Action Area 1: Sustainable, resilient food systems for healthy diets
- Scale up the inclusion of nutrition objectives in food and agriculture policies: increase production of context-appropriate fruits and vegetables for domestic consumption, and of legumes and pulses that contribute to healthy diets; raise production of oils in support of the elimination of industrially produced trans-fat in the food supply. [First of all, I find it devious that here you use the verb scale up in almost all action areas while in the survey you have the original verbs. The reference to SUN is, as I say, devious]. Wording on elimination of transfats must be stringer here.
- Accelerate food reformulation: provide reference ranges for sodium reduction level benchmarks for processed foods. Reformulation applies mostly to ultra processed foods. This is no solution, it is the white washing of Big Food to keep the public hooked to their products. World Nutrition has articles that make this plenty clear.
- Accelerate strengthening food control systems: implement national programmes for surveillance of food-borne diseases in humans and contamination of food-borne hazards in the food chain.
Action Area 2: Aligned health systems providing universal coverage of essential nutrition actions
- Scale up the integration of nutrition actions into health systems: integrate essential nutrition actions into national Universal Health Coverage (UHC) plans. UHC has been a controversial theme with public interest CSOs and social movements having a different take on it than WHO. Yes, nutrition is important in there.
- Address funding gaps: increase investments for nutrition in UHC, including for integrated data systems for tracking coverage and quality of essential nutrition actions. What are essential nutr actions? Do we all agree on these? No. Tracking only chronicles trends; what is needed more is actions …and we know a lot already.
- Accelerate progress on wasting reduction: implement the UN Global Action Plan on Child Wasting and its Roadmap.
Action Area 3: Social protection and nutrition education
- Scale up the implementation of nutrition-sensitive social protection policies: ensure coherence between social protection and other sector programmes such as with agricultural production, livelihood diversification and local economic development; national supplementary food bank programmes provide weekly vouchers to each user for purchase of fresh fruits and vegetables from local farmers. Nutr-sens social prot pols are nothing but the social determinants of (mal)nutrtion that the UN system has NOT embraced. It is only secondarily about coherence; it is about the social determination!
- Better leverage of schools as a platform for food and nutrition education and enabling healthy diets: set and improve nutrition standards for school meals. What is leverage? Keep in mind that school meals are mostly an educational intervention (retention), not so much a nutritional one. (stunting is already done for… any data on improving wasting?)
- Accelerate building nutrition capacity: increase the number and quality of nutrition professionals; train healthcare workers to better deliver nutrition action across the life-course. The key here is the content of the curricula. The ones currently there are biomedical and nutrient-centered. …not much help.
- Scale up the implementation of nutrition education interventions: implement easily understandable nutrition (front-of-pack) labelling on food products that supports consumers’ choices for healthy diets. Same as above: the content of this education is the key. Needs to change to include social determinants. Front of pack info is just a tiny part of the challenge (not very helpful for rural populations important sufferers of malnutrition)
Action Area 4: Trade and investment for improved nutrition
- Accelerate responsible and sustainable investments in nutrition: a minimum percentage of the overall national governmental yearly budget is set for nutrition interventions. Something to be said here about curbing Big Food/Big Soda investments in junk.
- Scale up the implementation of nutrition-sensitive trade policies: establish a national task force represented by different sectors for assessing the coherence between national trade policies and the implemented nutrition actions. FTAs have quite consistently been negative for nutrition. Throwing a task force at them (even if multisectoral) will do little. It is politico-economic issues that control these SECRET negotiations.
- Strengthen partnerships for data collection and development of tools: global institutions to continue to improve data collection and develop methods and indicators to better understand trade policy impacts on nutrition. What tools? Partnerships of EQUALS are certainly not the norm. Look at SUN… Data collection (only by global institutions?) on impacts of trade policies is a-posteriori, so, what good? Just chronicle negative impacts? Will that help in future negotiations?
- Accelerate public investments in local food supply chains: gradual increase yearly public sector government budget for investments in cold chain technology and post-harvest handling of perishable foods.
Action Area 5: Safe and supportive environments for nutrition at all ages
- Scale up the implementation of regulatory instruments to promote healthy diets: introduce taxation of sugar-sweetened beverages and subsidies for fruits and vegetables; implement legislation of marketing restrictions of foods and beverages high in fat, sugar and/or salt to children. Scale up? Hardly much exists. Be aware that the concept of healthy diets was contested by CSM during negotiations of the Voluntary Guidelines on food systems. CSM lost on this and on many other red lines it set. Parliamentarians have been absent in most of the advocacy work, so how will we get the needed legislation? Corporations lobby parliaments much more effectively!
- Scale up the implementation of nutrition-sensitive public food procurement policies: set food and nutrition-based standards for the food and meals provided in hospitals, care facilities and other public settings. Does this also apply to the general public? Are you talking about nutrients or food and meals for the latter?
- Scale up the implementation of national dietary guidelines: include in national dietary guidelines for children, adults and elderly biodiversity and sustainability considerations. I’d say NOVA MUST be mentioned here as the preferred alternative.
- Scale up the implementation of nutrition-sensitive policies for improving local food and nutrition environments: introduce zoning regulations and tax regimes to minimize food deserts and swamps. Again, you are skipping the social determinant by mentioning them by name, because they ARE part of the ‘F+N environment’. The role of aggressive penetration of UPfoods in deserts/swamps must be denounced here.
Action Area 6: Strengthened governance and accountability for nutrition
- Enhance political commitment through political dialogue and advocacy at national and sub-national levels: establish and strengthen coordination mechanism through a multistakeholder consultation process for the uptake of the CFS Voluntary Guidelines on Food Systems and Nutrition. Who will do this? us? We have a pretty dismal record, no? Is it not organizing and mobilizing claim holders that we have a real chance for changing this politically? Claim holders have never had level field dialogue with duty bearers and they have to achieve such equal level. The UN (and SCN) say they are human rights based, but are they? HR/RTF are not mentioned once in this action for the next 5 yrs… And, please, as a respect to a high proportion of us out there who opted out from the Guidelines, do not use ‘multistakeholder’ in this action plan.
- Address research funding gap: increase investment for research on the adaptation of global recommendations to the country context to support capacity development for implementation.
- Scale up investments in national nutrition information system: establish and strengthen a national nutrition monitoring framework in line with global guidance and the SDG monitoring framework in order to identify challenges and gaps for informed and effective policymaking. Again, info systems are only good if the data are used. Can we say this has been the case in the last 50 yrs? Hardly. We keep good statistics on how bad things are, yes. We know the gaps. Quantifying gaps does not automatically result in ‘informed and effective policies’. I am not saying we do not need this, but coupled with what? This is the challenge for the next 5 yrs of the (ailing) Decade.
- Accelerate global governance and accountability: use global summits such as the UN Food Systems Summit 2021 and the Tokyo Nutrition for Growth Summit 2021 for setting new commitments for action on nutrition and streamlining the global nutrition accountability infrastructure. Accelerate?? The global governance and accountability in F+N badly needs replacement, not acceleration. Look at the role of the conflicted private sector in SUN in glob gov. Furthermore, please keep in mind that a high proportion of us out there have opted out from the FSS for reasons widely explained. If the next 5 years will be guided by outcomes on the FSS, we are doomed. I think colleagues at the UNN know this.
I THINK TOO MANY ACTIONS ARE ASPIRATIONAL AND ARE TOP-DOWN. WHERE IS THE CONSULTATION HERE (IN COMING UP WITH THIS SO FAR) WITH THE REPS OF THE AFFECTED POPULATIONS?
Dr. Claudio Schuftan