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

World Cancer Research Fund International welcomes the opportunity to comment on the Decade of Action's draft work programme - please find our submission below. 

Submission by World Cancer Research Fund International to the UN Standing Committee on Nutrition’s consultation on the Work Programme of the UN Decade of Action on Nutrition, 2016-2025

World Cancer Research Fund (WCRF) International welcomes the opportunity to provide comments on the work programme of the UN Decade of Action on Nutrition (hereafter ‘the Decade’).

WCRF International is the world’s leading authority on cancer prevention research related to diet, weight and physical activity. Our vision is to live in a world where no one develops a preventable cancer. Through our policy and public affairs work we advance the development and wider implementation of effective policies worldwide to help people reduce their risk of cancer and other non-communicable diseases. WCRF International is in Official Relations with the World Health Organization.

For further information contact [email protected] and www.wcrf.org.

Does the work programme present a compelling vision for enabling strategic interaction and mutual support across existing initiatives, platforms, forums and programmes, given the stipulation of Res 70/259 that the Decade should be organized with existing institutions and available resources?

• Overall, WCRF International welcome the emphasis on addressing all forms of malnutrition (stunting, wasting, micro-nutrient deficiencies and overweight & obesity), a focus on a food systems approach based on scientific evidence, the promotion of coherent national, regional and international initiatives and SMART policies, the effort to convene, coordinate and consolidate existing nutrition efforts across multiple sectors and actors, and the intention to develop improved accountability frameworks.

• Unfortunately, the roles and responsibilities remain vague, accountability issues are not addressed in detail, and the ‘how’ remains to be detailed - for example para. 13 does not outline how the Decade will ‘engage and support all sectors of government’ and help prioritise funding and action.

• In order to enable strategic interaction, there is a need to have more of a focus on mobilisation of financial and policy commitments, more concrete outlines of specific actions, timelines/time commitments and next steps.

• Para. 3: In addition to reference to SDG 2, we believe that the work programme should include a reference to SDG target 3.4: By 2030, reduce by one third premature mortality from NCDs through prevention and treatment 2 and promote mental health and well-being. In that way, the Decade promotes a coherent approach to tackling malnutrition in all its forms and the double burden of malnutrition by linking SDGs on health and nutrition.

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?

WCRF International believes that the work programme should be strengthened by:

• Including a specific emphasis on ‘preventing’ malnutrition in all its forms, in conjunction with ‘addressing’ it – in its ‘Aims and Added Value’ section (para. 9) we propose an additional clear aim to “Supporting all countries’ efforts to prevent all forms of malnutrition through effective multi-sectoral action to address underlying determinants”.

• Including references to the importance of ‘double-duty actions’ when developing and implementing national nutrition action plans, which has the potential to impact both undernutrition and prevent overweight & obesity at the same time.

• Including mention of the vital importance of independent legal frameworks to hold governments to account and promote implementation of action plans and policies.

• Be strongly and explicitly anchored in a rights-based framework and the universal realisation of human rights, including the right to health and food. Macro-economic policies (e.g. fiscal and trade) must be aligned with nutritional goals and human rights more broadly.

• Detailing how the Decade propose to manage and prevent conflicts of interest overall in its engagement with the private sector and industry actors, specifically with regards to the food and beverage industry and through multistakeholder mechanisms (para. 38 and 47 specifically).

Comments specifically with regards to ‘Action areas’ (para. 16-39)

• The role of the food environment and policies to create supportive food environments are not adequately captured within the action areas (only to a small degree in Action area 1 (para. 19) and Action area 5 (para. 36).

• Para. 19: On ‘improving food systems’ the link should be made explicit between improved food systems, agricultural production, trade and environmental policies.

• Para. 28-32: The benefits of knowledge and education should not be overstated in relation to changing behaviours and a focus on a comprehensive package of policies is necessary.  

• Para. 34: Consider including reference to the human right to health, alongside the right to adequate food.

• Para. 36-37: Consider adding the importance of marketing restrictions to children of food and drinks high in sugar, salt and fat, and the creation of healthy food retail environments, as part of creating a safe and supportive environment.

