Глобальный форум по продовольственной безопасности и питанию (Форум FSN)

The International Food & Beverage Alliance (IFBA) would like to thank the Food and Agriculture Organization of the United Nations (FAO) for the opportunity to submit comments on the ICN2 Framework for Action zero draft to implement the Rome Declaration on Nutrition.

IFBA is a group of eleven companies - The Coca-Cola Company, Ferrero, General Mills, Grupo Bimbo, Kellogg, Mars, McDonald’s, Mondelēz International, Nestlé, PepsiCo and Unilever. IFBA is committed to leading the industry to support the implementation of the 2004 WHO Global Strategy on Diet, Physical Activity and Health (the WHO Global Strategy), the 2012 Political Declaration of the High-level Meeting of the General Assembly on the Prevention and Control of Non-communicable Diseases (the UN Political Declaration) and more recently, the WHO Global Action Plan for the Prevention and Control of Noncommunicable Diseases 2013-2020, (the WHO Global Action Plan) through product innovation, improved access to nutrition information, responsible marketing practices, the promotion of healthier diets and physical activity.

1.            General comments on the ICN2 Framework for Action zero draft

Stakeholders in global nutrition share a common interest in tackling the problems of malnutrition and noncommunicable diseases (NCDs).  IFBA was one of the NGOs consulted by WHO throughout the process of developing the WHO Global Action Plan.   In line with the   UN Political Declaration, WHO strategies recognize that the solution requires a whole of society approach, multisectoral actions and the collaboration of governments, civil society and the private sector.  IFBA members strongly support this approach.  One of the fundamental principles underpinning IFBA’ s work is a commitment to public-private partnerships that support public health strategies.  Given the complexity and multifactorial causes of malnutrition and NCDs, it is essential that all stakeholders work together to develop holistic, impactful and sustainable solutions.  IFBA strongly supports the frequent references to these principles in the FFA zero draft document

The FFA zero draft is positioned on page 3 as a document to provide a “technical basis” for adopting major policy guidelines and strategies for governments, in partnership with non-state organizations (including NGOs and the private sector). We consider that the words “technical basis” do not reflect the content of the document, and instead propose

“This FFA provides the technical basis framework for adopting major policy guidelines and strategies and for developing and updating national plans of action and investments to improve nutrition.”

IFBA would encourage a more concise and precise document, with clarification of the following elements:

-              The status of this document vis-à-vis the Member State-approved WHO Global Action Plan.  In particular, to highlight those areas where the finally approved FFA calls for actions beyond the scope agreed to by Member States in the WHO Global Action Plan.

-              How duplication of the processes already established by WHO and the UN will be avoided (e.g. the Global Coordinating Mechanism.)

-              As a framework for action, it is important that assertions made in the FFA are evidence-based. In its comments, IFBA will cite a number of paragraphs where more precise scientific evidence would be helpful.

2.            Comments on chapter 2

2.1          IFBA supports the following references made in chapter 2:

◦                              2.1 Enabling environments (1st paragraph)

◦                             IFBA also believes that “knowledge and evidence-based strategies, policies and programmes” are essential to the creation of an enabling environment to improve nutrition. 

◦                             2.2 Better governance for nutrition (1st paragraph)

IFBA is committed to multistakeholder collaboration and supports the inclusion of all stakeholders in a consultative process for the development of appropriate strategies to improve nutrition should “involve regular consultations among all implementing partners, including consumer groups, other civil society organizations, producers, processors, distributors and retailers of food…professional nutritionists, research scientists; educators 2.2                Priority actions for nutrition governance, pg. 5:  More clarification would be helpful with regard to the call for the establishment of a  “cross-government, inter-sectoral governance mechanism ...” .

How would this align or link in with the Global Coordinating Mechanism or UN Inter-Agency Task Force for the implementation of the WHO Global Action Plan? Will there be any linkage to the work down in the Scaling up Nutrition (SUN) movement?

3.            Comments on chapter 3

3.1          IFBA supports the following reference:

             3.1 Food systems, 2nd paragraph

• IFBA supports the important point that: “interventions in isolation may have limited impacts within such a complex system, interventions that consider food systems as a whole are more likely to succeed.”

3.2          IFBA does not support the following statements: 

                (3.1 Food systems, 4th paragraph):

“However, they have also increased the availability of highly processed foods of minimal nutritional value which have contributed to obesity and diet-related NCDs.”

IFBA considers that this statement is over-simplistic.

It is well known that food processing can affect the nutritional value of foods.  This includes processes that expose food to light, oxygen, high temperatures, or mechanical processes such as the milling of cereals. 

However, the extent of any deterioration in nutritional quality is probably less than many consumers realise.  The USDA data set of factors for calculating the retention of micronutrients during food preparation shows that many food processing methods only weakly impair the nutritional the value of foods, if at all. 

Eicher-Miller et al (2012) have recently evaluated whether the level of food processing is associated with nutritional quality. The study looked at the contribution of processed foods to the US diet using data from 25,351 people over the age of 2 years from the 2003–2008 NHANES survey. The authors categorised foods according to five levels of processing:

1.            Minimally processed (e.g. milk, coffee)

2.            Processed for preservation (e.g. frozen or canned fruit and vegetables)

3.            Mixtures of combined ingredients (e.g. sauces and dressings)

4.            Ready-to-eat foods (e.g. breakfast cereals, yoghurt, ice-cream)

5.            Prepared foods (e.g. frozen meals, pizza).

They found that the level of processing was only a minor determinant of the nutritional quality of a food, and conclude:

“In conclusion, processing level is not a major determinant of foods’ nutrient contributions to the diet and does not have a clear association with the health of a food as determined by either “nutrients to encourage” or “food components to reduce” as specified in the Dietary Guidelines for Americans 2010. A food’s nutrient composition and the frequency and amount eaten, rather than level of processing, should be stressed as the most important considerations for the selection of a healthy diet.”

