts are creating biases towards larger-scale farms and food companies – in terms of policies related to land acquisition, marketing, trade policies, and even food and safety regulations. While some important considerations are included in the draft in terms of supporting smallholders, there would be scope for acknowledging the macro-level situation and their present and potential role therein.

2. On the guiding principles and their focus: 

- Given the above, the concern of these guidelines should not only be addressing policy fragmentation (para 12) and promoting policy coherence (para 16), but in promoting policies that lead to the most equitable and inclusive outcomes in terms of advancing food systems that provide healthy nutrition for all. In many contexts, we arguably have a degree of policy coherence towards supporting food systems where (especially large, multinational) actors are enabled to make significant profits providing cheap and poor quality food to consumers, in many cases at the expense of smallholders and rural people who lose their rights to land and who are often employed under poor conditions on large plantations. So the issue is not only one of coherence, but also one of policies that promote equity and inclusion.

3. On the guidelines and policy relevant areas:

- Topics to improve consumer awareness, education and choices rightly feature in the draft. At the same time, there seems to be relatively little recognition of the working of markets and prices and how this skews consumer behaviour towards food that is not the most nutritious. Without markets that better reflect the true cost of food – taking environmental and social, as well as environmental costs into account – it is doubtful that it will be possible to change consumer behaviour to a sufficient extent, especially in the case of relatively low-income consumers. In this context, the issue of true cost accounting and reflecting how fiscal and trade policies, as well as those related to land, create inequalities and biased food markets needs to be reflected upon; on this issue, the comments provided by the Honourable Ambassador of Hungary below on true cost accounting are important and need to be taken into account.

- With rising urbanization levels shaping food systems and food demand, as recognized on p.18 of the draft, significant opportunities emerge in terms of promoting rural-urban linkages – both hard (infrastructure) and soft (institutional) – to enable local rural smallholder producers to supply nutritious food to urban residents. The resulting short value chains could reasonably be expected not only to improve nutrition outcomes in rural and urban areas – and maintain traditional healthy dies as opposed to shifting to diets comprising much highly processed goods – but to generate income among rural communities, thereby improving the purchasing power and nutrition of rural and smallholder communities, who are often among those most likely to suffer from undernutrition.

- Finally, it is slightly surprising that there is virtually no consideration of the role of indigenous peoples and indigenous food systems. Advantages of these systems in terms of diversity, nutrition, and agrobiodiversity are well-documented and have been alluded to in the comments by McGill University who provide a range of good recommendations on this topic. In particular, the fostering of indigenous knowledge, partnering with indigenous peoples’ organizations, and respecting their intellectual property rights are important considerations.