Comments specifically on ‘Means of implementation’ (para. 40-66)

• A database can be a valuable tool for monitoring, accountability and advocacy, and as such we welcome the initiative to develop a repository of commitments. However, a database is only useful provided it is kept up to date and with strong institutional support and separate earmarked funding. Specifics of where such earmarked funding would come from would be a welcome addition, as would more information about what type of information would be included.

• We question the level of ambition to member states only achieving ‘one or more’ of the nutrition targets, or ‘one or more’ of the ICN2 recommendations, as this will not hit the 2030 targets. Commitments should not be voluntary, as this is unambitious and not SMART enough - clear time-bound targets and commitments over the next two years are needed, with review and follow up hereafter.

• Ensure consistency throughout document, for example para. 45 speaks of a ‘repository’, while para. 72 refers to an ‘open access database’. Clarity is needed whether this is the same thing?

• Para. 42: What are these ‘intermediate outcomes’?

• Para. 44, 49 and 51: Is the ‘resource guide’ referenced here already available? If so, it should be clearly sign posted. Also, what ‘operational tools’ and ‘tools’ are specifically thought of?

• Para. 47: Are ‘Nutrition Champions’ an official or unofficial title and what counts as an ‘international initiative’? How will conflicts of interests be managed and prevented?

• Para. 57: How will the Decade ‘foster the exchange of experiences’? What is the role of the proposed repository in this? • Para. 58-60: How will this technical support be financed?

 Comments specifically on ‘Action networks’ (Table 1, page 14)

• There is a lack of clarity around how these particular topics were chosen, if any are priorities (if so, how and why), and whether there is a current level of activity in any of the networks outlined in the table, and if so how do they operate?

• Para 49: Ensure that Action networks have the active participation of government representatives from across nutrition-relevant ministries to promote a health in all policies approach and policy coherence. Furthermore, ensure that CSOs are involved in all Action networks.

Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas?

• WCRF International has already strongly supported the Decade’s launch and promotion, through being the focal point within the International Coalition on Advocacy for Nutrition (ICAN) guiding the coalition’s engagement with the Decade. WCRF International is also an active member of the ICN2 Civil Society Group in Rome and committed to ensure coordination between the two groups in its involvement with the Decade.

• Our NOURISHING framework and policy database highlights where governments need to take action to promote healthy diets and prevent overweight and obesity, and as such is a valuable tool for the success of the Decade. The framework brings together ten policy areas across three domains: food environment, food system, and behaviour change communication. The framework is accompanied by a regularly updated policy database, providing an extensive overview of implemented government policy actions from around the world. It is a tool for policymakers to assess whether an approach is sufficiently comprehensive, for researchers to decide where more research is needed, and for civil society organisations to hold governments to account. The database currently holds nearly 400 policy actions in over 120 countries, as well as 70 impact evaluations. www.wcrf.og/NOURISHING.

How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing?

• The general vision for the Decade is of a monitoring purpose, not an advocacy purpose. Advocacy is only mentioned passing (para. 61-6) and does not reflect the sense of urgency needed to invest in nutrition to achieve internationally agreed targets.

• Para 62-3: It is unclear how a ‘network of advocates’ will be established and who this will consist of, as well as how capacities for evidence-informed advocacy be aligned and strengthened? 5

• Para. 70: WCRF international calls for annual reporting to UN coordinating bodies, such as UNGA and WHA, rather than biannually. This would help create annual goals as benchmarks to monitor progress and success, create a sense of urgency and ensure achievements are made within the Decade’s existence.

• Para. 71: Tracking implementation of country-specific commitments will be based on country’s self-assessments – how will this information be verified?

• Para. 75: There is a need to outline how data collection and sharing of resources across the range of sectors and actors involved can be best utilised. Furthermore, how will the targeted programme and policy evaluations be ‘facilitated by the UN system to identify good practices’?

Dear Christine Campeau,

What we need presently now is action. There is need to start with immediate effect,  if we are going to achieve all this beautiful plan. According to Christine Campeau,  the sense of urgency to act is very essential.

