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

Swiss Comments to the HLPE Report and answers to the questions

In order to strengthen this draft, the HLPE would welcome submission of material, evidence-based suggestions, references, and examples, in particular addressing the following important questions:

1. The purpose of this report is to analyse the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft?

There are many interesting views and graphics in this report. The reader can understand well the complexity of food systems and especially of how to make them more sustainable and improve nutrition globally.

We particularly appreciate that a focus is given to the links between nutrition and trade policy instruments, bearing in mind their significance in shaping food systems, and yet often not being articulated enough. We are of the view, that all instruments having a particularly negative impact on food systems of net food-importing developing countries should be addressed.

The consideration of nutrition and diets through the report lack the sustainability criteria, in its economic, environmental and social dimension. Yet these criteria are essential elements to apprehend the interconnections and linkages between humans, their health and environment. In order to make food systems more sustainable by policies and programs, it is crucial to include the social and economic dimension of sustainability, and consider the whole food chain, including the production level. Food production - and thus food security - relies on a natural resource bases that is becoming increasingly more fragile and scarce, and that is extremely vulnerable to climate change as well as biodiversity loss.

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?

The following aspects are not stressed enough from our perspective:

• Education and Knowledge: Education and knowledge creation of the different actors along the whole value chain is not given appropriate attention, despite its importance to improve nutrition. Enhancing knowledge must encompass diverse aspects such as human rights, safety of workers, food safety, or retail to the final consumers as well as food literacy, cooking skills and the understanding of nutritive value throughout the food chain.
• Gender: The section on gender in the report is entirely about women. We consider it important to also reflect about the role of men for improving nutrition. This includes their role for women empowerment but also beyond.
• Humanitarian Aid/ Protracted crisis: An important dimension not yet covered by the report is challenges and opportunities for Nutrition and Food Systems in protracted crisis and in humanitarian food aid programs in general.
• Farmers and Food producers: Even though the focus can be on consumers, producers are key to any solutions leading to any sustainable and healthy nutrition and food systems.
• Investment: the effects of investments into agricultural production, infrastructure and trade on nutrition outcomes should be mentioned and developed further as they form an important part of a favorable or unfavorable food environment.
• Collaboration approach:  Multistakeholder initiatives are not yet mentioned, as well as the Sustainable Food Systems Programme of the 10YFP as one key Multistakeholder Programme for Food Security, Nutrition and sustainable food production and consumption.

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

The causal links within the framework are not very clear (p. 14). It seems diets are only influenced by consumer behaviors which again are influenced by food environment. However, if someone has not access to nutritious food and therefore changes his/her diet this cannot be considered results of consumer behavior only, but the dietary choice is influenced by the food environment on his diet.

We think the conceptual framework could gain significantly in clarity if the “Food Environment” is central to the framework. This may help to show interdependencies and feedback loops in given food system more clearly, cross-sectoral, integrated and therefore comprehensively. And at the same time keep the framework clear and simple not to hamper understanding.  

4. Are production systems and their role in shaping diets and nutritional outcomes adequately addressed?

We appreciate the link made between agricultural production subsidies, divers primary production and nutrition (p.56) and would suggest to replace the term “agricultural production subsidies” with policy instruments to cover the full range of influencing measures.

However, we think that actors in the production system still don’t get enough focus, such as producers (in particular farmers), investors, and commodity traders. Farmers are at the heart of any sustainable and healthy diets and should be included in this report as producers but also as consumers. 

5. Does this draft cover adequately the main controversies in the field of Nutrition and food systems? Are there any remaining gaps?

A reflection on marketing/ advertisement of unhealthy food and beverages and the role of media should figure in the section of “economic drivers”, given the importance of these factors in influencing changing diets (p.50).

In the area of sustainable consumption, the importance of label and non label approaches should be explored. For example Multi-stakeholder sector initiatives like the Round Table on Responsible Soy, the Better Cotton Initiative or the Sustainable Trade Initiative can contribute to market transformation by setting new standards for entire sectors. However, other and non-label based approaches to enhance shared/equitable valorization and sustainability should be explored.

6. The project team is working on a categorization of food systems. Are you aware of specific approaches of use in that perspective, and particularly of quantitative indicators that could be used?

