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E-consultation on an Issues Note proposed by the HLPE Steering

Committee:

HLPE report on Nutrition and Food Systems

From 24 October to 5 December 2016

http://www.fao.org/fsnforum/cfs-hlpe/nutrition-and-food-systems-v0

− Collection of contributions received −

These proceedings are compiled by the Global Forum on Food Security and Nutrition (FSN Forum)for the High Level Panel of Experts (HLPE)

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Table of contents

Topic.......................................................................................................................5Contributions received...........................................................................................7

1. Claudio Schuftan, PHM, Viet Nam..................................................................72. Joost M.E. Pennings, Netherlands................................................................103. Moises David Rojas Peña, Dominican Republic............................................114. Florence Egal, independent expert, Italy.....................................................125. Roseline Remans, Bioversity International, Belgium...................................146. Jonas Schmitt, FAO, Chile............................................................................147. Ducrocq Thomas, INRA/AgroParisTEch, France...........................................158. Lal Manavado, University of Oslo, Norway..................................................159. Adolfo Chávez, Mexico................................................................................3110. Gro-Ingunn Hemre, National Institute of Nutrition and Seafood Research, Norway..............................................................................................................3311. International Food Policy Research Institute, United States of America. .3412. Bibhu Santosh Behera Ouat, Bhubaneswar, Odisha, India.......................3613. Dele Raheem, Arctic Centre, University of Lapland, Finland....................3714. Ali Abdalrahman Iuide, Egypt...................................................................3715. Fardet Anthony, France...........................................................................3716. Santosh Kumar Mishra, Women’s University, India..................................3817. Diana Lee-Smith, Mazingira Institute, Kenya...........................................3818. Jeevananda Reddy, formerly Chief Technical Advisor – WMO/UN, India...4119. Michael Crawford, Imperial College, United Kingdom..............................4420. Sam L. J. Page, UN Committee and the Agriculture Committee, United Kingdom............................................................................................................4521. Paul Sommers California State University, United States of America......4522. Fisheries and Aquaculture Department, FAO, Italy..................................4623. Roberto Capone CIHEAM, Italy.................................................................4924. Dhanya P, Climate Change Division, Environment Protection Training and Research Institute, Hyderabad, India................................................................5225. Hector Bourges, Mexico...........................................................................5226. Jane Sherman, Food and Agriculture Organization of the UN, Italy..........53

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27. Edda Fernández Luiselli, Dirección General del Sector Primario y Recursos Naturales Renovables de la SEMARNAT, Mexico...............................................5628. Dalia Mattioni, Italy..................................................................................5929. Javier Carrera, FGH Latin America Agro Consulting, Mexico....................6030. Omoyemen Lucia Odigie-Emmanuel, Centre for Human Rights and Climate Change Research, Nigeria....................................................................6131. Chadwick Digo, Egerton University, Kenya..............................................6132. Minna Huttunen, Ministry of Agriculture and Forestry, Finland................6233. Manuel Moya, Real Academia de Medicina, Spain...................................6334. Elsa Victoria López, WFP, Honduras.........................................................6535. Frédéric Dévé, FAO, Italy.........................................................................6536. Joost de Jong, Ministry of Economic Affairs, Netherlands.........................6637. Anne-Marie Mayer, United Kingdom........................................................6738. Ekin Birol, IFPRI, United States of America...............................................6839. Janine Pierce, Australia............................................................................7440. Denish Ogwang, Lango Joint Farmers Association, Uganda.....................7441. Frank Mechielsen, Hivos, Netherlands.....................................................7542. Victor Owino, International Atomic Energy Agency, Austria....................7843. Mark Lawrence, Deakin University, Australia...........................................8044. Patrick Mink, Federal Office for Agriculture (Switzerland), Switzerland. . .8245. Florence Macherez, Animal Task Force European Public Private Platform, Belgium.............................................................................................................8546. Judith Benedics, Federal Ministry of Health and Women’s Affairs, Austria

8647. Barrie Bain, International Fertilizer Association (IFA), France..................8648. Henk Westhoek, PBL Netherlands Environmental Assessment Agency, Netherlands.......................................................................................................9049. Hélène Delisle, Université de Montréal, Canada......................................9250. Zoltan Kalman, Permanent Representation of Hungary to FAO, Italy......9251. Jennifer Dias, Brooke, United Kingdom....................................................9452. Anita Utheim, Ministry of Trade, Industry and Fisheries, Norway............9653. Rafaela Batista, Ministry of Health, Brazil................................................9754. Teresa Borelli, Bioversity International, Italy.........................................10455. Sheryl Hendriks, University of Pretoria, South Africa.............................109



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56. Laurence Rycken, International Dairy Federation, Belgium...................11257. Teresa Borelli, Bioversity International, Italy.........................................12858. Oliver Mellenthin, Federal Government of Germany, Germany.............12859. Beate Scherf, FAO, Italy.........................................................................13160. Elin J. Boll, Arla Foods, Denmark............................................................13261. Marília Leão, National Council on Food and Nutrition Security, Brazil....13762. Morgane Danielou, Private Sector Mechanism, France..........................13963. Ana Islas, FAO, Italy...............................................................................14964. Ann Steensland, Global Harvest Initiative, United States of America... .14965. Stineke Oenema, UNSCN.......................................................................15966. Theresa Jeremias, CARE International, Germany...................................15967. Darinka Anzulovich, COPAL – Coordinadora de las Industrias de Alimentos y Bebidas.........................................................................................................16668. Carlos Monteiro, Center for Epidemiological Studies in Health and Nutrition, University of São Paulo, Brazil.........................................................16969. Elena Cadel, Barilla Center for Food and Nutrition Foundation, (BCFN), Italy 17270. Robyn Alders, University of Sydney, Australia.......................................17271. Patti Rundall, IBFAN, United Kingdom....................................................17672. Lidan Du, The SPRING project/HKI, United States of America................17773. Elle O’Flaherty, United States Department of Agriculture, United States of America...........................................................................................................17874. Florence Tartanac, FAO, Italy.................................................................18175. Donald Moore, United States of America...............................................18376. Janine Giuberti Coutinho, Ministry of Social Development, Brazil..........18977. Marlene Heeb, Swiss Agency for Development and Cooperation (SDC), Switzerland......................................................................................................19578. John Connelly, National Fisheries Institute, United States of America. . .20179. Tony Prescott, Department of Agriculture and Water Resources, Australia

20380. Isabelle Mialet-Serra Représentation Permanente de la France auprès des institutions des Nations Unies à Rome, France................................................20481. Alena Matzke, NCD Alliance, World Cancer Research Fund International, Switzerland......................................................................................................20582. Marzella Wüstefeld, WHO, Switzerland..................................................221



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83. Jacopo Valentini, WFP, Italy...................................................................23184. Civil Society Mechanism........................................................................23885. Pete Howson, DFID, United Kingdom.....................................................26086. Corrado Finardi PhD- Coldiretti Italian Farmers Union –University of Parma- food Sciences Dept.- Lecturer.............................................................261



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TopicAt its 42nd session in October 2015, the UN Committee on World Food Security (CFS) requested the High Level Panel of Experts on Food Security and Nutrition (HLPE) to prepare a report on Nutrition and Food Systems. This report is expected to be presented at CFS 44 in October 2017.

As part of the process of elaboration of its reports, the HLPE is organizing a consultation to seek inputs, suggestions, and comments on the present V0 draft. This open e-consultation will be used by the HLPE to further elaborate the report, which will then be submitted to external expert review, before finalization and approval by the HLPE Steering Committee. HLPE V0 drafts are deliberately presented early enough in the process - as a work-in-progress, with their range of imperfections – to allow sufficient time to give proper consideration to the feedback received so that it can play a really useful role in the elaboration of the report. It is a key part of the scientific dialogue between the HLPE Project Team and Steering Committee, and the rest of the knowledge community. It should be noted that the present V0 draft report does not yet identify areas for recommendations as it is too early to determine the major propositions stemming from the report.

To participate to the discussion, please visit the dedicated HLPE e-consultation website: http://www.fao.org/fsnforum/cfs-hlpe/nutrition-and-food-systems -v0

HLPE Steering Committee V0 draft on Nutrition and Food Systems

It should be noted that there are several reports that have just been released or will be released over the coming year including the Foresight Report on the Future of Diets (September 2016) and the EAT-Lancet Commission on Sustainable Diets and Food Systems (June 2017). The Project Team members will ensure that these reports will be kept in due consideration.

In order to strengthen this draft, the HLPE would welcome submission of material, evidence-based suggestions, references, and examples, in particular addressing the following important questions:

1. The purpose of this report is to analyse the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft?



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2. Do you think that the overall structure of the draft is comprehensive enough, and adequately considered and articulated? Does the draft strike the right balance of coverage across the various chapters? Are there important aspects that are missing? Does the report correctly focus on the links between nutrition and food systems without straying beyond that?

3. Does the conceptual framework need to be edited? Simplified? Should “the food environment” as defined in the draft be central to the framework?

4. Are production systems and their role in shaping diets and nutritional outcomes adequately addressed?

5. Does this draft cover adequately the main controversies in the field of Nutrition and food systems? Are there any remaining gaps?

6. The project team is working on a categorization of food systems. Are you aware of specific approaches of use in that perspective, and particularly of quantitative indicators that could be used?

7. Does this draft adequately show the multiplicity and complexity of diets and nutrition issues across different food systems and specific contexts with a good regional balance?

8. What areas of the document are in need of strengthening or shortening?

9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win outcomes in terms of addressing the different dimensions of diets for FSN?

10. Section 4.2.2 on “Institutional Changes and Governance Across the Food System Movements for Nutrition” requires more work, and more inclusion of evidence and of the various players. Any inputs on this section are most welcome.

11. Is the report too technical or too simplistic? Are all the concepts clearly defined?

12. Are there any major omissions or gaps in the report? Are topics under-or over-represented in relation to their importance?

We thank in advance all the contributors for being kind enough to read and comment and suggest inputs on this early version of the report.

The HLPE Project Team and Steering Committee



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Contributions received

1. Claudio Schuftan, PHM, Viet NamOverall general comments: (all in a personal capacity)

[V0 is way too long and academic to digest. It must be drastically cut for it to have any impact on the CFS. If V0 cannot say what is needed and why in 30 pages, CFS will simply be overwhelmed (I am not talking about an executive summary, but a convincing piece of around 33 pages). One possibility, to start with, is to put the case studies in annex and summarize the outcomes of those in the main report.].

V0 variously speaks of food, nutrition and/or unhealthy environments. Using this terminology, avoids using already UN-sanctioned language as relates to the influence of a) the physical environment, and b) of the social determinants of nutrition (a la Social Determinants of Health that are very explicit of what these determinants are).

The concept of ‘value chain’ replaces the over 50 year old concept of ‘food chain’ (from production to digestion). Yes, it adds increases and losses of nutrients along the chain. But does it/shouldn’t it also add the tracking of for-profit hikes or distortions of food prices negatively affecting poor consumers as foods go from producers to consumers? (the latter not presented in Figure 27, p68 and only tangentially touched upon in Fig 29, p69)

VO mentions the concept of food sovereignty only twice: Once anteceded by “it is argued…” and another time quoting CSM. It does not take a stand on whether the concept ought to be recommended for adoption by the CFS

VO mentions the concept of ultra-processed foods 3 times: Once quoting the Brazilian Dietary Guidelines, once citing Popkin, and once just describing these products are consumed. V0 does not take a clear position on them.

V0 does not mention the grave issue of land grabbing at all. This cannot be omitted in this day and age.

There are very few examples worldwide of where the burdens of malnutrition have been made a political priority (Brazil for example--although in jeopardy now). The best we have to show for is a collection of vertical interventions with little or no participation of the affected, i.e., the claim holders. Malnutrition has simply not been addressed as a human rights violation. Publications like the Lancet Nutrition Series have nothing but contributed to this, claiming to be the best our profession(als) has(ve) to offer.

In multiple places and indifferent contexts (7 times), V0 refers to “the poor”… This is such a depersonalizing pejorative thing to do… What we are really talking about is “those individuals and groups rendered poor by an unfair economic system”. Along the same vein, V0 mentions poverty alleviation or reduction 2 times when what it really ought to be talking about is “disparity reduction” in a 99/1 world.

V0 mentions nutrition-sensitive approaches or programming five times without ever defining the concept.



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If we take the example of the needed mobilization aimed at democratizing all instances of nutrition governance, we have to be clear that this objective is not separate from, but very much part of, a mobilization effort of a wider perspective. To treat nutrition governance as somehow independent of national and global economic and political governance is outright absurd. Simply said, proclaiming that the challenges of nutrition governance can be dealt independently plays the important political role aimed at obscuring the vested interests and power relations at play. (relates to p72 and p104)

Section 4.2 on p92 and beyond focuses on food system supply interventions. This is only one arm of the problem! The bigger constraints, many of us argue, are on the demand side, i.e., on the social determinants of nutrition as I argue in the first bullet above and also below as I critique the conceptual framework. (For instance: is innovation in technology really a very high priority? (Line 11 p92).

In many places, V0 calls for multidisciplinary or multisectoral approaches to solve the problems of right to food violations. There is nothing terribly wrong with this concept, but it just gratuitously assumes that looking at the problem of these violations from a ‘wider’ multi-professional perspective is going to automatically lead us to the better, more rational and egalitarian solutions. The call is for sharing paradigms among the different scientific disciplines or sectors where practitioners come from. But by just putting together brains ‘sowed’ differently, without considering where they are coming from ideologically, is not going to, all of a sudden, make a significant difference in the outcome and the options chosen. They may well stay in the domain of immediate or underlying causes, only now everybody involved contributing a small monodisciplinary window to the package of (still pat?) solutions proposed. Multidisciplinary approaches simply, most often, take the social and political context (i.e., the individual and institutional power relations) as given; they therefore end up being conservative in their recommendations.

Specific comments:

INTRODUCTION

Line 16 p9: not only decision-makers in the public and private sector (duty bearers) need to be empowered; they already have excess power in the prevailing system. It is claim holders that need to empower themselves to demand changes in the food system.

Line 18 p9: The SDGs are not per-se accountability tools… Line 25 p10: It is not for the current leaders (duty bearers) alone to act for nutrition. Claim

holders have to be given a say.

CONCEPTUAL FRAMEWORK

Line 15 p11: The definition given is for Food Systems and not for Nutrition Systems which the VO claims to also address. The definition wrongly puts socioeconomic growth and equity (should be equity and equality!) only as outcomes and not as determinants. [see comment on social determinants (and not only outcomes) above].



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The Conceptual Framework diagram p14: o Under Political and Economic Drivers, only livelihoods and income, markets and trade are

mentioned. The more structural political and drivers are not mentioned: not acceptable in this day and age.

o A special box is allocated to consumer behaviors, but not a word is mentioned here about the role of Big Food in negatively influencing those behaviors: Should be in the diagram. (This is mentioned on p17, but not in the diagram). (The role of Big Food in shaping consumer behavior is also missing on page 108).

o The economic and social impacts are placed on the very right of the diagram as outcomes; should economic and social considerations not also find a place on the very left of the diagram as determinants of the food system?

THEREAFTER:

Lines 1-6 p16: Mention is missing of the documented negative effects of fee trade agreements. Line 7 p16: GDP/cap is actually meant, but we know it is an average so of no help for work from a

right to food perspective. Lines 21-29 p16: The determinants of demographic drivers are missing here. Lines 36-49 p16: No mention is made of the encroachment of cash crops displacing food crops. Lines 14+15 p18: No mention is made of why some vulnerable groups rendered poor spend most

of their income on food. Line 29 p18: Reformulation of ultra-processed foods is not the solution as clearly shown by

Monteiro et al. Yes, industry can reformulate, but will boast about it as an advertising gimmick….and we will still be hooked on ultra-processed (junk) food for ever longer. (also in p83)

Lines 24-35: Mention of the Brazilian Guidelines ought to be made here too. Lines 2-4 p24: Again here, economic and social equity parameters are seen as outcomes and not

also as determinants. Lines 25-32 p33: The focus called for must also include regulating Big Food/Big Soda and the

advertising of ultra-processed foods and soft drinks. Lines 16-21 p38 (Conclusions): See the 6th bullet of my general comments. Lines 32-40 p50: To preserve the fairness of V0, the critical literature towards the SUN Initiative

(not a movement…) must be quoted, particularly in what pertains to the conflicts of interest of and lack of substantial investments by participating private sector actors to address the multiple burdens presented in V0. (Will this come after line 42 in p104?).

Lines 18-19 p54: For many years, open trade on food dumped highly subsidized US grains in countries rendered poor with devastating consequences for small farmers.

Lines 20-21 p.54: Increased trade is actually seldom associated with rising incomes; look at NAFTA.

Lines 42-43 p54: Yes, nutrition and trade policies are included in the SDGs, but better coherence will not resolve the negative effects of the latter; much more is needed in terms of protecting nutrition in existing and upcoming FTAs. (V0 says this in the next page).

At this point I started skipping….Just too much information to digest…

Lines 19-25 p.62: This is the crux of the problem we are faced with in 2016 and beyond!



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Line 13 p72: Says: “Having good governance helps to support the provision of social services.” …. Not always the case: look at the USA.

Lines 3-14 p86: This intro on nutrition education totally ignores educating and organizing consumers about the role Big Food and Big Soda play in eating and drinking habits that lead (not only) to NCDs. This, so consumers turned claim holders can demand their governments regulate and or tax ultra-processed foods.

Lines 2-7 p87: CODEX is mentioned in a positive role here. But CODEX gives an inordinate place in the table to Big Food/Big Soda with public interest civil society organizations being shut out of meaningful negotiations that protect consumers.

Lines 21-24 p87: What the example of Chile does not say is that the levels of unwanted nutrients in the labeling’s ‘red light’ (‘stop sign’) category are set too high due to industry pressures; permitted levels will go down to internationally recommended levels only over a period of four years: a typical delaying tactic by industry.

Line 16 p91: Why is V0 asking more R&D in nutrient-rich foods? The Brazilian Guidelines are clear about the alternative (and correct) options.

Line 37 p93: V0 says: “There are also ethical issues with genetic modification… Should it rather say: “There are serious issues….?

Lines 29-38 p96: V0 says: “Increasingly, technology is playing a bigger role in influencing behavior through nudges or prompts in purchasing decisions.” Meaning what? and “A technology focus on prevention through nutrition and wellness category could be a well over USD trillion dollar market opportunity”. Really?? …and why should V0 worry about market opportunities? Furthermore, “The increase in available technology has empowered consumers to take charge of their own health”. Really?? …this must come from some type of a fabricated evidence source…

Lines 13-17 p87: V0 says: “The ability to connect the right social nudges through information and convenience will help combat the issues of obesity.” Very unclear what this is supposed to mean, but it somehow rings wrong to me.

Line 41 p100: V0 calls for subsidies for nutrient-rich foods. Why only? Why not mentioning subsidies for unprocessed foods as the Brazilian Guidelines call for?

Lines 4-23 p104: By targeting the very poor, safety nets somehow attempt to ‘reduce poverty’ but, in reality, going for safety net approaches means accepting the exacerbation of inequality. As said above the real issue is not poverty alleviation, but rather disparity reduction.

Line 29 p104: Why do these require “top-level design”? Is V0 not for participatory approaches? Lines 19-28 p105: V0 does not mention the many published important PPP critiques relating to

inherent conflicts of interest in private sector participants. (Also missing on Line 42 p109). (I see V0 plans to still add a short section on conflicts of interest on page 107).

Line 33 p109: V0 speaks of a nutrition-sensitive value chain approach and centers the same on nutrients, not on foods….Is this the way to go?

I AM AWARE THESE COMMENTS ARE LONG AND DO NOT HIGHLIGHT THE MANY GOOD POINTS THE V0 DRAFT HAS. THE INTENTION JUST IS TO MAKE IT BETTER.



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2. Joost M.E. Pennings, NetherlandsThe paper attached may be helpful for the report as it examines the relationship between consumers buying light (low fat) products and obesity.

http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/Obesity-IJRM.pdf

3. Moises David Rojas Peña, Dominican RepublicNutrición y Sistema Alimentarios

La desnutrición es el resultado del consumo insuficiente de alimentos y de la aparición repetida de enfermedades infecciosas. La desnutrición puede ser crónica, aguda y desnutrición según peso para la edad.

La desnutrición implica tener un peso corporal menor a lo normal para la edad, tener una estatura inferior a la que corresponde a la edad (retraso en el crecimiento), estar peligrosamente delgado o presentar carencia de vitaminas y/o minerales (malnutrición por carencia de micronutrientes o mejor conocida como hambre oculta).

Los factores que influyen en la desnutricion, aunque normalmente se menciona a la pobreza como la causa principal de la desnutrición, existen otras causas tan importantes como ésta, tales como la no lactancia materna exclusiva, la presencia de enfermedades como diarrea, infecciones respiratorias agudas, y otras; la falta de educación y de información sobre la buena o adecuada alimentación, el no consumo de suplementos vitaminados o alimentos fortificados, y el costo de los alimentos.

Esta se compone de bajo peso, retraso del crecimiento, emaciación y deficiencias en esencial vitaminas y minerales. Además, la deficiencias de micronutrientes la falta de el hierro o deficiencia de yodo son todavía prevalente, lo que indica que muchos países están luchando con múltiples cargas de desnutrición.

Una publicación de UNICEF de 2006, expresa que todos los años nacen en el mundo más de 20 millones de niños y niñas con un peso inferior a los 5.5 libras, lo que equivale al 17% de todos los nacimientos del mundo en desarrollo, es decir una tasa que duplica el nivel de los países industrializados que es de 7%.

Desnutrición en la República Dominicana

Entre 1940 y 1989 la desnutrición habría sido responsable de la muerte de 265 mil menores de cinco años que tendrían entre 15 y 64 años en el 2004 y, por tanto, formarían parte de la población en edad de trabajar.

De acuerdo al Informe del Estado Mundial de la Infancia 2007, entre los años de 1998-2005 en el país un 11% de los recién nacidos nacían con bajo peso, y en los años de 1995-2005 el 2% padecían de desnutrición moderada y grave y un 9% de desnutricion crónica (talla/edad) moderada y grave.

En el país la deficiencia de talla para la edad se daba en el 7% de los niños y niñas menores de 5 años; de forma severa en el 2%. Las regiones de Enriquillo con un 10%, el Valle 9% y Cibao Nordeste 9% eran las que presentaban mayor desnutrición crónica. También San Juan de la Maguana y Elías Piña



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eran los lugares donde estaban los más altos porcentajes de desnutridos, ya que aproximadamente un 6% de niños y niñas presentaban desnutrición aguda.

La desnutrición crónica en menores de 5 años con el nuevo patrón de la OMS, en 9.8%. Se observa como el nivel educativo de la madre influye de forma significativa en la desnutrición. De esta manera, la desnutrición crónica en hijos de madres sin educación es de 15.4% y en los hijos de madres con niveles educativos secundario o superior es de 9.4% y 4.7% respectivamente.

El factor decisivo en la presencia de desnutrición aguda en los menores de 6 meses, se debe a la baja práctica de la lactancia materna exclusiva en menores de 6 meses, la cual es de sólo 7.8%. Esta situación es responsable de la alta prevalencia de la desnutrición aguda entre los menores de 6 meses que es de 5.6%, en contraste con la presentada entre los niños de 18 a 23 meses de 0.6%.

Otros factores que causan el hambre y la desnutrición están los desastres naturales, los conflictos, la pobreza, la falta de infraestructura agrícola y la sobre-explotación del medio ambiente. Recientemente, el número de personas con hambre se incrementó debido a las crisis financieras y económicas.

El costo que representa el hambre y la desnutrición crónica para las naciones en desarrollo, representa más 450 mil millones de dólares al año.

Las soluciones que se plantean para enfrentar el problemas son las siguientes. Realizar una alianzas con las instituciones responsables del área de la salud y la alimentación. Regular la venta de alimentos en el entorno escolar y los horarios de publicidad de ciertos tipos de comida. Que en las escuelas de tanda extendida se incluyan espacios para que los niños realicen actividad física regular.

Que la decisiones de los alimentos que lo componen no se escojan en base a los hábitos de alimentación de los niños, como ocurre en la actualidad, sino que se diseñe una dieta balanceada que pueda educarles sobre la buena alimentación.

4. Florence Egal, independent expert, ItalyThanks for this opportunity to comment on this very important document and apologies for the length of my (personal) comments.

There is an increasing consensus that we need a change of paradigm. Present food systems are dysfunctional because they result in unhealthy diets. They are the outcome of a supply-driven and macroeconomic approach to food, which itself has shaped to a large extent research to date. Literature review by itself (in particular in the areas of food security and nutrition) cannot therefore be expected to provide a comprehensive basis for the report. The report should acknowledge this from the start. The report should for example explicitly question food policy prospective studies based on unhealthy food habits (e.g. excessive consumption of meat). The research principles agreed upon by IPES-food should lead the way for joint learning to guide food systems transition in the coming years.

Since the problem is diets, the report should start from diets, and in particular from the dietary transition resulting from the commodification of food and globalization. Revisit traditional diets and local food systems with a view to improving them in terms of health, culture, livelihoods and



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environmental management (e.g. Mediterranean diet the New Nordic Food) can provide a basis for sustainable diets. (It is important to go back to indigenous knowledge and not to the prevailing understanding that rice or maize are the national foods in West africa or Southern Africa) There is a need to re-localize food systems and ensure a harmonious articulation of local food systems with national, regional and global food systems.

Understanding the causes of malnutrition for affected population groups is also essential to understanding local challenges and opportunities, identifying the role of different institutions and ensuring complementarity between the food and agriculture and the health sectors. This can provide insights for the reorientation of food systems.

It is no surprise to note in several sections of the report a degree of confusion between value chains and food systems. While the report looks at health and environmental dimensions, insufficient attention is given to the social (employment and livelihoods) dimension of sustainable development and to institutional dysfunctions (governance is by far the major issue).

Most of the research reviewed mentions country data. There are several references to low and middle-income countries. The SDGs and Agenda 2030 have recognized the need to move beyond this simplistic classification.

The report focuses to some extent on food industry. More attention should be given to the distribution system (in particular the role of hypermarkets and supermarkets) since they are playing the lead role in shaping both consumption and production. It is essential that local markets and short food chains (e.g. farmers’ markets) be protected and supported. The shift to supermarkets (including in nutrition CCT interventions) has in many cases resulted in degradation of diets and destruction of local food systems. And roads have often resulted in depleting communities of the food they produced, thus decreasing home consumption, or isolating them from the national commercial system. More research is needed in this area.

The report is biased towards industrial-scale food production to the detriment of farming families. While increased dietary diversity is certainly needed, priority should be given to making the best of local biodiversity and ecosystems, which should of course be complemented through fair trade of quality products. This contributes to resilience of local food systems: areas most affected by the 2008 food crisis were those most dependent on international trade. More balance between national/local food production and food imports is needed.

Regarding possible solutions, the report emphasizes possible technological solutions, including fortification, which of course reflects the significant funding bias of recent research. These can certainly play a supporting role but have not proven to contribute to sustainability.

Urbanisation is indeed a key dimension but the report should emphasize the need for a territorial approach to food policies, which is central to sustainable food systems. The opposition p. 50 on urban vs. rural infrastructure is misleading and very reductive. The New Urban Agenda recently adopted in Quito could provide additional language. The process of the Milan Urban Food Policy Pact (which commits mayors to promote more sustainable food systems) could also be mentioned in a box. The examples of good practices collected could provide a basis for interdisciplinary research to elicit practice-based evidence.



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Public catering - and in particular school canteens – are indeed key entry points for promoting more healthy and sustainable diets. This is increasingly being done all over the world: Brazil’s home-grown school feeding programmes, school canteens in Copenhagen, etc. The role of HORECA (https://en.wikipedia.org/wiki/Horeca) is also essential and should be mentioned.

The assumption that healthy diets are more expensive (p. 51) needs to be substantiated: the issue is not to compare a mass produced commodity with the biologically produced equivalent, but to look at the food budget as a whole: cutting down on meat, dairy products, processed foods and soft drinks helps to reallocate household resources to better quality pulses and vegetables. In general, households have never spent such a small portion of their budget on food anyway and this cannot be sustainable.

Monitoring the impact of food crisis on diets is key for designing appropriate responses and will vary according to culture: in most places it results in sacrificing micro-nutrients to calories, but this is not always the case (e.g. Syria).

Sustainable food systems will require reviewing the legal and regulatory system at local level in order to identify and address contradictions and gaps. Many of the norms and procedures have been set up and adopted at national or regional level on the basis of a silo approach. Their relevance to sustainable development needs to be reviewed from a right to food perspective.

5. Roseline Remans, Bioversity International, BelgiumThe report has many valuable pieces but I agree with a previous comment that it is too long and too broad. Therefore here a short, hopefully constructive, suggestion:

This is to start with # major food system trends [e.g. the supermarket revolution, agricultural intensification and specialization, the glocal (globalization-localization) trend, increased processing and ultra-processing, the concern for food safety, the merging of food-related companies into expanding multinationals….. perhaps select 10 such trends] and then assess how those trends influence diets and sustainability in # settings and/or for # population groups, followed by recommendations, based on the reality of those trends. And to skip, or greatly reduce, the very general parts in the beginning.

6. Jonas Schmitt, FAO, Chile Dear Colleagues,

The report on Nutrition and Food Systems is really interesting and offers useful information for further research. In the following, I like to suggest a few points which could be helpful.

HLPE Comments:

Page 9, lines 8-10: “And the burdens are transmitted across generations, because malnourished mothers are more likely give birth to malnourished babies who are more likely to grow up to be malnourished adults.”



https://en.wikipedia.org/wiki/Horeca

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Comment: This is rather from a perspective of developed countries. Considering the transformation in developing countries (e.g. China) during the last 25 years, the problem lies not only by the mother. For example, when you think about obesity in China currently, the problem lies in the food habits of younger generations. Within this generation, there is a bigger demand for street and convenience food. This aspect is not expressed in this part of the introduction. Source: Zhai et al. (2014): Dynamics of the Chinese diet and the role of urbanicity, 1991-2011 (Table 2 and 3).

Page 21-22: Typologies of food systems

Comment: Regarding to this aspect Gómez, M. I. and Ricketts, K. D. (2013) with the paper “Food value chain transformations in developing countries: Selected hypotheses on nutritional implications” in Food Policy, could help by definitions (Table 1).

Page 54: Trade and globalization

Comment: The role of foreign direct investment could be illustrated more clearly. Multi-national food companies not only trade export their products to foreign markets through free-trade and globalization, they also enter the market by buying domestic food companies. This aspect is clearly described in Hawkes, C. (2006): The role of foreign direct investment in the nutrition transition, in Public Health Nutrition.

Page 58 f.: Demographic drivers – Population pressure, changing ages and urbanization

Comment: Zhai et al. (2014): Dynamics of the Chinese diet and the role of urbanicity, 1991-2011, describe the effects of urbanization for different age groups. This could be interesting in terms of which age-groups are most vulnerable to negative nutritional changes (especially younger groups) and therefore which groups have to be protected through political agendas.

Best regards,

Jonas Schmitt

7. Ducrocq Thomas, INRA/AgroParisTEch, FranceDear all,

Here I join the 1st results of y work in the topic of food insecurity and collective gardens, led in 5 gardens of poor neighbourhoods near Paris.

Tha contributions analyses 2 facts:

(i) The way organisations diversly linked to the collective gardens consider the food function of these gardens relatively to vulnerable people

(ii) The motivations and hopes considering the food function of collective gardens of 15 gardeners members of 5 different gardens located in areas which have socioeconomic difficulties ("Quertiers politiques de la ville").

Hopefuly, it can be useful to you in your evaluation.

Thomas Ducrocq



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La fonction alimentaire des jardins associatifs urbains: Quelles particularités pour les quartiers prioritaires « Politique de la ville »?

http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/M2EDTS2016_DucrocqThomas.pdf

8. Lal Manavado, University of Oslo, NorwayComments on the Draft V-0 Nutrition and Food Systems

I appreciate that the draft report attempts to convey a holistic view of the problem, and tries to design a systematic means of mitigating it. However, I find it makes certain basic assumptions, which owing to their untenability, would hinder the committee’s Endeavour. I shall comment on them as they occur, and suggest a possible solution. Before dealing with some concrete issues, I should like to direct your attention to the following issues concerning the questions posed at the beginning of the draft.

Question 1:

“The purpose of this report is to analyze the ways in which food systems influence dietary patterns…”

The Introduction begins with the fallacy of substituting the effect for its cause—

“Malnutrition in all its forms affects every country on the planet and is a major impediment to achieving

Both global food security and nutrition and sustainable development worldwide.”

Rather it is the very lack of an adequate Global Food Security and Nutrition that causes “all forms of malnutrition. In other words, malnutrition is a symptom of the former. This is a logical fact.

And later on---

“Food systems govern the types of food produced and the nature of their journey from farm to fork …”

This is an ontologically unsound notion, for food systems are tools designed by man to serve his nutritional needs and not vice versa. As such they cannot govern human habits any more than a motor car could govern where you want to go.

“The objective is to focus on consumers and consider sustainability issues.”

A food system consists of several sub-systems (see below). Operators of each sub-system are a ‘consumer’ of the output of the preceding one. So, whom do you mean? End-user who actually consumes the food, or some middleman?





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“The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft?”

The draft seems to lack the cohesion it has tried to achieve. As for solutions, it is not very clear how general or specific they were intended to be.

If I may make a suggestion, after the initial problem statement with less statistical details, the draft could have described a generic food system so that the reader would be able to apprehend the tool whose inept/unskilled use has brought about a considerable amount of malnutrition and environmental harm. It is the consequences of this latter that threaten the sustainability of our food systems.

Then, it would be possible to identify the sub-systems of a food system that have been put to dubious use, which in turn is one major cause of our problem. Once this has been done, we could identify the kind of policies needed to ameliorate the situation, possible generic strategies for their implementation, and finally, some examples of good practices that may be adapted for use in specific locations.

Question 2:

“Do you think that the overall structure of the draft is comprehensive enough, and adequately considered and articulated?”

It is comprehensive, but its value attribution is erroneous, for it consistently overlooks the obvious fact—

Food acquires its high value by virtue of it being essential for remaining alive.

The function of a food system is to enable us to secure food for our own use. Thus, a food system acquires a value as a tool that enables us to secure food.

But, when it is used principally as a means of gaining profit as it is often done today, it may become ‘valuable’ to tradesmen, but that use of a food system could hardly constitute a justifiable reason for attributing a value to it. The draft suffers from failing to make this critical distinction.

“Does the draft strike the right balance of coverage across the various chapters?”

The chapters could be re-arranged as suggested above.

“Are there important aspects that are missing?”

Yes indeed! The draft looks at the people’s procurement of food and eating habits as pieces of behaviour hard-wired to food systems. Most of us know what we need for adequate nutrition with reference to our particular food cultures. Today, operators of food systems have disenfranchised the end-users of their ability to choose through appeals to people’s innate desire for easier ways of doing things, and advertising. It is this atmosphere of helplessness this report ought to dispel if it wishes to nourish our hope for better and balanced nourishment.

“Does the report correctly focus on the links between nutrition and food systems without straying beyond that?”



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Much of the factual information would have been best placed as an appendix.

Question 3:

“Does the conceptual framework need to be edited? Simplified?”

It would repay to re-think the conceptual framework so that its ontological status would be sound, and its epistemological foundations solid.

“ Should “the food environment” as defined in the draft be central to the framework?”

I think this notion can be more of a ‘silo’ than the well-known ones we are now trying to avoid. I would strongly advise its removal from the text. As sustainability of food systems is intimately linked to the soundness of our environment, we should reserve this term to refer to our habitat to avoid confusion.

Question 4:

“Are production systems and their role in shaping diets and nutritional outcomes adequately addressed?”