We can always start with campaign,  with good headlines,  like " stop searching for luxury jobs,  embrace farming ". Make 3million naira within three years,  starting capital is two hundred and fifty thousand naira. .. Get loan now and payback latter.  e.t.c. with captures that will get the attention of young graduates and the unemployed.

Let's get this started in the urban centres and we can camp these people and do it in form ot training school,  where by,  examinations will be conducted and only the outstanding and ready-made candidates will proceed to the next stage.

They will be posted to departments based on their performance ranging from, crop....livestock. ...processing....preservations.

Let them know that the days of white collar jobs are over and  high time to engage themselves in farming.

Different types of training in conjunction with the small and medium enterprises development agency  (SMEDA) will be meaningful and produced a very good results,  in fact nearly 90% successfully, if well implemented.

Since we all know that the days of Nigeria's dependence on crude oil are over. If we let the young people know that the days of oil boom and white collar jobs are over. That if we concentrate and put more effort on the agricultural sector,  the lamentation about food scarcity and employment opportunities will be over. Much more than we realise on crude oil can be made also in agricultural sector.

This programme has to take off like an empowerment programme for young people and the unemployed to embrace it and run with it.

We must start now.

Yemisi Jaiyeola.

On behalf of the International Coalition on Advocacy for Nutrition (ICAN), please find below our joint submission on the UN Decade of Action work programme consultation. Thank you for the opportunity to comment on the draft, e look forward to future collaboration.

Submission by the International Coalition on Advocacy for Nutrition (ICAN) to the UN Standing Committee on Nutrition’s consultation on the Work Programme of the UN Decade of Action on Nutrition, 2016-2025

ICAN welcomes the opportunity to provide comments on the work programme of the UN Decade of Action on Nutrition (hereafter ‘the Decade’). Our consolidated comments are below, which accompanies the individual submissions by ICAN members. The International Coalition on Advocacy for Nutrition is a civil society coalition of organisations worldwide, which jointly calls for greater investments in, and commitments to, end all forms of malnutrition. This submission was compiled by World Cancer Research Fund International, with input from the following ICAN members: 1,000 Days, WaterAid, RESULTS UK, ACTION, Save the Children UK, The ONE Campaign and Action Against Hunger.

Does the work programme present a compelling vision for enabling strategic interaction and mutual support across existing initiatives, platforms, forums and programmes, given the stipulation of Res 70/259 that the Decade should be organized with existing institutions and available resources?

• Overall, we welcome the emphasis on addressing all forms of malnutrition (stunting, wasting, micro-nutrient deficiencies and overweight & obesity), a focus on a food systems approach based on scientific evidence, the promotion of coherent national, regional and international initiatives and SMART policies, the effort to convene, coordinate and consolidate existing nutrition efforts across multiple sectors and actors, and the intention to develop improved accountability frameworks.

• The Decade has so far produced a compelling and clear identity/brand through its communications materials, which has been helpful in support of promoting and launching the Decade (para. 64-5).

• Unfortunately, we believe that the roles and responsibilities remain vague, accountability issues are not addressed in detail, and the ‘how’ remains to be detailed. In order to enable strategic interaction, there is a need to have more of a focus on resource mobilisation, more concrete outlines of specific actions, timelines/time commitments and next steps.

• A welcome addition would be more country-specificity outlining a focus on high-burden countries and awareness of differences between locations in terms of how to tackle malnutrition in all its forms.

• Clearer links should be made to existing initiatives and platforms in other nutrition-related sectors, such as the recently formed coordination between SUN, the Sanitation and Water for All partnership (SWA) and the Global Partnership for Education (GPE).

• Para. 3 – consider including reference to SDG target 3.4: By 2030, reduce by one third premature mortality from NCDs through prevention and treatment and promote mental health and well-being.

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?

Overall comments:

ICAN believes that the Decade should be further strengthened by:

• Having a clearer remit to promote integrated action between nutrition and other nutrition-related sectors such as WASH.

