Here: GER position on the e-consultation on the V0 draft of the report
General remarks
We thank the CFS and HLPE for submitting the above-mentioned V0 draft and for the possibility to provide input at an early stage. We welcome the fact that they address the important issue of reducing inequalities in food systems, particularly in the context of food security and nutrition (FSN).
Among other things, high inequality limits development opportunities and the realization of human rights. The current multiple crises, including climate change and unprecedented biodiversity loss, are exacerbating the situation.
Reducing inequality is one of the key tasks we face. The HLPE Report and the CFS Policy Recommendations on reducing inequalities for FSN will contribute to the achievement of Sustainable Development Goals (SDGs) 2 and 10 as well as the realization of the right to adequate food.
The report should elaborate more clearly how the 2030 Agenda and especially the holistic approach require inequalities and inequities to be addressed.
With a view to existing literature and research, it could help to highlight more often what evidence is generally accepted and what is more controversial.
Remarks on the individual chapters of the report
Chapter 1
This chapter sets the scene well for engaging with equality and equity in food systems. The conceptual framework is well developed in order to capture the drivers of inequality and inequity in food systems for achieving FSN at different levels.
On p. 9, the scope could be broader and it should not just be the 14th Amendment of the US constitution that is mentioned as an example for (racial) equality, as many states globally have similar clauses. This should be specified in the text.
This is also the case on p. 17, when “food lobbies of the US” are named as an example for power asymmetries - many states, including the US, are experiencing this.
Figure 1.2. (p. 26) is generally helpful in guiding readers through the conceptual framework but the readability should be improved (too small, low resolution).
A major part of the proposed framework describes the current state. In order to provide more practical guidance to policymakers and other stakeholders on how to reduce inequalities for FSN, the descriptive chapters (Chapters 2, 3 and 4) could be shortened considerably.
A smaller part of the report addresses actions. To increase the practical value of the framework, a single chapter on “actions and recommendations” would be more useful than the distinction between Chapter 5 (Actions to reduce inequalities in food and other systems to improve FSN) and 6 (Transformations necessary for positive structural change to reduce inequalities in FSN).
In addition, reference is made to a Chapter 7; it seems, however, to have been omitted. This chapter would be of interest to us. The envisaged recommendations should be directed at the global governance level to identify pathways for reducing inequality and inequity in food systems collectively.
Finally, we welcome the fact that this introductory chapter recognizes climate change as an important additional layer of threat that particularly affects vulnerable communities. We would welcome additional general language to describe global biodiversity loss as a threat both to FSN as climate change (twin crises) - especially after the adoption of the Kunming-Montreal Global Biodiversity Framework. Biodiversity is mentioned in other chapters throughout the text but not in this important introductory chapter.
Chapter 2
This chapter provides a sound analysis of inequalities in FSN outcomes across and within countries and regions.
Chapter 3
We welcome the fact that the focus of Chapter 3 is broadened and that the effects are considered in a food systems approach. However, this chapter could be improved with regard to trade issues. Overall, a more balanced and differentiated point of view would provide valuable insights for reducing inequalities.
It would be interesting to hear about the role of women in informal cross-border trade (e.g. p. 57).
Furthermore, we would be interested to see an explanation of the comparison with self-sufficiency on p. 59. In (ii), (iii) and (iv) the comparison with self-sufficiency is not explicitly mentioned and it should thus not be mentioned in (i).
The remarks on economic specializations should be more precise (i.e. specialization according to comparative advantages; p. 60).
Moreover, important aspects of facilitating trade for certain groups are missing, including governmental trade facilitation initiatives by WTO and others and outgrower schemes. This would help to get a balanced overview of the current situation.
This also applies to the examples given of certain groups that are disadvantaged by trade (p. 61 and following). It would be more constructive to also give examples where marginalized groups could benefit from trade and trade liberalisation, by clearly pointing out the conditions under which benefits are possible.
Furthermore, the section on “Power and policy space for developing FSN-relevant policies” should be carefully reviewed with regard to the WTO rules that are mentioned. It may be helpful to not only refer to the TBT agreement, but also to trade costs in general.