This change in terminology from food systems to ‘production systems’ is both inaccurate and confusing. As for the question, once again, are we controlled by our own tool, or shall we do something to ensure that those who use it to do so appropriately? Shall we make money offerings to the god of commercialized food system and praise the deity for the food we get in return, or shall we reward the food system operator fairly for providing what we need and like? This may sound harsh, but this is the unappetizing crux.

Question 5:

“Does this draft cover adequately the main controversies in the field of Nutrition and food systems?”

Draft’s conception of a food system does not enable it to identify the nature of the controversies, hence their adequate resolution.

“The project team is working on a categorization of food systems. Are you aware of specific approaches?”

Yes, please see below.

“…. and particularly of quantitative indicators that could be used?”

It is impossible to categorize food systems either qualitatively or quantitatively due to logical reasons. Their only justifiable categorization would have to in terms of complexity with reference to number of sub-systems constitutive of a food system. This may be of some academic use, but of little practical significance.

Question 7:



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“Does this draft adequately show the multiplicity and complexity of diets and nutrition issues across different food systems…”

I think here the draft commits a category error, viz.; complexity and diversity of diets are not mediated by food systems. It is important to understand that a food system however complex it may be, is just a tool to obtain food. What food it may help one to obtain is determined by the flora and fauna of an area, and the degree of cultivar and household animal diffusion into it. One may argue that this diffusion is a man-mediated expansion of a yielder system (see below), but even then, please note that it is a man-made addition to a system, and not vice versa.

Question 8:

“What areas of the document are in need of strengthening or shortening?”

After identifying how various sub-systems of a food system may not be put into its ‘best use’ and its nutritional consequences like various forms of malnutrition, I suggest we proceed to solutions. Of course, each kind of far from best use of sub-system could be illustrated with concrete country examples if it is thought necessary.

The statistical data and descriptions of different manifestations of malnutrition ought to be placed in an appendix so that the main line of argument remains clear and free of factual clutter.

Question 9:

“Section 4.1 contains case studies/examples of effective policies …”

There seems to be a slight confusion here with respect to effective policies. An effective policy to ensure a sustainable, adequate and balanced nutrition to a populace will be similar in kind irrespective of the ethos, economy, etc., of countries. But, constituents of the end result of their successful implementation may differ. For example, in one land, the successful result will involve X tons of rice, Y tons of fish and Z tons of fruits and vegetables a, b,c, d, etc. But in another, it may be X tons of assorted meat, Y tons of fish, and Z tons of fruits and vegetables b, d, e, f, etc. Moreover, how they are prepared may also differ, not generically, but in surface details like spices and condiments use, etc. This is only complexity in detail, but not in kind.

Question 11:

“Is the report too technical or too simplistic? Are all the concepts clearly defined?”

It is too technical in details, eg. Malnutrition, and these details and be placed elsewhere with profit. It is simplistic in that it does not follow the chain of elements of a food system in a sound conceptual framework.

Question 12:

“Are there any major omissions or gaps in the report? Are topics under-or over-represented in relation to their importance?”



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The most crucial omission is a clear representation of the instrumentality of food systems. This has several unfortunate consequences, which have been mentioned earlier.

Specific examples and factual data distributed throughout often hinder one from following the reasoning. I have already commented on this.

Some Additional Problematic Statements:

“All forms of malnutrition are the result of interactions between poor diets and unhealthy environments.”

This is patently incorrect unless ‘unhealthy environment’ is believed to mean ‘human body’.

“Value chains…”

I know this has become a fashionable phrase, but it is not only unsound, but also highly misleading. Do please refer to my description of a generic food system given below.

Its physical ‘length’ has no real importance except in that it may involve expensive/polluting transport, costly preservation en route, etc., all of which are at the expense of the end-user.

It certainly cannot enhance the nutritive value of food, at best, it may be retained. Adding nutrients to food to make up for their loss in transit or during industrial processing cannot count as enhancing its nutritive value.

A Suggestion:

I think it would serve no useful purpose to pick more questionable statements from the draft. The good practices and examples will be very useful if placed in their appropriate place is a sound conceptual framework.

1. Introduction:Aim and the problem.

How one is going to achieve that aim in very general terms.

Chapter 1.

Description of a generic food system.

How its components can be used recursively.

It’s appropriateness.

Examples from real life (successful cases)

Chapter 2.

Dubious use of a food system and their consequences.

Examples from real life.



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Chapter 3.

Generic solutions:

Appropriate policies

Intra- and inter-policy disharmony to be avoided.

Examples of success (brief).

Chapter 4.

Implementation of policies

Level 1:

How to choose right strategies

What to avoid.

What is required.

Chapter 5.

Policy implementation continued.

Level 2:

Execution of chosen strategies:

How to choose the right ways and means

What to avoid

What is required.

Chapter 6.

Evaluation

Mechanism of policy/strategy revision with reference to feed back.

Long-term follow-up, etc.

Appendix 1.

Examples of successful policy and modes of their implementation.

Appendix 2.



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Successful examples of tools used to implement various strategies, ie.e., successful projects, case reports, etc.

Appendix 3:

Other data; definitions, tables, charts, etc.

References can be made in the main text, i.e., chapters to relevant info in the appendices. This will make the main argument easy to read and understand, while the supporting evidence is just at hand. This arrangement is not only logical, but it is also very pragmatic as it allows a busy decision-maker quickly to see the way forward without having to plouh through piles of supporting evidence.

The suggested conceptual framework:

1. The problem:Incidence of the various forms of malnutrition is indefensibly high especially in developing countries.(this may be expanded with a few statistics). Some of its forms like obesity is an increasing public health problem in developed countries, but it is also becoming a health issue among the relatively affluent in developing countries.

Every form of malnutrition is brought about by a qualitative and/or quantitative deviation from a balanced diet for a given individual at a given time. Obviously, what makes a balanced diet for a person varies according to whether one is in an infant, child, teenager, adult, pregnant or old. Moreover, it also varies with one’s nutritional needs related to what one does daily. I think everybody will agree with me this far, and I’ll go a step further.

Our climate, geography and soil type of habitat have played a key role in determining what we eat today, because what is available to eat depends on those factors whether we are hunter-gatherers or agriculturalists of today.

Look at the actual diets of those who live above or near the northern polar circle like the Greenlanders, The Samoyads of northern Russia, etc., and those who dwell in Tierra del Fuego. Animal protein and fat from blubber are their dietary mainstays, and over the centuries their bodies have become adapted to that diet.

But as we approach the tropics, vegetable components begin to predominate people’s diets owing to the greater availability of vegetable food. The nomadic peoples of central Asia and the middle-east were an exception to this general trend, because their habitat was best suited for grazing, but not for cultivation. Here, I refer you to the shrinking of the Aral sea and the desertification of central Asian grasslands, , the greatest man-made environmental disaster brought about by the Soviet attempts to ‘cultivate the Steppe’ using modern agro-technology, when it was totally unsuited for the purpose.

I say all this to impress on the reader the indisputable fact that there is no such thing as a universal balanced diet, for even for an individual it varies with time and what one does. Secondly, whether we like it or not, our bodies have evolved to store a certain amount of



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nourishment because regular feeding is not a given, but a convention. True, we are evolving towards adopting this convention as a regular habit, but some traces of our ancestral traits in nutrient storage still persist in our anatomy. San people of South Africa and the general plumpness of a one from extreme North are striking examples of this. Meanwhile, many intermediate anatomical variations can be seen throughout the world. Therefore, it seems hardly scientific to consider some ‘body mass’ based number as a universal indicator of ‘ideal/perfect/standard’ physique resulting from a regular intake of a balanced diet.

I strongly recommend you to avoid this dangerous line of universal body standardisation whose evil consequences are now plaguing considerable numbers of teenagers in affluent countries who suffer from Anorexia or Bulimia. Let us move away from people standardisation with respect to dietary habits, and confine ourselves to informing them what is reasonable to eat under given conditions, and empower them to make their own choices.

Let me next outline how qualitative and quantitative deviations from a balanced diet can affect us adversely:

Qualitative and quantitative shortages result in various deficiency diseases, defective cognitive development and/or impaired physical development. This can be expanded hugely, but it is not necessary.

Qualitative and quantitative excesses could lead to problems ranging from vitamin poisoning (excessive intake of vitamin D for instance) to obesity and its consequences.

Now, it is time to move on to the causes of the two undesirable phenomena above. As our brief restricts us to view the problem in terms of food systems, I shall assume that the rest of a holistic perspective is already in place, and what we need to do is to fit food systems into their correct niche there.

Thesis:

A food system is a tool man invented, and whose use was intended to enable him to satisfy his nutritional needs.

True, our hunter-gatherer ancestors made use of a natural food system as all other members of the animal kingdom did and do. But after a while, a change emerged even in their simple way of satisfying their nutritional needs. And so, some of the generic sub-systems of a food system were invented. Later on, when agricultural revolution changed our way of life greatly and that of nomadism to a lesser extent, all the components of a food system were in place.

What has actually changed since then is merely the degree of sophistication of each generic sub-system, and an insertion of a non-essential sub-system as will be shown later.

Anatomy of a Food System

The Essential Sub-Systems:

1. The Yielder System; it may be a forest, some body of water, a ranch, a modern farm, etc.Existence of a yielder system depends on having adequate ecosystem services. This became increasingly difficult due to repeated cultivation, grazing, population growth, etc. Hence,



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ecosystem service supplements were invented at a relatively early period (irrigation canals of ancient Sumeria for instance). I call this an adjunctive system to ecosystem services. Irrigation, the use of fertilisers, biocides, agricultural machinery, etc., are examples of this.

As the output of yielder systems could not keep up with population increase merely by increasing the size of a yielder system, i.e., bigger farms or ranches, increasing the output by using high-yielding cultivars and animals was invented. This represents agricultural research in this area. It also justifiably belongs to adjunctive system to ecosystem services, because plants and animals in the domain of agriculture are indeed a component of ecosystem services to man for we took them from nature to serve our dietary needs.

2. Even at hunter-gatherer stage, we used another sub-system to procure food from the natural ielder system, .e., the forest or a river, etc. This may involve going around and collecting edible vegetable food, active hunting or fishing.

When agriculture and animal husbandry become yielder systems, procurement system becomes a two-way action involving cultivation/taking care of animals and harvesting/milking/killing and butchering. This is still the case with subsistence farmers of today.

However, when we invented division of labour for our own greater ease, procurement system was ‘updated’ so that an end-user did not have to grow/raise one’s own food and harvest it, but procure it from a producer in exchange for something of commensurable value, i.e., engaging in barter. Later on,bartering was replaced by money, but the same principle obtains, i.e., an exchange of commensurable values.

3. Transport system.After procuring it, even the stone age man had to transport his food from the place of its gathering to where he lived in a social group. Whether it is on a man’s or an animal’s back, or on board a giant refrigerated ship, it represents a system performing the same function, carrying X from A to B and nothing more.

4. Storage system.There is archeological and anthropological evidence to indicate that even stone age people resorted to storing food in some way. Usually, a hollow in a tree was chosen for this purpose. Then storage was combined with another system as described below. For the moment, both that hollow in a tree, an Indonesian rice bin on stilts, a grain silo or a refrigerated store room perform the same function.

5. Preserver system.Most items of food are perishable, hence their storage for extended use require their preservation by some suitable means. Some stone age people placed a mixture of honey and



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venison in a hollow of a tree and sealed it with clay (Veddas of Ceylon). Whether it is that drying, smoking, salting or freezeing, all are instances of a preserver system in use.

6. preparation system.On procurement of food whether by harvesting one’s own cultivation, animal or poultry farm or through fishing, or by barter or purchase, it is passed through a preparation system before it is actually eaten. Exception to this are cases like one plucking a fruit from one’s own orchard and eating it and similar instances.

Note that food may be sent into a preparation system directly or indirectly via a transport and/or storage system at home (fridge, larder, etc.)

The preparation system may consists of two sub-systems of its own, viz., a refiner system and a culinary system. In the first, inedible components of procured food is removed by some suitable way. This may include husking and grinding the cereals, peeling, skinning, gutting, washing etc. More sophisticated version of a refiner system is seen in the manufacture of sugar and extraction of salt from sea water.

Food is then passed into the culinary system proper, where it may be cut into desired size and shape, dressed in different ways, and then eaten either cooked or raw. The cooking procedures are universal and need no further elaboration.

These then, are the absolutely essential sub-systems of a food system.

Meanwhile, social evolution towards greater ease and convenience gave birth to division of labour. As a result, people could purchase their food from farmers, butchers and fishermen, which gradually became even more specialised. It resulted in the emergence of food sellers of two different kinds, and both were fairly well established in Europe (this does not exclude it from other parts of the world) by the early middle-ages.

7. The seller systems.The first might be called the plain seller system. In its simplest form, which is still the commonest by far, a seller purchases food from an operator of some yielder system, i.e. a farmer, husbandsman, or a fisherman and transports it to potential end-users (street hawkers still active in many developing countries), or sells it from an stationary retailer outlet.

A wholesale seller purchases food on a large scale to re-sell it to retailers, but is not categorically different from his humbler colleague, the street hawker. And a retail outlet may range from a simple booth to a supermarket with advanced storage and transport facilities.

The second seller system began as a service of convenience to travellers and pilgrims. There, an operator purchases the food items and sends them through a suitable preparation system and offers his customers cooked food for consumption in exchange for money. It represents a combination of procurement, storage, preparation and selling systems. A simple sausage stand and a world-renowned restaurant are both examples of this combination.



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In the 3rd variant of a seller system, procurement, preparation and a packaging system are combined, and the product is then disposed of by a seller system. Its output may include baked beans, tinned foods and various types of frozen or refrigerated industrial food.

A less industry-intensive variant of this seller system involves the use of procurement and refiner systems, whose output may be packaged and sold directly, or stored and disposed of in batches through a retailers. Examples of this are pre-cut and packaged meat, vegetables etc., ready to go into a culinary system.

Argument:

I. There cannot be a food system without the operators of yielder systems and end-users.II. They have created the tool food system in order that the two parties may engage in an

exchange of commensurable values, i.e., fair trade if you will.III. By this exchange, an end-user procures food, while the operator of a yielder system gains

something else of equal value he desires. Thus, the exchange is mutually beneficial.IV. Food acquires it value by virtue of its necessity for survival, hence its value is equivalent

to the value we attribute to human life. This is a logical fact, hence it is indisputable.

V. Selling system is a tool of ease and convenience invented in the aftermath of division of labour. When an end-user uses it to procure food by purchase, an additional cost is added to the intrinsic value of food. This cost can neither increase nor decrease the value of food qua food.

VI. Therefore, it is a fallacy to attribute an increase in its value when food passes down various sub-systems that may constitute a food system.

VII. Hence, it would be both logical and factual to speak of “chains of increasing cost” rather than untenable ‘value chains’ in connexion with food.

VIII. Moreover, SDG-Nutrition is concerned with the dietary well-being of hungry end-users, for many of whom food is not affordable or available but its value for them remains unchanged while its cost may be unjustifiably high.

IX. Therefore, it is incumbent upon us to bear in mind whom we attempt to help, and their value perspective.

X. Doing XI above, entails we refrain from using commercial notions of value in our endeavours.

I have already noted packaging system that has become increasingly ‘important’ for the tradesman not so much as a container, but as an object that appeals to the eye of an end-user owing to its colourfulness rather than the potential wholesomeness, flavour, colour, and the texture etc., of the food a package may contain. This adds an extra cost to the food, but hardly contributes to its value.

. Another such system that imposes a high monetary burden on the end-user is advertising system. It is purported to ‘inform’ the end-user about the availability and ‘wholesomeness’ of items sold. This becomes a little difficult to believe when we know that mankind has managed to meet its nutritive needs since antiquity without this ‘expensive service’



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It is true that the continued social upheavals brought about a radical change in global demography, whose incidence was first greatest in the industrialised world. It involved a huge migration of employment seekers into the cities, which were the industrial centra at the time. And the trend continues to this day.

This distanced the end-user more and more from the source of his food. It is at this pointing the evolution of our tool, i.e., the food system, that several undesirable additions were made to it, and a long string of middlemen of different ilk sprang up. They located themselves between the actual producers of food and the retailer, each demanding a reward for his real or putative service to the food supply.

These include various brokers, those involved in sales of commodities including those who speculate in commodity futures which ought to be illegal, highly paid designers of packages, printers of labels and cartons, and those engaged in advertising trade whose charges are exorbitant.

So, when their cost is added to the real cost of food and the reasonable profit a retailer must make to live, the end-user is left with an unreasonable financial burden i.e., to support a small army of middlemen who make no worthwhile contribution to human nutrition. In developing countries, this often puts wholesome food beyond the affordable range of even the middle class.

In a word, excessive commercialisation of food supply is one of the most important hindrances to wholesome dietary habits as it makes As food passes from one sub-system of a food system to another so many times as it often does today, food spoilage and wastage increase. Independent reports on the ingredients of some industrial food indicate that their manufacturers are not very particular about the raw materials used. Health consequences of this attitude are obvius.

Even though it is not directly linked to food systems, economic policies promoting cash crops in place of food crops has diminished the potential food production of several developing countries. This short-sighted policy ought to be revised very soon if we wish to improve the status of nutrition in those countries.

After this long preamble, let us look at the causes of malnutrition in both its manifestations:

1. Malnutrition from qualitative or quantitative deprivation of a balanced diet is brought about by---

I. Lack of availabilityII. Lack of affordability

2. Malnutrition from qualitatively or quantitatively excessive intake of food brought about by---I. Lack of availability of wholesome food, while the opposite kind may be freely available.II. Wholesome food is not affordable while the opposite kind is cheap.III. External influences on eating habits of people that turn them into consumers of

unwholesome food. Various forms of direct or indirect advertising is the major cause of this. Once it takes root in a social group, peer pressure seem to spread and reinforce it in ever-widening circles. This is commonly seen among affluent youth everywhere.



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IV. Personal situation that makes traditional cooking difficult for various reasons, and forcing people to consume ‘convinience food’ not known for its wholesomeness. For instance, working single-parent families.

V. Lack of sound dietary knowledge.

I think it would be reasonable to call these the 7 causes of malnutrition. Please note that other things being equal, real hunger has but two causes, while the second category of malnutrition can be due to any one or more of the five causes given above.

The Problem:

Our problem then, is how to counter these two generic types of malnutrition by changing the food systems in use today. At the same time, such changes should make our food systems environmentally sustainable. It is important to recall that environmental sustainability is incompatible with the unlimited quantitative increase in population of any single species.

Malnutrition due to 1.I and 1.II, is mainly due to an insufficient output from a yielder system. It may arise from any one or more of the following shortcomings in it:

A. An inadequate area used for cultivation, grazing, etc., due to a natural shortage in arable land or its misallocation, or over-population.

B. Insufficient soil fertility, low-yielding crops and animal breeds in use.C. Reduction in the numbers engaged in agricultural pursuits.D. Inadequate adjunctive services to compensate for reduced ecosystem services.E. Inadequate infra-structure and/or a fair trade mechanism to link those who run

yielder systems and end-users, which results in food wastage.F. Inadequate agriculture knowledge and skills among those engaged in the area.I shall not describe the specific policies needed to address the issues above, because they have been thoroughly discussed elsewhere in this forum. But, I must add that policy makers ought to remember the importance of the local food culture, and when choosing modern methods, employment opportunities to the greatest number of people have the moral, political, and pragmatic priority over high technology which is intended to save labour.

Another factor that adversely affects the availability of wholesome food is its wastage during its passage through a food system. Inadequate storage and transport systems are the main difficulties here. In affluent countries, food wastage in selling system serving ready-to-consume food, and at home is indefensibly high. Fortunately, the latter is now receiving the attention it deserves.

I have already mentioned the problem of policy that gives undue priority to cash crops (or animals) over the food requirements of a country. A comprehensive policy to combat malnutrition, ought to pay careful attention to this error.



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Another cause of malnutrition is the demographic change I have mentioned earlier. It has two components. First, the rapid increase in the population of urban centra puts an excessive strain on even food system with an adequate yielder system owing to rapid increase in demand for transport or storage systems. Keeping these systems up-to-date with respect to increasing demand is often beyond the capacity of developing nations.

Secondly, migration of rural youth into cities creates a shortage of people engaged in agricultural pursuits, thus exacerbating the consequences of the first above. Hence, we must formulate a policy to retain rural youth at home by enabling them to earn a decent income through agricultural pursuits. It would be useful if one could incorporate into it a suitable mechanism to attract those who have already migrated into cities back to their home districs for the same purpose.

Even though it is not directly connected with a food system, health of its operators, particularly those who run various yielder systems has a significant bearing on its output. It will repay the policy makers to bear this in mind. Likewise, a sound environmental and a security policy will be of considerable help.

Let us now look at malnutrition due to 2.I and 2.II, which is commoner in affluent countries, but it is rapidly advancing into some developing ones. If one examines the anatomy of food systems I have outlined above, it would be obvious to anyone the chain of events that has brought about 2.I and 2.II type of malnutrition, which is most frequent in cities.

I hope the reader would be kind enough to follow my reasoning as carefully as possible. I think there would be a general agreement on the facts listed below.

1. Food systems are getting more and more commercialised, i.e., the number of intermediaries between an actual producer/harvester of food and the end-user is increasing.

2. These intermediaries often operate one or more sub-systems of a food system. Fro example, industrial food production involves the use of a procurement system to obtain the raw materials, which are then passed through an industrialised preparation system into a packaging system, and thence to a selling system. To mislead the end-users and the analysts, these intermediaries always resort to jargon even though what they do is so obvious.

This processing robs the raw materials of their natural flavour, colour, taste and the wholesomeness. Moreover, they are mixed with a variety of chemical taste ‘enhancers’ preservatives, etc.

These intermediaries are motivated by their desire to earn a profit. Let us not be naïve enough to assume anything else.

There are no legal limits on how much wealth one may acquire by profiting from trade, be it food trade or any other.

Profits are increased in two basic ways, which are always combined, viz., cutting down the cost of production and increasing the demand for what one produces, in this case, industrial food.



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Cutting down the cost is easily achieved by using cheapest possible ingredients to make ‘ready-to-eat industrial food’ that is easiest to make.

These products are marketed into society, where factors 2.III, 2.IV and 2V above have become social concerns.

Under these circumstances, carefully targeted packaging and advertising cannot fail to increase the ‘demand’ for items known to cause type 2 malnutrition. And this trend is spreading rapidly in all industrialising countries.

Bluntly put, this undesirable health and nutrition problem stems from nothing but use of food systems by intermediaries to earn huge profits at an enormous personal cost to the public. It is a sad irony that their free profit extraction from the possibility of satisfying one of man’s fundamental needs, i.e., nutrition, is called ‘added value’! Indeed, it is to them, but is it to the poor, and to those affected by 2.III-2.V? Do let us call spade a spade for the nonce!

So, I have now drawn the picture of the holy cow of modern commerce in its manifestation as one freely browsing the food systems. What is unacceptable is that the creature’s greed seems to be limitless. We have no alternative but to restrain the brute starting now. This is not a solution that has much political appeal, but when nearly third of the world’s population goes hungry and NCD’s are called a pandemic by the WHO, I think the time has come to act decently.

Two other undesirable consequences of this over commercialisation of food systems are---

1. Reduction of biodiversity among the cultivars and in animal husbandry. As cheap production is the goal, a relatively few ‘high yield’ species are used in yielder systems catering to industrial food producers. This can threaten our future food security seriously. It is irrational, because local food cultures emerged with reference to centuries of empirical knowledge about what is best grown and raised in a given area.

2. The cheap high-yield yielder systems are extremely energy-intensive and depend on extensive adjunctive services. Both of these are harmful to our already highly insulted environment. As a result, sustainability of such a system is extremely dubious.

Yes, I know, it is easy to identify the causes of a problem, and its solution is another matter. Nevertheless, I shall give it a try.

1. Success of this endeavour depends on formulating appropriate policies which are in harmony within and one another. For instance, a sound agriculture policy to produce sufficient quantities of local foods people want, cannot succeed even it is well implemented, if the trade policy allows manufacture/import of dubious industrial food and drink and their colourful packaging and advertising. Here the two policies are in disharmony.

2. There has been much talk about ‘thinking in silos’, but I have noticed something a lot worse, viz., ‘acting in silos’. This happens when ministries do not enter into a dialogue to harmonise their policies. This is justified by invoking another holy beast of ancient pedigree, namely, institutional autonomy. A more mature attitude at ministerial level would help here.

3. Education policy is critically important here. Dietary education should be re-introduced as a compulsory subject from the very first school year. However, it should not be concerned with calory count and ‘body-mass’, rather the relationship between growth and health, and one’s diet. Not eating enough and over eating should be dealt with as personal habits that need change. Children should not be taught to think of their bodies as machines to be fuelled



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correctly, rather they should learn the other pleasures associated with eating a well.prepared balanced diet. Free and wholesome school lunches could prove an important dietary support and a way of introducing them to tasty balanced meals. In some areas of the world, I think there is a considerable need for public education on dietary matters.

4. Health policy should require medical professionals and other health personnel to help their patients to understand the benefits and pleasures of balanced diets. At present, their work in this area is mostly restricted to NCD patients or those who are already overweight, etc.

5. Trade policy will often provide many stumbling blocks to food security and access to balanced diets. This is not limited to national policy, but the international agreements on ‘free trade’ often serve to free you from any chance of getting a balanced diet at a reasonable cost. I think food ought to be given a special status so that it is not treated as just a thing to sell to get the highest profit. No rational trade policy would undermine a country’s agricultural output, rather it ought to do everything it can to boost it with respect to the local food culture.

A pre-emptive means of curtailing the expansion of over commercialisation of diverse sub-systems in a national food system and enabling those who experience type 2 malnutrition to obtain a balanced diet, involves the establishment of msall restaurants throughout urban areas where wholesome national food is served at affordable prices. This requires a supportive trade policy with financial help to establish them, and tax incentives until they can stand on their own. Moreover, their small size would make them a source of employment for many people, which is animportant consideration in many developing countries.

Another enabling action would be help to establish small farmer cooperatives not too far from urban centra and equip them to transport fresh produce to urban customers as quickly as possible. This could be sold at dedicated stalls reserved for such cooperatives, and the urban authorities could be responsible for their erection and maintenance. This will benefit the end-users and enable the producers to earn a decent income without having to reward middlemen.

6. Financial policy should be geared to support and sustain the agricultural and catering strategies mentioned above. Moreover, in annual allocation of funds, food production, its proper storage and transport by environmentally benign ways ought to receive a greater priority.

7. Unless they are duly enforced, legal measures have the least impact on the situation in a country. Having said the obvious, I think it is time that we undertook legal steps to limit the commercialisation of food systems, and actively enabling the small holders to retain their property. Huge retail chains are rapidly overtaking the food sales in many countries, and are already exerting a monopoly on what the end-users may buy. As food producers have to sell their produce to those chains, they are forced to produce what the chains want rather than the end-users. This has become a familiar problem in affluent countries. Therefore, it is essential to revise the monopoly laws so that national dietary diversities are preserved and the end-users are given a real choice. To this end, it is essential to establish legal mechanisms to protect independent retailers of food from unfair competition or take over. It is paradoxical that giant national food chains and their multinational counterparts defend ‘free trade’, while they do everything legally allowed to deprive the small independent retailers of freedom to trade. Real diversity both in food production and sales, and limits on commercialisation of food systems is vital for success.



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8. A general government policy on serving wholesome food in the cafeterias of government offices, armed forces canteens, all public offices, schools, hospitals, etc., would have some effect as a ‘vorbild’, or an action worth emulation.

This is an outline only, and there may be other areas one needs to develop sound policies congruent with our purpose. However, I hope the conceptual framework in which policies are to be embedded is clear. To recapitulate, some of us are using food systems exclusively to gain as much profit from them as possible. To compound the problem, deprecation of the value of food production by media, entertainment industry, cultural norms, etc., have driven the those with aptitutde for agriculture away from it. The latter has also deprecated national food cultures, while education has continued to ignore the vital importance of dietary education at schools. Under these conditions, commercialisation of food systems continues apace, which results in big profits for food and pharmaceutical industries while the incidence of hunger and NCD’s increases, and environmental sustainability and biodiversity in agriculture decreases.

The need for action is acute, and we know what to do, the only question that remains is, are we really willing to do it before it is too late?

Best wishes!

Lal Manavado.

9. Adolfo Chávez, MexicoDear sirs,

My name is Adolfo Chávez and during 1988-1990 I was Director at the Applied Nutrition Services at

FAO. Before for some years, I was President and Secretary of the Nutrition Planners Forum

supported by AID. I also had experience planning and advising programs in my own country Mexico.

I believe that the Draft Report: Nutrition and Food Systems does not make enough emphasis in 4

fundamental subjects that have a growing and dominating trend in the less developed countries, at

least in Latinamerica and Africa. They are the consequences of the prevalent neoliberal system. As a

matter of fact the situation give place to a “neoliberal food consumption pattern”.

1. The increase dominance of supermarkets that are promoting a new way of eating, actually a

new food system. They have their own purchasing methods thorough their own associated

merchants with big producers. The tendency is to leave outside all small producers. They

import when they have advantages and with their control they manage prices. Another problem

of the supermarkets is that in their stores it looks as if they were offering thousands of products,



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but more than half are made of cereal meals (corn, wheat) with different presentations,

crackers, breakfast cereals, breads, cakes, pan cakes, meals, etc. with different colors, flavors,

packages, etc. Their offer of fresh foods is limited, in amounts and reduced to few species, the

ones that have long shelf live.

2. It is expected that the bio-technology and the transgenic progressively will control-regulate the

food systems, as their production is more extensive and capitalistic, related with the

supermarkets. Unfortunately the predominating transgenic products are the ones that render

more profit, not better nutrition. We know that, per-example, there are potatoes and other

roots that can be albumin enriched and dozens of other kind of foods with nutritional

improvements, but this kind of transgenic are more “technological developments” than actually

commercial products.

In this neoliberal context, countries that are based in imports, surely are and will be progressively

consuming large amounts of transgenic and many other products of the technological-

economical advances. They will be at the central structure of food systems.

3. The junk food consumption, made of meals, sugars and lots of fats of low quality, is growing in

incredibly amounts and forms. In Mexico, a poor country just 3 companies, sells 21.7 billion

dollars a year. The poor people, on government cash transferences, accepts to spend 16.8% of

their income on them, but they don’t know which foods are junk, and that means that for sure

they consume much more than the amounts they accept in surveys.

Most of the junk foods do not have proteins, most of them are also very low in micronutrients.

They have large amounts of unnecessary fats with additives and contaminated with pesticides,

aflatoxins, acrylamide, clembuterol, dioxin, etc. As a group they are a big part of the food basis

of chronic malnutrition and most of the chronic non-transmissible syndromes and diseases.

Beer and alcoholic beverages are not mentioned in the report. They have a roll in the food

systems. In Mexico only one brewing sells 1.5 billion dollars a year. As least they have to be

considered as competition with the purchasing possibilities of families.

Most of the evaluations don´t show the roll of the large commercial chains of junk food

producers including foods sold by big companies as Nestlé, Danone and Unilever. One



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important part, not always considered, are the heavy sells of many products in schools and work

places.

4. Another problem that progressively grow without control that affects food systems are the

increasing use of synthetics. Some times are total substitutes as chocolate and sugar. Also most

of the times are used as flavors and colors of fruits like orange, lemon, berries, etc., all these

cause big unemployment on the fields of tropical countries. Any new synthetic leaves hundreds

or more of unemployed.

All these 4 problems are growing so strongly that causes a new system, very strong with power to the

degree that countries can’t do anything against. It is frequent that they pay low taxes, have influence

on the research, etc. They are growing so fast that in few years they will be the entire food system,

with actually extraordinary profits, but in countries full of nutrition problems and chronic diseases.

10. Gro-Ingunn Hemre, National Institute of Nutrition and Seafood Research, Norway

Comments to the HLPE report on Food systems: p24-p38.

2. The Burden

This is a nice and balanced chapter on statistics, and shows the positive trends in diminishing undernutrition in most parts of the world. The issue on hidden hunger is raised, where you still lack micronutrients, but have sufficient energy intake. It gets even worse when this meets the challenge of overconsumption of energy-dense food which is close to micronutrient deficient, but often affordable (cheap). I would recommend to even stronger emphasize this as a future challenge. As we learned from the US conference on Food Security in Ithaca (NY) autumn 2015, plants grow faster, but being less micronutrient dense, the soil gets poorer, and fortification is urgent. Still, plants do not cover all nutrients needed for human health; e.g. iodine. The only commodities rich in this essential element is milk (milk products), or marine fish.

Nice and informative figures,

Causes and consequences only mention VA, iron and iodine; but for sure there are more that should be mentioned; e.g. DHA/EPA fatty acids and brain function (the Durham study on learning ability is essential here), B12 and folate; imbalance of these also cause anemia and is important to mention. We still have scarce knowledge on the importance of micronutrients and the implications of imbalances for human health. It might even turn out that a balance of the micronutrient package, e.g. all the B-vitamins well balanced, to secure a healthy life, e.g. as these are all important co-factors in most metabolic pathways in our body, but here we have too little knowledge.



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--------

Page 68 in the report; here all is considered; macro- and micronutrients, but very briefly; the micronutrient rich food groups could be even more emphasized. Agri is mentioned to a large degree, while the possibility that lays in the ocean has too little focus; fish is mentioned only briefly; this is an important commodity to combat several of the challenges we face when it comes to micro-nutrients, and fish is important both for undernutrition and is emphasized as important in lowering of NCDs. Fish also support the poor low-income countries that have small fish eaten whole (e.g. Africa) as an opportunity. In my opinion, this deserves a separate chapter; the opportunities, and challenges when it comes to seafood / fish.

Page 97, lines 15-17 “the ability to connect the right social nudges through information, and convenience will help combat the issues of obesity”.

This I think is an imbalanced view. The combat obesity will demand good information based on science and idealism; and that there is food available in the marketplace to support people’s nutrient requirements, and where food safety is taken care of. My point here is; that reflection seems a bit too positive. If we cannot say exactly what is leading to obesity, how can we combat it by means of social nudges?

Final comment:

Besides the above mentioned; this V0 report is a nice reading, lots of good data, and very good figures, looking forward to the next version.

11. International Food Policy Research Institute, United States of America

Overarching comments:

• This early version of the report, while very comprehensive, still lacks a strong storyline. Some reorganization of the sections may help this. The initial section on dietary guidelines, for example, can be merged with the later section (which contains case studies). The Looking to the Future section is repetitive with the previous section containing solutions and case studies—these could be merged and tightened, followed by a more robust Knowledge Gaps section and Recommendations section.

• There is very little discussion of the role that other sectors play in shaping the food system, aside from perhaps trade. How does the food system interact with health, water and sanitation, etc.? A discussion of the synergies between and among various sectors and their positive/negative impact on diets would be useful.

• Smallholders are not addressed much until the end of the report, with an assumption that large-scale/industrial agriculture is being referred to in many cases. We suggest weaving in the contributions of and unique challenges and shifts facing smallholders throughout the report.

• Similarly, the role of youth in agriculture needs to be woven throughout the text (currently, there is only a small section).



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• The report uses the terms ‘value chains’ and ‘food systems’ interchangeably…these need to be consistent.

• The importance of a climate-smart food system does not come through sufficiently yet. While it is discussed as a driver and some case study boxes are presented, it would be great to delve deeper into the actions needed to develop a food system that can cope with and overcome challenges related to climate change. The overview chapter of the 2015-2016 Global Food Policy Report provides a framework for this and other issues.

• Governance, accountability, and financing needs to come through more strongly. The Global Nutrition Report addresses many of the relevant issues.

Specific comments:

Section 1.1.1:

• In the conceptual framework, suggest to elevate population growth as one of the drivers since it has a substantial impact on food systems.