• Having a stronger nutrition-sensitive focus, in addition to the nutritionspecific one; there is a need to ensure ambitious funding for ‘nutritionsensitive’, as well as ‘nutrition-specific’ actions are made explicit, as well as the Decade’s role in convening high-level stakeholders across nutritionrelevant sectors.

• Be strongly and explicitly anchored in a rights-based framework and the universal realisation of human rights, including the right to health, food, water, self-determination, education etc. Children’s, women’s, small-scale food producers and consumer rights must be protected and fulfilled by aligning macro-economic policies (e.g. fiscal and trade) with nutritional goals and human rights more broadly.

• Include references to the importance of ‘double-duty actions’ when developing and implementing national nutrition action plans, which has the potential to impact both undernutrition and prevent overweight & obesity at the same time.

• Include mention of the vital importance of independent legal frameworks to hold governments to account and promote implementation of action plans and policies.

• There is an urgent need to detail how the Decade propose to manage and prevent conflicts of interest in its engagement with the private sector and industry actors.

• Para. 9 ‘Aims and Added Value’ - The stated aims should be strengthened by a greater emphasis on not just “addressing” malnutrition (implying a focus on treatment) but preventing it. We propose an additional clear aim to “Supporting all countries’ efforts to prevent all forms of malnutrition through effective multi-sectoral action to address underlying determinants”.

• Para. 13 ‘Guiding Principles’ – on ‘facilitating action across rural and urban areas’ an explicit connection towards integrating food supply systems between urban and rural would be a welcome addition.

Comments specifically with regards to ‘Action areas’ (para. 16-39)

• Para. 18 - The reference to conducting “a full and thorough mapping” of existing initiatives and movements is welcome. We propose that this should explicitly include initiatives between nutrition-relevant sectors. For instance, SUN and the SWA have recently agreed a joint work plan for action on WASH-Nutrition integration, which may provide a useful model and example of cross-sectoral action at the global governance level.

• The role of the food environment and policies to create supportive food environments are not adequately captured within the action areas (only to a small degree in Action area 1 – para. 19 (p.5) and action area 5 – para. 36 (p.8).

• Action area 1 – “Sustainable, resilient food systems for healthy diets”:

o The action area needs to address the income challenges for those working in agriculture, and there is little reference to livestock, environment or disease.

o Para. 19: on ‘improving food systems’ the link should be made explicit between improved food systems, agricultural production, trade and environmental policies.

o Para. 21: Water availability and water resource management are critical aspects of sustainable food systems (e.g. for adequate and consistent supplies to crops and livestock as well as people) and should be referenced.

o Para. 22 and 23: Improving access to WASH is fundamental to preventing Anti-Microbial Resistance (AMR).

• Action area 2: “Aligned health systems providing universal coverage of essential nutrition actions”:

o Para. 25: Ensuring adequate WASH in healthcare is critical to delivering quality health care, including the treatment of malnutrition. The Global Action Plan on WASH in Healthcare Facilities[1] , co-led by WHO and UNICEF is therefore a key initiative to highlight and coordinate with that will be fundamental to improving nutrition.

• Action area 3: “Social protection and nutrition education”:

o There is a need to employ more evidence in this area, include more detail of what transfers can achieve and who they should be targeted at.

o The benefits of knowledge and education should not be overstated in relation to changing behaviours and a focus on a comprehensive package of policies is necessary.

Action area 4: “Trade and investment for improved nutrition’:

o Para. 34: Consider including reference to the human right to health, alongside the right to adequate food.

• Action area 5: “Safe and supportive environments for nutrition at all ages”:

o Para. 37: We welcome the inclusion of an area on water, sanitation and hygiene. The paragraph would be strengthened by including a more thorough overview of the key links between WASH and nutrition.

o Consider adding the importance of marketing restrictions to children of food and drinks high in sugar, salt and fat, as part of creating a safe and supportive environment.