The line of thought about the “regulatory chill” should be explained more clearly by presenting more details and being more specific. For example, regulatory traditions would need to be mentioned as an additional factor. It would be helpful to name the relevant factors that cause the “regulatory chill”, while making reference to domestic policy-making. It would be interesting to see the recent evidence base as well as more and especially positive examples.
Finally, with a view to reproductive systems and time use (p. 72), the text should look beyond agriculture, in particular towards women’s and men’s contributions to care work and other activities.
Chapter 4
The chapter’s section on “Global political architecture, geopolitics and food regimes” (p. 82 and following) should be carefully reviewed and be made more specific with regard to the WTO negotiations, especially the Doha Development Agenda round.
Moreover, relevant agreements from the WTO Ministerial Conferences (e.g. the Trade Facilitation Agreement (TFA) adopted at the Bali Ministerial Conference in 2013) as well as Special and Differential Treatment (SDT) and measures to support developing countries in engaging in negotiations and trade should be added.
Furthermore, the role of trade in inputs, and thus trade of technology, is missing in the chapter.
The chapter’s section on the conflict between nature conservation and land rights correctly identifies possible trade-offs relating to social inequalities. However, given the newly adopted Kunming-Montreal Global Biodiversity Framework, this section must be reviewed to adequately reflect the international agreement on the 30x30 target (target 3), which includes the important role of Indigenous Peoples and Local Communities (IPLCs). Furthermore, the report could also elaborate on how conflicts between nature conservation and land rights should be or have been successfully resolved or managed.
Finally, the cited source “Wittmann et al, 2010” is missing in the list of sources and should be added. Overall, the statement on the influence of the seed industry on movements for the rights of local populations should be revised as it seems sweeping. In this regard, the OECD report on “Concentration in Seed Markets – potential effects and policy responses” could be consulted.
Chapter 5
As an action to address inequalities, partnerships and the exchange of accumulated information are important tools. As stated in the previous chapters, the contexts in which inequalities arise can vary widely. Nevertheless, the lessons learned by one actor can help another to move forward, and vice versa. This should be seen against the backdrop of strong partnerships and cooperation as laid out in SDG 17.
We welcome the approach of developing inclusive farmers’ organizations. This should be considered as a broad concept, involving stakeholders throughout the value chain and focusing on living conditions in rural areas. The governance level could assist in setting up these organizations and implement ways for political consulting in multi-stakeholder processes.
While food safety is mentioned and the report acknowledges that it “has not historically been well-integrated into food system and food security research and action”, little effort is made to overcome this issue in the present framework. Food safety is linked to the food security dimensions of availability, utilization and stability. Yet this is currently only highlighted under “utilization” on p. 68.
We suggest considering whether the establishment/strengthening of food control systems could be embedded in the “actions” part of the framework (currently chapters 5 and 6). Such action would constitute a concrete structural change to reduce inequalities in some countries.
Furthermore, we note that a recent publication by FAO offers a concrete case study that underlines the links between food safety and food security (https://www.fao.org/3/cb8715en/cb8715en.pdf).
Finally, the aspect of consumer behavior (cf. Figure 1.2, p. 26) is underrepresented in this chapter and could be further highlighted, e.g. with a view to nutrition knowledge.
Chapter 6
We welcome and support the fact that this chapter emphasizes the human right to adequate food and rights-based approaches for the transformation of food systems.
In this regard, we particularly welcome the focus on marginalized groups and their participation, as well as the sections on social protection and universal access to services and infrastructure. It is important to highlight the multisectoral nature of the required transformative actions and that this is one of the key challenges in making progress in the transformation of food systems.
We emphasize that sustainable food systems must be equitable and inclusive and, without exception, based on a human rights approach. Safeguarding all human rights is an integral and indispensable element of sustainable development worldwide and consequently one of Germany’s key concerns.
In addition, we underline the challenges listed that more equality data and research is needed to gain further insights and to identify global connections
Silke Stallkamp