Section 1.1.2:

• Local knowledge should be included as a driver. This is discussed in the last section but overlooked in the beginning. Inequality is also missing as a key driver and should be interwoven throughout the text.

• In the discussion of processing and packaging, suggest to clarify that in addition to food safety concerns, processing and packaging also adds economic value to the product.

• The food access discussion covers the macro determinants of distribution but not factors affecting intra-household distribution of food.

Section 3.1.3

• Are there any data on the diets of children under 5 that can be reported? The section focuses on infants (under 2 years of age), adolescents, and women but skips over this key age group.

Section 3.2.3

• The discussion of urbanization would be strengthened by differentiating between the urban rich and urban poor. IFPRI’s upcoming 2017 Global Food Policy Report explores many different aspects of rural and urban life, including food security, poverty, and malnutrition, and the two-way linkages between rural and urban areas.

• The discussion on the Doha round and Nairobi package is overly technical and needs to be elucidated.

• The food policies sub-section would benefit from a brief discussion on the impact of large-scale social protection programs on diets.

• What about the role of financing?



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• The gender sub-section could be strengthened greatly through a more comprehensive discussion of women’s empowerment and control of resources. Some key findings from IFPRI include:

o In a study of biofortified oranges sweet potato in Uganda, adoption was higher on plots that were jointly owned, but where the woman was the primary decisionmaker on what to grow (Gilligan et al. 2013).

o As measured by the Women’s Empowerment in Agriculture index, the number of groups in which women actively participate, women’s control of assets, and a narrowing gap in empowerment between men and women within households are positively associated with calorie availability and dietary diversity (Sraboni et al. 2014).

o Women’s empowerment mitigates the negative effect of low production diversity on maternal and child dietary diversity and height-for-age z-scores, suggesting that it has greater potential to improve nutrition outcomes in households with monoculture production (Malapit et al. 2015).

Section 4.1.3

• On the sub-section re social protection program, a good source on the Brazil nutrition governance story is Chapter 11 in Nourishing Millions: Stories of Change in Nutrition. Similarly, a more recent assessment of Mexico’s Oportunidades (which includes Fernald among numerous other references) can be found in Chapter 7 of Nourishing Millions. The book also contains full discussions on other topics that could strengthen the various boxes in this section, such as SHOUHARDO, enhanced homestead food production, salt iodization, and Mexico’s sugary drinks tax.

• On the sub-section re investment in R&D:

o Beintema and Stads 2014 offer useful statistics on investment in building up agricultural research capacity. In Africa for example, investment levels are still below the recommended 1-percent target in many countries, which face unstable research funding and a lack of well-trained research staff.

o A recent IFPRI study shows investing in agricultural R&D with the aim of increasing agricultural total factor productivity by 2 percent can lower world prices of cereals and meat by as much as 17 and 15 percent, respectively, as well as increase crop yields by 8.5 percent by 2030. Under this same scenario, the number of malnourished children can be reduced by 7 million (5.4 percent), and hungry people by 160 million (23.2 percent) (Perez and Rosegrant 2015).

• The language re farm to school programs needs to be more cautious. Much of this evidence is still preliminary.

12. Bibhu Santosh Behera Ouat, Bhubaneswar, Odisha, IndiaCONCEPT OF DIABETES FOOD AND DOCTOR’S FOOD FOR MINIMIZING DISEASE AND MALNUTRITION



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By Bibhu Santosh,PhD,OUAT,Bhubaneswar

Pulses and Millets are only the Energy foods for both human and animal .Millets may provide the nutrition to diabetes patients. We should take balance food by taking Pulses, Millets, Cereal crops, vegetable crops, and Horticultural edible crops. If we together consume this food then it may give all supplements to our body and help us from diseases. For Doctor’s Tonic all hygienic and nutritive food likes Fruits, Vegetables, Non-veg items and Raw edible foods. So recycle, reuse and replicate the food by preserving and conserving the food for the future. Prepare the food with proper recipe. For eradicating Hunger and malnutrition Diabetes food is the best Way and Rural food Hub and Urban Food hub.

So this concept may be the best for India and world.

Regards

Bibhu Santosh,Independent People’s Scientist,India

13. Dele Raheem, Arctic Centre, University of Lapland, Finland1. The report is quite comprehensive as it is, a glossary section may be necessary. It will be better to summarize some of the chapters and emphasize the food environment as to how nutritious foods need to be promoted with less chemical additives and preservatives. In every region of the globe are underutilized food crops that need more research support.

2. Processing, storage, and distribution of foods with adequate packaging materials are meant to reach consumers unadulterated. To ensure this will require strict monitoring along the value chains, with strict regulations. In this regard, it is a good idea to ponder on the role that production systems play in shaping our diets.

3. In ensuring a sustainable food system for the next generation, demands empowering them with the right education on basic Food Nutrition - in order to avoid misconceptions and for them to demand and make the right choice.

14. Ali Abdalrahman Iuide, EgyptGood, effective and useful for specialists and policy-Food Policy and Nutrition report, as well as policy-makers.

Notes

1- Must focus on feeding the poor and the poorest, and this will contribute to the development of effective policies and programs.

2 Very important food environment and the sustainability of nutrition.

3 Of economic and social point of view, the production is set the most important in the field of nutrition and food systems.



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4-There are relative gap between the food and nutrition for the quality of the people from the economic perspective.

5- Should be classified as dietary quality of people's specific and clear manner.

6- Feeding systems vary from state to state, and the quality of the people, by the people's income.

15. Fardet Anthony, FranceHello,

My main concern with the report is the lack of clear propositions regarding food processing which is essential. Indeed, populations adhering the most to ultra-processed foods exhibit the highest risks of chronic diseases, especially in Western countries and big cities of emerging countries.

Therefore I propose that the concept of ultra-processed foods be more present in the report, as devlopped by Monteiro and collaborators with the international NOVA food classification according to degree of processing.

Besides, fractionating and recombining ingredients to create these ultra-processed foods is energy-consuming for no real health benefit: there is therefore a link with sustainibility.

Therefore I think this issue is essential and should adressed and developped in the report.

Available I remain,

16. Santosh Kumar Mishra, Women’s University, India

There is general recognition of the importance of sound natural resource policy to ensure long-term sustainable food production.

Most stakeholders recognize that farmers play an important role in producing food while at the same time managing a significant portion of natural resources and contributing to a range of public goods.

Sound soil and water management is critical for ongoing agricultural production. Improvement in soil management is seen as a key factor for improving productivity. At the same time, greater efficiency in water use is primarily seen as the best way to manage trade-offs between environmental and food production objectives.

Some stakeholders view environmental regulations as a major inhibitor to farmers’ and fishers’ abilities to produce food. There is, thus, need for continuous improvements in food production to minimize effects on the environment.

The merits and shortfalls of different food production systems are a major point of interest in relation to farming and fishing industries.

Many stakeholders perceive an opportunity to minimize unnecessary food waste and redirect surplus food to members of society facing food insecurity. Organizations that donate



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surplus food to those in need are seen as a positive example of how food waste could be reduced.

Reducing food waste is seen as an easy way to save money, reduce pressures to produce more food globally, reduce the impact on the environment, and help others in need. Creating functional products from food waste, such as compost, is seen as having dual benefits of reducing food waste in landfill while also reducing reliance on synthetic fertilizers for further food production.

http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/Dr.Mishra.doc

17. Diana Lee-Smith, Mazingira Institute, Kenya

With reference to the questions posed for response:

1. Purpose and Objectives: These are to focus on how food systems influence dietary patterns and hence nutritional outcomes. The paper's emphasis is on consumers but this should not be to the exclusion of production as part of food systems.

2. Structure and balance: The report is very comprehensive but probably too diffuse and needs tightening in later drafts to zero down on key factors. It is a bit like a long review of the literature at present. I agree with other suggestions to have appendices.

3. Conceptual framework: it is a good start with its definitions and lead-in to the development of a typology. The typology will provide the skeleton on which later versions and the impact of the report will depend for structure and support. However, “food environment” needs to be re-thought. As per the definition, environment is a part of the food system, not outside it. The systems approach needs strengthening. A system incorporates composition (or components), environment, structure, and mechanisms. For a given entity we want to know what it consists of, what the features are of the environment within which it functions, how it is arranged internally, and how it works. (Bunge, Mario, Emergence and Convergence. University of Toronto Press Inc. 2003). No entity, organism or system can exist independent of environment.

4. Production systems (sic.) adequately addressed? No, see Q.1&3. Production is part of the food system and not a separate system. This component of the food system has a major role in shaping diets and nutritional outcomes.

5. Controversies: There is a central controversy that the report does not adequately confront, but rather falls on one side of in its selection of sources. There should be more substance in the report on the food sovereignty debate as well as on systems that are based on small farmers. This is a core weakness of the report; small farm-based food systems that provide 80% of food in Asia and Sub-Saharan Africa (as referenced) are reduced to allusions to “vulnerable groups” (4.2.2). I support other comments made along these lines. The report as it stands contains bias.

6. Categorization of food systems: Farming systems thinking should be included. It is hardly touched on in the report, if at all, consistent with the gap I identify on the diversity of



http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/Dr.Mishra.doc

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production systems. As per Figure 1, the overwhelming bias of the report this far is towards the industrial food system model. This is influenced by most of the early writing on food systems, which was grounded in industrial, market-oriented and consumption-based thinking about food. To be up-to-date, useful in the long term and analytically correct, climate and agro-ecosystem-based food production, and small farm-based food systems, must be part of the analytical framework, and thus the emergent typology. I treat measurement in my concluding comment below.

7. Balance in food systems: There is a lack of this as per responses 4. and 6. Also, the constraints faced by poor populations in trying to meet their nutritional needs should be highlighted more. I support other comments in the on-line debate along these lines. Further, the urban poor must be better included. Now they are lumped in as “consumers” in an under-developed classification of “urban”.

8. Strengthening / shortening: The typology will be the key to the success and impact of the report. Most other sections can be tightened, shortened, moved to appendices as suggested and bias removed as above (5).

9. Cases: I cannot provide cases which give evidence of policy impact on nutritional status. However, section 4 is generally weak and leaves no room for treatment of contingent factors that affect nutritional status. I can cite studies that demonstrate the impact of urban agriculture on food security and nutrition, including urban livestock, for example. Urban and peri-urban agriculture needs to be addressed somewhere.

10. Institutional changes and governance: Yes section. 4.2.2 is particularly weak and also biased, as noted above, item 5. Perhaps here is the place to introduce the strides that have been made on urban food governance, internationally (CFS-CSM, Milan Urban Food Policy Pact), nationally and at city level in both North and South (urban food policy councils, urban agriculture legislation and administration). While nutritional impacts have not been measured as yet, the policy intention is clear (Brazil, several African countries/cities). But the urban nutritional deficits and lack of access must be treated in earlier sections of the report as well, in order for this to cohere.

11. Balance in communication: The report is balanced regarding technicality, accuracy and communication. However, while some concepts are clearly defined, more conceptual development is needed, as above. While the initial boxed definitions are good, and grounded in previous work, the definition of diet (4) could be improved by including the concept of dietary diversity, perhaps in the second sentence, before moving to environmental impact?

12. Omissions and gaps: As above, production processes, agro-ecology and climate-based food systems incorporating small farmers must permeate the whole analysis which is slanted towards industrial value chains, including and especially Figure 1 and other later figures on food system interventions. The urban poor dimension of food and nutrition insecurity including urban and peri-urban agriculture is omitted as item 10 above. I have separately made a submission on critical and emerging issues in this respect. Finally, the treatment of soil quality and food production needs more depth and emphasis. This could be expanded upon in 3.2.1 which is very good on natural resource degradation and ecosystems, but needs to permeate other aspects of the paper as well (and should not be consigned to an appendix). In particular, the food system diagrams do not encompass waste in the ecological cycle “…production-processing-consumption-waste-production..” and so on. Nutrient cycling is an essential part of the food system, whether planned or unplanned (i.e. malfunctioning).



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The Milan urban food pact is likewise weak on this, only addressing food waste and not the cycling of waste and nutrients in the food system.

Overall comment and suggestion on developing the typology:

Starting from the excellent (and brief) treatment in Section 3.2.1 on Natural Resource Degradation and Ecosystems, which includes analysis of the homogeneity of world food supply (Fig. 16), I would like to suggest that this give direction to the search for a typology. What will be needed as an outcome of this work is a way of measuring and comparing food systems, specifically with regard to their impact on nutrition levels. After naming types that can form a nominal scale as a basis for comparison, it should be possible to interrogate these with quantitative data on variables that are amenable to measurement.

As included in Table 2, “percent imported foods / total food supply” could be a key variable to describe different food system types (not just countries and not just the production element as per Table 2). The types must include small scale peasant, regional market oriented, peri-urban and urban farming systems, in order for comparisons to be first made and subsequently measured in terms of nutritional impact. Necessarily, these will vary by agro-ecological zone. See the CFS-CSM typology of farming groups for example. Once the types are named and defined, a multiplicity of variables could be developed, measured and analysed now and in future.

This next step in developing the paper is central to its purpose and long term usefulness. The task is to establish the groundwork on food systems and nutrition. It must break free from analyses based in other discourses and become a benchmark for describing and analysing food systems.

18. Jeevananda Reddy, formerly Chief Technical Advisor – WMO/UN, India

Observations/suggestions to “Nutrition and Food System Vo Draft eConsultation” by Dr. S. Jeevananda Reddy

In the past also I provide my observations and suggestions, I don’t know what happened to them? However, here are some of my observations and suggestions to Draft “Nutrition and Food system”

1. UN role: Firstly, as long as UN sub-serving the interests of Multinational Western Companies [MNCs], primarily who were/are involved in fertilizer, pesticides, GMO seeds business, reports of this nature have little practical use;

2. Report writers on ground practical experience: Secondly, Chapter 1 clearly shows that the whole exercise is “theoretical” with little “practical” real world scenarios. Definitions don’t matter much but they should have taken factual information existing on ground over different parts of the globe – countries and regions within the country. It appears the members preparing this document were not trained in this direction. Thus, this report has little practical utility.

For example, in Chapter 2, even with availability of all vitamins, if the food is adulterated or produced under polluted atmosphere the inferences are quite different. This needs practical scenario. Musi



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River passes through the city Hyderabad, Telangana State in India. The river carries a cesspool of poison – with domestic and industrial pollution [treated and untreated] and using this water farmers in the downstream of the river grow crops-vegetables and feed the fodder to animal that give milk and meat. Eating such food introduced innumerable diseases/health hazards. Even groundwater is contaminated with this water.

3. Role of climate change: In Chapter 3 under 3.2.1 Climate change [& 3.2.2] the statements on Page 45, lines 26-28 are inaccurate.

If we look in to Indian agriculture practices over different parts of the country before green revolution technology, known as chemical input technology, farmers developed farming systems practices for different regions of the country based on their hundreds of year experiences for soil and climate conditions. The farming system was a crop/cropping pattern linked to animal husbandry system. This system provided economic and nutrition security. This is a healthy diet. This was modified with green revolution technology after 1960s. This is a mono crop system. In the traditional system crop residue was used as fodder to animal but the mono-crop system has disastrous effect on animal husbandry with poor quality fodder.

Let me give an example of recent air pollution levels in Indian Capital City Delhi. The neighbouring states grow paddy and wheat. Farmers burn the paddy stubbles/fodder in the fields causing pollution, as this fodder is not useful for animal consumption.

4. IPCC’s role: IPCC’s climate change argument runs around temperature. In fact this runs around green fund – billions of dollars – to divert from multinational companies ineffective technologies in environment point of view.

I myself presented a study on how the climate factors, particularly temperature, influence the crop development of new high yielding crop varieties with reference to Sorghum [Reddy, 1984a]. This analysis showed a range of temperature tolerance for different varieties of the same crop. However, this varied with relative humidity and soil humidity [Reddy, 1993]. Crop growth and yield [biomass and rain] are primarily related to soil moisture condition. Texam A.M. group developed a crop-weather model, known as SORGF. This model was brought to ICRISAT [one of the 13 institutions of CGIAR] to test whether this model works for tropical semi-arid regions or not. This model was tested with the data collected over several locations [23 data sets] during 1979 and 1980 kharif and rabi seasons. It presented very poor correlation coefficient [Reddy, 1984b] – the authors tried to modify energy term but did not show any improvement. By replacing soil water balance model [Reddy, 1983] that works under diverse soil, crop & climate conditions, the correlation coefficients improved drastically. That means crop-soil-weather interaction play interactive role but temperature alone has little role.

5. Deficiency in Technology: In agriculture technology involves seed, fertilizers, Soil, irrigation & rainfall. The technology innovations were Western Multinational Companies profit driven. Here the major casualty is the environment – air, water, soil and food pollution and thus health hazards. While calculating the food production gains we rarely account this loss. Reddy (2003a) analyzed this aspect in terms of production.

With reference to paddy in the state of Andhra Pradesh – The Rice Bowl of India – the traditional paddy under irrigation yielded 1300 kg/ha; with the high yielding seed the yield increased by 500



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kg/ha; and by adding chemical inputs the yield level rose by 2000 kg/ha. That mean the new technology raised the yield by 2500 kg/ha over the traditional 1300 kg/ha.

To achieve this raise in yield, government invested huge sum towards development of irrigation and fertilizer. The fertilizer subsidy has increased from Rs. 4,389 crore in 1990-91 to Rs. 75,849 crores in 2008-09. The yield reached a plateau around 1983-84 within a span of around 20 years of introduction of this technology. Under this technology, the high yielding seed is replaced by genetically modified seed showed its life is still shorter. For example, even though Bt-Cotton was not superior in any way with non-Bt-Cotton in terms of yield, in 13 years starting from 2002-03, even after changing the seed three times – Bt1 to Bt2 to Bt3 – in India the last five years the yield reached a plateau.

6. Drought Types: The mono-crop with chemical inputs technology introduced technological drought in addition to weather related three droughts, namely meteorological drought, hydrological drought and agriculture drought.

The meteorological drought is associated with rainfed agriculture and hydrological drought is associated with irrigated agriculture, which rarely coincides. On an average around 60% of the cultivated area is rainfed varying between 35% and 85% over individual countries and regions within a country.

Due to excess use of groundwater indiscriminately with water intensive crops, ground water dried out in several countries/regions within a country affecting crop production and availability of potable water [Reddy, 2003b]. With the population growth, the area under the traditional tanks gradually decreasing with the time – due to silting, due to encroachment, etc --.. In practical sense all these affect crop production and food quality.

7. UN Manipulation: The 70s environmental movement related pollution aspects were sidelined by MNCs through UN, Rio Summit. Here global warming versus carbon dioxide was brought in. Since then this tirade is going on in full speed. Now with the Republican President-elect in USA there appears to be some change in global warming; to thwart this now MNCs are directly entered the arena under the disguise of “Climate Smart Agriculture”.

The major initiatives for the agriculture sector that were discussed frequently at COP so far are Global Alliance for Climate-Smart Agriculture (GACSA) and Adaptation of African Agriculture (AAA). While GACSA was launched at COP 21 in Paris, AAA has been launched at COP 22 with much fanfare.

Both of these initiatives are being promoted by Food and Agriculture Organization of the United Nations (FAO) along with various governments, especially African countries. The founding membership and steering committee of GACSA include fertilizer companies, their front groups and partner organizations. Of the alliance’s 29 non-governmental founding members, there are three fertilizer industry lobby groups, two of the world’s largest fertilizer companies and a handful of organizations working directly with fertilizer companies on climate change programmes. This leaves a lot of ambiguity and raise serious concerns. For example, CGIAR, a FAO partner in GACSA, promotes climate smart “success stories”, which promote the use of fertilizers and genetically-modified organisms (GMO), and make no mention of traditional agriculture system. There is a fear that seeds, fertilizers, pesticides promoted by big corporations multinationals will be pushed in the guise of climate smart agriculture. This will make farmers more and more dependent on market forces and hence increase their vulnerability and reduce their adaptive capacity.



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8. Food waste: Globally, FAO itself reports that around 30% of the food produced is going as waste. With this, the natural resources used to produce that much is going as waste. Therefore there is a need to identify those location-region specific issues responsible for that waste. This is more important over the more production.

9. General points: Food availability is different from nutritious food availability; food production is different from nutritious food production; sea-water food is polluted, on farm-aqua-farms food produced is also polluted with chemical fertilizer use; irrigated agriculture effect food quality with salt & water-logging. Farmers need a technology that does not depends on government subsidy and western MNCs technology. This only improves the quantity and quality of food produced. India government introduced Food Security bill in which nutrition security is also part. Government is not looking at the bill in its totality to achieve the goal of food and nutrition security to vulnerable groups. No agency is bothered on it. They forgot the content of the bill while FAO trying to write reports after reports.

Reddy, S.J., 1983: A simple method of estimating the soil water balance,, Agric. Meteorol., 28:1-17 – later red it as Agric. For. Meteorol.

Reddy, S.J., 1984a: An iterative regression approach for prediction of sorghum (sorghum bicolor) phenology, in the semi-arid tropics, Agric. For. Meteorol., 32:323-338.

Reddy, S.J., 1984b: Agroclimatic classification of the semi-arid tropics III: Characteristics of variables relavent to crop production potential, Agric. For. Meteorol., 30:269-292.

Reddy, S.J., 1993: Agroclimatic/Agrometeorological Techniques: As applicable to dry-land agriculture in developing countries, www.scribd.com/Google books, 205p [book Review appeared in Agric. For. Meteorol., 67:325-327 [1994].

Reddy, S.J., 2003a: Evolution of seed technology, biotechnology!, Current Environmental Issues, Edited by B.B.S. Kapoor, et al, Madhu Publications, Bikener, India, pp. 139-158.

Reddy, S.J., 2003b: Rainfall deficit and drought intensity, Drought Management – Present & Future [With special reference to Andhra Pradesh], Edited by A. P. Rao, Sundarayya Vignanakendram, pp.29-44 & 163-167.

Dr. S. Jeevananda Reddy

Formerly Chief Technical Advisor – WMO/UN & Expert – FAO/UN

Fellow, Andhra Pradesh/Telangana Akademy of Sciences

Convenor, Forum for a Sustainable Environment

Hyderabad, Telangana, India

[email protected]



mailto:[email protected]

http://www.scribd.com/Google

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19. Michael Crawford, Imperial College, United KingdomThe documentation for this initiative is detailed and comprehensive. There is however a major missing item and this is one on which the future of humanity depends. There is misconception in human nutrition for the brain which is leading food policy to the increase in mental ill-health.

The genomic difference between H. sapiens and apes is no more than 1.5%. A major difference is the brain. We separated from the great apes some 5-7 million years ago. With that 1.5% genomic difference it is obvious that our genome is adapted to wild foods. The brain evolved in the sea 500 million years ago using marine nutrient which it still requires today. The food system since WWII has been based on a flawed concept of protein and calories with increasing use of land based intensively reared and processed products. Fish and sea foods were not rationed during and after WWII.

I like my messages from Nature rather then expert committees. Human milk contains the least protein compared to any large mammal. It is however rich in the essential fats specifically needed for the finalisation of brain development. Even before birth, the human placenta screens out the fats not needed and concentrates those needed for neurogenesis, cardio-vascular and immune system development. This has been known since the 1970s and is a component of several FAO/WHO expert consultations 1978, 1994, 2008-10. Yet it has not been incorporated into food policy to our cost. As we predicted in 1972, mental ill-health has now risen to be the topmost burden of ill-health and is being globalised. It can only get worse whilst policies focus on protein and calories and ignore the requirements of the brain.

(DoH 2007 £77 billion. DoH 2010 105 billion, 2013 £113 billion Wellcome Trust.)

Food policy has to revolve around the priority of H. sapiens - the brain. Without that, brain disorders, mental ill health and cognitive abilities will continue to decline with unthinkable consequences.

A new paradigm is urgently required to reverse this dangerous movement and protest if not enhance the intelligence of our children and theirs.

I am happy to justify any remarks above with the scientific evidence.

Michael Crawford

20. Sam L. J. Page, UN Committee and the Agriculture Committee, United Kingdom

Dear Madam/Sir

Please see the comments below:

P.35-38 Section 2.3 Micronutrient malnutrition and its causes and consequences

The emphasis seems to be on ‘food supplementation’ and ‘food fortification’ to reduce micronutrient malnutrition, however this does not address the needs of millions of women who are subsistence farmers, and thus do not normally purchase food. These women and their children require improved access to seed of crops that are high in nutrients, especially those of iron-rich pulses and dark green leafy vegetables, to protect them from micronutrient malnutrition.



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Please see the Critical and Emerging Issue: ‘Iron and vitamin C deficiency in female subsistence farmers’ that was sent to your office on 21st October 2016.

Please note that Box 8 (p. 75) contains two case studies on biofortification and “lead mother” training that could be scaled up for the benefit of smallholder farming households. Additional case studies that demonstrate the value of educating women farmers and school children in nutrition, including ICRISAT’s work in climate-smart pulses, could be included.

Yours sincerely

Sam L. J. Page, Ph.D.

Administrator to the UN Committee and the Agriculture Committee

21. Paul Sommers California State University, United States of America

Dear Committee,

I have done a very quick read-through of the document.

The first question is, who is the main audience for the document? I could not find it described.

While it is clearly one of the most comprehensive documents in terms of describing issues and research needs going forward, a thorough assessment of why each one of these issues has not been addressed successfully to date beyond a well-financed pilot here and there is missing. I have been involved with agriculture-nutrition linkages since 1976 and have come face to face with most of these issues running field programmes and I ask myself why are we still discussing basically the same issues some 40 years later? Lessons learned on why things don't work would enrich the final product.

Paul Sommers

Institute for Food and AgricultureCalifornia State University, Fresno

22. Fisheries and Aquaculture Department, FAO, Italy GENERAL

There is loose usage of the terms ‘fish’ and ‘seafood’. It is not clear whether when these terms are used (e.g. in the recommended food guidelines, Table 1) they are meant to apply only to fish and seafood (which means shellfish and sea fish, according to one dictionary definition) or not. Or does ‘fish’ include shellfish and aquatic plants (including seaweeds) and does ‘seafood’ include freshwater fish are included (freshwater fish actually makes up the greater component of farmed fish production).



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Good definitions are thus essential. We would suggest defining fish very early on, maybe as a footnote the first time it is used, and to have it include all fish species, and include shellfish (mussels, oysters, etc.), crustacea (shrimps, lobsters, etc.) and cephalopods (squids, octopus, etc.) whether caught (hunting wild or enhanced stocks) or farmed (aquaculture). Seaweeds and other aquatic plants should be kept separate …and should be mentioned also in the document, as they can be good sources of important micro-nutrients.

Fish is viewed primarily as a source of protein (e.g. l. 5, p. 18). It is also a source of highly bioavailable micronutrients and essential fatty acids (EPA and DHA), which is often more important. Fish is actually one of the few natural sources of iodine and DHA, both essential for an optimal neurodevelopment in children.

There is a sense in some places that the phrases food systems and value chains are used interchangeably. These two are not the same, as is well defined in the document. Care must be taken in the use of these phrases by the various authors.

Sources of tables and figures are important, and not always provided.

We note that the food safety section (p18) is yet to be developed.

Also, a spell check is needed. Some typos spotted.

QUESTIONS

1. The purpose of this report is to analyse the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft? No … not as far as fish production systems is concerned. There are no descriptions of major fisheries or aquaculture systems which identify those parts of the world that are heavily dependent on fish (including shellfish) as a major source of food security and nutrition. There are no examples, which exist occur in Pacific SIDS, for example, of what happens to dietary health and nutrition outcomes, when these food production systems (i.e. tuna fisheries) become export oriented.


3. Does the conceptual framework need to be edited? Simplified? Should “the food environment” as defined in the draft be central to the framework? Yes, it should be central, although it’s not sufficiently comprehensive. What’s missing to me are the cultural norms within households that determines who gets what food. For example, male heads of household often get to satisfy their hunger first, the rest of the family often dividing up what’s left according to who can eat fastest. Such norms often condemn the youngest/smallest family members, especially if female, to very poor diets.

4. Are production systems and their role in shaping diets and nutritional outcomes adequately addressed? In addition to 1 above, there is little here about the growing role of aquaculture



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as a provider of fish and shellfish. See, for example, Beveridge, M C M et al. 2013. Meeting the food and nutrition needs of the poor: the role of fish and the opportunities and challenges emerging from the rise of aquaculture. Journal of Fish Biology 83, 1067-1084. doi:10.1111/jfb.12187; Troell, M, et al. 2014. Does aquaculture add resilience to the global food system? Proceedings of the National Academy of Sciences 111, 13,257-13,263. doi: 10.1073/pnas.1404067111 and Little, D C et al. 2016. Aquaculture: a rapidly growing and significant source of sustainable food? Status, transitions and potential. Proceedings of the Nutrition Society 75, 274-286.

5. Does this draft cover adequately the main controversies in the field of Nutrition and food systems? Are there any remaining gaps? I think so. However, something needs said about the impact of aquaculture, now the main source of fish that is consumed, and changes in aquaculture production methods on nutrient content and intake. It’s implied in Fig. 14, p. 40, but no

6. The project team is working on a categorization of food systems. Are you aware of specific approaches of use in that perspective, and particularly of quantitative indicators that could be used? No.

7. Does this draft adequately show the multiplicity and complexity of diets and nutrition issues across different food systems and specific contexts with a good regional balance? It strikes me that the SIDS are somewhat ignored. Also, are the contrasts between urban and rural diets sufficiently explored?


9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich the report and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win outcomes in terms of addressing the different dimensions of diets for FSN? Consider work of Thilsted et al. in South and Southeast Asia on small fish and nutrition (e.g. Thilsted, S H Sustaining healthy diets: The role of capture fisheries and aquaculture for improving nutrition in the post-2015 era. Food Policy 61, 126-131; Belton, B., van Asseldonk, I.J.M., Thilsted, S.H., 2014. Faltering fisheries and ascendant aquaculture: Implications for food and nutrition security in Bangladesh. Food Policy 44, 77–87.


11. Is the report too technical or too simplistic? Are all the concepts clearly defined? There is loose usage of the terms ‘fish’ and ‘seafood’. See above comments on this.

12. Are there any major omissions or gaps in the report? Are topics under-or over-represented in relation to their importance? Antimicrobial resistance is mentioned once in reference to livestock, but AMR needs to be better reflected in the document. We recognise that the document focuses on food systems and nutrition, but AMR is a major public health issue, and



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has some of its roots in food production (wider than livestock) with implications for food systems and nutrition.

SPECIFIC

p. 14, Fig. 1. I don’t think the health element is strongly enough mentioned here, especially the links between Diets and Nutrition and Health outcomes. A child living in a house with no water supply or adequate sanitation, for example, will likely have diarrhoea and be unable to properly absorb dietary nutrients.

p.15, l. 12. ‘fisheries and aquaculture systems’ ..

p.16, l.37 …into raw food materials, namely crop, livestock and fish commodities…..

p.16, l.38 …include growing crops and fish, animal husbandry ….

p.20, l.15-17 This sentence infers that processed foods are nutrient poor and high energy. They aren’t in many cases. Needs to be rewritten to be more specific on those processed foods that are nutrient poor and high energy.

p. 22, Table 2. The focus in the table is on dietary energy; what about micronutrients?

p.39, l.18 Consumption of seafood omega-3 fatty acids, present in fatty fish……

p. 40, Fig, 13. I find the change in Omega-3 fatty acid intake interesting – this despite the doubling of global per capita fish intake over the past five decades. This may be attributable to the rise of aquaculture and the increasing proportion of freshwater fish in our diets (see Beveridge et al. 2013, referred to in 4 above).

p. 42, Fig. 15. What does the y-axis refer to?

p. 45, l. 3. Delete ‘.. in various parts of the globe.’

p. 47, l. 13 & 28. You could cite Hall et al. (2011) re methane evolution from cattle versus fish (Hall et al. 2011. Blue Frontiers: Managing the Environmental Costs of Aquaculture. WorldFish, Penang, Malaysia. pp. 93).

Also, we would not agree that fish is lower down the food chain than cattle, if you talking about who eats who.

p.48, l.26-29. A repetition of l.10-13.

p. 49, Fig. 19. Need more explanation as to whether ‘fish’ means fish (or fish and shellfish) and whether they are farmed or wild caught. This table also is unclear as to what each column refers to. Why are there 4 fish columns, 5 F&V columns, 3 livestock columns, etc. Define each column. Are “fish” coming from capture or farmed production systems?

Section 3.2.2. Nothing here about increasing productivity in aquaculture.

p. 49, l. 10. Fish have a high ecological footprint – high relative to what? If to plants, it’s obvious. If ‘fish’ includes mussels and oysters and non-fed carps, then the statement is wrong and misleading.

p. 79, Box 17. ‘WorldFish’ not ‘World Fish’. (Also Box 24).



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p.81, l. 16-17. Box 24 should be Box 22, and Box 25 should be Box 23. The whole document should be checked in this regard.

p. 81, l. 23. ‘24’ not ‘26’.

p. 82, Box 24. Interesting example on how fish could contribute with micronutrients. Fish powder could also be made of bigger fish, or even processing byproducts from bigger fish which represent about 50% of the fish and most of the micronutrients in the fish.

p.102, l.14 “……production activities that have been overlooked before, such as gathering, hunting and fishing.” It is not often that fishing is overlooked, hence the status of fish stocks globally. It might be better to qualify this statement.

p. 107, 4.2.4. For future research and data needs, data on food/nutrient composition should be included. In order to combat micronutrient deficiencies, there is a particular need to improve the knowledge on levels of micronutrients, and which foods (at local level) have significant levels of the nutrients needed.

23. Roberto Capone CIHEAM, Italy

Feedback from CIHEAM-Bari

Dear colleagues,

First of all I would like to thank HLPE and authors for this interesting and informative report that fills in an important knowledge gap regarding the multifaceted relations between nutrition (cf. diets) and food systems. A better understanding of these linkages is of paramount importance to foster transition towards sustainable food systems in the framework of sustainable food consumption. In fact, the report provides interesting insights on how food systems shape dietary outcomes including nutritional ones and vice-versa. The categorization of food systems, although challenging, is original in this sense.

The major objectives of the report are clearly reflected in the V0 draft. Moreover, the report is balanced (neither too technical nor too simplistic) and structure of the draft is comprehensive enough. However, more attention can be paid to the other dimensions of sustainability as in many parts of the report the focus is on health outcomes. Having said that, I think that no relevant aspects are missing.

However, I think that there is still room for improvement, which is quite normal as it is matter about a V0 version. You will find hereafter some comments and suggestions, that I hope will be helpful for this purpose.

As a representative of a Mediterranean organization, I think that the report can better valorize the work that has been done so far on the Mediterranean diet. In fact, CIHEAM and FAO started since 2010 a multifaceted cooperation program on sustainable food consumption and production with a



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particular reference to food systems sustainability and sustainable diets in the Mediterranean area. The Mediterranean diet is currently studied by CIHEAM and FAO as a case study for the assessment of the sustainability of dietary patterns in the Mediterranean area (1)(2). The Mediterranean diet is considered not only as a healthy dietary pattern but also as a sustainable lifestyle and cultural model. The perception of the Mediterranean diet solely as a “healthy” dietary pattern has until recently overshadowed other important socio-cultural, economic and environmental benefits. Therefore, I suggest to integrate box 12 (page 77) considering the above-mentioned elements.