• Action area 6: ‘Review, strengthen and promote nutrition governance and accountability’:

o Para. 36: Member states should firstly establish national multi-sectoral coordination mechanisms in nutrition governance, then develop new plans or update previous ones. In countries which have signed up to the SUN movement, this mechanism should be aligned with SUN.

o Para. 38: How does the governance mechanism avoid conflicts of interest?

Comments specifically on ‘Means of implementation’ (para. 40-66)

• We support the proposal for “a publicly-accessible repository” of commitments made by Member States in support of the Nutrition Decade, which will help to drive transparency and accountability. This is particularly crucial for commitments to ‘nutrition sensitive’ action, which are often less easy to track and carry greater risk of ‘double-counting’ of existing commitments in other sectors without sufficient thought and effort to enhance nutrition-sensitivity.

• Ensure consistency throughout document, for example para. 45 speaks of a ‘repository’, while para. 72 refers to an ‘open access database’. Clarity is needed whether this is the same thing?

• A database can be a great tool for monitoring, accountability and advocacy, provided it is kept up to date and with strong institutional support and separate earmarked funding. Specifics of where such earmarked funding would come from would be a welcome addition.

• Para. 44, 49 and 51: Is the ‘resource guide’ referenced here already available? If so, it should be clearly sign posted. Also, what ‘operational tools’ and ‘tools’ are specifically thought of?

• We question the level of ambition to member states only achieving ‘one or more’ of the nutrition targets, or ‘one or more’ of the ICN2 recommendations, as this will not hit the 2030 targets. Commitments should not be voluntary, as this is unambitious and not SMART enough - clear time-bound targets and commitments over the next two years are needed, with review and follow up hereafter.

Para. 47: Are ‘Nutrition Champions’ an official or unofficial title and what counts as an ‘international initiative’? How will conflicts of interests be managed and prevented?

Comments specifically on ‘Governance’ (para.69)

• Country representatives should be from the office of Heads of State to ensure highest level of accountability.

Comments specifically on ‘Action networks’ (Table 1, page 14)

• There is a lack of clarity around how these particular topics were chosen, if any are priorities (if so, how and why), and whether there is a current level of activity in any of the networks outlined in the table?

• Para 49: Ensure that Action networks have the active participation of government representatives from across nutrition-relevant ministries to promote a health in all policies approach and policy coherence. Furthermore, ensure that CSOs are involved in all Action networks. and Action networks must engage with already existing groups (for example SUN).

• ICAN members believes that other particular topics could be suggested:

o Investment in research and evidence building on nutrition interactions with other sectors and the impact of such sectors on nutrition outcomes

o WASH-nutrition integration

o Exclusion, e.g. how to put the most vulnerable and marginalised first.

o Food safety, e.g. in terms of environmental pollutants and antimicrobial resistance

o Healthy retail environments

Do you feel you can contribute to the success of the Nutrition Decade or align yourself with the proposed range of action areas?

• ICAN welcomes the specific mention of our coalition in the work programme (para. 69), and the reference to ensuring coordination with the Nutrition for Growth moments (para. 45, 54, 69, 74). As a coalition we stand willing to support the implementation of the Decade’s work programme and is committed to coordinating with other civil society coalitions, such as the ICN2 CSO coalition in Rome. ICAN is able already actively engaged with several of the foras of the proposed priority activities (Table 2).

How could this draft work programme be improved to promote collective action to achieve the transformational change called for by the 2030 Agenda for Sustainable Development and the ICN2 outcomes? What is missing?

• The general vision for the Decade is of a monitoring purpose, not an advocacy purpose. Advocacy is only mentioned passing (para. 61-6), and the implication of this is that it does not reflect the sense of urgency needed to invest in nutrition to achieve internationally agreed targets, as well as how a ‘network of advocates’ will be established (para. 62).

• ICAN believes that collective action could be improved by focusing on the resource tracking of ODA via the OECD DAC measurement.

• There is a missing element in how to ensure UN agencies include nutrition in in their strategies and work programming, such as the need to implement nutrition (sensitive) indicators into related programming, as well as ‘doubleduty actions’.