Typologies of Food Systems (p. 21 ff)

Appreciating the attempt to categorize Food Systems into typologies, the list of elements relevant to a food system as well as the list of indicators proposed seems not yet comprehensive or representative.

The table on p.22 may have to better reflect the aspects of a food system influencing consumer behavior and final diet composition, beyond what is currently described as food environment. The policies, programs and institutional actions influencing food environments and thus consumer behavior and diets are not satisfyingly incorporated in the current proposal of elements to be assessed. As this classification will serve to observe trends and changes, it seems crucial to capture this dimension well.  

A few concrete proposals on expanding the indicators are mentioned below:

• Element Production: As policy instruments are actively shaping agricultural production priorities, volumes as well as production methods, it is crucial to include an indicator assessing the public investment for making primary production more divers and nutritious. We therefore suggest developing an indicator which assesses which policy instruments are existing and putting them into relation to each other regarding financial volume (and possibly also their contribution to world trade): One could imagine the following categories of subsidy schemes relevant for nutrition
  • Policy instruments promoting the (over-) use of agricultural inputs (seeds, fertilizers)
  • Policy instruments dedicated to support beans, fruit and vegetables production
  • Policy instruments dedicated to promote staple crops (maize, rice, wheat)

• Element Processing/ Packaging: Fortification may be one cost effective approach to some nutrient deficiencies, keeping fully in mind that malnutrition cannot be mainly approached by filling single nutrient gaps. Furthermore, legislations aiming to avoid the production and presence of unhealthy food items on the market are equally crucial and information on it needs to be gathered.
  • Make the “Fortification legislation” Indicator more comprehensive and include salt iodination (besides wheat fortification)
  • Assess the existence of legislations which define the maximum content of ingredients classified as unhealthy when consumed in high quantities, such as trans-fat, sugar, sodium, etc.

Element Food access: Besides FIES, there may be an additional indicator which reflects more directly on the accessibility of healthy nutritious food items, like fruit and vegetables.  Include the following information in form of indicators:

• Number of servings of fruit and vegetables consumed per day
• Share of Fruit and Vegetable sales on food sales in general (in volume and financial)

• Element Information and guidelines: Food Based Dietary Guidelines (FBDG) are vital not only to shape consumer knowledge, awareness and habits, but also to inform policy measures.
  • Include an indicator on the existence/absence of nationally/regionally adapted FBDG (WHO)

• Element composition, quality and safety: The two proposals on assessing percent of calories coming from food groups (1. Fruit and vegetables, 2. Animal protein) are both addressing nutrient adequacy issues, but neglect the dimension of challenges leading towards overweight/obesity. We therefore advocate for identifying an additional suitable indicator which captures the unhealthy share of calories consumed.
  • Percent of calories coming from ultra-processed food, Food related to NCD’s (for definitions, see publications of Carlos Monteiro and/or Dario Mozzafarino)

7. Does this draft adequately show the multiplicity and complexity of diets and nutrition issues across different food systems and specific contexts with a good regional balance?

8. What areas of the document are in need of strengthening or shortening

As seen in the section on Typologies of Food Systems, having adequate indicators and data to measure changes in Food systems is vital and yet a big challenge. This report may stress further the need of better and more globally available data on indicator relevant to observe the sustainability of food Systems.

Develop further on the solution of strengthen direct food sales and marketing from producer to consumer to increase food security, nutrition, fair price and sustainability. The impact of well-designed nutritious school feeding programs may also be further elaborated in this view, highlighting on the impact as well as policies required and the potential on supply chains with smallholder farmers in the center.

The importance of responsible investment (in agriculture and food chains) should be strengthened in the report.

A lot of emphasize is placed on various definitions, which is important to understand the background but which leads to some redundancies that should be prevented.

9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich the report and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win outcomes in terms of addressing the different dimensions of diets for FSN?

10. Section 4.2.2 on “Institutional Changes and Governance Across the Food System Movements for Nutrition” requires more work, and more inclusion of evidence and of the various players. Any inputs on this section are most welcome.

If this report really would like to be solution oriented and highlight efficient policies and programs it has then to include a specific chapter on Collaboration issues and Partnerships, and in particular multi-stakeholder initiatives, as these are essential to address the multiple challenges of food systems and Nutrition. Food systems are simply too big and complex to be tackled by any single stakeholder group in isolation. Moreover, SDG 17 specifically underlines their importance.