Moreover, in table 3 (page 34), I do believe that the Mediterranean diet has positive health benefits not only in terms of type 2 diabetes and cardiovascular diseases. As a matter of fact, since the pioneer Seven Countries study, much scientific evidence has highlighted the health benefits provided by adherence to a Mediterranean dietary pattern to prevent chronic and degenerative diseases (3) and various types of cancers (4). The Mediterranean diet appears to have numerous other health advantages that are under current study such as: less peripheral artery disease (5), decreased inflammation and improved endothelial function (6), improved respiratory fitness (7), less allergic diseases (8) and improved immunity (9), decreased mental disorders such as depression (10), as well as

1 CIHEAM & FAO (2015). Mediterranean food consumption patterns: diet, environment, society, economy and health. A White Paper Priority 5 of Feeding Knowledge Programme, Expo Milan 2015. CIHEAM-IAMB, Bari/FAO, Rome. http://www.fao.org/3/a-i4358e.pdf

2 Dernini S., Meybeck A., Burlingame B., Gitz V., Lacirignola C., Debs P., Capone R., El Bilali H. (2013). Developing a methodological approach for assessing the sustainability of diets: The Mediterranean diet as a case study. New Medit3/2013, pp: 28-36. Available online at: http://www.iamb.it/share/img_new_medit_articoli/949_28dernini.pdf

3 Gotsis E., Anagnotis P., Mariolis A. et al. (2014). Health benefits of the Mediterranean diet: an update of research over the last 5 years. Angiology 66(4), 304-318.

4 Giacosa A., Barale R., Bavaresco L. et al. (2013). Cancer prevention in Europe: the Mediterranean diet as a protective choice. Eur J Cancer Prev 22, 90-5.

5 Nosova E., Conte M., Grenon M. (2015). Advancing beyond the “heart-healthy diet” for peripheral arterial disease. Journal of Vascular Surgery 61, 265-274.

6 Schwingshackl L., Hoffmann G. (2014). Mediterranean dietary pattern, inflammation and endothelial function: A systematic review and meta-analysis of intervention trials. Nutr Metab Cardiovasc Dis 24, 929-939.

7 Garcia Marcos L., Castro Rodriguez J.A., Weinmayr G. ‐ ‐ et al. (2013). Influence of Mediterranean diet on asthma in children: A systematic review and meta analysis. ‐ Pediatric Allergy and Immunology 24, 330-338.

8 Nurmatov U., Devereux G., Sheikh A. (2011). Nutrients and foods for the primary prevention of asthma and allergy: systematic review and meta-analysis. Journal of Allergy and Clinical Immunology 127(3), 724-733.

9 Del Chierico F., Vernocchi P., Dallapiccola B. et al (2014). Mediterranean diet and health: food effects on gut microbiota and disease control. International Journal of Molecular Sciences 15, 11678-11699.

10 Psaltopoulou T., Sergentanis T.N., Panagiotakos D.B. et al (2013). Mediterranean diet, stroke, cognitive impairment, and depression: a meta-analysis. Ann Neurol 74, 580-591.



http://www.iamb.it/share/img_new_medit_articoli/949_28dernini.pdf

http://www.fao.org/3/a-i4358e.pdf

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improved quality of life (11). Surveys have repeatedly shown that adherence to a Mediterranean diet pattern is also associated with a reduced obesity (12), and a lower incidence of the metabolic syndrome (13), and of type 2 diabetes (14). The Mediterranean diet may also positively influence the aging process (15) and delay the evolution of cognitive decline linked to Alzheimer’s disease (16) and vascular dementia (17). Moreover, the Mediterranean diet has also nutritional benefits. Subjects who adhere closely to a Mediterranean diet pattern fulfill most minerals and vitamins requirements much better than persons on a typical western diet (18).

Last but not least, and as the conceptual framework is concerned, it is clear that it provides an original schematic view regarding the different factors that determine the nutrition outcomes in relation to the food systems with a particular focus on food environment(s). I think that all drivers can be put in one rectangle and then connected through arrows to food environments, consumer behaviors and diets. In fact, sometimes the impacts are directly on diets without passing through consumer behavior and all types of drivers have impacts on all components of the conceptual framework. Moreover, there should be an arrow that shows feedback loop from diets to value chain actors choices since consumer behavior, so their effective diets, have also impact on the value chain decision making and choices. It seems a bit reductive to connect social impacts only to social equity as it is much broader. In addition, stability pillar of food security should be added. Governance should be as well considered alongside political institutions and institutional actions.

I would like to thank again all scientists and experts that were involved in drafting this outstanding report and I look forward to its upcoming publication in order to use it in research, education and cooperation activities of CIHEAM-Bari related to food and nutrition security.

11 Sanchez P.H., Ruano C., de Irala J. et al. (2012). Adherence to the Mediterranean diet and quality of life in the SUN project. Eur J Clin Nutr 66, 360-368.

12 Romaguera D., Norat T., Mouw T. et al. (2009). Adherence to the Mediterranean diet is associated with lower abdominal adiposity in European men and women. J Nutr 139, 1728-1737.

13 Kesse-Guyot E., Fezeu L., Hercberg S. et al. (2012). Adherence to Mediterranean diet reduces the risk of metabolic syndrome: a prospective study. Nutr Metab Cardiovasc Dis 142(5), 909-915.

14 Koloverou E., Esposito K., Giugliano D. et al. (2014). The effect of Mediterranean diet on the development of type 2 diabetes mellitus: a meta-analysis of 10 prospective studies and 136,846 participants. Metabolism 63:903-911.

15 Trichopoulou A., Kyrozis A., Rossi M. et al. (2014). Mediterranean diet and cognitive decline over time in an elderly Mediterranean population. Eur J Nutr 54 (8), 1311-1321

16 Singh B., Parsaik A.K., Mielke M.M. et al. (2014). Association of Mediterranean diet with mild cognitive impairment and Alzheimer’s disease: a systematic review and meta-analysis. J Alzheimers Dis 39(2), 271–282.

17 Feart C., Samieri C., Barberger-Gateau P. (2015). Mediterranean diet and cognitive health: an update of available knowledge. Current Opinion in Clinical Nutrition & Metabolic Care 18, 51-62.

18 Castro-Quezada I., Román-Viñas B., Serra-Majem L. (2014). The Mediterranean Diet and Nutritional Adequacy: A Review. Nutrients 6, 231-248.



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Regards

Roberto Capone

24. Dhanya P, Climate Change Division, Environment Protection Training and Research Institute, Hyderabad, India

Under the heading “Gender”

Unemployment accelerates Male out-migration f4rom the rural areas. Education also plays a major role in migration. Illetearacy amoung women is yet another issue

This transfers the responsibility of farm management on the shoulder’s of Women farmers. Their physical burden increases tremendously as they have to solely handle most of the farm operations along with household chores. Disasters events like droughts, heat waves fuel up their physical and psychological distress situations.

There should be a methodologies for calculating Women Discomfort Index and periodical assessmen assessments should be done during distress period.

25. Hector Bourges, Mexico1 Global Panel on Agriculture and Food Systems for Nutrition. 2016. Food systems and diets: Facing the challenges of the 21st century. London, UK.


1. The purpose of this report is to analyze the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft? I think they are

2. Do you think that the overall structure of the draft is comprehensive enough, and adequately considered and articulated? Does the draft strike the right balance of coverage across the various chapters? Are there important aspects that are missing? Does the report correctly focus on the links between nutrition and food systems without straying beyond that? The draft is comprehensive and articulated, the balance between chapters is right

3. Does the conceptual framework need to be edited? Simplified? Should “the food environment” as defined in the draft be central to the framework? Perhaps simplified, and the food environment occupying a central place

4. Are production systems and their role in shaping diets and nutritional outcomes adequately addressed? Yes they are. More emphasis on ecological matters are perhaps necessary



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5. Does this draft cover adequately the main controversies in the field of Nutrition and food systems? Are there any remaining gaps? Sorry. I am not familiar with the controversies

6. The project team is working on a categorization of food systems. Are you aware of specific approaches of use in that perspective, and particularly of quantitative indicators that could be used? No

7. Does this draft adequately show the multiplicity and complexity of diets and nutrition issues across different food systems and specific contexts with a good regional balance? I think the multiplicity and complexity are adequately shown


9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich the report and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win 8outcomes in terms of addressing the different dimensions of diets for FSN? Sorry. It is not my field of expertise

10. Section 4.2.2 on “Institutional Changes and Governance Across the Food System Movements for Nutrition” requires more work, and more inclusion of evidence and of the various players. Any 11 inputs on this section are most welcome. Sorry. It is not my field of expertise

11. Is the report too technical or too simplistic? No Are all the concepts clearly defined? Yes

12. Are there any major omissions or gaps in the report? Are topics under-or over-represented in relation to their importance? No

26. Jane Sherman, Food and Agriculture Organization of the UN, Italy

GENERAL COMMENTS ON THE HLPE REPORT ON NUTRITION AND FOOD SYSTEMS

This report is very welcome. The extensive references are very useful, there are some eye-opening data, and there is a good range of cases. My comments are mainly on the consumer’s actual and potential role in the food system, which I feel deserves more attention, and a number of imbalances in the coverage. Specific comments are made in the notes on the attached pdf (http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/HLPE-Nutrition-and-Food-Systems_Draft-V0-24_October_2016_jscomments%2026.11.2016.pdf) .

1. The “education” dimension needs more prominence, coherence and specificity. “Education” in food and nutrition now means anything (including independent insights, perceptions and actions) which results in informed food practices (the currently accepted definition of “nutrition education” is given in the comments on the text). The various schools of thought and practice (STPs) (e.g. “food and nutrition education”, “communication”, “behaviour change”, “behavioural economics”, “social marketing”) which outline, practise and test essential processes, structures and theoretical frameworks in nutrition interventions, need to be defined early in the report and the terms handled correctly and consistently.



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(a) Specifically, the current philosophy of "nutrition education" is misrepresented as meaning information dissemination.

(b) Generally, many of the interventions mentioned in the report (e.g. community development, service training, counseling, health promotion, social marketing, consumer education, awareness-raising, political advocacy, labeling, ENAs, conditional social protection schemes) involve consumer outlooks, understanding, attitudes, perceptions and practices, and hence some form of education. The report has a tendency to comment in passing on the effectiveness or ineffectiveness of such approaches rather than recognizing commonalities and linking them to the principles promoted by the STPs.

(c) All STPs have inbuilt limitations and strengths, which should be acknowledged when proposing strategies (e.g. “nudges” work only in specific conditions). A consistent stance should be taken, for example, on the effectiveness of information dissemination, community dialogue, different forms of mass media etc.

(d) A great deal is known by STP practitioners about what works and what does not. It would be desirable for a team of at least three experts from different STPs to be invited to review the report at this stage, agree on the use of the terms and suggest clarifying detail.

2. Socio-cultural drivers (p.57) This is the field of action of the STPs mentioned above. There is considerable evidence for a more elaborate picture than the one presented here (see e.g. Contento,2007[1]). Socio-cultural drivers should include (among other elements) (a) the inertial power of acquired habits and skills and the time it takes to change them, (b) household food expectations as a drag on change (change is easier for individuals), (c) time and convenience for HH cooks (major factors in the nutrition transition), (d) the social values given to specific foods (e.g. F&V not seen as a “real” food, pulses as “food of desperation”, soda drinks as young and glamorous, meat as an aspirational luxury),(e) “health beliefs”, especially the perception that what one eats makes a real difference to one’s health, (f) the practice/ understanding of prevention rather than cure in all health matters, including diet, (g) the habit of making changes, maintaining them and passing them on to the next generation, and the confidence to do it (“self-efficacy”), (h) the practice of getting information, knowing where to get it, and acting on it. All of these are more widespread and influential than specific food taboos, which seldom have a critical effect on overall diet quality.

3. Access, availability and utilization: Theory of change. The report often makes the assumption that access and availability will change dietary behaviour. For example, “Lack of affordable nutritious food can create a marked barrier to consumption” (p.70)– but so can perceptions of nutritious food and belief in its value, even in situations of scarcity. (The experience of the International Year of Pulses has highlighted some of these barriers.)The limitations of this mainly economic change model should be spelt out, exemplified and taken into consideration throughout the report.

4. Balance and discrepancies in emphasis Several parts of the report focus on one aspect of the issue at the expense of others – e.g. developed vs developing countries, smallholders vs industrial agriculture, high tech and low-tech solutions, obesity vs undernutrition. In particular:

- Environment and behaviour A main assumption is that environments condition consumer behaviour (e.g. p.99). This is of course correct, but the influence is reciprocal, as implied in Fig. 1 (food system): environment and consumer are both conditioned and conditioning: e.g. having only fast-food restaurants in an area limits the eating-out possibilities, but if there is consumer demand



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for fast-food, the market is likely to supply. The trick is to work out the balance of influences in any given context.

- Community development, consumer capacity, consumer demand are treated well, but do not get the attention that they deserve in relation to other parts of the food system. There is evidence that supplyside actions frequently need to be reinforced by social acceptance and readiness to change. In Fig. 27, for example, surely one of the main entry points for nutrition must be consumer demand for healthier food (as shown in the Conceptual Framework, Fig.1).

- Agriculture’s impact on nutrition A great deal of attention is given to improvements in agriculture, PH losses, marketing etc. but the claim is also made (p.109) that there is “little empirical evidence on the role of agriculture and other nutrition-sensitive sectors on nutrition”. Such discrepancies need to be aired.

- Information and advice Although the report states that information and advice alone have weak effects on changing dietary practice, much of the document assumes that information is the only “educational” strategy required - e.g. labeling and dietary guidelines figure in the model of the food system in Fig 1 as “educational” aspects of the food environment (both are likely to be ineffectual without some more diverse implementation strategy). The report proposes (near the end) to explore whether information makes a difference – however it needs only cite the existing evidence.

- Emphasis on specific micronutrients The report states (p.35) that "the best estimation of the relationship between diet and health consists of evaluating global dietary patterns and not in the analysis of specific foods and nutrients". However the text goes on to look in depth at three specific micronutrient deficiencies. Should there be more on overall dietary imbalances?

- Supplements and food-based solutions The issue of micronutrient supplements vs food-based solutions is rightly raised - needs more discussion?

- School meals The report claims that feeding programs - particularly school feeding - have “a direct impact on nutrition and diets”. The impact of school feeding needs a more nuanced discussion, especially in view of the relatively great length of some of the other sections in the report (e.g. on trade), the enormous sums which are spent on school meals, and the absence of evidence of nutritional impact (according to the Global School Feeding Sourcebook). Further questions about school meals are whether they have any concurrent impact on home diets, or longitudinally on children’s food choices when they become adults –i.e. whether there is any real effect on attitudes, understanding or food practices. I do not know of any studies in these areas.

- Policy p.69 What about examples of policies and programs aimed at improving consumer awareness and demand?

5. Strategy choices How are policy-makers to choose between, balance or combine the different options for tackling national nutrition issues? Ideally governments should be able to map what is already in place, assess its cost and review models of other countries’ overall policies and plans. Cost-effectiveness and long-term, sustained impact on food practices are key criteria. The ICN2 Framework listed desirable actions, but did not supply the means for governments to arrive at workable and affordable strategy choices based on their own situations. What guidance can this report give?



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6. Some gaps in coverage are urban agriculture, consumers’ associations, and professional training in FNE/BCC in national services.

Jane Sherman, Food and Nutrition Education consultant

Rome 26.11.2016

[1] Contento, I. R. (2007). Nutrition education: linking research, theory, and practice (1st ed.). Sudbury, Mass: Jones & Bartlett.

27. Edda Fernández Luiselli, Dirección General del Sector Primario y Recursos Naturales Renovables de la SEMARNAT, Mexico

1. La finalidad de este informe es analizar cómo los sistemas alimentarios influyen en los hábitos alimentarios y, por tanto, en los resultados nutricionales. El objetivo es centrarse en los consumidores y considerar las cuestiones relacionadas con la sostenibilidad. El informe pretende estar orientado a la búsqueda de soluciones y destacar las políticas y programas eficaces. ¿Refleja claramente el borrador cero este/estos objetivo(s) principal(es)?

Así es, aunque aún se siguen escribiendo algunas conclusiones del informe.

2. ¿Considera que la estructura general del borrador es suficientemente exhaustiva, y está adecuadamente considerada y articulada? ¿Cree que el informe logra encontrar el equilibrio apropiado en lo que respecta a la cobertura de los diferentes capítulos? ¿Hay aspectos importantes que no aparezcan reflejados? ¿Considera que el informe se centra adecuadamente en los vínculos entre la nutrición y los sistemas alimentarios sin desviarse a otras consideraciones?

Creemos importante el enfocarse más en la producción agroalimentaria sostenible, con el objetivo de crear mercados e incentivos que fomenten modelos de consumo y producción sostenibles, promoviendo la mejora de la productividad y métodos de producción con un uso eficiente de recursos a través de enfoques basados en el mercado.

3. ¿Es necesario modificar el marco conceptual? ¿Simplificarlo? ¿Debe ser el “entorno alimentario”, tal y como se define en el borrador, un elemento esencial del marco?

Creemos que el marco conceptual no debe modificarse.



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4. ¿Aborda de forma apropiada este borrador los sistemas productivos y su papel en la elaboración de las dietas y los resultados nutricionales?

Sería recomendable el elaborar algún cuadro en donde se explicara como son los “Sistemas Ingeniosos del Patrimonio Agrícola Mundial” (http://www.fao.org/docrep/014/i2232s/i2232s.pdf).

5. ¿Cubre adecuadamente este borrador las principales controversias en materia de nutrición y sistemas alimentarios? ¿Detecta alguna carencia?

Las cubre

6. El equipo del proyecto está trabajando en una categorización de los sistemas alimentarios. ¿Conoce algún enfoque específico empleado para este fin en este marco, y concretamente, algún indicador cuantitativo que pudiera ser utilizado?

No

7. ¿Cree que este borrador describe adecuadamente la multiplicidad y complejidad de las dietas y las cuestiones nutricionales en los diferentes sistemas alimentarios y contextos específicos con un apropiado equilibrio regional?

Sería más claro el poner qué tipo de cultivos son mayormente consumidos contra el costo de las mismas.

8. ¿Qué secciones del documento deben ampliarse o acortarse?

Se toca muy brevemente el tema de pérdidas y desperdicio de alimentos, sería muy interesante abordar el tema de investigaciones sobre especies que presentan por ejemplo mayor tolerancia a la sequía. Debería abordarse el tema sobre consideraciones del conocimiento tradicional en los sistemas productivos.

9. La sección 4.1 del capítulo 4 incluye estudios de casos/ejemplos de políticas y actuaciones efectivas en diferentes contextos/países en todo el sistema alimentario para mejorar las dietas y la nutrición. ¿Podría compartir otros ejemplos prácticos, bien documentados y significativos para enriquecer el informe y proporcionar una visión más objetiva de los diferentes casos y



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lecciones aprendidas, incluyendo las contrapartidas o los resultados mutuamente beneficiosos a la hora de abordar las diferentes dimensiones de las dietas para la SAN?

Recomendamos tomar en cuenta otros documentos de las Naciones Unidas y de la FAO e iniciativas como el reporte de “Sustainable Diets and Biodiversity” (http://www.fao.org/docrep/016/i3004e/i3004e00.htm ), el programa 10YFP ( http://www.unep.org/10yfp/ ), reporte del talle “Biodiversity in sustainable diets” ( http://www.fao.org/ag/humannutrition/24994-064a7cf9328fbe211363424ba7796919a.pdf ).

10. La sección 4.2.2 sobre "Cambios institucionales y de gobernanza en los movimientos del sistema alimentario para la nutrición" requiere más trabajo y más evidencias de los diferentes agentes. Cualquier contribución a esta sección es bienvenida.

Para la sección de manejo de recursos naturales sostenibles recomendamos el reporte “Sustainable Diets and Biodiversity” (http://www.fao.org/docrep/016/i3004e/i3004e00.htm ).

11. ¿El informe es demasiado técnico o demasiado simplista? ¿Están todos los conceptos claramente definidos?

Es un documento equilibrado.

12. ¿Tiene el informe alguna carencia u omisión significativa? ¿Hay temas poco o demasiado representados en relación a su importancia?

Podría ahondarse más el tema de promover, mejorar y facilitar el cambio hacia sistemas alimentarios más sostenibles, se debe seguir investigando cultivos que pudieran aportar nutrientes a poblaciones vulnerables o con problemas nutrimentales, es decir el tomar en cuenta la conservación y protección de los ecosistemas y sus recursos naturales, en este sentido integrarse las metas de Aichi con los Objetivos de Desarrollo Sustentable, por ejemplo la meta 14 dice “Para 2020, se habrán restaurado y salvaguardado los ecosistemas que proporcionan servicios esenciales, incluidos servicios relacionados con el agua, y que contribuyen a la salud, los medios de vida y el bienestar, tomando en cuenta las necesidades de las mujeres, las comunidades indígenas y locales y los pobres y vulnerables”, y no solo tomar en cuenta el tema de fortificación agronómica o modificaciones genéticas.

De acuerdo a la decisión 21 de la COP 12 del CBD, se reconoció el valor del enfoque “Salud compartida” para abordar la cuestión intersectorial de la diversidad biológica y la salud humana como enfoque integrado coherente con el enfoque por ecosistemas que integra las



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complejas relaciones entre los seres humanos, los microorganismos, los animales, las plantas, la agricultura, la vida silvestre y el medio ambiente.

Otro tema que se toca poco es sobre la desertificación y la pérdida de la biodiversidad las cuales están estrechamente relacionadas con la producción de alimentos, así como podría darse algún ejemplo sobre buenas prácticas de manejo del pastoreo para evitar la degradación de los suelos (http://www.fao.org/3/a-x5320s/x5320s0b.htm).

También deberían tomarse en cuenta publicaciones sobre la huella hídrica en la agricultura, para promover tecnologías como agricultura por goteo (http://wfn.project-platforms.com/Reports/Report47-WaterFootprintCrops-Vol1.pdf).

28. Dalia Mattioni, ItalyDear HLPE Project Team,

I have read through your Report with interest and commend you for the great effort and amount of work carried out. I will focus my comments on the conceptual framework which I think may need to be simplified a little, and make a small comment on section 4.2.3.

I believe the conceptual framework you have developed may be a bit “heavy”- it seems to put together 3 different sets of concepts and the final outcome is a bit confusing. To specifically respond to your question # 3, I do believe that making the concept of food environment (FE) the centre piece of the framework would help make the latter simpler and clearer and would “tighten” the text a little. This is also justified on the grounds of what you write in Chapters 2 and 3. In the these you tell us: 1) that unhealthy diets account for “at least 40% of all NCD mortality” (p.33), 2) that globally speaking the world is moving towards unhealthy diets as incomes increase. This raises the question of what kind of food is becoming more available and accessible (and partially as a consequence, more desireable) worldwide. This is where I think the Food Environment framework stands at the intersection between what the food system supplies and what people actually eat.

In my view, it is important to recognize the mediating role of food environments on what people eat, and in turn the effect that various aspects of the food system have on the food environment rather than connecting the different elements of the food system directly to diets (see Figure 6.1 in the latest Glopan Report for an illustration of this). The central message should be that food systems need to make healthier food more available, accessible and acceptable – the three pillars of food environments. The question is then how do food systems, in their various aspects which you identify as “drivers” and value chains activities contribute to making healthy food more/less available, affordable and acceptable. This is what you have started to do in Section 4.1.2, which I think should be given more relevance. What I think would be needed is to transfer information that you have under 3.2 under each of the paras on page 70. For example, section 3.2.3 could feed into para 2 on page 70 thus contributing to explaining what helps/hinders healthy food becoming more affordable. And so on… I would also categorize the policies and programmes that you have under section 4.1.3 in



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the same way (i.e. which contributed to making healthy foods more available, etc). That would help identify whether countries are working more on one aspect (eg: availability) and not another (eg. affordability) and whether there are any trade-offs.

The NOURISHING website has some interesting examples of policies:

http://www.wcrf.org/int/policy/nourishing-framework/about-nourishing

I think the above approach I am suggesting would also help countries focus better on what needs to improve in order to help their citizens achieve a better diet and to monitor their work. In this respect, the benchmarking work of the INFORMAS team is very useful:

https://www.fmhs.auckland.ac.nz/en/soph/global-health/projects/informas.html

On the topic of Nutrition Governance, I was happy to see that you have a section on social movements. Historically social movements related to food (especially in HICs) have focused their efforts on environmental sustainability aspects- so: locavore movements, KM 0, Farmers’ markets, box delivery schemes, etc. Increasingly however the healthiness of (such) foods is entering their narrative and becoming an important topic. What this suggests is the role played by social movements in raising people’s awareness and in partially determining a shift in consumer demand (food acceptability?). In other words, “policies” “from below” need as much attention and support as those from above.

An interesting article in this respect would be:

Huang T. et al, (2015) “Mobilisation of public support for policy actions to prevent obesity”, The Lancet, vol.385

One last small thought on the structure of the report: I think that at the moment the Report is indeed a bit too long and not focused enough. I think that taking the FE concept as a categorizing tool should help avoid some repetitions and take out links between food systems and diets that are maybe a bit too indirect. As Florence has pointed out, I would also start the Report by outlining “the problem” (i.e. increases in NCDs worldwide, triple burden of malnutrition), followed by the strong role played by diets, the evidence that diets worldwide are becoming unhealthier (Section 3.1.2), the role of FE, and the contribution of the various elements of the food system in leading to this.

Thank you for the opportunity and I hope these comments are useful.

Kind regards,

Dalia

Consultant

Nutrition and Food Security Division

FAO

Ps. I have not had time to read through all the comments that have come in- just the first ones. I may thus be repeating comments already made… apologies for that!



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29. Javier Carrera, FGH Latin America Agro Consulting, MexicoDear committee:

Fully agree with Mr. Sommers, from California, for more than 40 years still the same questions and guidelines, more discussion. Here are my points.

Introduction page 9: lines 17-22 the paragraph is like a question-answer dilemma to justify the lack of an adequate answer.

Introduction page 9: lines 31-34, the simple statement that industrial scale production is a threat for environment, and with the exact amount of money on environmental damage of US$ 3 trillion, is ridiculous, if you simply do the math’s with the WB actual population of 7.5 billion (2016 e), means that the cost of living, we owe US$ 400/year/human, to Mr. Environment, and this bring me to a simple question: Does it worth to feed the hunger at any cost? Or you prefer to let the most needed die? Because the FAO´s expert panel argued that the environment in the long term will suffer. This full paragraph looks like a environmentalist or a vegetarian type individual was in charge of it.

The Title is a Wikipedia like study case, and it avoids crucial facts, like the promotion at governmental levels of proven tools like the use of GMO´s to close the gap. This year example is Brazilian the severe drought, living the government to use fast track 10 million TN “permit” of GMO maize from USA, or the Mexican case, where authorities deny breeding GMO maize for poor farmers do to “cultural” reasons argued by NGO´s and they have to buy Transgenic maize flour imported from USA.

The argument that obesity comes solely for industrial foodstuffs can be a misleading opinion, the fact is: “the energy balance”, you can be eating the same, for instance in low income rural areas, but reduction of energy output do to a change in labor habits can be a trigger in obesity, and my point is clear, rural farmers energy in labor works reduction (agricultural, water supply, firewood collection, etc.) due to a beneficial factors such as electricity, water pumps, etc. and this Framework do not address it, is not knowing the “whole Picture” of the matter.

The Chapter 4.2.4 should make the point of promoting alternative energy output, mainly some type of organized exercise to balance the energy income, that´s the most important point in rural as in urban areas, rather than blame the use of industrialized food.

It has no sense, to be writing the same over and over and not making any important point that can leave to any government to make a clever choice.

30. Omoyemen Lucia Odigie-Emmanuel, Centre for Human Rights and Climate Change Research, Nigeria

The section on Climate Change is very commendable and clearly articulates the nexus among agriculture, food and nutritional security and the threat of climate change. Although some of your casestudies are focused on sustainable agriculture. The report can be strengthened with simplifying the language generally; and using language and more case studies that promotes this nexus in intervention.

Also, the graphs can be more explicit for anyone to relate with and use with anyone.



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31. Chadwick Digo, Egerton University, KenyaMalnutrition has for too long been a neglected issue. Yet it is a problem that affects one in three people worldwide. Today, 159 million children are stunted, 50 million are wasted and more than 2 billion people are overweight or obese. But in 2015 for the first time in history, through the Global Goals, the world has committed to ending malnutrition in all its forms. As the 2016 Global Nutrition Report makes clear, tackling malnutrition is one of the largest challenges facing all countries. Malnutrition comes in many guises: stunting, wasting, deficiencies of essential vitamins and minerals, and obesity. Reaching the ambitious target of ending malnutrition is only achievable if world leaders can ensure agriculture and food systems policies strengthen nutrition outcomes. There is a moral imperative to eliminate malnutrition. Undernutrition contributes to 45% of the 16,000 children under the age of five who die every day. The impacts extend well beyond health: stunted children who survive are permanently disadvantaged, perform worse at school and are robbed of future earnings that could support them and their families. But eliminating malnutrition is also an economic imperative. The costs of undernutrition in terms of lost national productivity are significant, with between 3% and 16% of GDP lost annually in Africa and Asia. The good news is that we know that the economic returns from investing in nutrition are high – GBP 16 generated for every pound invested. Boosting nutrition can boost growth.

32. Minna Huttunen, Ministry of Agriculture and Forestry, Finland

We wish to thank for the opportunity to comment on the Nutrition and food systems V0-draft. The draft is well planned and covers the food system as well as diet and health as well as diet and NCD. As a response to the specific important questions 1-12 we would like to give the following input:


Solution oriented approach is very welcome. It is important to state clearly the different stakeholders in the food system and the interests. Consumer focus is important, as food price is a big driver of consumption. It is equally important is to clearly state how profit drives trade. Political decision makers have an obligation and responsibility to act. Very important message on p.10 paragraph starting on line 14: Acting to change systems is never easy. Vested interests, technical difficulties and human and financial resource constraints all have to be overcome. Effort and focus need to be sustained. But key decision- makers in the public and private sectors have an obligation and a responsibility to act, and they should feel empowered to do so. Right now the political momentum is with those who aim to shape their food system towards improved nutrition. The SDGs – the world’s main accountability tool for sustainable development over the next 15 years – have a lot to say about food security, nutrition, climate and sustainable consumption.



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The draft is well balanced. However, the role of trade and agricultural subsidies could be more clearly stated. We have evidence on their role in shaping the consumption (increase sugar consumption, replace healthier plant oils with palm oil). This should be stated clearly as policy instruments and the decision makers using them are directly steering consumption, sometimes towards unhealthy diets contributing to NCDs, expenses and deaths.


The draft states clearly there are many stakeholders and players in the food system, all contributing to the food environment.


The role of economic drivers in the food system can be clearly (and briefly) stated. There is profit in the food system, unfortunately not always for the primary producer, nor equally distributed. Food system is complex as food is a necessity as well as a commodity - it is up to the food system stakeholders to act responsibly. As stated at the end of the draft (p. 105) “Nutrition is not a sector but cross-cutting development problem that needs to be integrated into the activities and policies of…. such as ministries of finance…”. It is clear not all the stakeholders act responsibly.





9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich the report and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win outcomes in terms of addressing the different dimensions of diets for FSN?



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Section 4.2.4 on future research and data needs. It would be valuable to mention here the need for nutrient content data, as it is the basis of all calculations. The nutrient content differs due to climate, soil, fertilizers, storage, cooking, etc.



33. Manuel Moya, Real Academia de Medicina, SpainGeneral comments

The structure of the V0 report is fully adequate due to the four chapters and subentries. So is the Conceptual framework and the five Definitions and extended concepts. The Introduction (page 9) quite precisely outlines the present frame of the report.

Specific comments

1 APPROACH AND CONCEPTUAL FRAMEWORK

1.1: Definitions 1, 2 (sustainable) and 3 (F. environments) are sequentially necessary, but reading one after the other one perhaps gets the impression of redundancy.

1.2: FS Typologies are very important because of the different food environments. To whom will this be addressed?

2 THE BURDEN

Due to my medical background and nutritional path I’ll concentrate on the triple burden of the adequate approach given to the malnutrition term.

2.1 When considering Undernutrition I would only like to make two comments. The first is related to the evaluation of anthropometric measurements, maybe it would be worth suggesting a proved general standard, such as the one by Cole or CDC, WHO because of its design would be the third option. The second is that when considering stunting (and obese stunted children), the easy calculated target height should be attempted in order to evaluate more precisely the causes of height reduction.

2.2 Overweight & Obesity. It is ok for adults. Because of the firm tracking from childhood to adulthood and the poor therapeutic results in all ages, the pediatric approach should be particularly stressed, as the World Heart Federation has signaled since 2004. This, furthermore due to the presence already in children of obesity comorbidities (1)

2.3 Micronutrient Malnutrition, causes and consequences. Perhaps it would be worth adding a 2.3.4 entry for zinc



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2.3.4. Other important micronutrients. For further versions I would consider the importance of essential amino acids (EAA), because in LMIC the amount of protein intake is less worrisome nowadays, but the quality does matter. The deficiency in lysine and tryptophan (2, 3) have clinical consequences that should be avoided. Deficiency of all EAA is also associated with stunting (4).

4 GARNERING QUALITY DIETS FROM SUSTAINABLE FOOD SYSTEMS

4.1.2. Food value chains and Food environments affect nutrition and diets. Figure 27 (page 68) depicts precisely the value chain for nutrients. In this context one option for dry LMIC will be to get complete proteins from plants. Mixing flours (5, 6) of chickpeas and sorghum (~20/80%) could be an issue until transformed seeds could be available.

REFERENCES

1. Moya M. Fatty Liver Disease among Other Comorbidities Requiring Early Diagnosis in Pediatric Obesity. Obes Control Ther 2013; 1(1), 02. http://symbiosisonlinepublishing.com/obesity-control-therapies02.pdf.

2. Moya M. Lysine genetically enriched cereals for improving nutrition in children under 5 years in low- and middle-income countries. J Nutr Health Food Eng 5(2): 00164. DOI: 10.15406/jnhfe.2016.05.00164.

3. Moya M. Low tryptophan chronic intake present consequences. BAOJ Pediatrics 2016 (In press)

4. Semba RD. Trehan I, Gonzalez-Freire M, Kraemer K, Moaddel R, Ordiz M. Perspective: The potential role of essential amino acids and the mechanistic target of rapamycin complex (mTORC1) pathway in the pathogenesis of child stunting. Adv Nutr 2016; 7(5) 853-65.

5. El-Adawy TA. Nutritional composition and antinutritional factors of chickpeas (Cicer Arietinum L) undergoing different cooking methods and germination. Plant Foods Hum Nutr 2002; 57(1): 83-97

6. Suri DJ. Tano-Debrah K, Ghosh SA. Optimization of the nutrient content and protein quality of cereal-legume blends for use as complementary foods in Ghana. Food Nutr Bull 2014; 35(3): 372-81

34. Elsa Victoria López, WFP, Honduras Considero que el informe es completo y muy importante para guiar/asesorar políticas públicas.

Sería recomendable enfatizar en la formación alimentaria de los agricultores de subsistencia, en los cuales sus dietas y la de sus familias, depende en gran medida de su producción familiar. Ellos reciben orientación agrícola pero no alimentaria. Deben aprender a valorar su cultura alimentaria, a protegerla y recuperar los cultivos autóctonos que se están perdiendo por la introducción de variedades genéticas importadas.

Incluir también que en las escuelas de agricultura sea obligatoria la enseñanza de los sistemas alimentarios autóctonos y su relación con la nutrición. Que a los agricultores se les capacite en el



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aprovechamiento de sus recursos alimentarios locales, pues por la influencia de la publicidad de alimentos de baja calidad nutricional sus dietas han cambiado. Debe dársele mayor estatus a los cultivos locales que han sustentado la alimentación desde hace siglos en estos países.

También recomendaría (si se puede) una tabla resumen sobre los alimentos autóctonos de gran potencial nutricional cada país y que deben recuperarse.

Si se puede hay que reducir y condensar el informe para facilitar su socialización y comprensión con los técnicos de las contrapartes gubernamentales o de la sociedad en general.

35. Frédéric Dévé, FAO, Italy Dear colleagues,

Many thanks indeed for a very rich, well structured and informative report, as well as for a rich discussion on the FSN Forum.