• Table 2 seems incomplete, without specific timelines and details of activities and responsibilities. There is also a lack of what the intended impact/outcome would be for the secretariat’s activities (besides ‘convening member states’ etc.). We therefore urge the Secretariat to finalise Table 2 in conversation with member states and civil society actors to act as a work plan for the period April 2016-April 2018.

Do you have any specific comments on the section on accountability and shared learning?

• Para. 70: ICAN believes that the reporting to UN coordinating bodies, such as UNGA and WHA, should be done on an annual basis, not biannually, to have annual goals as benchmarks to monitor progress and success, create a sense of urgency and ensure achievements are made within the Decade’s existence.

• Para. 71: Commitments by governments are only encouraged as voluntary and not required - and all reporting done through self-assessments - which will lead to issues of accountability. There is a clear need to outline whether and how this information will be verified.

• Para. 75: There is a need to outline how data collection and sharing of resources across the range of sectors and actors involved can be best utilised. Furthermore, how will the targeted programme and policy evaluations be ‘facilitated by the UN system to identify good practices’?

• Further, explicit mention of DAC and SUN as additional networks of reporting mechanisms should be added.

FEDERALIMENTARE, the Italian Food and Drink Industry Federation, would like to thank you the UNSCN for the opportunity to comment the first draft of the Decade of Action on Nutrition 2016-2025.

Please find enclosed our comments in the attached file.

Should you need any further information and/or clarifications, please do not hesitate to conatct us.

Best regards,

FEDERALIMENTARE

I am pleased to contribute to the draft work programme on the UN Decade of Action for Nutrition.  I have three suggestions:

1. I suggest adding the bolded clause below.

48. Through the convening and catalytic roles of the Nutrition Decade, action networks will be established. These action networks are informal coalitions of countries aimed at advocating for the establishment of policies and legislation, allowing the exchange of practices, promoting the conduct and capacity strengthening for implementation science, highlighting successes and providing mutual support to accelerate implementation.

2. I suggest adding the bolded clause below:

58. The Nutrition Decade will seek to strengthen the quality and efficiency of policy and programme implementation and monitoring, including the application of implementation science. Technical assistance will need to be responsive and opportunistic in leveraging technological advances. An emphasis will be placed on amplifying country capacities and on ensuring that knowledge and experiences are shared and successes are scaled up where possible.

3. In Table 1 I suggest adding the following:

Implementation science: strengthen the capacity, funding and practice of implementation science at country and global levels.

To whom it may concern:

We are sending in the attached comments on behalf of two InterAction members who also submitted separately. Apologies for missing the first deadline!

Please let us know if you have any questions.

Best,

Marilyn

Based on Christine's commentary so far, I want to emphasize something I touched on in my contribution earlier in the debate.

There are existing data linkng lack of dietary diversity (over-consumption of starches and sugars) to low incomes in Southern Africa. See the work of AFSUN (African Food Security Urban Network) and the article I co-auhtored in the attached issue of Right to Food and Nutrition Watch Magazine last year (attached). I think it is also establlshed through other evidence that lack of dietary diversity is linked to life-style diseases and to obesity.  From this we can conclude that there is already some evidence that, in the urban transition, the malnutrition associated with obesity and life-style diseases is not associated with income increase and over-eating as is often asserted. Rather, it seems to be associated with urban poverty. The lack of afforbale food for the urban poor is a major issue.

One of the ways this is being tackled in Africa is through encouraging urban agriculture. This enables poor urban residents to produce micro-nutrients for themsleves, in the form of animal source foods such as milk and eggs as well as fresh fruit and vegetables. These may also increase available supplies in urban areas and help increase employment and incomes. I also attach the book Healthy City Harvests, published in 2008 which contains extensive research on urban agriculture, including establishing the link between urban agriculture and improved food and nutirtion security.

English translation below

Estimada, FSS moderador,

Es importante la reestructuración de los ministerios o departamentos en los diferentes niveles de gobierno (nacional, regional, local) para que se alineen en las mismas políticas alimentarias y nutricionales, por que en ocasiones chocan o están ausentes.