In the area of sustainable food systems, the Sustainable Food Systems Programme (SFSP) of the UN 10-Year Framework of Programmes on Sustainable Consumption and Production (10YFP) represent one of the main comprehensive Programme worldwide and should therefore be mentioned in the document. This Programme is a multi-stakeholder initiative to accelerate the shift towards more sustainable food systems, aiming to promote sustainability all along the entire food value chain, from farm to fork. The Sustainable Food Systems Programme has a network of already more than 100 members around the globe. They work together to develop and implement concrete projects on the ground in the areas of awareness raising, capacity development, facilitating access to knowledge and information, and strengthening partnerships. The Programme will for example disseminate knowledge on sustainable diets, and it will promote information for consumers enabling them to adopt more sustainable dietary habits promote information for consumers enabling them to adopt more sustainable dietary habits. A strength of the Programme is that it brings together existing initiatives and partnerships working in related areas, highlighting success stories and building synergies among stakeholders to leverage resources towards mutual objectives. For further information on the SFSP of the 10YFP: Website: http://www.scpclearinghouse.org/sustainable-food-system; Email : [email protected]

11. Is the report too technical or too simplistic? Are all the concepts clearly defined?

The report is definitely not too simplistic, rather too technical, if it aims at addressing new audiences not yet well familiar with the issues.

From a communication perspective, the report is way too long and therefore risks not to be read by the audience aspired. Attention shall be given to make it easy readable and avoid redundancies. An excellent summary will be vital to reach the urgently needed new public outside the nutrition community.

12. Are there any major omissions or gaps in the report? Are topics under-or over-represented in relation to their importance?

The report and its content shall be well linked into the Agenda 2030 and the agreed SDG’s.

The research chapter 4.2.4, shall stress more on the importance of Systems Level research, like studying the management of food systems, nutrition sensitive value chain approaches, impacts on nutrition outcome of more diverse production systems, impacts of public regulations, potential and impact of private initiatives to improve sustainable food systems and to secure adequate producer and consumer prices for fresh, healthy and nutritious food; produced, processed and consumed in a sustainable way.

Chapter 4.2.1 instead of focusing on technology, could broaden it perspective on a mere innovation perspective, which would include other kind of promising approaches accessible to smallholders too, such as improved varieties of local crops. In or after the chapter “movements for nutrition” there shall be a paragraph expressing the views and possible contributions of farmers and their organizations.

References are partially not very recent, especially taking into account that the report will only be launched in 2017. This can make the report already out of date when it is issued, what is not wanted.

One aspect that should be mentioned and developed is the importance of informal economy and market, including informal production and accessibility of food (outside the usual market) such as self-production and informal access to food, for example through exchanges of goods. The question of local self-produced nutritious food (food production for self-consumption) is not mentioned, while it represents a substantial part of agricultural production in Southern or Eastern countries, especially in cities, but also – increasingly –Northern countries, especially those in crisis. This kind of production is also increasingly linked to urbanization as it can now be found on roofs, along roads, in community garden, in parks and vacant land; directly in the land or in various containers. Such production is mainly composed of vegetables but can also include eggs, milk and meat.[1]

Further comments to the draft:

p. 18, line 23: there is a new publication by WHO EURO on this topic: WHO (2016). Tackling food marketing to children in a digital world: trans-disciplinary perspectives.

p. 30, line 19 and page 31, line 5: the numbers on obesity and overweight are not coherent with the introduction chapter (page 9, line 8) or within the chapter due to numbers from different sources. Please make sure that numbers are consistent.

p. 44, line 1-13: For readers not familiar with the concept of planetary boundaries it would be helpful to have a box, illustrating the nine planetary boundaries and the consequences of crossing these boundaries.

p. 46, line 11-19: This is a repetition to page 45, lines 28-34

p. 48, line 10-29: repetitions in line 12f and line 28f

p. 49, chapter 3.2.2: There is not much on research here.

p.50, line 7: In the context of what has been said before, the last sentence of this paragraph is biased, as built environments can also be developed in a way that can favor healthy dietary patterns.

p. 50, section on social networks and movements: this section deals with international policy and collaboration at international level. As it is rather related to politics, one could consider putting it under chapter 3.2.3. Political and economic drivers

p. 66, Figure 26: The graphic is very complex and not easily understandable. The numbers need further explanation for “non-statisticians”.