I would like to share a personal opinion from a food system governance (and a political economy) perspective.

When referring to the drivers of the evolution of our food system, the report currently does not provide, really, sufficient insight on the role of the private sector as major stakeholders in the food system.

In this connection, I would suggest everyone gives a quick look, if not yet done, at:

1. the picture/graph and text provided in http://convergencealimentaire.info/ and

2. the following link: http://www.fool.com/investing/general/2014/12/22/can-silicon-valleys-food-movement-spur-coca-colas.aspx .

My personal view is that the HLPE report could and should:

Make an attempt of publishing - in its body - a “map” of the kind provided in the first link above. In doing so, the report should be adjusting and rectifying what is relevant, so as to secure robust information and evidence, doing what is feasible in this connection before its publication.

Make a final recommendation calling for a more in depth exercise of this kind as soon as possible, in relation to the Decade on Nutrition. This would be a fundamental contribution to better informed policy debates . Such an exercise could be carried out by a next report of HLPE for CFS, of a study by FAO in partnership with strong research and intelligence entities (tbd). The idea is to develop a systematic picture and set of data related to the major players in the private sector. For each of the major players, these data could include: land and water under direct or indirect control, labour force mobilized in the industry, and population of small scale producers into the chains of these major stakeholders (under contract farming, or whose product is captured by these chains), as well as information on the countries where they operate. Of course, this information would be complemented by basic data on the value



http://www.fool.com/investing/general/2014/12/22/can-silicon-valleys-food-movement-spur-coca-colas.aspx

http://www.fool.com/investing/general/2014/12/22/can-silicon-valleys-food-movement-spur-coca-colas.aspx

http://convergencealimentaire.info/

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of companies, their total sales, and other information such as their official expenditures for publicity and lobbying. Such a recommendation could be a major contribution of this report.

I trust enhanced transparency and evidence always improves the quality of the debates and of public policies.

It is possible and necessary to carry out such an exercise based on information that is publicly available for most of it.

Such information never was systematically gathered and analysed in a robust manner by a super partes body.

Hope this is useful and helps.

Please note that this is a personal, not an institutional contribution.

Best regards,

Frederic

Frédéric DévéSenior Policy and Governance OfficerCoordinator of the Community of Policy Practitioners (CoPP)Governance and Policy Support unit (ESD)Economic and Social Development Department (ES)FAO, Viale delle Terme di Caracall a -00100 - Rome – Italy

36. Joost de Jong, Ministry of Economic Affairs, Netherlands Dear all,

We have read your draft HLPE paper on ' Nutrition and Food systems'.

Our compliments for all your work you have done so far.

We have some remarks on a few issues:

1. The impact of trade. In our opinion trade between countries is necessary to stimulate productivity and production. We want to refer to a research for the European Commission, just finished on the impact of trade agreements for the agriculture. We have added this research. Import in Europe from developing countries will increase with trasde agreements.

In our opinion this research provides a more realistic view on trade.

2. The necessity of 'sustainable intensification'. To reduce GHG from agriculture a sustainable intensification of the agriculture is necessary to reduce deforestation. We want to refer to a recent research of the Institute on the Environment. You can find this on:

http://www.environmentreports.com/how-does-agriculture-change/#section2

3. Transfer of knowledge and technology: The western world has a role to support developing countries with knowledge and technology: Due to the necessity of increasing productivity and



http://www.environmentreports.com/how-does-agriculture-change/#section2

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sustainability a transfer of knowledge and technology might increase productivity in the developing world. It’s important to stimulate this transfer.

For climate smart agriculture a lot of techniques will be available in the next years.

Kindly regards

Joost de Jong

Ministry of Economic Affairs

The Netherlands

http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/cumulative-fta-study_en.pdf

37. Anne-Marie Mayer, United KingdomThanks for sharing this draft. It is full of interesting material, I think the topic of nutritional quality of food is not fully covered, however.

Section 3.2.1

On nutritional quality of food, there are many more influences related to the environment in addition to CO2 on Zn content of foods

Studies on links between soil and nutritional quality need to be included here such as Iodine and soil quality, Se in soil and crops. Also the nutritional quality historical decline data needs to be added as this is the foundation for the subject of agronomic influences on nutritional quality. My own paper on this using UK data would be a starting point and Davis from US data

Mayer, A. B. (1997). "Historical changes in the mineral content of fruit and vegetables." British Food Journal 96(6): 207.

Davis, D. (2009). "Declining fruit and vegetable nutrient content: what is the evidence." Horticultural Science 44(1).

Section 4.1.2 Value chains

Thinking about nutritional quality through value chains. I have done an analysis of the potential to improve micronutrient content of rice through 'plugging the leaks' in the chain from farm to fork





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Mayer, A. B. (2011). A food systems approach to increase dietary zinc intake in Bangladesh based on an analysis of diet, rice production and processing. Combating Micronutrient Deficiency : Food-based approaches. B. Thompson. Rome, FAO: 256.

Section 4.2.1

The process of agronomic fortification is described, but again, I think this topic could be approached in terms of fulfilling the genetic potential for optimum nutritional value rather than fortification. So if crops are grown in optimum conditions their nutritional quality will not be compromised. This means, healthy soils, healthy crops and healthy people. For example you can compare agro-ecologically grown foods with organically grown and there is mounting evidence of the differences, though not everyone agrees.

For example, look at the full web-based data related to this study:

Dangour, A., S. Dodhi, et al. (2009). "Nutritional quality of organic foods, a systematic review." American Journal of Clinical Nutrition 28041.

You can look at the dilution effects of high yields vs quality, traditional varieties vs new varieties of different crops. Davis has done work on this.

Look at the nutritional quality of foods grown on different soils. There are some papers that explore these topics & I could seek them out for you given a bit more time. Some old ones that you only find by trawling through the stacks in libraries. I have done a literature review for rice and nutritional quality with several papers showing various ways to improve quality - including genetic varieties, use of fertilisers but also mycorrhizal differences, organic vs conventional differences etc etc

I think there is much more potential to improve nutritional quality of foods than the examples mentioned so far in this report. The research on this area however has rarely been funded whilst the genetic approaches have been much more popular, hence you have to look harder to find the material!

38. Ekin Birol, IFPRI, United States of AmericaDear HPLE Project Team,

I would like to congratulate you on an incredibly well thought-out, well researched and well written report. It was a pleasure to read, and it is commendable that you could cover all the causes of and promising solutions to addressing malnutrition, within a systematic framework and in one, comprehensive document. I especially appreciated the optimistic yet urgent tone of the report, and the actionable recommendations presented therein. I am sure the targeted readership (policy makers) will appreciate this one stop shop as we embark upon the UN Decade of Action for Nutrition. What a V0 draft!



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I read the report with a biofortification lens, and have some general (as well as minor) suggestions pertaining to the sections on biofortification.

(1) We are very glad to see biofortification acknowledged as a promising innovation that can increase the micronutrient content of food value chains. The 2016 Global Panel report on food systems and diets (which you cite in your report) has highlighted biofortification as an “approach with huge potential for scale-up”. The recent TIMES feature on 25 best innovations of 2016 has also identified vitamin A OSP (and biofortification) as an effective and cost-effective innovation in reducing vitamin A deficiency http://time.com/4572079/best-inventions-2016/

(2) Box 8: Biofortification to improve micronutrient intakes. It is true that regular consumption of biofortified foods improves micronutrient intake. However, we also have strong evidence (from efficacy and effectiveness studies) revealing that biofortification can also improve micronutrient deficiency status and functional indicators of micronutrient status (e.g., visual adaptation to darkness for vitamin A crops, physical activity for iron crops, etc.) and even health outcomes.

a. Efficacy trials for vitamin A OSP (van Jaarsveld et al. 2005; Low et al. 2007), vitamin A orange maize (Palmer et al. 2016; Gannon et al. 2014), vitamin A yellow cassava (Talsma et al. 2016), iron pearl millet (Finkelstein et al. 2015; Scott et al. 2014; Pompano et al. 2013), and iron beans (Luna et al. 2015; Haas et al., 2016) provide promising evidence that biofortification improves micronutrient status among target populations.

b. Effectiveness evidence on vitamin A OSP showed that OSP delivery had significantly increased vitamin A intake among children and women(also mentioned in Box 8), and measurably improved vitamin A status among some children, with a 9.5 percent reduction in the prevalence of low serum retinol (Hotz et al. 2012a). In Mozambique, where the delivery of OSP doubled vitamin A intakes, with OSP providing almost the entire total vitamin A intake for children (Hotz et al. 2012b), consumption of OSP was also found to reduce the prevalence and duration of diarrhea among children (Jones and de Brauw 2015). Among children who consumed OSP, the prevalence of diarrhea was 11.5 percentage points lower for children younger than five, and 19 percentage points lower for children younger than three, compared with children who did not consume OSP. Similarly, children who consumed OSP suffered from less diarrhea—0.6 days (for those younger than five) to 1.3 days (for those younger than three) less per week—than children who did not consume OSP (Jones and de Brauw 2015). These results reveal that biofortification could improve child health (Jones and de Brauw 2015).

c. To strengthen the India high iron pearl millet example, you could mention the results of the consumer and farmer acceptance research. This research shows that (i) even in the absence of information about the nutritional benefits of high iron pearl millet, consumers were found to like the sensory attributes of the grain of and bread made with the high iron pearl millet variety as much as (if not more than) those of the



http://time.com/4572079/best-inventions-2016/

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conventional variety (Banerji et al. 2016), and (ii) farmers who planted the high iron pearl millet for the first time liked the various production, processing and marketing and consumption attributes of the iron pearl millet variety more than its conventional counterpart (Karandikar et al., 2013).

d. Minor comments on Box 8: OSP effectiveness study was almost 3 years (2.5 years of implementation) and in line 7 OSP is misspelt as OFP.

(3) Since the objective of this report is to focus on consumers (as mentioned on page 2, point 2), you could cite the consumer acceptance research on biofortified foods (e.g., please see Chowdhury et al., 2011 for vitamin A OSP; Meenakshi et al 2012 and Banerji et al., 2013 for vitamin A orange maize; Talsma et al., 2013 and Oparinde et al., 2016a for vitamin A yellow cassava; Oparinde et al., 2016b for iron beans and Banerji et al., 2016 for iron pearl millet - majority of these papers and more is synthesized in Birol et al., 2015). Overall consumers’ acceptance of the biofortified varieties has also been very promising. Biofortified crops are liked by target consumers, as expressed either in terms of consumer valuation (captured as willingness to pay) or in terms of their sensory evaluation (captured through hedonic rating with 5 or 7 point Likert scales), in some cases even in the absence of information about their nutritional benefits, though information and awareness campaigns often have an important role to play. This finding is important for proving the acceptability of both vitamin A biofortified crops – which change colour and some other organoleptic characteristics due to their beta carotene content, as well as for mineral-fortified crops, which don’t have any visible changes, and hence may not be considered as more nutritious than their conventional counterparts.

(4) In section 4.2.1 of the report, I would recommend having separate sub-sections for fortification and biofortification. These two approaches – although complementary – have different origins and targets. Fortification is usually done during processing, and fortified food are mainly targeted at urban consumers who have access to processed foods sold in the markets. Biofortification starts with the planting material, and the main target of this approach is rural farmer-consumers who rely on staple crops to meet their families’ food needs and who may not have all year around access to diverse diets (including fortified foods). Therefore I would recommend having fortification and biofortification under two different subheadings, and changing “Crop fortification/biofortification” to just “Biofortification”. I would also recommend you to take a look at the 2014 Global Hunger Index report - chapter 3 has an excellent section on the various solutions to tackling hidden hunger (https://www.ifpri.org/publication/2014-global-hunger-index) and their various advantages/limitations.

(5) Again in section 4.2.1., I would suggest revising the definition of biofortification from“This can take place through improvements to the ways in which foods are grown (including soil health), enhanced nutrition through conventional plant breeding techniques and by genetic modification to have plants produce nutrients they otherwise would not be able to.” To the official definition of biofortification, which is “Biofortification is the process of increasing the density of vitamins and minerals in a crop through plant breeding or fertilizer applications or genetic modification using bioengineering technologies so that the biofortified crops when



https://www.ifpri.org/publication/2014-global-hunger-index

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consumed regularly will generate measurable improvement in vitamin and mineral nutritional status.” Even if you decide not to use the official definition, I would recommend changing “through conventional plant breeding techniques and by genetic modification” to “through conventional plant breeding techniques OR by genetic modification” since transgenic crops are not legally available in several countries, and we don’t want to deter policy-makers away from biofortification.

(6) As you rightly point out, there are 3 common approaches to biofortification: agronomic, conventional, and transgenic. These are usually defined as follows: Agronomic biofortification provides temporary micronutrient increases through fertilizers. This approach is useful to increase micronutrients that can be directly absorbed by the plant, such as zinc, but less so for micronutrients that are synthesized in the plant and cannot be absorbed directly (Lyons and Cakmak 2012). Conventional plant breeding involves identifying and developing parent lines with high vitamin or mineral levels and crossing them over several generations to produce plants with the desired nutrient and agronomic traits. Transgenic plant breeding seeks to do the same in crops where the target nutrient does not naturally exist at the required levels. Majority of the aforementioned efficacy, effectiveness and consumer acceptance evidence is from crops biofortified through conventional breeding (and some from agronomic biofortification). To date biofortified varieties of various crops have been officially released in over 30 countries and by the end of 2015, 20 million people have been reached with biofortified planting material – all of these varieties being conventionally bred.

Three other general comments are:

(1) Perhaps you can emphasise that just as undernutrition is an invisible problem (excellent point), so are several of the solutions (such as fortification, food safety and biofortification with iron and zinc) unless fortified/biofortified/safe food is labelled and certified by authorities that are trusted by the consumers. Such labelling and certification are more common and relatively well endorsed/monitored in developed countries (Loureiro reference most spot on!), though in developing countries (where micronutrient malnutrition and food safety risks are more prevalent) trusted mechanisms for certification and low cost technologies for endorsing/monitoring such identification mechanisms are not always available. Research and investment should be made to correct for such market failures.

(2) The sections on the importance of agricultural biodiversity, especially for providing diverse diets, is well-warranted. You may be interested to read this document on the relationship between biofortification and biodiversity http://www.harvestplus.org/sites/default/files/AtIssue1_Dietary_Diversity.pdf Additionally, conservation of agricultural biodiversity (both in situ and ex situ) is important for its insurance value. We do and will continue to tap into agricultural biodiversity resources for improvement of our current crops and livestock, whether it is for breeding for higher



http://www.harvestplus.org/sites/default/files/AtIssue1_Dietary_Diversity.pdf

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nutrient content (i.e., biofortification) or for better climate adaptation or to resist pest and diseases that may be surfacing in years to come.

(3) Since the key audience is the policy makers, perhaps in an appendix, they could be provided with the contact details of institutions/NGOs etc that are at the forefront of the initiatives and technologies mentioned in section 4. That way the report could also be a useful guide for those policy makers who want to act on the potential solutions.

I would be happy to discuss more or provide you with any of the references, in case you cannot access them.

Many thanks for your consideration and best regards,

Ekin Birol, HarvestPlus, [email protected]

References:

Banerji, A., E. Birol, B. Karandikar and J. Rampal. 2016. “Information, branding, certification, and consumer willingness to pay for high-iron pearl millet: Evidence from experimental auctions in Maharashtra, India.” Food Policy 62: 133 - 141.

Birol, E., J.V. Meenakshi, A. Oparinde, S. Perez, and K. Tomlins. 2015. “Developing country consumers’ acceptance of biofortified foods: A synthesis.” Food Security 7(3): 555.-568.

Chowdhury, S., J. V. Meenakshi, K. Tomlins, and C. Owori. 2011. “Are consumers in developing countries willing to pay more for micronutrient-dense biofortified foods? Evidence from a field experiment in Uganda.” American Journal of Agricultural Economics 93 (1): 83–97.

Finkelstein, J., S. Mehta, S. Udipi, P. Ghugre, S. Luna, M. Wenger, L. Murray-Kolb, E. Przybyszewski, and J. Haas. 2015. “A Randomized Trial of Iron-Biofortified Pearl Millet in School Children in India.” Journal of Nutrition 145(7): 1576-1581.

Gannon, B., C. Kaliwile, S. Arscott, S. Schmaelzle, J. Chileshe, N. Kalungwana, M. Mosanda, K. Pixley, C. Masi, and S. Tanumihardjo. 2014. “Biofortified orange maize is as efficacious as a vitamin A supplement in Zambian children even the presence of high liver reserves of vitamin A: A community-based, randomized placebo-controlled trial.” American Journal of Clinical Nutrition 100(6): 1541-1550.

Haas, J., S.V. Luna, M.G. Lung’aho, F. Ngabo, M. Wenger, L. Murray-Kolb, S. Beebe, J. Gahutu, and I. Egli. 2016. “Consuming iron biofortified beans significantly improved iron status in Rwandan women after 18 weeks.” Journal of Nutrition, doi: 10.3945/jn.115.22474

Hotz., C., C. Loechl, A. Lubowa, J. Tumwine, G. Ndeezi, A. Masawi, R. Baingana, et al. 2012a. “Introduction of B-carotene-rich orange sweet potato in rural Uganda results in increased vitamin A intakes among children and women and improved vitamin A status among children.” Journal of Nutrition 142: 1871-1880.




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Hotz, C., C. Loechl, A. de Brauw, P. Eozenou, D. Gilligan, M. Moursi, B. Munhaua, et al. 2012b. “A large-scale intervention to introduce orange sweet potato in rural Mozambique increases vitamin A intakes among children and women.” British Journal of Nutrition 108: 163-176.

Karandikar, B., E. Birol and M. Tedla Diressie. 2013. Farmer feedback study on high iron pearl millet delivery, distribution and diffusion in India. Paper presented at the 2013 AAEA & CAES Joint Annual Meeting, August 4-6, 2013, Washington, DC

Jones, K., and A. de Brauw. 2015. “Using agriculture to improve child health: Promoting orange sweet potatoes reduces diarrhea.” World Development 74: 15-24.

Low J. W., M. Arimond, N. Osman, B. Cunguara, F. Zano, and D. Tschirley. 2007. “A food-based approach introducing orange fleshed sweet potato increased vitamin A intake and serum retinol concentrations in young children in rural Mozambique.” Journal of Nutrition 137: 1320-7.

Luna SV, Lung’aho M, Gahutu JB, Haas J. Effects of an Iron-biofortification Feeding Trial on Physical performance of Rwandan Women. European Journal of Food Research & Review 5.5 (2015): 1189.

Luna SV, Denvir B, Udipi SA, Ghugre PS, Przybyszewski EM, Haas JD. Consuming Iron-Biofortified Peal Millet Improves Measures of Free-Living Physical Activity in Indian School Children. 2016. The FASEB Journal 30(1); Supplement 914.1.

Lyons, G. and Cakmak, I. (2012). Agronomic biofortification of food crops with micronutrients. In Bruulsema, T. W., Heffer, P., Welch, R. M., Cakmak, I. and Moran, K. (eds.) Fertilizing crops to improve human health: A scientific review. Vol. 1, pp. 97-122. Paris, France: International Plant Nutrition Institute.

Meenakshi, J. V., A. Banerji, V. Manyong, K. Tomlins, N. Mittal and P. Hamukwala. 2012. “Using a Discrete Choice Experiment to Elicit the Demand for a Nutritious Food: Willingness-to-Pay for Orange Maize in Rural Zambia,” Journal of Health Economics 31: 62-71.

Oparinde, A., A. Banerji, E. Birol, and P. Ilona. 2016a. “Information and consumer willingness to pay for biofortified yellow cassava: Evidence from experimental auctions in Nigeria.” Agricultural Economics 47(2): 215-233.

Oparinde, A., E. Birol, A. Murekezi, L. Katsvairo, M. Diressie, J.D. Nkundiamana, and L. Butare. 2016b. “Radio messaging frequency, information framing and consumer willingness to pay for biofortified iron beans: Evidence from revealed preference elicitation in rural Rwanda.” Canadian Journal of Agricultural Economics doi:10.1111/cjag.12105.

Palmer AC et al. Provitamin A-biofortified maize increases serum β-carotene, but not retinol, in marginally nourished children: a cluster-randomized trial in rural Zambia. Am J Clin Nutr 2016; 104(1):181-190.

Talsma, E., A. Melse-Boonstra, B. P. H. de Kok, G. N. K. Mbera, A. M. Mwangi, and I. D. Brouweret al. (2013). “Biofortified Cassava with Pro-Vitamin A iIs Sensory and Culturally Acceptable for Consumption by Primary School Children in Kenya.” PLoS ONE 8 (8): e73433.

van Jaarsveld, P. J., M. Faber, S. A. Tanumihardjo, P. Nestel, C. J. Lombard, and A. J. Spinnler Benadé. 2005. “ß-carotene rich orange-fleshed sweet potato improves the vitamin A status of primary school



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children assessed with the modified-relative-dose-response test.” American Journal of Clinical Nutrition 81: 1080-1087.

39. Janine Pierce, AustraliaPage 16: sub heading Socio cultural drivers:

line 17: suggest add in after 'different food choices' : or expectations of perfect shaped fruit and vegetables Bentley,2011).

Section 4.2.2. could mention also the impact on ecological systems in relation to destructive fish farming practices.

line 25. Urbanisation expands into rural areas with assocated depletion of farming land.

line 48: Diversification in extending land based farming to add in water based farming for income and protein sources has been proven successful in Vietnam (Pierce & O'Connor,2014)

40. Denish Ogwang, Lango Joint Farmers Association, UgandaGood Nutrition refers to a state when the food we eat is able to provide the recommended amount of nutrients for the body to perform all physiological activities. It is dependent on one's age, physiological status, physical activity level and sex. Good nutrition is important throughout the life cycle; right from preconception, conception, pregnancy, infancy, childhood, adolescence and/ adulthood. Good nutrition make an individual healthy, more productive the quality of life.

Good nutrition means:

Eating the right food.

At the right time.

The right amounts(quality and quantity) to ensure a balance diet and should be prepared in the correct way and right place.

Good nutrition is important because it:

Enhances physical and cognitive development.

Enhances breast milk production for the mother to adequately breastfeed her child.

Builds and or boosts body immunity reducing susceptibility to disease.

Reduces cost involved in disease management and control.

Enhances productivity.

A person with poor nutrition is at right risk of:



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Poor growth and development of the body and brain(especially in young)

Frequency illness,infections and prolonged(delayed) recovery

Reduced ability learn or perform in school

Reduced ability to work and earn a living

Death

41. Frank Mechielsen, Hivos, NetherlandsWe believe that the report highlights efficient policies and programmes quite well, overall. However, at least one important reference is missing: the Sustainable Food Systems (SFS) Programme of the United Nations 10-Year Framework on Sustainable Consumption and Production (10YFP)

The report can be strenghtened in several areas: gender (women are not just vulnerable groups), informal food systems (they serve most low income citizens) and different dimensions of food environment (the factor time is important).

For full comments see, the attachment.

Kind regards, Frank Mechielsen, Hivos, the Netherlands

HLPE CONSULTATION ON 0-DRAFT VERSION OF REPORT ON NUTRITION AND FOOD SYSTEMS

Input to the consolidated feedback by the SFS Programme


We believe that the report highlights efficient policies and programmes quite well, overall. However, at least one important reference is missing: the Sustainable Food Systems (SFS) Programme of the United Nations 10-Year Framework on Sustainable Consumption and Production (10YFP). The 10YFP is global framework of action to enhance international cooperation to accelerate the shift towards sustainable consumption and production (SCP) in both developed and developing countries. It is responding to several SDGs, especially to SDG12. It reports to ECOSOC and the High Level Political Forum on Sustainable Development

The SFS Programme of the 10YFP is a multi-stakeholder partnership to promote sustainable food systems through activities at global, regional and national level, in both developing and developed countries.

For more information see: http://www.unep.org/10yfp/food

2. Do you think that the overall structure of the draft is comprehensive enough, and adequately considered and articulated? Does the draft strike the right balance of coverage across the various



http://www.unep.org/10yfp/food

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chapters? Are there important aspects that are missing? Does the report correctly focus on the links between nutrition and food systems without straying beyond that?

…The 4.2 Looking to the future part should be strenghtened. Many more solution are available.

Most of the farmers are small scale farmers, most of them women. Most of the consumers are women. The youth are designing are future food system. They are currently addressed as “vulnerable populations” This is correct for certain groups of farmers, youth and women. But women, small scale farmers and youth should be addressed integrated in the paper and not in one chapter.


Regarding the definition of “food environments” on pages 11/12: we would suggest to beyond “healthy food environments”, focusing rather on “sustainable food environments”. Therefore, we would suggest to change the last sentence in the box into: “Sustainable food environments enable consumers to make nutritious food choices with the potential to improve diets, reduce the burden of malnutrition in all its forms, and improve the socio-economic as well as environmental impacts of their consumption patterns.”

Regarding the definition of “sustainable diets” on page 12: in line with the FAO 2012 definition, please add the following phrase at the very beginning: “Sustainable diets are those diets with low environmental impacts which contribute to food and nutrition security and to healthy life for present and future generations.”


…Production systems (agriculture, aquaculture and fishery, and pastoralism) receive very limited attention. Changes in these often traditional systems impact food and nutrition security of many people. For example currently many small scale farmers are net food buyers, they buy more food than they sell. Perhaps a specific sub chapter can be included under 3.2.


Looking at nutrition from a food systems angle implies that we have to link diets not only to consumption but also production. However, the current draft report focuses mainly on the health aspects of human nutrition, while the socio-economic and environmental aspects linked to nutrition are not well covered. In our view, this aspect should be strengthened in the report. For example, there could be a separate sub-chapter on “sustainable diets” under 1.1. Similarly, chapter 4 focuses on the impacts of food production systems and food value chains on nutrition, but it does not address the impacts of human nutrition on other socio-economic and environmental impacts in food production systems. It would be extremely valuable to include this; it could possibly be addressed under 4.1.4.

We miss a stronger reference to socio-economic and environmental externalities of the current food system. Many external costs are not taken into account in the value chain and the final price towards the consumers.



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…no comments


…The nutrition part is balanced, though Africa is missing in the informative tables on page 39-42 There is a bias towards more data from developed countries. For example, the table on page 22 , the part on processing and retail, marketing is biased towards the developed countries (Euromonitor). If possible include more data from developing countries. In case these are not available, the report should recommend further research in this area.

There could be more attention to the footprint of countries. How much water and land (nutrients) they indirectly import via international value chains. This is mainly an issue for developed countries and increasingly emerging economies like BRICSAM.


…As mentioned before there is a strong focus on nutrition and the other dimensions of the food systems receive less attention.

The part food environments (page 17) can be elaborated further, especially in relation to food prices, and in relation to the changes in food culture, from customary food cultures to western industrialized food culture which is promoted by advertisements and via popular culture. This is especially influencing the youth. They are the early adopters.

This is explained clearly in the following report. We recommend to include refernence to the September 2016 IDS-Oxfam paper on precarious lives, food, work and care after the global food crisis. http://www.ids.ac.uk/publication/precarious-lives-food-work-and-care-after-the-global-food-crisis

Food environment is also influenced by time availability of men (traveling further for work which encourages mobile eating) and of women (having less time to cook and start using processed, ready made food)

On page 106; movements: there are many more movements around. Focus is currently on CSM. They play an important role, but this text should be more representative and include other type of movements such as Slow Food, Via Campesina, CSO SUN, etc.


The international development organization Hivos is supporting local food system transformation in Uganda, together with the UK knowledge institute IIED. This is an example of local multistakeholder collaboration in which citizens are key. With other actors oft he food system the local farmers, food



http://www.ids.ac.uk/publication/precarious-lives-food-work-and-care-after-the-global-food-crisis

http://www.ids.ac.uk/publication/precarious-lives-food-work-and-care-after-the-global-food-crisis

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vendors, consumers join forces to review the challenges in the current food system and work on solutions. See http://www.foodchangelab.org/assets/2016/09/food-lab-pub.pdf


Include the above-mentioned 10YFP Sustainable Food Systems Programme under section 4.2.3 on “Nutrition governance, institutions and partnerships”.


The report maintains a good balance between technical information and examples in boxes to show how certain policy measures or programmes work in practice.


The importance of Informality in food markets does not receive sufficient attention. On page 16-17 the focus is on formal value chain actors. Many low income farmers and consumers depend on the informal market for their food sales and purchases (small informal traders, food vendors, market sellers, etc.) See 2016 IIED publication about informal food systems in East Africa http://pubs.iied.org/pdfs/17336IIED.pdf

The figures on page 68-69 again only show the formal value chains and do not incorporate solutions in relation to the informal sector.

The topic of food loss and waste does not receive sufficient attention. When we reduce the 30% loss and waste in our food system, many more people could receive adequate nutrition.

…The examples of technology drivers on value chain activities (page 15) focus on highly technical solutions such as the fortification of food. It would be good to complement with more accessible technology (for low income farmers), such as improved varieties of nutritious indigenous crops (orphan crops), and Open Source Seed Systems. See Hivos‘ experience https://www.hivos.org/focal-area/open-source-seed-systems

This comes back again in 4.2 Looking to the future, on page 92. Technology is focused on fortifications while there are many other technological solutions which are closer at reach for farmers or consumers. For example to improve varieties of “ orphan crops”, which are more nutritious and climate resilient.

On page 93. Genetic modification is presented as a solution without any considerations when there is a lot of critism. This should be presented in a more balanced way.

Gender should be stronger included in the paper. Especially in the economic and socio-cultural drivers (page 100-101). Women play a big role in producing, selling, buying and preparing food. Women’s unpaid care role should be taken into account. Their more limited available time to buy, and prepare food because of increasing participation in the labour market.

On knowledge gaps, page 91, could include reference to develop more research in relation to the informal food system, gender relations and the improvement of varieties of nutritious crops.



https://www.hivos.org/focal-area/open-source-seed-systems

https://www.hivos.org/focal-area/open-source-seed-systems

http://pubs.iied.org/pdfs/17336IIED.pdf

http://www.foodchangelab.org/assets/2016/09/food-lab-pub.pdf

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13. Any other general or specific comments:

No

42. Victor Owino, International Atomic Energy Agency, AustriaWe at the Nutritional and Health Related Environmental Studies Section (NAHRES), the International Atomic Energy Agency (IAEA) have reviewed the HLPE draft report and find it already very well structured. It covers the complex array of nutrition drivers in a highly competent manner. We propose a few areas where there could be improvement.

1. The conceptual framework need to be more simplified to aid easy comprehension by a wider audience

2. The concept of the double burden of malnutrition is not well articulated; our perception is that this phenomenon applies at individual (one could be stunted and obese at same time or stunting earlier could be a risk factor for obesity later), household (different members of same household could suffer different forms of malnutrition), national (cuntries in transition), regional and global level.

Our other detailed comments are attached.

A clear conceptual framework for increasing multi-disciplinary capacity to tackle nutrition needs to be articulated (nutrition spans many disciplines and success can only be achieved with adequate critical mass of technical skills that enhances cross-discipline harmony) – one approach is integrating nutrition in training of all relevant disciplines.

Enhancing food traceability: This cannot be discussed without addressing first the accountability factor, i.e. who and how can food traceability be monitored and who will control it throughout all the stages from production to the consumer’s table.

What standards will be applied on quality and safety of the food, again accountability becomes an issue.

Advertising: How do we define “healthy foods and beverages” when messages are being used. Who will police these “healthy messages”. Even if there are policies in place, they need to be interpreted in a systematic and scientific way so as to have an impact on nutrition as an outcome. There should be a regulator that will ensure that messages do meet the required bits and recommendations. But this can work locally or nationally, but with globalization and cross-boundary-country trading, how does that regulator work?

Dietary guidelines: Are they all guided by Law e.g. in America where they are reviewed every 5 years based on new scientific evidence and are for healthy people over 2 years old. Within the context of this document, individual countries will have to have their own guidelines based on the nutrition problems facing them such as, the current US Dietary Guidelines that focus on obesity and NCDs, recommending increase physical activity far and beyond the traditional calorie balance, foods to increase, foods to decrease and other recommendations on safety and “eat in moderation “and healthy eating patterns. How can we arrive at universal dietary guidelines for all countries with different nutritional problems and levels of



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education for the healthy people. How do we address the double burden of malnutrition for the rest of the world population. This need to be well addressed in this section.

Food labelling is another global issue that need to be standardized as trade allows food imports from world over in supermarket shelves or corner/spaza shops world over. But this needs to be simplified and preferably, use pictures. Look at the efforts on food labelling from the EU as an example. Accountability remains an issue again on food labelling, who will safe guard the children , e.g. Chinese stores from townships of South Africa and shanty towns of Kenya, selling infant formula from China and, and one cannot forget the case of amino acids in Chinese infant food that resulted in deaths. The other example is the horse meat saga in Europe that caused a scare in the meat industry of the EU countries.

The section on improving community based nutrition programme needs to be more relevant to all urban areas have come up with community gardens in the inner cities –including the roof-tops gardens? These do have a place in food production for nutrient dense eating patterns and dietary diversity. The good intention on food gathering and hunting has to be viewed from a precautionary perspective given the realities of extinction of some wild animals as control is not always guaranteed. Rather encourage research of propagation some indigenous foods and animal production of certain hunted birds and small ruminants to keep the balance of these food sources. This is missing in this section.

Agricultural heritage and precise targeting: There is really no bottom line or take home message on this section. This needs some more work and enhancement.

Making local and traditional diets for nutrition: What is implied in this section by “diets for health”/ Does this refer to therapeutic diets for addressing certain diseases or preventing them, e.g. saturated fats and heart diseases??? High salty foods and hypertension??? The example on West Africa does not address the traditional foods revitalization, rather it seems to be looking at “slow down trends towards dietary simplification”

Private Public Partnerships: There are examples from health sector that are working well and saving lives with MOUs and a clear legal structure in place, to guide this partnership e.g. Kenya’s case on cancer radiation treatment.

Movements for nutrition: This needs more work, the section was confusing to me. What ever happened to home/school gardens? These are training grounds and educational laboratories for the youth for nutrition and food systems.

Some terminologies need further clarity: e.g. animal-sources foods vs animal food sources… is there a difference? Staple crop commodities, nutrient-poor foods and beverage vs nutrient dense foods; high-quality eating patterns?; nutrition-sensitive value chain approach?

The rest of the document needs editing, more examples that are recognized as success stories.

43. Mark Lawrence, Deakin University, AustraliaThank you for the opportunity to provide comments on this important document. I believe that the document is valuable, but also it could be strengthened in a number of areas as outlined in the attached file.



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Best wishes

Mark Lawrence

Mark Lawrence response to the CFS-HLPE consultation

Thank for the opportunity to comment on this important document.

1. The document appears to preferentially emphasise nutrition-specific (NSp) interventions (supplementation and (bio)fortification) over nutrition-sensitive (NSe) interventions to combat micronutrient malnutrition. Whereas NSp interventions are an important component of an integrated and comprehensive approach to tackle micronutrient malnutrition, a concern is that they are displacing NSe interventions targeting food and dietary-pattern behaviours as well as activities targeting the social and ecological determinants of food security and nutrition. A recent paper by our team (http://www.mdpi.com/2072-6643/8/9/555) has documented the skewed profile of NSp- and NSe-interventions across evidence reviews (80% are NSp) guidelines (60% are NSp) practice (71% are NSp) relationship. The result is a virtuous circle in which NSp-interventions dominate decision-making and activities and the circle becomes self-perpetuating and fails to achieve a balanced and comprehensive programme of activities. In its current form the document risks contributing to this skewed profile of interventions.

2. I encourage the document to further integrate nutrition considerations into food systems thinking and vice versa and avoid treating each separately. There is a powerful bi-directional relationship between food systems and dietary pattern behaviours. Our dietary behaviours send strong signals to food systems about what foods to make available and food systems make available foods that influence our dietary behaviours. Hence dietary imbalances that contribute to non-communicable diseases invariably are embedded in the structure and operation of food systems – how they produce, process, distribute and market food.