Ejemplo  en México la Subsecretaria de Alimentación está asignada a la Secretaria de Agricultura (SAGARPA) y su  participación en la Estrategia antiobesidad, de manera oficial  es casí nula.. La Estrategia Antiobesidad está dirigida por la Secretaria de Salud.

M.C. Emerio Rubalcava

Instituto de Ciencias Agropecuarias y Rurales

Universidad Autónoma del Estado de México (UAEMex)

Toluca, México

Dear FSN Forum moderator,

Restructuring the ministries or departments at the different government levels (national, regional, local) to align their food and nutrition policies is important, as they are occasionally conflicting or not in place.

For example, in Mexico, the Under-Secretariat of Food is allocated to the Secretary of Agriculture (known in Spanish as SAGARPA) and its formal participation in the Strategy Against Obesity (Estrategia antiobesidad) is almost non-existent. The Strategy Against Obesity is directed by the Secretary of Health.

M.C. Emerio Rubalcava

Institute of Agricultural and Rural Sciences

Autonomous University of the State of Mexico (UAEMex)

Toluca, Mexico

VERTICAL PARTNERSHIPS

I am concerned that the approach discussed here does not give sufficient attention to what people at the community level could do for themselves. More attention should be given to what higher level agencies could do to facilitate those local initiatives. As Florence Egal put it, “Given the mandate of both FAO and WHO, the focus on national policies is logical. But unless we include explicitly the sub-national level we will not be in a position to address sustainably all forms of malnutrition.”

Top-down approaches tend to weaken and disempower those working at ground level. This is not a matter of simply favoring bottom-up approaches over top-down approaches. It is about figuring out how to work out an appropriate “division of labor” between agencies at different levels. Based on the principle of subsidiarity, higher level agencies should not do and decide things that ought to be done and decided at lower levels.

There is a need for discussion about how to work out the division of labor. Agencies at the higher levels should shift from designing interventions based solely on their understandings of both the problems and solutions, and move more toward facilitating analyses and action by those at lower levels. These should be partnership arrangements, with learning going on at all levels.

George Kent

The International Food & Beverage Alliance welcomes the opportunity to provide comments on the first draft (dated 27 January 2017) of the Work Programme of the UN Decade of Action on Nutrition, 2016-2015 (the “Nutrition Decade”). [1]

The Nutrition Decade calls for a global collective effort towards eradicating hunger and preventing all forms of malnutrition worldwide, to be implemented locally by Member States and their partners, working within existing structures and available resources. The Nutrition Decade will act as the umbrella for coordinating and aligning the nutrition actions of multiple actors across all sectors to achieve nutrition impact at scale and a healthier, more sustainable future.  

In general, we agree with many of the key components of the draft Work Programme, particularly its aims, guiding principles, key action areas, and accountability framework. 

We support the overall aim of the Work Programme to provide a clearly-defined, time-bound operational framework for governments to adopt and implement nutrition-related initiatives to create sustainable food systems and enabling environments that promote healthy dietary practices and support the fulfillment of the Second International Conference on Nutrition (ICN2) commitments and achievement of the diet-related NCD targets by 2025 and the Sustainable Development Goals by 2030. 

We support a Work Programme that is guided by the principles of inclusivity – maximizing the participation of a wide range of stakeholders and sectors, involving all countries and addressing the needs of all people everywhere.  We are pleased that the Work Programme acknowledge the contribution the private sector can make to the Nutrition Decade.   

We recognize the unique role the food and non-alcoholic beverage industry has to play in global nutrition and have committed to do our part to help consumers worldwide achieve healthy and sustainable diets. We also support the need for a transparent mechanism for tracking progress and ensuring mutual accountability for the commitments made. 

As proposed, the Work Programme seeks to assume a coordinating role among all actors and across all sectors to consolidate, align and reinforce nutrition actions; build on existing efforts to improve nutrition worldwide; and accelerate actions and expand the geographic and sectoral scope of actions.  We support this role. 

