Please find below the comments provided by the World Health Organization’s Department Nutrition for Health and Development (WHO/NHD) in Geneva to the Online consultation on the CFS VG on Food Systems and Nutrition.
1. Does Chapter 1 adequately reflect the current situation of malnutrition and its related causes and impacts, particularly in line with the goals and targets of the 2030 Agenda? What are the underlying problems that currently hinder food systems to deliver healthy diets?
The CFS VG on food-systems and nutrition are of high importance for the UN Decade of Action on Nutrition, and for achieving food security, improved nutrition and health and other related SDG targets. The added value needs to be to go steps further with the operationalization of the agreed ICN2 Framework for Action. Moreover, these voluntary guidelines need to build on and integrate the guidance adopted by other member state bodies of the UN system. This includes also the integration of relevant World Health Assembly guidance into the broader multisectoral context for enabling sustainable food systems supporting healthy diets and improved nutrition and health for all.
For the achievements of the global commitments and targets, we would like to underline for chapter 1, the importance of calling for an integrated approach to food systems from farm to folk. Too often, contrasting policies are observed, which are not achieving the intended outcomes of addressing all forms of malnutrition. An integrated approach from farm to folk is vital to avoid policy incoherence, and to ensure that policies included in the agricultural element are followed through in the different steps of the food supply chain, particularly around the elements of food distribution and retail and consumer policies. In addition, we would support the establishment of global policy targets in order to make that alignment; the CFS might consider establishing targets for the achievement of the overarching targets of addressing malnutrition in all its forms. (see also point 4).
For this section, an essential element is the inclusion that unhealthy diet is the top risk factor for the global burden of disease. The concept of healthy diet should be central to these voluntary guidelines. In fact, the latest analysis that looked comprehensively at the outcomes in terms of disease, the Global Burden of Disease Study, indicates that unhealthy diet is now the top risk factor for the global burden of disease. It accounts for 11 million death every year. This is a substantial element. The Global Burden of Disease Study is the most comprehensive worldwide observational epidemiological study to date, that assesses mortality and disability from major diseases, injuries, and risk factors to health. We would like to underline the importance of this study result for the CFS voluntary guidelines and suggest that it is reflected in the Introductory part 1 of the document. Furthermore, we would like to stress the importance that the Committee (CFS) looks at the concept of healthy diet as a guiding element for the discussion.
2. What should be the guiding principles to promote sustainable food systems that improve nutrition and enable healthy diets? What are your comments about the principles outlined in Chapter 2? Are they the most appropriate for your national/regional contexts?
Healthy people and healthy planet are key elements, and we do welcome the inclusion of the ‘healthy people – healthy planet’ concept among the guiding principles. In deed health objectives could be an overarching factor and an aligning factor for food and nutrition policies. Currently, food systems deliver in an inadequate way on their core-business which is to produce and provide the necessary food and nutrients for the population. Health of the population and health of the planet as key elements drive the food system transformation, and they should be placed more important than other aspects such as for example considering the food system as a production system of commodities only. We would like to suggest that this ‘healthy people- healthy planet’ element might be highlighted even more as a key driver to avoid policy incoherence.
In Section 2, we welcome the inclusion of the definition on ‘Healthy diet’, including the healthy diet of infants and young children (page 7). Moreover, we would like to inform the CFS Secretariat that WHO is collaborating with FAO and both agencies jointly organized an expert consultation on the topic in July 2019. This consultation looked at diet from different entry points: including health, affordability and sustainability. The objective of the Consultation was to develop guiding principles around what constitutes a sustainable and healthy diet, to be further translated into clear, non-technical information that can be used by governments and other actors in communication and policy-making. The guiding principles will be shared with the CFS and will certainly contribute to the development of the CFS VG. The proceedings of the Consultation will be published as well.
3. In consideration of the policy areas identified in Chapter 3 and the enabling factors suggested in paragraph 41 of the Zero Draft, what policy entry points should be covered in Chapter 3, taking into account the need to foster policy coherence and address policy fragmentation?
Overall, the right policy areas are highlighted in the document. A missing element is that the document does not provide sufficient reflection on how those policy areas outlined in the document should be shaped. Certain policy areas could go into complete different directions from the intended targets, and therefore, more clarity should be included on each policy area.
We would like to suggest that the policy areas could be organized around broad policy goals and the policy measures along the food supply chain. For example, the existing challenges on enabling healthy diets could be taking as a starting point:
Clearly one challenge is the availability and affordability of fruits and vegetables to the world population. Using an approach that addresses the question which different measures are required to address this challenge (which could be formulated as a global target), more clarity could be provided for the future user of the Voluntary Guidelines.
Another example could be the existing global problem over the supply of fats and oils for human consumption. The question to be addressed could be, what types of policies are required to increase the availability of healthier fats and oil and their production compared to the existing ones that currently are expanding; and to do this in line with the global target on the elimination of industrially produced trans fats or the target on the reduction of saturated fats in our food supply.