3. For the reasons expressed in 2. above, I encourage the document to place strong recognition on the importance of linking healthy and sustainable diets with healthy and sustainable food systems.

4. I encourage the document to place particular recognition on the broadly complementary nature of healthy and sustainable diets, i.e. a healthy diet generally is a sustainable diet.

5. I encourage the document to tackle the topics of discretionary (junk) foods, GMOs, agricultural chemical residues and/or contaminants, non-sustainable fisheries and intensive livestock systems, from health, sustainability and political (who controls and stands to benefit from these food system components) perspectives and identify what can be done to mitigate and better manage their disruptive influence over food systems.

6. In relation to Box 21, p81 – folic acid fortification: Folic acid fortification is a controversial activity and a poor choice of case study for food fortification. The contexts, circumstances and uncertainties associated with mandatory folic acid fortification are quite different to those for ‘normal’ food fortification activities. It is a concern that the document is referring to this controversial and peculiar case study as representative of food fortification in general. More concerning is the largely uncritical and simplistic analysis given to this particular food fortification case study. Mandatory folic acid fortification raises serious questions about ethics, effectiveness and safety (for example see,



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Lawrence, M. (2013). Food fortification: The evidence, ethics, and politics of adding nutrients to food. Oxford University Press). In terms of ethics, why is it not mentioned that the cause of NTDs is not due to an inadequate nutrient intake in the conventional physiological sense?, instead it is an intervention being implemented to increase folic acid exposure to a small number of at-risk individuals who require significantly raised folic acid intakes, while exposing the entire population who consume the fortified staple to raised levels of folic acid. In terms of effectiveness, why is there no mention that there are alternative interventions available (targeted supplementation in combination with education) that are more effective when adequately funded and targeted to the at risk individuals? In terms of safety, why is there no mention of the risk of raised folic acid exposure to masking the symptoms of vitamin B12 deficiency or potential problems resulting from epigenetic influences? It is recommended that a more balanced analysis is provided for this case study or it be replaced with a case study more representative of food fortification interventions.

7. In relation to Box 33, pages 87-88, the Australian Health Star Rating (HSR) scheme: The HSR is inaccurately referred to as an example where front of pack labelling can be used to shift purchasing behaviours towards healthy eating. In Australia the HSR scheme has not been supported by many public health and consumer groups and practitioners because of concerns that it undermines the national dietary guidelines (for example see, Lawrence, M, Pollard, CM (13 July 2015) A year on, Australia’s health star food-rating system is showing cracks. The Conversation. http://theconversation.com/a-year-on-australias-health-star-food-rating-system-isshowing-cracks-42911). Instead it has most favourably been embraced by food manufacturers as it is easily exploited to help market discretionary (junk) foods, e.g. systemic flaws in the scheme (it fails to differentiate between 5 food group foods and discretionary foods, it awards so-called health stars to junk foods and it is a voluntary scheme). The result of these systemic flaws in the HSR scheme is that dietary guideline recommendations are being undermined, e.g. food products such as apple juice receive the maximum 5 stars while nutritious 5 food group foods such as yoghurt receive 1.5 stars. I recommend that the HSR scheme is not cited in the document as an example of an intervention that should be strived for, instead if it is to be cited at all do so in the context of highlighting the need for caution to avoid how nutrient-oriented schemes can be exploited to undermine dietary patternoriented recommendations.

44. Patrick Mink, Federal Office for Agriculture (Switzerland), Switzerland

Input to the consolidated feedback by the SFS Programme


We believe that the report highlights efficient policies and programmes quite well, overall. However, at least one important reference is missing: the Sustainable Food Systems (SFS) Programme of the United Nations 10-Year Framework on Sustainable Consumption and Production (10YFP). The 10YFP is global framework of action to enhance international cooperation to accelerate the shift towards



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sustainable consumption and production (SCP) in both developed and developing countries. It reports to ECOSOC and the High Level Political Forum on Sustainable Development.

The SFS Programme of the 10YFP is a multi-stakeholder partnership to promote sustainable food systems through activities at global, regional and national level, in both developing and developed countries. It contributes to the achievements of several SDGs, in particular SDG 2 and SDG 12, as well as a series issues covered by other SDGs including in the areas of health, biodiversity and ecosystems, partnerships, etc. One of the five focus themes of the Programme is “sustainable diets”. Under this focus theme the SFS Programme aims to promote diets that take into account the three sustainability dimensions in addition to food security, nutrition and health aspects, thereby linking consumption and production. It does so by raising awareness, promoting enabling environments, and facilitating access to knowledge, information and tools. For example, FAO, UNEP and the United Nations Standing Committee on Nutrition are joining forces under the SFS Programme, to lead on the development of broadly recognized methodologies and indicators to assess the sustainability of diets, with a view to produce guidance materials for governments and other relevant stakeholders on how to account for the different dimensions of sustainable development (social, economic and environmental) in their respective dietary recommendations.

In its resolution on Agriculture development, food security and nutrition of 2015 (A/RES/70/223), the United Nations General Assembly welcomed the launch of the SFS Programme. In October 2016, the FAO Committee on Agriculture requested FAO to strengthen its work on sustainable food systems in relation to the 10YFP.

The SFS Programme could be included, for example, under 4.1.3 and/or 4.2.3.

For more information see: http://www.scpclearinghouse.org/sustainable-food-system


We feel that chapter 4.2 could be strengthened, as a variety of further solutions are available, including solutions that are less “high technology” and more accessible to smallholders and low income farmers (see also our comment under 12 below).

As it is correctly presented in the report, one of the big challenges in agriculture today is to ensure that youth have the proper incentives to stay in agriculture. In addition, today’s youth has an important role to play in shaping tomorrow’s food systems. Therefore, we believe that it would be useful to address youth in a more integral way throughout the report, and not only under the sub-section “vulnerable populations” under 4.2.2. Similarly, the role of smallholders and women could be further streamlined in the report.


When comparing the suggested definition for “food system” on page 11 with the one contained in the 2014 HLPE report that is cited as its source, we realized that the definition in the current draft differs from the one of the 2014 HLPE report in that it includes some new wording. Considerable consensus has emerged around the 2014 HLPE definition of the term “food system” (for example, it



http://www.scpclearinghouse.org/sustainable-food-system

http://www.un.org/en/ga/search/view_doc.asp?symbol=A/RES/70/223

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has been endorsed and /or used by the UN Secretary General’s High Level Task Force on Global Food and Nutrition Security, FAO, UNEP, UNSCN, the SFS Programme and many other stakeholders, and thus provides a strong basis. For this, and for reasons of consistency, we would suggest not to modify the 2014 definition. In case the experts should nevertheless decide to modify the 2014 definition, we would suggest that such wording changes should be as minimal as possible, for example: “[..] outcomes of these activities, including socio-economic (comprising also nutrition and health) and environmental outcomes.” In any case, we would suggest that possible changes to the definition be justified by some explanatory text.

Regarding the definition of “food environments” on pages 11/12: we would suggest to go beyond “healthy food environments”, focusing rather on “sustainable food environments”. Therefore, we would suggest to change the last sentence in the box into: “Sustainable food environments enable consumers to make nutritious food choices with the potential to improve diets, reduce the burden of malnutrition in all its forms, and improve the socio-economic as well as environmental impacts of their consumption patterns.”

Regarding the definition of “sustainable diets” on page 12: in line with the FAO 2012 definition, please add the following phrase at the very beginning: “Sustainable diets are those diets with low environmental impacts which contribute to food and nutrition security and to healthy life for present and future generations.”


Production systems (agriculture, aquaculture and fishery, and pastoralism) receive rather limited attention in the draft report. Changes in these - often traditional - systems impact food and nutrition security of many people, in particular smallholders. This can be exemplified by the fact that currently many smallholder farmers are net food buyers. Maybe this could even be addressed in a specific sub chapter under 3.2.


Looking at nutrition from a food systems angle implies that we have to link diets not only to consumption but also production. However, the current draft report focuses mainly on the health aspects of human nutrition, while the socio-economic and environmental aspects linked to nutrition are less covered. In our view, these aspects should be strengthened in the report. For example, there could be a separate sub-chapter on “sustainable diets” under 1.1. Similarly, chapter 4 focuses on the impacts of food production systems and food value chains on nutrition, but it does not address the impacts of human nutrition on other socio-economic and environmental impacts in food production systems. We would like to see a stronger reference to socio-economic and environmental externalities of current food systems, in which, often, external costs are not taken into account in the value chain and final consumer prices. It would be very valuable to include this; it could possibly be addressed under 4.1.4.


[no comments]



http://www.unep.org/10yfp/Portals/50150/10YFP%20SFS/10YFP%20SFSP%20Programme%20document.pdf

http://www.unscn.org/files/ICN2_TPM/Policy_Brief_EN_Impact_Assessment_FINAL.pdf

http://www.unep.org/resourceefficiency/Home/Business/SectoralActivities/AgricultureFood/tabid/78943/Default.aspx


http://www.un.org/en/issues/food/taskforce/wg3.shtml

http://www.un.org/en/issues/food/taskforce/wg3.shtml

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The nutrition part is balanced. However, proportionally more data from developed country data sources seems to be presented (e.g. Euromonitor on page 22) – this may be due to a lack of available data, but it could be useful to aim for a more balanced representation. In case of lack of data, this could be presented as an area for further work.

In addition, there could be more attention to the footprint of countries. How much water and land (nutrients) they indirectly import via international value chains for their nutrition.


As mentioned earlier, we would welcome to see some additional focus on the linkages between nutrition and socio-economic and environmental aspects of food systems, including the socio-economic and environmental externalities of our nutrition choices impact.


[no comments]


Include the above-mentioned 10YFP Sustainable Food Systems Programme under section 4.2.3 on “Nutrition governance, institutions and partnerships”.


The report maintains a good balance between technical information and examples in boxes to show how certain policy measures or programmes work in practice.


The report currently focuses mainly on the formal sector (e.g. focus on formal value chain actors on pp. 16-17; figures on formal value chain on pp. 68-69). However, many low income farmers and consumers depend on the informal market for their food sales and purchases. It may add value to the report if the informal sector would also addressed.

The report highlights several rather “high technology” solutions (e.g. on page 15 and page 92) such as food fortification, while there is relatively less focus on technology that is more accessible to smallholders and low income farmers, such as improved varieties of local crops that are more nutritious, developed for example through participatory plant breeding approaches.

Gender considerations and the role of women could be emphasized stronger throughout the report, and in particular in relation to the economic and socio-cultural drivers described on pp. 100-101, given the important role women play in producing, selling, buying and preparing food.



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45. Florence Macherez, Animal Task Force European Public Private Platform, Belgium

We are pleased to contribute by sending the draft White Paper of the Animal Task Force that will be published next Dec 19. This consists in a strategic research and innovation agenda for a sustainable livestock sector in Europe, including suggested priorities for research for Horizon2020 2018-2020 Work Programme, to enhance innovation and sustainability in the livestock production sector of Europe's food supply chains.

It includes an introduction summarizing i) current challenges faced by animal productions in Europe, ii) the livestock's role in realising a sustainable circular bio-economy for Europe and iii) the importance of supporting innovation, sustainability and competitiveness in Europe's livestock sector.

Please find attached short and full versions.

Attachment ‘Animal Task Force Second White paper’:

http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/ATF%20white%20paper%20Short%20version%20V7_0.docx

46. Judith Benedics, Federal Ministry of Health and Women’s Affairs, Austria

The report was reviewed with high interest. It is very well structured and informative. It is not too technical or to simple.

Nevertheless the Austrian Federal Ministry of Health and Womens´s Affairs (Departement III/8) wants to highlight some very important points which need further consideration.

The links between environment and nutrition are of high importance for present and future measures which try to improve nutritional status and behaviour. For this reasons it would be important that this report does contains more information and scientific data about:

Marketing to children and the different approaches how it could be limited

The role of producers and enterprises. They also have to contribute to a healthy nutrition in the context of under AND overnutrition. Different approaches of how they could contribute (e.g reformulation initiatives, stop marketing to children respective stop marketing for HFSS) should be highlighted.

The role of environments which contribute to healthy and adequate nutrition (e.g healthy school lunches, food in hospitals and retirement homes).

This report contains of course a big section about undernutrition. Austria highly recommends to also focus on mechanisms which contribute to undernutrition in western countries. E.g inadequate nutrition in hospitals and retirement homes.





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47. Barrie Bain, International Fertilizer Association (IFA), FranceThe draft report provides an excellent starting point and is comprehensive in it's scope. we have made detailed comments and suggestions in the attachment

The importance of increasing yield both quantitatively in kilograms (or calories) and qualitatively (in nutritious value, providing not just calories but essential proteins, micronutrients and vitamins) deserves more attention. Supporting farmers to encourage implementation of innovations to improve current agricultural production systems is imperative.

Providing farmers with access to quality inputs, in particular fertilizers, and the knowledge to apply them efficiently and effectively over a long period of time is the first step enhancing economic and environmental sustainable food security.

Submission on HLPE Draft V0 by International Fertilizer Association


A complete response to these questions is premature. The V0 draft is still missing an important part: the summary and recommendations, where the final analyses of ways food systems (and policy) influence dietary pattern should be consolidated. Consumers are well considered. Definitions of sustainable diets and food systems are provided. However, specific sustainability issues are not listed, though they are implicitly included in some of the case studies. The conceptual framework specifies the issues as: economic and environmental sustainability, but does not define the terms. Framing of economic and environmental sustainability is needed; outcomes towards economic sustainability may not always align with environmental sustainability and vice versa. Efficient policies are highlighted in the case studies, but a conclusion is lacking on what are the main constituents of an effective policy or program, or what policies have been shown not to be effective and why not.


The overall structure of the document is well designed to identify “what is not working, what is working and where there is potential to improve.”

Chapter 2 describes the triple burden of malnutrition. The link between malnutrition and food systems could be more strongly emphasized by structuring chapter 4 to reflect the potential of sustainable food systems to influence outcomes to lower these burdens: working up from the nutritional outcomes.




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The primary production of food is - per definition - agricultural production. Agriculture and agribusiness have been closely associated with culture, trade and politics, from their first appearance in human societies. The conceptual framework identifies agriculture as first actor in the food value chain. The inherent connectivity of agriculture within the food environment needs more emphasis in the next version of this report.

The draft report contains two references on the need for innovation and research towards sustainable agricultural intensification, but lacks emphasis of the fact that food security for all is within reach, but needs strong economic growth, global expansion of food supplies by about 70 percent, and relatively high production growth in many developing countries (FAO 2009: how to feed the world in 2050 but please also consider Green et al. 2016 (Planting seeds for the future of food, Journal of the Science of Food and Agriculture 2016 Jun;96(8):2932. doi: 10.1002/ jsfa.7734).

The importance of increasing yield both quantitatively in kilograms (or calories) and qualitatively (in nutritious value, providing not just calories but essential proteins, micronutrients and vitamins) deserves more attention. Supporting farmers to encourage implementation of innovations to improve current agricultural production systems is imperative.

Harvest security is the base for food security. There are many factors beyond the control of the farmer that are a threat to harvest security: for instance the climate, pests, diseases or war. However, the farmer does have control over how he treats his soil and the way he feeds his plants. As part of the daily job, support of farmers is integrated in agribusiness. This support improves livelihoods of small, marginal farmers through the targeted production and dissemination of locally relevant agricultural information. Supporting farmers to adopt optimal cropping practices helps to makes the crop more resilient to adverse climate conditions, and increases the farmers yield both in quantity and in quality. Balanced plant nutrition contributes to food and nutrition security by:

Providing nutrients for plants;

Preventing soils from becoming depleted of nutrients and replenishing soils that have become nutrient depleted;

Increasing yields and thus enabling food production to keep pace with population and income growth and the hunger reduction objectives

Maximizing agricultural productivity without increasing land surface use;

Addressing nutrient deficiencies in people that undermine both public health and economic growth.

Providing farmers with access to quality inputs, in particular fertilizers, and the knowledge to apply them efficiently and effectively over a long period of time is the first step enhancing economic and environmental sustainable food security.

The following sources provide a rich source of case studies and examples from all parts of the world:

IFA Farmer Stewardship

IFA Nutrient Stewardship

IFA Food and Nutrition Security

IFA Providing micronutrients to crops to improve human health



http://www.fertilizer.org/ItemDetail?iProductCode=9577Pdf&Category=AGRI&WebsiteKey=411e9724-4bda-422f-abfc-8152ed74f306

http://www.fertilizer.org/FoodNutritionSecurity

http://www.fertilizer.org/NutrientStewardship

http://www.fertilizer.org/En/Stewardship/Farmer_stewardship/Farmer_stewardship_home_page.aspx?WebsiteKey=411e9724-4bda-422f-abfc-8152ed74f306&New_ContentCollectionOrganizerCommon_2=3#New_ContentCollectionOrganizerCommon_2

http://onlinelibrary.wiley.com/doi/10.1002/jsfa.7554/abstract

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IFA Partnerships to develop macro and micro nutrient fertilization

HarvestZinc and iodine fertilizer program


Section 4.2.1 (looking to the future; technology) should include a section on finding a balance in inputs and outputs in the primary agricultural production of food: to increase yields, agricultural

a. on what exactly is meant by the term has considerable impact on development of policy and on all the factors currently mentioned in the box ”Food Environments” of Figure 1.

Controversies:

- Food technology:

On-farm or close to farm processing of food to make it more nutritious (e.g. culturally preserved fermentation techniques to increase availability of iron or zinc from grains), versus Technology increasing nutrient content of food on an industrial scale or prodution of functional foods.

- Supplementation, providing vitamins and minerals as dietary supplement in the form of tablets, capsules, powders:

Provided by goverments input is required, and technology is needed to ensure sustainable agricultural intensification.

The same section also includes a paragraph on food technology and fortification. The controversies around fortification are often a result of misunderstanding definitions behind the terminology.

A dedicated section to indentify controversies associated with the terms food technology, supplement, fortifcation, biofortification is needed as:

a. These are key elements in any policy or programme to improve micronutrient status. Good understanding or NGOs during famine or emergency situations, versus Required purchase by the consumer.

- Fortification:

a. Food fortification, adding micronutrients to foods or carriers like salt, oil:

Voluntary: Consumer has a choice in buying fortified food,

versus Mandatory: For example mandatory addition of iron to flour or iodine to salt, to increase micronutrient status of the whole population.

b. Biofortification, producing staple food and vegetables with a higher content of micronutrients or vitamins than are currently available:

Genetic biofortification: Breeding crops with a higher potential to accumulate essential mineral elements (zinc, iron) or vitamins (Vitamin-A), versus Agronomic biofortification: Enabling crops to accumulate more mineral elements (simulteneously also improving yield) by applying micronutrient containing fertilizers.



http://www.harvestzinc.org/

http://www.fertilizer.org/imis20/images/Library_Downloads/IFA_Infographic_POSTER_2_MAP.pdf?WebsiteKey=411e9724-4bda-422f-abfc-8152ed74f306&=404%3Bhttp%3A%2F%2Fwww.fertilizer.org%3A80%2Fen%2Fimages%2FLibrary_Downloads%2FIFA_Infographic_POSTER_2_MAP.pdf

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To build the conceptual framework defining food systems is indeed essential as stated in paragraph 1.3 (Conclusions on typologies of food systems). “… typologies of food systems that could be constructed for diets and nutrition. This report will focus squarely on this conceptual framework as its guide to detail what is not working, what is working and where there is potential to improve.” As this is going to be further developed, it is hard to judge what is missing or in need of adaptation at this moment. IFPRI, 2015 is cited but the document it refers to is not mentioned in the reference section. I base the feedback below on the tentative descriptions in table 2. This lacks indicators that would allow to qualify food system as to their potential to prevent micronutrient deficiencies: the third aspect in the triple burden of malnutrition. How can food systems be monitored for their ability to ensure an optimal intake of micronutrients and vitamins from the daily diet, and what are the drivers that affect this aspect of food systems ?


The reader is impressed with complexity and multiplicity of the subject at hand. The report focus is on the developing countries. Issues in developed countries, in particular in respect of micronutrient deficiencies are considered less. As food systems for developing and developed countries are very different, also the approach to micronutrient deficiency will have different aspects for both. 4


Chapter 4 needs strengthening: not necessarily by increase in volume but by restructuring to provide the reader with more guidance to differentiate the main points from the details. In 4.2.2 more attention could be given to agricultural policy and innovations that will enable primary agricultural production to become not only more sustainable but also more nutritionsensitive. The conclusions 4.3 are very general and would benefit of a concise summary of main points made in the previous paragraphs of chapter 4.

9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in 5 different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich the report and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win outcomes in terms of addressing the different dimensions of diets for FSN?

See references provided under question 4.


It is not too technical, the topic is very complex and the HLPE has done a very good job in collecting the data and designing a structure that provides a place for all the elements in the food system.

12. Are there any major omissions or gaps in the report? Are topics under-or overrepresented in relation to their importance?

No major gaps or omissions other than what has been identified above. The HLPE are best placed - using their combined expertise - to judge on the relative importance of the different topics. HLPE



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might consider to consult academic experts in agronomy, who would be well placed to provide an overview on current state of research and innovation in sustainable production intensification.

48. Henk Westhoek, PBL Netherlands Environmental Assessment Agency, Netherlands

Dear Panel,

Please find my personal comments (not from my institute) below. I will be happy to clarify these if needed. And if needed, I will also be willing to contribute more to a next draft.

General

This is a very important and timely report. It is very relevant to assess present (and past and future) consumption patterns in the light of ‘food systems’ and the food environment. This having said, the report could gain strength by providing more evidence, be more conclusive, while avoiding to be biased. Please find below some quick comments, as unfortunately I did have time for a full review.

The report could even stress more that there are large differences in types of food systems, with huge implications for nutrition. While the notion of ‘food environment’ is important, it should be noted that there is a large difference between the implications of what a food environment means certain rural areas in developing countries where food production sometimes is largely based on subsistence farming, compared to an urban environment. And within an urban environment, there is a large difference between richer and poorer countries, and also between richer and poorer neighborhoods. In case of regions with are still largely based on traditional food systems, the notion and large body of work around ‘farming systems’ might be of larger relevance.

While the report at one hand would need to take into account this notion of large differences, on the other hand the report cannot give ready answers for all situations. It is therefore more important to provide the readers/users of the report with some kind of relevant framework how to analyze their own situation (local or national food system), and identify potential points of intervention, than to try to cover everything. See for example the draft framework in the UNEP IRP report on Food systems and natural resources (Chapter 8).

1. Are those major objective(s) clearly reflected in the V0 draft?

I do not see yet a clean line of (evidence based) argument yet how food systems (and actors within food systems) influence dietary patterns. I would say that two lines of thought are important in doing so:

1) to acknowledge that food systems vary widely globally, implying that the analysis should also be specific per type of food system / region and 2) assess the business logic of actors within food systems (taking into account the diversity of food systems).

The sustainability issues are treated only quite briefly. For the sustainability / resource aspect, I would suggest to use the UNEP-IRP report Food systems and natural resources (2016).

I would be careful to explore to the question “what an ideal food system would look like” (p. 21, l. 15). The type of food system is largely determined by societal developments, and is hard to change. I



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would suggest to look within current food systems how nutritional (and environmental) outcomes can be improved.

I would suggest to put much more emphasis on food processors, retailers and food service. What is their business logic? A very important aspect is the processing of food: in general, the industry earns more many with more processed foods, which has led to a vast increase in the consumption of ultra-processed foods, starting in richer countries, now also in middle-income countries and more and more in LIC. The high consumption rates of processed and ultra-processed foods has an enormous impact on both human health as well as on the environment. In many cases (oil crops, cereals, etc) the best parts of the crop (minerals, proteins, fibers) are fed to animals, and human only consume the carbohydrates (oil, white bread and rice, beer, sugar, refined juices etc.).


Chapter 2 (The Burden) is framed quite negatively. Maybe this could be framed more neutral, without of course understating this burden. But for many people the nutritional status has improved over the last 20-40 years. While large famines were more a less normal in the previous centuries, there are now many regions in the world were food security is not really an issue anymore.


No, I would suggest to put the idea of ‘food systems’ central in the report, with food environment being an important aspect. Maybe the conceptual framework of the UNEP IRP could be combined with the present framework.

Some other points:

In chapter 2 other food related NCDs seem to be largely missing, as CVDs but also colon cancer and other diseases (for example alcohol related).

Alcoholic beverages are largely missing: what is their effect on health, family incomes etc? Take for example the aggressive marketing of beer, and high pressure in some groups to drink beer in many countries.

Paragraph 3.2 needs more elaboration

Future developments seem to be a bit scattered over the report.

The food service sector is largely missing (restaurants (from large chains to street vendors), caterers, food in institutions as schools, hospitals, work, prisons etc.). In many countries, the out-of-home consumption is more than 50%.

Typologies of food systems: see the UNEP IRP report. On Food systems. It is also important to note that food systems are interlinked, by trade, cultural exchange etc.

The trade section seems to be a bit biased. Trade is important for countries with limited production potential, it can help to mitigate production shocks, it can help to diversify diets etc.



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The food system is depicted (see for example page 69) as a linear one-way system, while in reality it is a two-way system, with many feedback loops.

With kind regards,

Henk Westhoek

Program manager Agriculture and Food

49. Hélène Delisle, Université de Montréal, CanadaThere have been several relevant and competent comments. My suggestion would be to follow the actions as recommended in the excellent and recent article by Haddad et al in Nature on the needed changes in food systems.

Everything is there, except perhaps that emphasis on capacity building is needed: nutrition capacity for food system people and food system capacity for nutrition people.

50. Zoltan Kalman, Permanent Representation of Hungary to FAO, Italy

Dear HLPE Members,

Please find below and in attachment our comments for your kind consideration.

Best regards,

Zoltan Kalman

The issue of food security and nutrition is very important. This is why the request of CFS to prepare a report on Nutrition and Food systems is timely and appropriate. As various recent international events concluded, the food system is broken, it is mentioned also in page 23 of the zero draft, and it needs to be urgently fixed. A paradigm shift or a new way of thinking is required, to take seriously into consideration all the 3 dimensions of sustainability, because the “business as usual” scenario would further worsen the situation.

It is highly appreciated that a zero draft is provided for first comments also through e-consultation.

The zero draft is well structured; its content is sufficiently comprehensive, although there are areas which require more specific attention or need to be supplemented.

First of all, a clearer reference to the Agenda 2030 and to the interlinkages among SDGs should be the applicable context in which the topic of nutrition and food systems is addressed. Some examples to illustrate this:

- In page 58 a “business as usual” scenario is admittedly applied to consider population growth and calculate need to increase food production. (“Business-as-usual scenarios of population growth and food consumption patterns indicate that agricultural production will need to increase by 70 percent



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by 2050 to meet global demand for food.”) A comprehensive report should not ignore the impacts of developments in achieving SDGs. Experiences show and it should be reflected in the Report that economic development, reduced inequalities, better education, etc. are important factors contributing to slowing down the pace of population growth. On the estimated need to increase food production, reference could be made to some recent studies and to the joint FAO-UNIDO event some months ago, at Director-General level, where around 20% increase was projected as a result of achieving SDGs (including reduction of food losses and waste). Therefore, projections of needs to increase food production should be revised and lowered in the Report accordingly. It would be a mistake and a wrong message if developments in SDG implementation were ignored.- Although the main focus is nutrition and food system (referring to Goal 2. End hunger, achieve food security and improved nutrition), the Report should have references to the impacts of other SDGs as well, such as Goal 1. Ending poverty, Goal 3. Ensure healthy lives, Goal 8. Inclusive and sustainable economic growth, decent work for all. It is obvious that it is not possible to end hunger and to achieve improved nutrition without addressing the root causes: poverty, inequalities, healthy lives, etc. which in turn, require decent employment. This seems very much simplified, but the concept would merit a careful elaboration and reflection in the Report.The draft provides a comprehensive overview on the various drivers of food systems, including political and economic drivers. However, under this chapter the implication of adequate, nutritious and culturally acceptable food as a human right should be betterintegrated into the Report. In particular, it should be better defined the obligations and responsibilities of states or other actors (for example food industry). Furthermore, the Voluntary Guidelines on the Right to Food and the Voluntary Guidelines on the Responsible Governance of Tenure should be considered as basic references in this regard.

Among the political and economic drivers the role of food prices is analysed from various points of views, including the impacts of price volatilities on food security and nutrition. Not sufficiently addressed, however, the impacts of low food prices on certain segments of the population in some countries. More specifically, there is no reference to the sometimes existing link between low prices and low quality of food. It is a matter of fact that, as an immediate impact, low food prices are advantageous for the poor people. On the other hand, it needs to be considered that low priced food generally means less nutritious, lower qualityfood. This might have serious health impacts, worsening the food security and nutrition situation of affected population. As the UN Special Representative on the Right to Food properly said, “cheap (junk) food products are violating the human right to healthy food”. Low food price policies, in an indirect way, can lead to increased financial burden for thepublic health care. These (and other) externalities should be taken into due consideration and the Report should draw attention to the need for calculating the real costs of food and for more transparency in the whole food value chain. The Report could also refer to the positive social impacts of decent food prices paid to farmers. Furthermore, higher food priceswould help recognising the real value of food and having more respect for it, providing incentives for reducing food waste as well.

Another economic driver could be included as well, namely the profit-orientation. It is a matter of fact that in market economies profit is the main driving force. It is natural that farmers and all stakeholders of the food value chain are and should be interested inmaximizing their profits. However, it is the responsibility of national governments andregional economic integrations to create the appropriate economic environment to provide (positive and negative)



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incentives. To put it in a simple way, such environment should make food producers interested in fully respecting the environmental and social dimensions of sustainability and in producing healthy food at affordable prices. (Affordability does not necessarily mean cheap food but rather mean decent employment and wages. This is again an example of interlinkages of SDGs.) As part of this “appropriate economic environment” measures such as junk food taxes, bans for advertising unhealthy food for children, promotion of healthy, organic and local food could be recommended for consideration. Local food production and consumption are important elements of a renewed food system. Short food supply chains can assure full transparency and offer a win-win-win-win situation: good for producers (stable market, higher prices), advantageous for consumers (healthy food, affordable prices), beneficial for the environment (zero km, less use of chemicals) and for the whole society (healthier population, more local employment).

In the process described above the international organisations (UN and others) should have a role as well, including through providing appropriate policy advice.

Finally, it is very much appreciated that documents and reports on nutrition and diets that have recently been released (such as the GloPan Foresight Report,) are being kept in consideration. It would be a value added if related documents prepared by the UNSCN, FAO, IFAD, WFP and WHO or others are considered as well.

More and more specific comments might be submitted at a later stage.

51. Jennifer Dias, Brooke, United KingdomDear Panel,

We welcome the first draft of this important report on nutrition and food systems and are grateful for the opportunity to participate in this consultation.

Please find our contributions attached.

With best regards,

Jennifer Dias,

UN Advocacy Manager, Brooke

BROOKE’S SUBMISSION TO THE HIGH LEVEL PANEL OF EXPERTS ON THE FUTURE REPORT ON NUTRITION AND FOOD SYSTEMS

December 2016

General Comments

1. Brooke congratulates the HLPE project team for this first draft of this very important report on nutrition and food systems, which will provide a critical evidence base for CFS policy convergence on nutrition-focused recommendations which have the potential to make substantial improvement for



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the one in three people suffering from malnourishment globally, as we work collectively to meet the Sustainable Development Goal (SDG) commitment to end all forms of malnutrition by 2030.

2. Brooke would like to take this opportunity to offer its perspective as an international NGO with over 80 years of experience operating in smallholder and pastoralist food production systems across Africa, Asia, Latin America and the Middle East, which seeks to support sustainable farming and food production practices which provide the best outcomes for people, animals and the environment.

Specific Comments

Sustainable and Healthy Diets

3. Brooke welcomes the focus on sustainable and healthy diets, which are culturally acceptable, accessible, fair and affordable, recognising the need for diverse solutions which take account of the broad range of economic, cultural and situational circumstances which people live in. As noted within the policy recommendations on connecting smallholders to markets endorsed at CFS43, smallholders produce 70% the world’s food, but many continue to face food insecurity and malnutrition themselves. Therefore, a focus on smallholder food systems, their contribution to nutrition and the barriers to food security and nutrition amongst smallholders would be particularly valuable.

4. In particular, we welcome the recognition of the need to protect and respect biodiversity and ecosystems, and ensure the optimal use of natural resources. In light of the recently endorsed CFS policy recommendations on the role of livestock in sustainable agriculture and the recognition of the crucial role which livestock plays within food security and nutrition, we would recommend that animal and livestock resources are included within the report’s considerations of the diets which best protect ecosystems, biodiversity and natural resources (and within the outcomes it is noted will be developed on page 23 of the report).

5. There is an emphasis within the report on new technologies and innovation. While we recognise the hugely valuable contribution that technology and innovation can make to nutritional outcomes, we feel there is a need to redress the balance, so that traditional farming and food production practices which have evolved over millennia and contribute greatly to food security and nutrition are given equal or greater attention and afforded the recognition and protection they deserve. We would also suggest that a deeper understanding of the traditional practices which contribute to sustainable and healthy diets should be identified as a key area for future research and knowledge building within the report.

Food System Typology

6. We note that the food system typologies on which the report’s recommendations will be based was not available in time for the release of the zero draft report. Therefore, our comments here relate to the future development of that typology. While it is important for governments to be able to identify and categorise the different food systems within their respective countries in order to develop appropriate policy and legislation, we would caution against the categorisation of countries by food system-type, due to the wide diversity of food systems found within each country based on the different livelihoods strategies employed by different communities.

Social Movements and Conflicts of Interest



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7. We are pleased to note that these sections will be elaborated and developed respectively in the future report. The inherent tension and conflicts between different food production systems must be considered and addressed if diets are to be sustainable. Due to its capacity to undermine traditional sustainable smallholder, pastoralist and agroecological food production systems, the impact of pursuing sustainable and healthy diets through industrial agriculture deserves special attention, as does an assessment and comparison of the nutritional value of food produced through the different systems.

8. While the CFS Civil Society Mechanism (CSM),which we are pleased to be a member of, and the ICN2/Nutrition Civil Society Group represent crucial mechanisms for the coordination of a large number and very broad range of civil society actors, including national and international NGOs and social movements (particularly in the case of CSM), these should not be considered social movements in themselves and a more nuanced and in-depth reflection on social movements and their contribution to the nutrition agenda would be welcomed.

Further Consultation

9. We are grateful for the opportunity to feed into this open consultation on the zero draft report. While we recognise that it would go against normal protocol, as fundamental sections of the report including the recommendations, food system typologies and conflict of interest section are not yet available, and other important areas such as the indicators are less developed than would usually be expected in the zero draft report, it may be appropriate to consider a further consultation once these areas are at a more advanced stage of development, before the finalisation of the report.

10. We have also submitted our general feedback for inclusion within the CSM Submission.

Thank you.

52. Anita Utheim, Ministry of Trade, Industry and Fisheries, Norway

We would like to thank the HLPE for the opportunity to comment on this draft report. The draft is comprehensive and covers many important issues and aspects.

We find it essential that the important role of fish in food security and nutrition is adequately taken on board. Both from a health and sustainability perspective an increased consumption of sustainable produced fish is desirable. This work on nutrition and food systems should include reference to relevant past work of the CFS High Level Panel of Experts (HLPE). However reference to the only HLPE report that has been focusing on sustainable fisheries and aquaculture is missing. Consumption of fish and its addition to the diets, especially of low income populations and vulnerable groups, offers important means for improving nutrition. According to the CFS HLPE report: Sustainable fisheries and aquaculture for food security and nutrition (2014), the qualities of fish are not fully recognized in global food security and nutrition, even though fish can provide important nutrients to vulnerable groups such as pregnant and lactating women and children and poor people. Reference is also made to the recommendations in the CFS Global Strategic Framework for Food Security and Nutrition (GSF) which is: to give to fish the position it deserves in food security and nutrition and to make fish a visible, integral element in food security and nutrition strategies, policies and programmes.