The action areas outlined in the Work Programme are centered on six pillars, derived from the recommendations of the ICN2 Framework for Action and representing a broad range of policy actions for addressing all forms of malnutrition:

·         Sustainable, resilient food systems for healthy diets;

·         Aligned health systems providing universal coverage of essential nutrition actions;

·         Social protection and nutrition education;

·         Trade and investment for improved nutrition;

·         Safe and supportive environments for nutrition at all ages; and

·         Strengthened nutrition governance and accountability.

Many of the action areas reflect the strategies and initiatives IFBA members have been implementing for many years. We are formulating and innovating products that support the goal of improving diets – reducing key nutrients of public health concern, adding nutrients to reduce micronutrient deficiencies and promoting food components and food groups beneficial for good health, such as fibre, whole grains, fruits, vegetables and low-fat dairy.  The provision of nutrition information to consumers forms the cornerstone of any policy framework to address poor dietary intakes and to promote healthier eating habits. We are providing nutrition information to consumers to help empower them to make informed dietary decisions tailored to their needs and lifestyles.  We are restricting marketing to children; and promoting balanced diets and healthy lifestyles in our workplaces and in the communities we serve.  We are raising awareness of the importance of good nutrition and promoting behavior change through our collaborations with governments and NGOs in public education campaigns and in schools and communities.   

Improving food security worldwide requires the collective effort of all stakeholders. We support actions for sustainable food systems that promote healthy and safe diets and strategies that integrate nutrition and food safety objectives into food and agriculture policies and strengthen local food production and processing.  As food and beverage companies that both depend on food production for its raw material and seek to deliver nutritious foods and beverages to consumers, IFBA members are committed to sustainable agriculture and the transition to a sustainable food future – innovating more food choices by using fewer natural resources. We are also working with our suppliers and smallholder farmers to promote sustainable supply chains, helping to increase farmer knowledge and yields, improve their livelihoods and build thriving communities.

The Work Programme calls for the establishment of action networks - informal coalitions of countries aimed at advocating for the establishment of policies, sharing best practices and providing mutual support to accelerate implementation.  Table 1 lists potential topics for the establishment of action networks.  We would suggest, to ensure consistency, that on the basis the six action areas are derived from the recommendations of the ICN2 Framework for Action, so too should the Table 1 topics.

We are supportive of the establishment of these action networks and are committed to lend our support and technical expertise to these efforts.  IFBA members are participating in successful multistakeholder coalitions, such as PAHO’s SaltSmart Consortium and the Scaling Up Nutrition (SUN) Movement and believe an action network can be a successful vehicle for implementation of the commitments to action, provided there is a coherent and sustained alignment of efforts, “win-win” based terms of reference, an agreed set of actions, clear rules of engagement and defined roles and responsibilities for each stakeholder, transparency and accountability and measured progress towards stated objectives.  Given the number of existing alliances and initiatives, we believe the Work Programme will benefit from clearly defined terms of engagement and an explanation as to how the Nutrition Decade will interact with existing alliances and initiatives to ensure increased focus and action.

We are encouraged to see that the Work Programme recognizes that actions taken by governments and other stakeholders must rely on the latest scientific evidence. We, too, believe that policy initiatives must be supported by strong scientific evidence – we need to understand what works and why. Given our significant research and development capacity, we believe there are real opportunities for collaborative research. We welcome the opportunity to share our technical expertise of nutrition science and consumer behavior with a view to finding new and relevant ways to leverage and collaborate on the science needed to improve food security and nutrition.

We support the establishment of repositories and knowledge-sharing mechanisms at national, regional and global levels and are willing to share our best practices on product reformulation, salt reduction strategies, nutrition labelling, responsible marketing practices and workplace wellness programmes.

We are committed to leading our industry in efforts to improve public health and look forward to working with all stakeholders to understand the most helpful role we can play toward realizing our shared goal of eradicating hunger and preventing all forms of malnutrition worldwide.  

We are grateful for the opportunity to provide our comments and look forward to participating in further dialogues and consultations with the joint FAO/WHO Secretariat as work to develop the Work Programme continues.