Dear FSN Moderator
Thank you for the opportunity to comment on on the first draft work programme of the UN Decade of Action on Nutrition. I write to comment specifically on the second posed question, ‘What are your general comments to help strengthen the presented elements of the first draft work programme of the UN Decade of Action on Nutrition?’
I fully endorse the programme’s Action area 1: Sustainable, resilient food systems for healthy diets and its recognition in points #19 and #20 of the need for sustainable food systems that promote healthy and safe diets. However, it is a concern that the programme also includes in certain places a focus on a reductionist approach to nutrition science, i.e. a focus on nutrient-based interventions, in potential conflict with the systems and dietary patterns approach emphasised in Action area 1. For example, Table 1: Potential topics for the development of commitments and the establishment of action networks, lists ‘Food reformulation’ as one of its first mentioned topics. In this context, food reformulation, an intervention in which the nutrient profile of food products is manipulated, is being proposed as a solution to nutrition problems that are predominantly a consequence of dietary excesses and imbalances and which in turn are predominantly determined by social and ecological circumstances. Such an intervention is a simplistic response to complex food and nutrition problems.
Also, food reformulation has risks because it has the potential to undermine the promotion of food systems and food-based dietary guidelines. Not only does it risk diverting attention away from dietary pattern, and food systems approaches, but also it risks framing potential solutions to the benefit of ultraprocessed (junk) foods and to the detriment of nutritious whole foods. For instance, in Australia we have a flawed front-of-pack labelling system (the ‘Health Star Rating’ system) that inappropriately rewards the reformulation of ultra-processed foods with so-called health stars. Here the problem is that the manufacturers of ultraprocessed foods such as high-sugar snack foods can reformulate their products by moderately reducing the product’s sugar content to attract a relatively high star rating despite the product remaining an ultraprocessed food.
Perversely, whole foods such as fresh fruits and vegetables which the Programme highlights as core components of a healthy diet, are less able to be reformulated and as a consequence, less able to compete against ultraprocessed foods in the implementation of many food reformulation interventions. In certain circumstances food reformulation may have a limited role, e.g. supporting the reduction on the salt content of bread, but it is a relatively low priority intervention and requires careful management to avoid being exploited for non-nutrition agendas.
Professor Mark Lawrence
Deakin University
Australia
Prof. Mark Lawrence