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Fish in aquaculture systems are efficient converters of feed into protein. Aquatic animal production systems also have a lower carbon footprint per kg output compared with terrestrial animal production systems Nitrogen and phosphorous emissions from aquaculture production systems are much lower compared with beef and pork. (HLPE report: Sustainable fisheries and aquaculture for food security and nutrition, 2014). Looking at the feed conversion rate, fish farming undoubtedly is the most effective production regardless of fish species. In this aspect aquaculture is a great contributor to global food security and nutrition. The draft report should reflect this.

We believe that responsible fisheries and aquaculture development will be key in achieving the 2030 Agenda. These sectors are important for several SDGs. As stated I the report from Rio+20 outcome document "The future we want": ‘Everyone has the right to have access to safe, sufficient and nutritious food’, and: ‘Healthy marine ecosystems, sustainable fisheries and sustainable aquaculture have a crucial role for food security and nutrition and in providing for the livelihoods of millions of people.’ Hence we encourage you to make the role of sustainable fisheries and aquaculture for food security and nutrition more visible in this report.

53. Rafaela Batista, Ministry of Health, BrazilHereby I send attached the commentaries of the Ministry of Health on the Draft V0 of Nutrition and Food Systems.

Best regards,

Rafaela Batista

Office for Advisory on International AffairsMinistry of Health of Brazil

NUTRITION AND FOOD SYSTEMS 5 6 V0 DRAFT REPORT

OVERVIEW:

The document discusses food systems and nutrition through a problematization of the impact of current food systems and their consequences, especially on the multiple forms of malnutrition. Therefore, the report presents two propositions: 1) to analyze how food systems influence food aspects and nutritional outcomes and 2) to highlight public policies and effective programs that shape food systems in order to contribute to better nutrition and guarantee the right to adequate and healthy food in a sustainable manner.

The report is divided into 4 chapters:

1) Conceptual framework of food systems for food and nutrition:

Brings the elements comprising food systems:



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Main components: environmental and biophysical factors, innovation and research, political and economic factors, sociocultural and demographic aspects.

Activities and actors: production, storage, distribution, processing and advertising. Food environments: food access, affordability, acceptability, information,

composition, quality and safety. Brings the characteristics of a healthy diet: aligned with the Dietary Guidelines for the

Brazilian Population.

2) General framework on all forms of malnutrition:

Raises the issue of stunting, overweight, micronutrient deficiencies and their socioeconomic impact.

3) Dietary changes and their drivers:

Debates on changing diets and its relation with income, age group and gender. Presents the components regarding food systems and its relation with challenges and

nutrition for food and nutrition: Biophysical and environmental drivers: climate and ecosystems. Innovation and research drivers: technology (pros and cons), infrastructure and

social movements

We believe it is important to emphasize the impact of strategies carried out by some social movements. Direct and more immediate nutritional interventions (based on the distribution of infant formulas, fortified foods and micronutrient supplements) are often dissociated from local eating habits and culture, being provided by the companies that manufacture these products, that is, with direct conflict of interests with the interventions and possible alternatives, characterizing, also, the absence of actions of a more structuring character that guarantee the sustainability of the impacts of the interventions and the autonomy, specificity and sovereignty of the countries in policy development. In the field of health, the National Food and Nutrition Security Plan and the Dietary Guidelines for the Brazilian Population are based on the right to food for the definition of guidelines for the promotion of adequate and healthy food, prevention and control of nutritional problems and other issues in the food and nutrition agenda. Still, the concept of food sovereignty argues that each nation has the right to define policies that guarantee the Food and Nutritional Security of its population, including the right to preserve traditional production practices and food practices. In addition, there is the recognition that such a process must take place on a sustainable basis from an environmental, economic and social point of view. In view of Brazil's successful experience in reducing hunger and malnutrition, strengthening of national systems based on a rights-based approach, including human rights to health, education, land, water and adequate and healthy food, based on the principles of universality, integrality, equity and social participation. The approach seeks to guarantee greater autonomy and sovereignty to national governments and sustainability and continuity of policies, as well as adequate to the epidemiological, historical and cultural realities of populations.



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Political and economic drivers: income, food prices, trade, globalization, food policies and agriculture subsidies.

Sociocultural drivers: culture, religions and gender. Demographic drivers: population pressure, urbanization, migration and conflicts.

Overall conclusion: Changes in diet over time have been positive as well as negative – as the consumption of healthy foods have been increasing, the consumption of ultra-processed food is increased on a larger scale. These data show a new methodology for other public policies on food, nutrition and agriculture, but also minimum standards, social norms and leadership.

4) Programs and public policies on food and nutrition based on the discussions of food systems:

Case studies presenting food and nutrition from the food systems perspectives for each component (environmental and biophysical factors, innovation and research, political and economic factors, sociocultural and demographic aspects).

How Brazil was represented in the document: Food and Nutrition Security governance; Farm-to-school programs.

Examples from other countries that could have also come from Brazil: detailed in question no. 9

Conditional cash transfers – Mexico case study; Aspects related to family farm production; Fortification of flour with folic acid and prevention of neural tube defects – Canada

and USA case study; Food fortification – Salt iodization could be mentioned; Strategies to reduce salt intake (reduction of sodium in processed foods) – UK case

study.

OVERALL COMMENTS:

Food processing: in the report, the processing of foods is considered advantageous due to food durability, food safety, health safety and shelf life.

Although the document related the importance of in natura foods, it would be interesting to highlight the aspects of the Dietary Guidelines for the Brazilian Population.

Biofortification: the document presents biofortification of staple crops as a strategy to increase the consumption of micronutrients.

It might be interesting to take some consideration in this regard, as there is a need for cautious studies on the benefits of biofortification.



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Fortification: is considered an important food technology tool to prevent micronutrient deficiency.

It is important to emphasize the importance of fortification, but along to the promotion of healthy food, considering the habits, culture and food sovereignty of the countries.

The document presents a section of the public-private partnership, and also a topic of conflict of interest (still in development).

It may be interesting to mention strategies for promoting adequate and healthy food as the main action to minimize the current scenario of food and nutritional transition and other strategies (fortification, supplementation, and reformulation of foods) as important and necessary points.

COVER Letter from the HLPE to this V0 Consultation

1. The purpose of this report is to analyze the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft?

Answer: Yes, the major objectives are reflected in the V0 draft.


Answer: Yes, the document is adequate.


Answer: We agree with the conceptual framework presents. The box “food environment” can be allocated in the center of the framework.



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Answer: Yes, they are.


Answer: Yes, there are no remaining gaps.


Answer: No, we are not.


Answer: Yes, it does.


Answer: When the "Conflicts of interest" section is elaborated it should highlight the public-private partnerships with caution and based on the human right to adequate and healthy food principles.


Answer:

Conditional cash transfer:



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In Brazil, the Bolsa Família Program is a federal conditional cash transfer program, aimed at families living in poverty and extreme poverty, in which the receipt of the aid is linked to the fulfillment of commitments assumed by the families and by the Government in the areas of health, education and social assistance. The health conditionalities of the program, including the monitoring of immunization, growth and development of children under 7 years of age and prenatal care of pregnant women and puerperium, reinforce the right to health of beneficiary families and assist in the rupture of the intergenerational cycle of poverty, which potentially foster the fight against future poverty, by investing in the development of human capital. The monitoring of health conditionalities is carried out twice a year (two semesters, two periods). In 2016, the first term of the program was able to accompany 8,480,299 families in health, encompassing 18,823,639 individuals with individualized follow-up, 5,256,289 children under 7 years old, 371,350 pregnant women and 13,567,350 women. Research shows important contributions from the conditional cash transfer program to health and nutrition conditions of those enrolled in the program, such as reducing child mortality in children under five years of age, especially from poverty-related diseases, and reducing chronic malnutrition and the risk of overweight among children.

Fortification of flour with folic acid and prevention of neural tube defects:

In Brazil, fortification of wheat and maize flour was instituted in 2002 in which was determined the mandatory addition of 4.2 mg of iron and 150 μg of folic acid in wheat and corn flours, with the aim of reducing the prevalence of anemia and prevent the occurrence of neural tube defects. Folic acid deficiency may have hematological consequences, complications during pregnancy and other congenital formations. The World Atlas for Birth Defects published by the WHO in 2003 showed variable prevalence in neural tube defects for the different countries in the period of 1993-1998. The prevalence of anencephaly in Brazil was 0.862: 1000 born and the spina bifida was 1.139: 1000 born. Evidence from a retrospective study that sought to determine the association of the mandatory addition of folic acid to flour and changes in the prevalence of neural tube defects in 19 million live births and about 195 thousand stillbirths showed a 30% reduction in the prevalence of neural tube defects (0.79 per 1000 births in the pre-fortification period and 0.55 per 1000 births in the post-fortification period). The national findings corroborate previous research, including a meta-analysis performed with 8 population databases that found a 46% reduction in the prevalence of neural tube defects due to the fortification of flours and other foods.

Sources:

Santos et al. (2016). Prevention of neural tube defects by the fortification of flour with folic acid: a population-based retrospective study in Brazil. Bull World Health Organ; 94:22–29.

Blencowe H, Cousens S, Modell B, Lawn J. Folic acid to reduce neonatal mortality from neural tube disorders. Int J Epidemiol. 2010 Apr;39 Suppl 1: i110–21.

Food fortification:

Since the 1950s, it is mandatory the iodization of all salt intended for human consumption. At that time, approximately 20% of the population had Iodine Deficiency Disorder (IDD). Thus, in order to reduce this high prevalence, universal iodination of salt was adopted, and the salt iodination range must be monitored and adequate according to salt consumption by the population. After



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approximately six decades of intervention, there was a reduction in the prevalence of IDD in Brazil (20.7% in 1955, 14.1% in 1974, 1.3% in 1994, and 1.4% in 2000). The Program for Combating Iodine Deficiency Disorders in Brazil – Pró-Iodo, is one of the most successful actions in the fight against micronutrient deficiency disorders and has been praised by the international organisms for its results obtained in the elimination of the endemic goiter in the country. Among other actions, the universal iodination of salt for human consumption and the monitoring and inspection of the saline industry are the main responsible for the success of the program.

Strategies to reduce salt intake (sodium reduce in processed food):

As principais fontes de sódio na alimentação são o sal adicionado no preparo e consumo dos alimentos e o sódio presente nos alimentos prontos, como os alimentos processados e aqueles consumidos fora do domicílio fazendo-se necessárias diferentes abordagens para alcançar a redução pretendida, que incluem a educação e informação à população em relação ao uso racional do sal e a escolhas alimentares mais saudáveis e ações voltadas para o setor produtivo, no sentido de ofertar produtos com melhor perfil nutricional. O Plano Nacional de Redução do Sódio em Alimentos Processados compõe o Plano de Redução do Consumo de Sal pela População Brasileira e traz que a redução do teor de sódio em alimentos processados deverá ocorrer de maneira gradual, voluntária e por meio de metas bianuais, considerando o desenvolvimento de novas tecnologias, formulações e a adaptação do paladar dos consumidores. O referido plano inclui acordos voluntários com as entidades do setor produtivo de alimentos com metas para a redução dos teores de sódio em diferentes categorias de alimentos, selecionadas com base na sua contribuição para a ingestão de sódio pela população, definida por meio de inquéritos populacionais de alimentação e nutrição (massas instantâneas, pães de forma, bisnaguinhas, pão francês, caldos e temperos, laticínios, biscoitos, margarinas, bolos, maionese, salgadinhos, batatas fritas, derivados de cereais, sopas, produtos cárneos e produtos lácteos). O monitoramento dos acordos tem mostrado mais de 90% de cumprimento das metas pactuadas pelo rol de produtos incluídos no acordo. Destaca-se que foi observada redução do teor médio de sódio em todas as categorias analisadas. Por fim, o monitoramento mostra resultados positivos e fortalecedores da estratégia para redução do consumo de sódio pela população, fazendo do Brasil país de referência para esta agenda nas Américas, junto à Argentina e Canadá.

The Ministry of Health of Brazil has been working on different strategies to reduce the intake of salt / sodium by the Brazilian population, which is more than twice the World Health Organization recommendation (less than 5g / day by 2020). The main sources of sodium in food are the salt added in the preparation and consumption of food and the sodium present in ready-to-eat foods, such as processed foods and those consumed outside the home. Different approaches are necessary in order to achieve the desired reduction, including the provision of education and information to the population regarding the rational use of salt and healthier food choices; and actions directed to the productive sector, in the sense of offering products with better nutritional profile. The National Plan for the Reduction of Sodium in Processed Foods composes the Plan for Reduction of Salt Consumption by the Brazilian Population in which is presented that the reduction of the sodium



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content in processed foods should occur gradually, voluntarily and through biannual targets, considering the development of new technologies, formulations and adaptation of consumers' taste buds. The plan includes voluntary agreements with food industry entities with targets for the reduction of sodium levels in different food categories, selected based on their contribution to the population's sodium intake, as defined through population surveys (instant noodle, bread, broth and seasonings, dairy products, biscuits, margarine, cakes, mayonnaise, snacks, chips, cereal products, soups and meat products). The monitoring of these agreements has shown more than 90% of compliance with the targets agreed by the list of products included in the agreement. It is noteworthy that a reduction of the average sodium content was observed in all categories analyzed. Finally, monitoring shows positive results on the strategy for reducing the consumption of sodium by the population, making Brazil a reference country for this agenda in the Americas, with Argentina and Canada.


Answer: -


Answer: The report is not too technical or simplistic, nor the concepts are unclear.


Answer: Suggestions may be found in the overall comments at the beginning of this document.

54. Teresa Borelli, Bioversity International, ItalyDear HLPE Steering Committee,

Please find attached inputs and suggestions on the present V0 Draft.

Examples provided are largely from Bioversity International research and the experience of the Biodiversity for Food and Nutrition Project.

I apologize for the last minute submission and happy to provide further inputs in subsequent versions.

Kind regards,



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Teresa Borelli

HLPE e-consultation on the Draft V0 of the Report - Nutrition and food systems – Comments from the Biodiversity for Food and Nutrition Project, Bioversity International

[part of it to be possibly inserted in page 44 – lines 21,22,23 or 35 – or later in Chapter 4]

Personal, community-level and national food choices that opt for greater use of agricultural biodiversity can positively affect human nutrition by increasing the variety in people's diets and the greater intake of essential nutrients needed on a regular basis for good health (Powell at al. 2015)

The differences in macro- and micro-nutrient content are such that consuming one species, variety or breed over another can tip the scale between nutrient adequacy and deficiency in human diets (Burlingame et al. 2009; Lutaladio et al. 2010; Hunter et al. 2015). Some small indigenous fish species like mola (Amblypharyngodon mola) consumed in Bangladesh contain 115 times more Vitamin A per gram than silver carp (Hypophthalmichthys molitrix) (Roos et al. 2003), while studies on nutrient content of milk have shown that milk from yak and mithun (a large semi-domesticated bovine distributed in South Asia and China) contain more protein on average (6.5g per 100g of milk) than buffalo (4.0g per 100g) and cow milks (3.2g per 100g) (Medhammar et al. 2012). Despite this evidence, considerable gaps exist in reliable food composition data for many important local nutritious species.

At the landscape level, communities with increased access to wild and cultivated diversity in their immediate surroundings have a greater likelihood of meeting their nutritional requirements. Studies have shown that the higher the species richness the higher the diversity in people’s diets and the lower the frequency of diet-related illnesses. For instance, women living in villages in Sub-Saharan Africa with access to a larger variety of nutritious fruits and vegetables were four times less likely to be affected by iron deficiency (6.7% compared to 23.3% in villages with lower on-farm diversity) (Remans & Smukler, 2013). [this can also fit in page 70 – line 9]

Choices countries make on what food to grow can also affect the diversity of national food supplies and have downstream nutrition-related health impacts. Research conducted by Bioversity International and the Earth Institute, Columbia University (Remans et al. 2014) demonstrates that countries with diverse food production and less reliance on staple grains exhibit lower prevalence of acute and chronic child undernutrition (stunting, wasting and underweight0. Similar results were observed by Smith and Haddad (Smith and Haddad 2015) using data collected from 116 developing countries between 1970-2012, showing that a 10% increase in the diversity of the food supply leads to a 1.5% decrease in the prevalence of child stunting, making dietary diversity the factor with the greatest potential to reduce child stunting, followed by access to sanitation and women's education.

Whether or not individuals, communities and nations chose to make use of this diversity is largely a function of awareness of its importance and knowledge surrounding the use and preparation of available foods (or wild and cultivated agricultural biodiversity) (Termote et al. 2012).

[To be inserted in page 78 – lines 10]

Encouraging results from Bioversity International and other research show that malnutrition can be addressed using agricultural biodiversity (Allen et al. 2015; Powell et al. 2015; McDermott et al.



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2015). Fostering the conservation and promotion of agricultural biodiversity through national health and food security policies offers a potential solution to reintroduce greater variety in people’s diets, achieve improved nutrition-related health outcomes and reduce national health spending.

[page 73 as a substitute to the existing case study on Brazil]

As part of the Biodiversity for Food and Nutrition (BFN) Project supported by the Global Enviornment Facility, Brazil - where one in three children aged 5-9 is overweight- is using existing policy programmes as entry points for promoting agricultural biodiversity to diversify food systems for healthier diets.

As the national executing agency for BFN in Brazil, the Ministry of the Environment (MMA) has forged partnerships and relationships with many of the agencies and ministries involved in the Zero Hunger strategy launched in 2003 to eradicate hunger and poverty in the country. Representatives from strategic policy programmes such as the Food Acquisition Programme (PAA), the National School Feeding Programme (PNAE) and the National Food and Nutrition Policy (PNAN) are part of the Project’s national steering and executing committees, which helps create an enabling policy environment for the promotion of biodiversity for food and nutrition in Brazil.

As part of its commitment to the Convention on Biological Diversity (CBD), BFN Brazil has led the revision of the National Biodiversity Strategy and Action Plan (NBSAP), engaging 400 participants from institutions across the business, environment, academia, federal and state government sectors as well as indigenous peoples and traditional communities to define twenty National Biodiversity Targets for the period 2011-2020 closely linked to the Aichi Targets of the CBD. Some of the activities within the NBSAP now include the utilization of native plant species with actual or potential economic value as a successful measure of biodiversity conservation.

On 18 May 2016, after much advocacy and lobbying by the BFN project and Plants for the Future, Ordinance Nº 163 on Sociobiodiversity was published in the Union Official Journal of Brazil. Signed by the two respective ministers of Environment and Social Development, this Ordinance is a very important step in mainstreaming biodiversity for enhanced food and nutrition security as it clearly articulates what defines sociobiodiversity (read neglected and underutilized). "Brazilian Sociobiodiversity Native Food Species of Nutritional Value" are now officially defined and recognized. Sixty four of the BFN Project’s prioritized species appear on the list. These are the species which the BFN Project in Brazil is focusing on to improve the evidence base for their nutritional value with a view to integrating into relevant national policies and programmes. The Ordinance will contribute greatly to better understanding and dissemination of knowledge on these species, which will ultimately enhance the promotion and sustainable use of the so-called sociobiodiversity species.

[To be included as a case study in the section Innovation and research drivers pp. 74-76]

Additional evidence of the nutritional advantage of local agricultural biodiversity is needed as well as knowledge of the impact of agriculture-nutrition pathways. A key component of this effort is to carry out nutritional composition analysis of prioritized native edible species, both wild and cultivated, to demonstrate that these species are rich in nutrients and to use this knowledge to bring biodiversity conservation and its sustainable use into these different public policies, and provide added incentives for procurement and use in school feeding (Hunter et al. 2015). As part of the Biodiversity for Food and Nutrition (BFN) Project, Brazil, Kenya, Sri Lanka and Turkey are generating evidence for more than 100 prioritized native species of nutrition importance by undertaking food composition analysis



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and gap analyses of food composition data. All countries have identified organizations for hosting their national databases on biodiversity for food and nutrition and associated traditional knowledge and planned national Biodiversity and Nutrition Symposia to review data collection in the project and to identify and fill gaps in knowledge and evidence. Food composition data generated by the countries are being sent to the FAO/INFOODS for inclusion in their online database.

[To be included as a case study in the section Policies and programmes targeting the food system activities and actors -page 77- or in the Food accessibility section – page 89]

In Busia County, Western Kenya, women and men farmers belonging to the community-based organization Sustainable Income and Generating Investment (SINGI) firmly believe that African Indigenous Vegetables (AIVs) such as spider plant, amaranth, cowpea and slenderleaf are nutritionally superior to exotic crops. With help from the Biodiversity for Food and Nutrition (BFN) Project and the Kenya Agricultural and Livestock Research Organization, Busia farmers are proving that it is possible to include indigenous foods in school feeding programs at little or no additional cost for school budgets while providing sustainable, long-term support and empowerment to children, families and communities.

To bridge the gap, demand and supply-side constraints linked to the marketing of traditional crops are being addressed by training 30 SINGI farmer groups to sustainably produce and respond to market demands for AIVs from institutional markets (such as schools and clinics) as well as to manage their agro-businesses. At the same time nutrition information, recipes and food fairs are being promoted to increase the appreciation and use of local nutritious biodiversity to improve dietary diversity.

One farmer group is now supplying six indigenous vegetables to one school under a negotiated memorandum of understanding. While the school purchases the produce at an agreed market price and has a reliable and constant supply of quality AIVs, the farmers have a dependable buyer for their produce and have been able to cut transport costs and avoid food losses by growing the vegetables directly on school land. School caterers are also trained on how best to prepare the foods to preserve their nutrient values and 410 students are now consuming more diversified and nutrient-rich diets. On the economic side, early projections for the dry season, when market prices for leafy greens are higher, show that the school can save up to 10 Ksh ($0.10) per Kg of leafy greens supplied. That sums up to a weekly savings of approximately $9 per week and yearly savings of $360 a year. The farmer group, on the other hand, who supplies 91 Kg of AIVs to the school per week, makes a profit of 15Ksh ($0.15) per Kg. This translates into a weekly profit of 1,365 Ksh ($13) per week and yearly profits of roughly $540 a year.

The success of this approach is raising the interest of neighbouring schools and local administrations. In addition, the plots provide a useful educational tool for students who learn about sustainable agricultural practices and get hands-on experience in growing and using local crops.

[To be included as a case study in the section Information and guidelines– page 77]

Increasing awareness on how biodiversity can benefit food and nutrition can change eating habits and attitudes to local foods that are often perceived as "food for the poor". Partner countries to the Biodiversity for Food and Nutrition Project have all organized traditional food fairs and raised considerable awareness among national policy makers and the general public of the importance of local nutritious biodiversity. Notable among these fairs are the weekly farmers' markets launched in



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the Brasilia Botanical Garden, the Busia Traditional Food Fair in Kenya, the Alacati Wild Herb Festival in Turkey and the Hela bojun campaign in Sri Lanka. Under the brand name “Hela bojun - True Sri Lankan taste”, nine market outlets for the sale of traditional foods are serving freshly-prepared local foods and empoweringrural womenacross Sri Lanka to earn a living while conserving and protecting biodiversity and making healthy food available at competitive prices. By working at Hela bojun, women can earn between $ 600-800 a month enough to change their role as the main breadwinners in the family. Rotas are organised allowing everyone to earn the much needed money to pay for children education and run the family household. Women who enrol in the programme are trained by the Women Farmers Extension Program of the Department of Agriculture and tutored on the nutritional value of traditional foods, food preparation and food safety. The restaurants and adjoining shops in Colombo and Peradeniya have become so popular they been highlighted by Trip Advisor, creating additional market demand for traditional foods such as honey, jaggery, treacle, bananas and organic products and boosted production for smallholders. The shops also promote underutilized crops identified by BFN Sri Lanka, including medicinal plants such as the water lily Nymphaea pubescens (olu in Sinhala) used in Ayurvedic medicine and a variety of pulses, such as cowpea, black gram and green gram, as well as traditional rice varieties.

We also feel there is a need to include nutrition education as part of the equation. [Could be part of the in the Food accessibility section – page 89]

Policies that foster nutrition education have the potential to improve dietary diversity. Work by Bioversity International and partners shows that mothers receiving information on the use of local agricultural biodiversity to improve dietary quality were more likely to feed their children more diverse and nutritious diets by incorporating one or more food groups into their children's meals (Waswa et al. 2015). Further Bioversity International research in Kenya has shown that incorporating wild, biodiverse food into diets (green leafy vegetables and wild fruits) also helps reduce the daily cost of obtaining a more nutritious diet by up to 65%, although additional research is needed to understand what the associated opportunity cost may be (Termote et al. 2014).

BFN Brazil has demonstrated great success in collaborating with schools to raise awareness about biodiversity for food and nutrition, with a view to promoting greater utilization of edible species of native Brazilian flora. Through collaboration with the National Fund for Educational Development and the Centre for Excellence in Tourism of the University of Brasília, a project called Educating through School Gardens and Gastronomy is guiding a number of schools in setting up tree nurseries for native species and growing non-conventional leafy vegetables in school gardens in collaboration with Embrapa Hortaliças, to encourage healthy eating habits, dietary diversification and greater appreciation of Brazilian biodiversity. Further, many awareness raising events were organized in different Brazilian cities, such as culinary workshops, tasting events and food fairs showcasing the deliciousness of native biodiversity.

References

Allen T., Prosperi P., Cogill B., Flichman G. (2014). Agricultural biodiversity, social-ecological systems and sustainable diets. Proceedings of the Nutrition Society, 73(4): 498–508.



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Burlingame, B., Charrondière, R. and Mouille, B. (2009) Food composition is fundamental to the cross-cutting initiative on biodiversity for food and nutrition, Journal of Food Composition and Analysis. p.22

Hunter, D., Burlingame, B., Remans, R. (2015) Biodiversity and nutrition. In Connecting Global Priorities: biodiversity and human health: a state of knowledge review. World Health Organization and Secretariat of the Convention on Biological Diversity.

Lutaladio, N., Burlingame, B., Crews, J. (2010). Horticulture, biodiversity and nutrition. Journal of Food Composition and Analysis 23, 6:481–485.

McDermott, J., Johnson, N., Kadiyala, S., Kennedy, G. and Wyatt A.J. (2015) Agricultural research for nutrition outcomes – rethinking the agenda Food Sec. 7: 593. doi:10.1007/s12571-015-0462-9

Medhammar, E., Wijesinha-Bettoni, R., Stadlmayr, B., Nilsson, E., Charrondière, U.R., Burlingame B. (2012) Composition of milk from minor dairy animals and buffalo breeds: a biodiversity perspective. J Sci Food Agric. 92(3):445-74. doi: 10.1002/jsfa.4690.

Powell, B., Thilsted, S.H., Ickowitz, A. et al. (2015) Improving diets with wild and cultivated biodiversity from across the landscape. Food Security 7: 535. doi:10.1007/s12571-015-0466-5

Remans, R. and Smukler, S. (2013). Linking Biodiversity and Nutrition. In J. Fanzo et al., eds. Diversifying Foods and Diets. pp. 140–163

Remans, R., Wood, S.A., Sahad, N., Andermane, T.L and DeFries, R.S. (2014). Measuring nutritional diversity of national food supplies. Global Food Security, 3 (3-4), pp.174–182.

Roos, N., Islam, M.M., Thilsted, S.H. (2003) Small indigenous fish species in Bangladesh: contribution to vitamin A, calcium and iron intakes. Journal of Nutrition. 133(11 Suppl 2): 4021S-4026S.

Smith, L.C. and Haddad, L. (2015). Reducing Child Undernutrition: Past Drivers and Priorities for the Post-MDG Era. World Development. 68, pp.180–204.

Termote, C., Bwama Meyi, M., Dhed'a Djailo, B., Huybregts, L., Lachat, C., Kolsteren, P., Van Damme, P. (2012). A biodiverse rich environment does not contribute to a better diet: a case study from DR Congo. PloS one 7(1), p.e30533.

Termote, C., Raneri, J., Deptford, A., Cogill, B. (2014) Assessing the potential of wild foods to reduce the cost of a nutritionally adequate diet: an example from eastern Baringo District, Kenya. Food Nutr Bull. 35(4):458-79.

Waswa, L.M., Jordan, I., Herrmann, J., Krawinkel, M.B., Keding, G.B. (2015) Community-based educational intervention improved the diversity of complementary diets in western Kenya: results from a randomized controlled trial. Public Health Nutr. 18(18):3406-19. doi: 10.1017/S1368980015000920. Epub 2015 Apr 10.

55. Sheryl Hendriks, University of Pretoria, South AfricaChair, Panel Members and members of the project writing team,



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Congratulations on the draft HLPE report on Nutrition and Food Systems. The draft is comprehensive and well written. Attached are a few comments for your consideration.

Best wishes,

Sheryl

Prof Sheryl HendriksDirector: Institute for Food, Nutrition and Well-being University of Pretoria

26 May 2016

Dear Chair, Panel Members and members of the project writing team,

Congratulations on the draft HLPE report on Nutrition and Food Systems. The draft is comprehensive and well written. Below I propose a few points for consideration

I wondered what will set this report apart from the recent GloPan report and a number of others cited in the report and indicated as forthcoming in the covering letter of the input request? There is little controversy presented in the report. The real substance of HLPE reports is to present the points of controversy and disagreement and bring science into the debate on what policy makers should believe and then to guide them in their actions.

One trait of HLPE reports that is missing in this report is the framework related to international human rights and in particular the rights of children with regard to nutrition such as the International Convention on the rights of the Child of 1989 and the African Charter on the rights and Welfare of the Child (1999). This could be one very distinctive component of this HLPE report, reminding countries if their obligations and providing opportunities to strengthen their policies and actions in this regard.

While the report is a great piece of work bringing together these elements, it does not really set out the points of contention. They feature in the report but not as controversies. These include issues such as:

a. The report provides a balance of underweight, malnutrition and overweight and obesity and reports that 44% of countries reported in the GNR have problems with both underweight and overweight. What the report does not provide insight into is that this problem often occurs in the SAME household. How is this possible and what needs to be done about it?

b. The fats vs sugar debatec. The use of high fructose sugar derivatives and the impact on diabetes rates – see the

‘Skinny on Obesity” by Dr Lustig of the University of California. One issue the HLPE report could put firmly on the debate table for CFS is whether or not it is time for pubic policies to regulate consumption and shift consumption behaviour for improved nutrition? How is it possible that we know so much about the debates but governments are not ready to accept



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that we need large scale pubic policy action? Dr Lustig from the University of California’s ‘Skinny on Obesity” episode 7 (http://www.uctv.tv/shows/The-Skinny-on-Obesity-Ep-7-Drugs-Cigarettes-Alcohol-and-Sugar-23723) sets out why dealing with obesity should be a public health issue. His arguments for action are very persuasive and well worth considering as a policy message. He states that there are four reasons for public health action:

Identifies an exposures where mass behavioural change and environmental change is needed and instituted it for the benefit of society

Toxic and abused at the same time regulation is needed. This exposure is unavoidable – the excessive availability and adulteration of foods with

sugars and the availability at low cost of sugary foods and drinks. The food environment is such that these sugars are difficult to avoid unless you prepare all foods form raw ingredients.

Has a negative effect on society (the stats on health care costs, lost productivity etc.) Sugar fits this bill on all four counts. The New Nordic Cuisine story is a powerful case of how change can be championed.

No mention is made of how higher education and training programmes can be recurriculated to solving the nutrition and food systems issues. Most training is very silo’ed. We need to get professionals entering the field schooled in these current debates and ready to deal with them. For example, most reports written by nutritionists refer to overweight and obesity as overconsumption – a phrase that depicts the professional training of these professionals and the blindness too seeing that overweight and obese people are very likely to suffer from inadequate intakes of essential nutrients. There is a significant body of research emerging about how nutrient deficiencies are related to regulation of hormones and satiety. Far too little research has been done to understand these medical and biochemical elements. This could be a recommendation for further research.

Along the same line, few educational programmes at universities train students in this area. Countless meetings and papers bemoan the capacity gaps with regard to nutrition at all levels - from community centres, health care systems and research. Maybe it is time to do something about boosting the supply of nutritionists who understand food security and the food system and are able to play an active role in shaping this in future. A neat example of such a programme in Agricultural economics is the Collaborative Masters in Agricultural Economics and Allied Economics run by the AERC that recognised a dearth of this capacity in Africa and set out to do something about it. Over 10 years close to a 1000 graduates have been added to the continental capacity. See http://aercafrica.org/index.php/collaborative-masters-in-agricultural-and-applied-economics-overview.

Many national food guides and recommendations for consumption are not within the reach of the average and especially not poor households. This could be a challenge articulated in the report. For example, research we recently completed researched what people grow, eat and what they can grow to improve their diets year-round. More research is needed such as this but the findings need to be translated into accessible tools for communities to use. See http://www.researchmatters.up.ac.za/researcher-projects/view/29 .

There is very little recognition of the role of gut health in nutrition and the potential for understanding and exploiting this better for health and nutrition.



http://www.researchmatters.up.ac.za/researcher-projects/view/29.%20

http://www.uctv.tv/shows/The-Skinny-on-Obesity-Ep-7-Drugs-Cigarettes-Alcohol-and-Sugar-23723

http://www.uctv.tv/shows/The-Skinny-on-Obesity-Ep-7-Drugs-Cigarettes-Alcohol-and-Sugar-23723

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The section on gender (p57) is not really about gender – it focusses on women. This is a missed opportunity given a whole range of new initiatives to promote men’s involvement in maternal and child care for better nutrition. See the article at http://theconversation.com/when-men-tackle-mother-and-child-health-lessons-from-malawi-69501 for some ideas to balance this section and turn the section into a debate.

The report could do much more in terms of tying the various HLPE reports into this topic. How can social protection, water, climate change (somewhat addressed), prices, waste (also somewhat addressed) be linked into this discussion.

Best wishes with finalising this important report!

Yours sincerely,

Sheryl

Prof Sheryl HendriksDirector: IFNuW

56. Laurence Rycken, International Dairy Federation, Belgium

IDF greatly appreciates the opportunity to comment on the CFS-HLPE DRAFT V0, Nutrition and food systems. We commend the members of the expert panel to draft this report on a very complex issue. The design and implementation of policies and systems for food and nutrition systems requires robust, comparative data over time and across countries, therefore there is a clear need to establish a global research network to collect, analyse, and synthesize data.

We have provided some comments in the document attached on the requested questions. However we do feel that some crucial parts of the report are missing in this zero draft. We would therefore request a second consultation round for all stakeholders to provide comments to the entire document.

Sincerely,

Laurence Rycken on behalf of the International Dairy Federation

COMMENTS FROM THE INTERNATIONAL DAIRY FEDERATION (IDF)

CFS-HLPE DRAFT V0Nutrition and food systems

General comments:



http://theconversation.com/when-men-tackle-mother-and-child-health-lessons-from-malawi-69501

http://theconversation.com/when-men-tackle-mother-and-child-health-lessons-from-malawi-69501

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IDF greatly appreciates the opportunity to comment on the CFS-HLPE DRAFT V0, Nutrition and food systems. We commend the members of the expert panel to draft this report on a very complex issue. The design and implementation of policies and systems for food and nutrition systems requires robust, comparative data over time and across countries, therefore there is a clear need to establish a global research network to collect, analyse, and synthesize data.

We have provided some comments below on the requested questions. However we do feel that some crucial parts of the report are missing in this zero draft. We would therefore request a second consultation round for all stakeholders to provide comments to the entire document.

Comments Responding to Questions 1-12

1.