To address these and other challenges, which could be formulated in terms of global policy goals, clearly will require an alignment of consumer policies, industrial policies, food reformulation policies, research and agriculture policies. We would like to suggest that the CFS Secretariat considers to be more explicit about what the VG are trying to achieve. In addition, regional specific goals and targets may be considered.
4. Can you provide specific examples of new policies, interventions, initiatives, alliances and institutional arrangements which should be considered, as well as challenges, constraints, and trade-offs relevant to the three constituent elements of food systems presented in Chapter 3? In your view, what would the “ideal” food system look like, and what targets/metrics can help guide policy-making?
With regard to targets, we would like to suggest the establishment of global policy targets. In order to reach alignment between the different policy areas, the CFS might consider establishing such global policy targets that should be designed to achieve the overarching targets of addressing all forms of malnutrition. One step in that direction would be to clearly state the objectives for each policy mentioned in the document. In this way, the formulation of the policy would be more easily understood by countries for relevant implementation. CFS might help the global community and countries in providing these essentials. Without such an analysis of how a particular policy element contributes to reaching overarching targets of addressing all forms of malnutrition, the different sub-sections in Part 3 of the document, the way they are presented, could appear to be fragmented and disconnected. There is a call on countries to address this matter when they plan to use the voluntary guidelines, but CFS is well positioned to help in providing the key elements around which integrated food and nutrition policy planning might be done.
On specific policy measures we would like to share the following comments:
Regarding the food environment, WHO is currently conducting systematic policy reviews on four areas: Marketing of food to children, Labelling policies, Procurement of food in public institutions, Fiscal policies. The outcomes of this work might support the provision of evidence-base for certain policies. Moreover, some of these policies might require some broadening with reference to the current wording in the document. For example, on marketing we strongly recommend that the whole of marketing policies is considered, and that the document stays broad as it is now and is not limited to one element like the marketing to children. Equally important are the marketing of breastmilk substitutes and the marketing of foods for young children as significant public health components.
On food quality and safety: we would recommend not having a specific item but rather have it as cross cutting element that should be present in multiple policy areas. Moreover, we observe inconsistency in placing food safety in the document: food safety is mentioned in Farm-to-school Programmes but not elsewhere in Production Systems, is mentioned in Handling/ Storage/Distribution/ Processing/ Packaging but not in Retail/Markets, and is totally absent in Consumers Behaviours section while the final preparation of food is particularly important for food safety including in informal sectors (street-vended foods). Food safety is an integral part of food security and nutrition; therefore, its actions should take place along the entire food chain.
On the food environment, and particularly on the economic access component: - We would like to suggest more specificity around the nutrition-sensitive trade policies, and to mention the need to consider nutrition impacts of trade policies. We also would like to suggest the inclusion of import policies as a measure to shape the food environment.
Regarding the fiscal and pricing policies - When it comes to pricing policies, we would rather suggest to use the term ‘economic measures’ and to not just consider taxation as the only measure. A broader concept would be more adequate that includes besides taxation also the management of subsidies, which is an important and critical element in the way food availability and the price of food are shaped.
The informal food sector - has a role to play in many parts in Asia and also in urban areas in Africa and elsewhere. In many low-income countries, the informal food sector is comprised of street and market food vending. Given its importance for a huge number of people in the world and often the most vulnerable, we suggest including policies that address the nutritional value and safety of food produced in the informal sector, under the section on food environments – availability and physical access.
5. How would these Voluntary Guidelines be most useful for different stakeholders, especially at national and regional levels, once endorsed by CFS?
There are multiple actors involved in food systems at all levels. Under this point, we would like to suggest including the need for setting up rules of engagement to strengthen transparency and accountability. As addressed in the HLPE report on Multistakeholder Partnerships, this includes identifying and acknowledging possible tensions, power asymmetries and conflict of interest among partners; developing appropriate support tools to address these, and defining clear roles and responsibilities of the different partners. We consider it important to address the rules of engagement in chapter 4 of the document.
The UN Decade of Action on Nutrition as an implementation mechanism for the VG. The discussion of the VG might inform the workprogramme and the commitments for the second half of the Nutrition Decade. We would like to suggest that the Nutrition Decade is mentioned as a means to follow up and implement the VG.
FAO and WHO are preparing for the Mid-term Review of the Nutrition Decade to lead to an event in 2020. The main objective of the Mid-term Review will be to identify existing gaps and set priorities for the second half of the Nutrition Decade. The CFS VG play an important role in identifying these priorities with regard to food system action and guiding countries in further operationalising the relevant ICN2 Framework for Action recommendations. More information on the Mid-term Review are available at this link https://www.un.org/nutrition/sites/www.un.org.nutrition/files/general/pdf/concept_note_for_nutrition_decade_mid-term_review_rev_130619.pdf
WHO looks forward to continuing working closely with the CFS Secretariat and all partners involved in this process.
Marzella Wustefeld