                (3.1 Food systems, 5th paragraph):

                IFBA would urge caution and recommend the FFA not use statements such as “the private sector will facilitate more sustainable and nutritionally desirable diets when it pays to do so.” In IFBA’s view, the private sector should not be singled out and it is an unfair depiction of the motives and role of the private sector in global nutrition.

Moreover, it already “pays” for the private sector to contribute to more sustainable and nutritionally desirable diets if companies want to be in the business for the long-term. 

(3.1 Food systems, 10th paragraph):

The reference to WHO recommendations on diets contained in this paragraph, refers to draft recommendations not yet approved by Member States, such as the one included in the 5th bullet point:

“WHO recommends that diets should ensure: Intake of free sugars is less than 10% of total energy intake or, preferably, less than 5%”.

These Guidelines are still in a draft version, recently put to public consultation and still under revision. The WHO website itself states, in fact, the following: “Once the peer-review and public consultation are complete, the guideline will be finalized and reviewed by the WHO Guidelines Review Committee for final clearance prior to its official release”.  We recommend that this paragraph be amended to read:

“The WHO draft guideline recommends that diets should ensure: Intake of free sugars is less than 10% of total energy intake or, preferably, less than 5%”.

(3.1 Food systems, a suggested addition)

Strengthening facilities for local food production and processing while at the same time ensuring that local markets are developed (e.g. through school meals and corner stores) for the sale of these foods

3.3          (3.1.1 Food environments: Priority actions to improve the food environment: Incentivize healthy dietary choices, pg. 12):

Well-constructed fiscal measures might be effective as part of a wider public policy programme.  However, we would like to see that any economic tools are supported by evidence. Therefore we propose the following edit: “Review the scientific evidence for creating fiscal incentives and disincentives to encourage healthy diets by reducing the cost of more healthy diet options relative to less healthy ones”. 

·         Unedited, this sentence does not cite or provide the evidence base of the effectiveness of fiscal instruments, specifically applied to nutrition. This could open the door to unjustified forms of “food taxes” which, without proper scientific evidence, would unfairly discriminate certain types of foods which, when consumed in the correct portions and with the correct frequency, would not be considered as “unhealthy”.  Food taxes have unpredictable and negative consequences. They are regressive and their social and cultural value has not been fully assessed.  Our understanding of the academic research indicates there is no science to show that the taxation of food products is an effective means to address NCDs, nor is there any evidence to show that food taxation will achieve behaviour change or improve consumers’ access to healthier foods. [1]

It is also worth recalling the recent failed experience of the Danish “Fat Tax”, introduced by the local Government in 2011 but withdrawn after just one year by the same Danish Administration, which admitted unpredictable and even negative consequences:  “the fat tax hit jobs and increased cross border trade, with rising numbers of Danes heading into Germany to buy butter”2.We would therefore recommend that this proposed action either be removed or modified.

3.4          (3.3.4 Nutrition education for behavior change, 3rd paragraph)

IFBA fully supports the FFA call for nutrition education and information.  We too believe “People need clear and accurate information to be able to make healthy choices.”

Empowering the consumer to make healthy food choices is essential. The product label and nutrition facts panel or table is a principal source of information for consumers. Experience has shown that providing data, i.e. transparency around the nutrient content of food as well as increasing nutrition facts in a simple and easy-to-use format help consumers understand the information and make healthier choices. IFBA supports a fact-based approach to nutrition labelling as set out in its commitments (www.ifballiance.org). Fact-and science-based labelling systems, which provide meaningful and understandable nutrition information on overall diet, allow consumers to make the dietary decisions to meet their individual nutritional needs.

4.            Comments on Chapter 4

4.1          (4.4 International trade and investment, 3rd paragraph)

IFBA has concerns about the following statement: “The availability of and access to unhealthy foods should be effectively regulated and discouraged. International standards in regulations for nutrition content to promote compliance with nutrition requirements should be established, implemented and enforced.”

This sentence goes beyond what was agreed by Member States in the WHO Global Action Plan.  Regulating the nutrition content of food products with pre-set standards applicable to International Trade would not only most likely be contrary to applicable competition rules, but would also pave the way for burdensome legislation which, without any proper scientific basis, would unjustly discriminate certain foods, with serious negative consequences particularly on traditional quality European products (such as olive oil, parmigiano, mozzarella, feta, camembert, prosciutto di Parma, Jamon Serrano, honey, jam and even fruit compote), which would all be stigmatized as “unhealthy” for their fat, sugar and/or salt content.  We recommend therefore that this sentence be removed or modified. At the least, a precise definition of both “healthy” and “unhealthy foods” should be developed in consultation with all relevant stakeholders.

4.2          Accountability Mechanisms, 1st paragraph

IFBA would encourage FAO / WHO to consult widely on the establishment of credible, independent accountability mechanisms.  From IFBA’s experience, the complexity and cost involved in the development of an independent monitoring and evaluation system is underestimated. This applies especially to NCD-related areas such as reformulation of products, marketing to children and labeling. IFBA would be willing to share its experience and methodologies used.            

5.            Other questions