Page Line Questions Comments

1. The purpose of this report is to analyze the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft?

In general, this report appears to give an in-depth review of how food systems influence nutritional outcomes along with social, economic, and other implications. However, this report did not comprehensively illustrate the complexity of food systems, and it would be beneficial to include a systems expert (i.e a life cycle analysis expert) to define the proper boundaries and evaluate the beneficial contributions and detrimental



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impacts of food systems, diet choice and the interaction of different system segments.


The overall structure of the draft is comprehensive. Chapter 3 discussions associated with ASF were not well-balanced, and were not consistent with the 2016 CFS report Sustainable agricultural development for food security and nutrition: what roles for livestock?

The 2016 CFS report provided a balanced view of the environmental and nutritional challenges likely to be faced in the future, and the role of livestock in addressing these challenges.

In general, some parts (e.g. chap 3) of this draft report on the food system is overly simplify a complicated issue, for which there is a considerably larger body of research to reference.. If left, additional examples should



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be given and livestock should not be singled out.


The conceptual framework of food systems for nutrition and diets illustrates the interactions and crosslinked relationships among different segments of the food systems.

We agreed with making the food environment as the center of the food systems, and suggest illustrating the interactions and complexity of the system.





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We note that the report provides a strong focus for systems that promote healthy food options with fruits and vegetables only. We feel that other food groups namely whole grains, dairy, protein also play an essential role and this should be highlighted more in the report..

Considerable emphasis is put on the “culprits” associated with unhealthy diets – sugar, fat, sodium. There is a lack of focus on food systems that promote availability and consumption of beneficial nutrients. Tone is more “restrictive” of unhealthy components vs. “enabling” of healthier choices.

The role of behavior change nutrition education as a necessary and effective complement to food systems in terms of supporting healthy eating patterns is really not addressed.

6. The project team is working on a categorization of food systems. Are you aware of specificapproaches of use in that perspective, and particularly of quantitative indicators that could be used?

7. Does the draft adequately show the multiplicity and complexity of diets and nutrition issues across different food systems



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and specific contexts with a good regional balance?

We would like to underscore the need to have clear terminology throughout the report; The emphasis should be put on healthy eating patterns; nutritious or nutrient-rich foods. We feel that the term healthy foods has little meaning and is open to broad and varied definition.

11 In the definition of “Sustainable food system” does the term food security include both legs of food quality/quantity and food safety? As we feel that this should be the case.

12 The definition of “Diets” should stop after the first sentence. There is a definition of sustainable diets given in the definition 5.

19 8-11 We feel that this is point is essential to characterize diets for health. And would recommend that this kept the final report. Unfortunately, we have not seen this theme carried forward in the remainder of the report.

There is a lack of consistency about how animal-sourced foods are represented in the report in terms of the nutrients they provide. In section 3.1.3 the authors note that adolescent girls have inadequate intakes of iron, zinc, calcium, vitamin D, folate, thiamin and riboflavin. However, red meat and processed meats, are sources of iron and zinc, are identified as “unhealthy foods” in 3.1.1. A more balanced consideration of the pros and cons of animal-sourced foods in nutrition and food systems could provide valuable perspective.

Some of the sections in Chapter 3 could be their own reports – climate change, globalization, urbanization, culture/religion/rituals, etc. However, much of the content is very topline and not particularly solution-



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oriented, especially regarding food systems and animal agriculture.

In general, the difference between regional, national and global data are not clearly indicated. For example, in section 3.2.1 “one study from West Africa” is mentioned regarding the link between soil degradation and child mortality. How is that relevant to other regions, countries, etc.? Is there a review that could better capture the issue? It is challenging to interpret of translate these examples into policies and programs.

The report mentions the term healthier foods, but does not provide a definition for this category of foods. However it is not foods but diets that should be considered. Examples of healthy diets, such as the Mediterranean diet and DASH diet, are given throughout the report, but there is no mention of how this has been defined.

109 18-22 Science should focus on the components and variability of dietary patterns that avoid chronic diseases rather than focus on single nutrients.


34 3-4 We have noticed that the report references positive research around plant-based diets and decreased risk of CVD and several types of cancer. However it does not take into account some of the positive research around other commodity products such as dairy and decreased CVD risk.



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39-43 Please add uncertainty information for diet change and nutrition research models

44 14-23 This paragraph, describing the variety of foods available to all of humanity throughout all of human history, does not provide useful context for establishing a nutritionally secure future.

We suggest keeping the last sentence, “Variation in food species contributing to diets has been associated with nutritional adequacy and food security (citation).” Followed by “Within the capabilities of the modern food system, variability in diets should be encouraged.”

45 It would be useful to further emphasize and clarify that there is a wide range of environmental sustainability performance within all production systems, which depends on management practices and skills.

48 10-43 When discussing the contribution of animals sourced foods to food and nutrition systems the CFS report of 2016 on sustainable agricultural development for food security and nutrition: what roles for livestock? should be referenced.

Therefore if the paragraph is kept we would request that it is redrafted.

48 20-29 ASF production and its social, nutritional benefit and environmental impact should be considered altogether, not just GHG, or water, the nutritional benefit cannot only be calories. Food Systems are complex systems, a systems expert can help with the analysis and arguments.

49 Fig 19 Figure 19 shows the GHG emissions per kilocalories, and this exactly shows the unjustified functional unit for comparison can lead to silly conclusion - sugar is the best food



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for highest calories and lowest GHG emissions.

49 16 Are the authors writing specifically about plant-based diets, or dietary patterns with higher levels of fruits and vegetables? Clarity is important because the two are very different.

49 29-31 Suggest removing the sentences as it does not provide the complete picture. If left in, additional examples should be given; livestock should not be singled out. The paper cited (Ranganathan et al., 2016) is not a peer reviewed scientific article and does not examine any data related to potential for AMR resistance based on preventive use of antimicrobials in livestock.

The prudent use of antibiotics is necessary in animal husbandry in order to improve animal welfare, avoid chronic infection, and achieve sustainable animal husbandry. Animals that are sick and/or in pain and suffering should be treated in a correct way in order to ensure good animal welfare and avoid the development of chronic infections.

http://store.fil-idf.org/product/guide-to-prudent-use-of-antimicrobial-agents-in-dairy-production-in-english/

54 23 Delete the word “protected from” and replace by “not as heavily impacted by”.

The sentence should acknowledge that (some) farmers are heavily impacted by global price fluctuations.

54 30 Add the word “in practice” after the word “trade”

54 31 Replace the words “are also questionable” with “is a question meriting further examination”

54 37-39 Delete the sentence starting with “The association….”






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As it does not appear to be fully substantiated by the prior citations.

54 39-40 Redraft the sentence starting with “Concerns have also been raised…”

We support the promotion of breastfeeding, but we also need to consider those women who are not able to breastfeed. As the sentence is currently written it seems to suggest that the existence of breastmilk substitutes is in itself inappropriate. We would suggest rewriting the sentence in order to put the focus on evidence-based approaches that have been found to increase breast-feeding.

54 50-51 Remove the part of the sentence starting with “; however the history of international trade negotiations and the resulting rules framework has not been very positive in this regard.”

Despite this assertion there has been an increase in food production in numerous developing countries at the same time that trade & globalization have expanded.

55 3 Add following sentence:

“This introduced important disciplines on agricultural trade policy in order to move countries towards a less trade-distorting and more market-oriented policy footing”

55 3-11 Delete paragraph starting with: “the categorization of agriculture related…”

55 12 Replace the wording “It has been … “, with ‘Some have…”

55 13 Add following sentence: “Others have argued that those existing trade policies established under the GATT introduced critical disciplines that have created the footing upon which ample growth in numerous developing countries has taken place over the last two decades. “Alternatively, remove the prior



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sentence in lines 12 – 13 in order to address the bias created by citing only one viewpoint on this issue.

55 13-16 Delete sentences “Further, there is a bias in the trade policies towards strengthening larger corporations and allowing the dumping of cheaper, imported products into developing countries. This could also skew the food systems towards imported foods.”

This is simply an opinion without fact and therefore should be removed.

55 16-17 Change the start of the sentence to: “ It is relevant to note, however that trade can have an impact…” and add the following at the end of it: “in some cases while in others expanding the access of consumers to healthy foods.”

55 21-27 We feel that the assertion mentioned in this paragraph is unfounded. Developing countries were very active in the Nairobi outcome and in fact have been “successful” in blocking work on certain topics in the WTO. An agreement could not have been reached in Nairobi without their involvement.

Therefore, we would redraft the paragraph to the following:

“It is in this context that the 10th Ministerial Conference of the World Trade Organization (WTO) in Nairobi is relevant. The contentious Doha Development Round, with its promise of a single undertaking (SU) framework, has now been abandoned in light of an inability of countries to reach consensus resolutions on the critical issues that prompted its launch. In its place, WTO members now seek to reach agreement on those areas where consensus can be achieved. That included the historic commitment at the WTO ministerial in Nairobi in 2015 to eliminate export subsidies, among other commitments. As a major international agreement pertaining to agriculture, the Nairobi package has



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implications for policies affecting diets and nutrition in developing countries.”

55 28-42 Delete both paragraphs as they present a one-sided view of the complex dynamic in WTO agricultural discussions.

55 43-46 We feel that a variety of marketplace factors can drive the impacts of trade. Therefore we would suggest using other wording in this paragraph:

“Trade policies encourage the growth in availability of products. This growth has an impact on the food-system by introducing new ways to sell and promote foods, stimulating new forms of competition, thereby affecting the availability, accessibility, price and desirability of foods from various actors in the food market.”

56 36-43 Suggest rewording the paragraph:

“In contrast, there is a debate in the United States of America regarding whether a link between farm subsidies and obesity exists. Some studies have speculated that production of maize and soy, followed by excessive calorie consumption, is the prime cause of the increase in body mass index in the United States of America and elsewhere (Putnam et al., 2002; Silventoinen et al., 2004). On the other hand, some have argued that it cannot be established convincingly that agriculture subsidies have a role to play in impacting diets and therefore obesity or overweight prevalence. In addition, some argue that the dietary guidelines focus on low-fat over the last three decades has coincided with an increase in obesity due to the rise in sugar consumption as a substitute. The emerging science regarding the benefits of certain types of fats should also be considered.”



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62 23-24 Suggest rewording the sentence to say: “There is pressure to produce more food in an environmentally sustainable way, while upholding safety and health standards.”

73 5 - 6 Suggest rewording the ending of this sentence to say “subsidies have the potential to shift production patterns and lead to changes in the way food is produced”.

87 2-24 The overarching objective of Front-Of-Pack nutrition labelling should be to deliver meaningful public health outcomes and enable consumers to choose nutritious foods. It is imperative that consumers are encouraged to purchase and consume ‘core’ foods which are easily recognizable as nutritious food choices as compared to energy-dense, nutrient-poor discretionary foods.

Foods are a complex matrix of nutrients, which interact in a multitude of ways to influence health outcomes. Nutrition is not only about nutrients but also about having a balanced diet. Thus, recommending decreasing or increasing the consumption of a single nutrient will result in a modification of the diet itself.

More evaluations of these policies should be done before mentioning these in the report.

87 2-24 The potential pitfall of such policies such as traffic light system is that they try to apply whole dietary intake recommendations to individual foods. Such systems ignore the context of the total diet/complete dietary patterns and instead focus on attributes of individual foods. If implemented then the focus should be put on dietary patterns.



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92 16-38

Animal sourced foods, such as milk, are also an effective delivery vehicle of fat-soluble vitamins and minerals (WHO and FAO, 2006). The FAO book on milk and dairy products in human nutrition provides multiple examples of successful fortified milk programmes, such as the virtual elimination of childhood rickets in Canada and the US by the fortification of milk with vitamin D.

93 37-38

Suggest removing the sentence that begins with: “There are also…”.

This is an opinion, not a scientifically supported statement. In addition, ample differences of views exist on this point.

98 28-48

We note the paragraph on developing cold chains only provide examples for vegetables, fruit and fish, but there are other commodities such as milk and dairy products where the cold chain plays an important role.

99 45 Suggest inserting the words “WTO-compliant” before the word “subsidies” here to clarify that the recommendation would be in keeping with international trade commitments.

100 18-19

Reword the sentence so that it read:

“Government should examine the effectiveness of legislative resolutions to limit advertising and marketing of unhealthy foods and beverages to children (Boyle et al, 2007), taking into account legal and regulatory constraints in each country.”

100 42 Remove the words “the counter-cyclical trade policies” as these are not clearly defined nor is a basis provided for recommending their elimination.

101 22-29

Rephrase the paragraph to the following:

“Subsidy interventions can be used both at production and consumption stages. From the producers’ side, fiscal incentives to promote resource-use efficiency should be pursued, coupled with the gradual



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elimination globally of trade-distorting agricultural subsidies. Policy-makers should use the savings from the global elimination of trade-distortive subsidies to diversify agricultural production and consumption to include more nutritious food products such as beans, vegetables, fruits and dairy products in ways that are in keeping with the country’s trade commitments. “

104 13 Suggest rephrasing to the following: “…important role of smallholder agriculture in contributing to food security, the needs of smallholders should be taken into account.”

9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich the report and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win outcomes in terms of addressing the different dimensions of diets



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for FSN?General comment:

We feel that the most compelling examples given are those that provide the information of what has been achieved. Even if those examples of programs that just started are interesting we would suggest deleting some of these in order to decrease the number of examples.

73 Box 6

We would recommend deleting this example.

91 An additional example for food accessibility would be School Milk Programs.

Around the world, school milk programmes exist to encourage the consumption of milk and milk products by children in order to make a positive contribution to their nutritional status, to address issues of malnutrition and to engender healthy eating habits. As a result of these programmes, the macronutrient and micronutrient intakes of millions of school children around the globe can be improved through the consumption of nutrient-rich milk and milk products. IDF worked jointly with FAO to map out examples of school milk programs worldwide more details can be found here: http://store.fil-idf.org/wp-content/uploads/Publications/Freeofcharge/Bulletin-no480-2015_The-contribution-of-school-milk-programmes-to-the-nutrition-of-children-worldwide.CAT.pdf

10. Section 4.2.2 on “Institutional Changes and Governance Across the Food System Movements for Nutrition” requires more work, and



http://store.fil-idf.org/wp-content/uploads/Publications/Freeofcharge/Bulletin-no480-2015_The-contribution-of-school-milk-programmes-to-the-nutrition-of-children-worldwide.CAT.pdf



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more inclusion of evidence and of the various players. Any inputs on this section are most welcome.

106-107

9-21

Industry also pays a role in supporting the critical nutrition research and improvements. These should be reflected in this paragraph.



57. Teresa Borelli, Bioversity International, ItalyRegarding cross-sectoral collaboration, much can be learnt from the BFN experience. Section 4.2.3 Nutrition governance.

At the policy level, all countries established cross-sectoral national policy working groups which revised existing national legislation to identify entry points for the mainstreaming of biodiversity for food and nutrition and Bioversity International contributed to the writing and endorsement of the Voluntary Guidelines for Mainstreaming Biodiversity into Policies, Programmes and National and Regional Plans of Action on Nutrition in 2015 by the Commission on Genetic Resources for Food and Agriculture (CGRFA)



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Happy to contribute more at a later stage if needed.

More information can be found here:

http://journal.frontiersin.org/article/10.3389/fnut.2016.00014/full

58. Oliver Mellenthin, Federal Government of Germany, GermanyPlease find the German comments on the VO draft attached.

Kind regards,

Oliver

Comments on the HLPE Zero Draft (V0) “Nutrition and food systems” by the Federal Government of Germany

Germany highly welcomes the opportunity to comment the HLPE V0-Draft on nutrition and food systems that aims to analyze ways in which food systems influence dietary patterns and hence nutritional outcomes for consumers and, additionally, to highlight effective policies and programs that shape food systems in order to contribute more effectively to improved nutrition.

I. General remarks

1. The report – at its current stage – provides a broad overview on the topic, covering a wide range of relevant aspects. So far, however, the focus seems to be on diets and their interdependency with food systems. From our perspective, the report could benefit from dealing more generally with the nutritional status which also relies on other factors such as health, WASH, care (see UNICEF 1990). Similarly, the impact food systems have on e.g. health and care issues should be considered such as time constraints women face working in agriculture and being responsible for the nutrition of their children. Likewise, irrigation measurements for agricultural production, that lead to increasing malaria rates due to better breeding situation for vectors, might play a role.19 In sum, it seems essential to provide explanations of how food systems affect nutrition and which policies and programs are needed in order to trigger the positive effects of food systems on nutrition. On this basis, the report should provide more concrete conclusions regarding possible pathways (e.g. in chapter 4.2).

2. Given the fact that a combination of different measures often has a strong impact on nutrition, e.g. food security interventions that are combined with nutrition education, case studies should better look at programs rather than focusing on simplistic linear cause-effect relationships.2

19 See Worldbank 2013: https://openknowledge.worldbank.org/bitstream/handle/10986/16953/751030BRI0Impr00Box374299B00PUBLI C0.pdf?sequence=1 2 See FAO 2016: http://www.fao.org/fileadmin/user_upload/nutrition/docs/education/infant_feeding/Programme_Lessons.pdf 2



http://journal.frontiersin.org/article/10.3389/fnut.2016.00014/full

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3. So far, the report does not sufficiently address the effects of nutrition education at all stages of the food system (i.e. breeders, farmers, processors, retailers, out of home suppliers, etc.). Likewise, the role of communal catering as part of the food system should be better highlighted.

4. In addition, we would like to refer to the range of reports on nutrition and diets that have just been released or will be released over the coming years including the GloPan Foresight Report1 (September 2016) and the EAT-Lancet Commission on sustainable diets and food systems (June 2017). These reports should be kept in due consideration.

5. Changes of technologies particularly food processing methods and their impact on food quality as well as social interventions for better nutrition should be adequately considered in the report. Likewise, the report should take into account the effect of programs in the food system on eating disorders and on the image/perception of food should be included.

6. Business-consumer relations play an important role. The effects of marketing on consumer behavior and dietary preferences should be taken into consideration and how consumers can be supported in their abilities to make the healthy choice the easy choice.

7. The report could be more balanced. So far, it mainly recognizes and recommends regulatory approaches to achieve better nutrition, thereby it seems to neglect the constructive character of voluntary approaches.

II. Statements regarding the questions raised on pp. 2-3


Yes.


The report is comprehensive, right balanced and many important aspects are covered with regard to consumer understanding. However the scientific background of different labelling systems is not covered. Additionally, the report sometimes lacks precision. Some items are presented in a very biased way (e.g. Iodine, food taxes), claiming validated facts where there are still assumptions and models.


The Food Environment-concept is a comprehensive way to fully describe the drivers of healthy diets and is therefore addressed here in an adequate way.



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The role of production systems in shaping diets is important and considered in a well balanced manner in this report. Production systems are important as one of the drivers of consumer’s choice is availability of food – an aspect mainly driven by production systems. However, it has to be clear that production systems are only one driver of consumer choice. Main drivers are also income and traditional behavior as well as availability and access.


Yes.


Not aware of specific approaches.


Yes.


Chapter 4.1 The number of case studies/examples is quite high, demonstrating mainly that the measures implemented have to be tailored to specific situations in the countries. For this conclusion it might be better to shorten the examples. Also the choice of examples seems somewhat arbitrary and not always well documented.


Germany’s Action Programme INFORM https://www.in-form.de/profiportal/inform/internationales/in-form-english-version.html should be mentioned as an example for comprehensive awareness building. See also answer to question 8.


---

11. Is the report too technical or too simplistic? Are all the concepts clearly defined

The report is mainly well balanced, however with regard to front-of-pack labels the controversy of setting transition points for “low”/”medium /high level of a nutrient is not covered and therefore too simplistic. The concepts are clearly defined.



https://www.in-form.de/profiportal/inform/internationales/in-form-english-version.html

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12. Are there any major omissions or gaps in the report? Are topics under-or overrepresented in relation to their importance?

No.

59. Beate Scherf, FAO, ItalyDear Panel,

In order to avoid repeating comments that were already made I went through the comments submitted previously and limit myself to issues that I feel were missing from these submissions.

General comments:

Definitions and concepts: FAO has developed a common vision and an integrated approach to sustainability across agriculture, forestry and fisheries. The 5 principles of the Sustainable Food and Agriculture (SFA) approach has been endorsed by COAG (FAO’s Committee on Agriculture). This approach should be included in section 1.1. and section 4.2.2. (find further information at http://www.fao.org/sustainability/background/principle-1/en/).

Coverage of different sectors of agriculture production: While the report tries to cover the different sectors of agriculture that contribute to food production (crop and livestock production, aquaculture and fisheries and foresty), there are quite some biases towards crop production. This should be reviewed (e.g. p16 line 42-49 is also true for livestock production).

Micronutrients: I think it would be important and helpful if the panel provided some summary statistics on micronutrient deficiencies and a list of the most important micronutrients and which foods/food groups contains them. Animal-source foods (meat, eggs, milk, dairy products, honey, fish, seafood etc) provide not only a source of protein but particularly a range of micronutrients that are absent or only in small quantities in plant based foods. (E.g. Please review section 2.3.3 on Iodine deficiency – no mention of animal-source foods and fish and seafood but related to lack of Iodine in soils.) This is also important when we talk about obesity and overconsumption of animal-source foods. In adequate quantities, animal-source foods should be an essential part of the diet of particularly children and pregnant women. Culturally however, women and children tend to receive less animal-source foods than men.

Smallholders vs multinational companies: The role of smallholders in production is not sufficiently emphasized (see e.g. http://agro.biodiver.se/2016/11/smallholders-are-bigger-than-you-imagine/?utm_source=Agro.biodiver.se+subscribers&utm_campaign=3c95f6c1e7-RSS_EMAIL_CAMPAIGN&utm_medium=email&utm_term=0_949cf01306-3c95f6c1e7-109200741). Smallholders are usually disadvantaged because of the relative small quantities that they produce and struggle to produce standardized quality that is required by processing plants. The unequal power of big companies should be more emphasized. Also at some places in the report it would be important to also specifically mention pastoralists (e.g. p16 line 39).

Nutrition education: The importance of nutrition education is hardly mentioned in the report. It should be far more emphasized particularly in relation to women and home gardening which should be an important element of farmer field schools and extension services.



http://agro.biodiver.se/2016/11/smallholders-are-bigger-than-you-imagine/?utm_source=Agro.biodiver.se+subscribers&utm_campaign=3c95f6c1e7-RSS_EMAIL_CAMPAIGN&utm_medium=email&utm_term=0_949cf01306-3c95f6c1e7-109200741



http://www.fao.org/sustainability/background/principle-1/en/

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Antimicrobial resistance: AMR should be far more emphasized in the report. It is only linked to “concentrated” livestock production (btw – page 49 line 30 reads strange).

Need for good data: (page 109) should be expanded and completed; e.g. lacks need for food composition data

Specific comments:

Page 48 line 30 down: How about GHG emissions from rice production.

Page 49 line 15: new breeding should be replaced with genetic improvement

Page 58 line 33: access to education and knowledge (extension service) e.g. to specific gardening knowledge of vegetables and fruits, is lacking

Figures 27 and 28: focus on crop production only

Page 74 section on innovation and research drivers focus on crop production only

Page 94: section on emerging technologies in food safety focus on crop production only

60. Elin J. Boll, Arla Foods, DenmarkDear CFS/HLPE,

please find attached comments to the HLPE report on Nutrition and Food systems from Arla Foods.

Best regards

Elin J Boll

HLPE-report V0 draft report

Nutrition and Food Systems

Comments from: Arla Foods

Arla Foods is a global dairy company and a cooperative owned by dairy farmers in seven countries: Denmark, Sweden, UK, Germany, the Netherlands, Belgium and Luxembourg. Our products are sold under well-known brands in more than 100 countries globally. Arla is the world’s fifth largest dairy company, based on milk intake, and the world’s largest producer of organic dairy products.

Arla Foods is grateful for the opportunity to provide input to the report and congratulate the High Level Panel of Experts to an interesting and multifaceted report. We look forward to coming drafts and continuous opportunities to provide our perspectives on the challenges of global nutrition and food systems, where we see dairy- production and products potential to contribute towards achievement of the Sustainable Development Goals.

In addition to the comments provided in here, Arla Foods supports the input provided by the International Dairy Federation (IDF) and the Private Sector Mechanism (PSM).



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On an overarching level, we want to stress the importance of dairy products in healthy and sustainable diets around the globe. Dairy products provide high quality nutrition to comparatively low price and with comparatively low environmental impact. Dairy products offer a nutrient package with essential nutrients in a mix suitable for complementing a balanced diet rich in vegetables, fruits, grains, pulses and smaller amounts of high quality protein sources like fish and meats. Thus, dairy can provide valuable nutritional contributions to healthy and sustainable eating patterns to both under- and over nourished populations. This is why dairy is part of dietary recommendations in countries around the world.

We support the reports’ objective to focus on consumers and consider sustainability issues. Further, the reports aim to be solution oriented and to highlight efficient policies and programs will help members of CFS to create bold and decisive strategies that will contribute to food systems that will promote better nutrition in a sustainable manner.

As pointed out in the cover letter, the present V0 draft report does not yet identify areas for recommendations as it is too early in the process to determine the major propositions stemming from the report. Considering the impact this report can have on how healthy and sustainable diets are addressed by the public- and private sectors, we believe another consultation is called for. We therefore strongly encourage the HLPE to consider sending the report for a second round of consultation, once the recommendations are formulated.

In the introduction, it is stated that “the report will provide guidance on which policy and programme actions to take in a given malnutrition context, and the environmental synergies and trade-offs of doing so”. It is important that this notion is carried out throughout the report, to focus on guidance and conclusions based on the HLPE vast experience and knowledge in this field.

Specific questions:


Chapter 4.2 is solutions oriented, whereas most of the report leading up to that chapter is more descriptive. When revising the document and adding recommendations, the report will surely become more solutions oriented. We therefore encourage a second consultation in order to capture ideas on how the solutions provided by the HLPE can be improved further, fulfilling the aims of the report.



The interrelated nature of food production and consumption, the drivers and feedbacks is extremely complex and we acknowledge the difficulty in addressing this. We find that figure 1 illustrates that diets would drive environmental impacts, which is a simplification that ignores the



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interlinked nature of the production and consumption side of food. We would rather describe it as consumer behavior in terms of purchasing certain foods is a driver for value chain actors that in turn produce food in a manner that cause the environmental impacts. There is a strong signal from the consumers that food affordability is important, hence there is a drive to push production towards a cost-minimization strategy.


There is a strong focus on describing the environmental problems related to industrial agricultural production, e.g. already in the introduction (pg 9 row 31-34), whereas the environmental impact of inefficient small-scale farming, with e.g. high carbon footprints for individual foods, is not problematized. Despite the focus on problems related to industrial and large scale production, the solutions discussed in Chapter 4.2.2 focus on changes aimed at increasing production in small-scale farms through sustainable intensification and agroforestry,



The approach by Gustafson et al. (2016) with the seven food system metrics of sustainable nutrition security presented a methodology to define sustainable food systems by combining many aspects. There seems to add little value for the HLPE to create a separate categorization method.



In page 9 row 13-16, we propose to change the usage of the word “opportunities” towards a more neutral wording, e.g. “situations” or alike. The usage of “opportunities” implies that industry deliberately influences the nutritional value of foods towards both improvements but also impairment of nutritional value. This is not conformable with our view of a responsible food industry. Alternatively, we propose to change the sentence “This provides many opportunities to enhance or diminish the nutritional value of foods” to “This provides many opportunities to influence the nutritional value of foods”. With the same wording in the last row of that paragraph (row 16; many opportunities are generated for influencing the nutritional value of foods).

In page 9, row 35-45 the report discusses the potential for low- and middle income countries that are currently shaping new food systems have the possibility to influence the future development of those systems. We believe that it is important that the report also covers high income countries with mature food systems, with choices identified and made to change current food systems in a better direction. In addition, the last sentence in that paragraph states that the development of current food systems in many high-income countries are based on maximized profits without adequate focus on the nutrition consequences. We strongly suggest to remove this sentence. There is many aspects



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and reasons behind the current food systems, with one simple example being current and historical evidence-based knowledge around nutrients, food and health. Today new evidence emerges to suggest that historically dietary recommendations have tended to be too narrow in focus and new suggestions indicate that we need to shift from focusing on single nutrients towards a dietary pattern approach.

Page 9 row 46 –page 10 row 2. Please include all aspects of sustainable foods systems as defined in “Definition 2 Sustainable food system”. Food systems need to address all aspects; social, economic and environmental, to be considered sustainable and this needs to be addressed by decision-makers in the future.

Page 14. Figure 1 gives the impression that diets cause environmental impacts, which is a simplification that ignores the interlinked nature of the production and consumption side of food. Rather, consumer behavior in terms of purchasing certain foods is a driver for value chain actors that cause the environmental impact. The environmental impact will also depend on the drivers identified in the figure.

Page 48, row 41. This paragraph discusses complexity of animal sourced foods (ASF) in terms of nutrition and health. ASF provides nutrients that could be difficult to obtain in adequate quantities from e.g. plant-sourced foods alone, and the importance of these nutrients in relation to certain illnesses. However, the last sentence of the paragraph concludes that “overconsumption of processed meats and ASF high in saturated fats contributes to increased risk of obesity and NCDs.” And this statement is referenced to two scientific papers.

We strongly suggest that this sentence is either changed the references or removed since it does not reflect the cited references (You and Henneberg, 2016; Bouvard et al., 2015). It is of utmost importance that the HLPE report is making statements and conclusions backed by scientific evidence and in this case this statement is not supported by the noted references. The sentence as it is written in the draft report draws erroneous conclusions regarding the health aspects of AFS.

You and Henneberg concludes in their paper that “High meat availability is correlated to increased prevalence of obesity” however in this analysis fish, dairy and egg are not included in “meat”, hence the HLPE reports statement to ascribe effects of ASF to obesity or NCDs are not correct. You and Henneberg 2016 further describes their result “Our results show animal protein (excluding meat protein) is associated with the three stages of BMIs, but not as significantly as meat protein does may be because protein from dairy [73] and fish products [75] don’t contribute to body weight increase.”

Additionally, Bouvard et al., 2015 includes only red and processed meat in their analysis, hence also here the reference to ASF (including fish, egg and dairy) are not correct. In addition, this reference discusses the impact on red- and processed meat on various forms of cancer, and not NCDs in general. In relation to the effects of dairy products on certain cancers, The World Cancer Research Fund indicates that the evidence for milk inducing a decreased risk of colorectal cancer is probable, this have also been concluded in a meta-analysis (Aune et al., 2012, Ann Oncol. Jan;23(1):37-45.

Page 98, row28-48. The section mentions the importance of cold chains for vegetables, fruit and fish and we propose to also include dairy as an example of perishable food with a lot of nutritional value. Dairy chains are being developed around the world, providing access to market for small scale producers in low- and middle income countries, contributing to better food safety and improved nutrition.



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Page 100, row10-11. Traceability is a requirement for animal foods.




Unfortunately, there is a lack of consistency in terminology throughout the report which creates confusion and add unnecessary complexity for the reader, and for HLPE when creating future recommendations. One example is the use of “dietary pattern” vs “eating patterns”, and another relates to the topic of processed foods. Processed foods are not clearly defined in the report, although a good start is given at page 17 row 14-30. E.g. processed foods are discussed in the light of providing benefits to nutrition and food systems through increased access to nutritious foods by enhanced safety and shelf-life; as well as improved palatability and nutrient bioavailability of staple foods, and reduced food loss. In the other end hyper-palatable, nutrient-poor, high-energy processed foods rich in fat, sugar and salt are associated with negative outputs such as increased risks of developing non-communicable diseases. The concept of ultra-processed foods is introduced in table 1, with following statements in page 60 row 22, without any further explanation of the term, in relation to the already mentioned “processed foods”. We believe that this inconsistency needs to be addressed and further clarified.

We fully support chapter 1.1.3 Healthy Diets that comprehensively discusses the complexity of healthy diets. We are impressed by the HLPE approach to include characteristics that goes beyond the single nutrient focus, traditionally used to describe healthy diets to also include the important aspects of taste, balance, accessibility and affordability. However, we see a need to add a definition box of healthy diets/un-healthy diets. Both Diets and sustainable diets are defined in the report (def 4 and 5). The statement “Diets for health contain an appropriate level of food energy, help achieve nutrient adequacy, support growth and maintenance of health across the life course, and reduce the risk of chronic/non-communicable diseases” (page 18 row 41-43) are close to a clear definition. It is important that the meaning of the term healthy diets as described in chapter 1.1.3 is kept throughout the report.


There is an unbalance in how the environmental challenges of different production systems are described. The environmental challenges with animal food production systems are mentioned throughout the report, and explored in detail on page 48, whereas the challenges with other food production systems are not addressed to the same extent. This risk leading to the erroneous conclusion that animal agriculture, and ruminants in particular, is the only sustainability challenge for current food production systems. Two examples of sustainability challenges for non-ASF that could



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be assessed include pesticide use (fruits and vegetables) and biodiversity loss from land use change (palm oil),

61. Marília Leão, National Council on Food and Nutrition Security, Brazil

National Council on Food and Nutrition Security Suggestions to the Document Nutrition and Food Systems – V0 Draft Report

1) Insert an additional item at “Characteristics of diets for health” (page 19, after line 17):

Healthy food is characterized by in natura and minimally processed foods, suitable for all life cycle phases, which begins with breastfeeding. Healthy food is the one produced through the natural resources proper management, taking into account the sustainability principles, traditional knowledge and local specificities. Healthy food must go beyond the biological dimension and not be restricted to the nutrients perfect combination; it must take into account the food production and distribution impact on social justice, natural resources integrity and biodiversity.

Reference: FIFTH NATIONAL CONFERENCE ON FOOD AND NUTRITION SECURITY. Final Report. Brasilia, Federal District, Brazil, 2015.

2) Insert the following at the item “Eating patterns associated with health as described in evidence-based dietary guidelines” (page 19, after line 37):

Food guides broaden the knowledge and autonomy on food choices. Access to reliable information about adequate and healthy food characteristics helps individuals, families and communities to increase their autonomy in making food choices and to demand even more compliance of the human right to adequate food.

Reference: HEALTH MINISTRY. Brazilian Population Food Guide. 2ª edição. Brasilia, Federal District, Brazil. 2014.

Food guides are documents that have repercussions in a set of sectors directly or indirectly involved with all food system stages. This kind of document serves not only as a guideline for actions of education on food and nutrition, but is also an instrument of dialogue between the Brazilian government most different sectors and the society committed to the adequate and healthy food human right, to the sovereignty and to the food and nutritional security.



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Reference 2: NATIONAL COUNCIL ON FOOD AND NUTRITIONAL SECURITY. Explanatory Statement n. º 004/2015. Brasilia, Federal District, Brazil. 2015.

3) Insert the following at the item “Undernutrition and its causes and consequences” (page 25, after line 3):

All forms of malnutrition represents human right to adequate food serious violations and a risk to the lives of those affected. Malnutrition exists when people do not have physical and economic access to a healthy and adequate sufficient amount of food in order to supply their needs, according to their ages, gender, work type and food preferences. However, there is also malnutrition in cases of overweight, widespread availability and accessibility to unhealthy foods, food contaminated by agrochemicals, ultra-processed foods and incentives to ultra-processed food by insidious marketing practices.

4) Insert the following at the item “Social networks and movements” (page 50, after line 46):

The main lessons of Brazil in the social construction process of a newnew governance for the public policies to reduce hunger and poverty and to promote the human right to adequate food were:i) Systemic and intersectorial approach for the provision of public policies within the State; ii) Civil society relevant role due to social participation formal mechanisms;iii) Human rights framework protagonism in guiding the public policies formulation;

iv) Family and peasant agriculture, women, indigenous peoples and traditional communities seen as leading elements of food and nutritional sovereignty and security;

v) Primacy of traditional and agroecological forms of agricultural production respecting the rights of men and women to cultivate, conserve, use, exchange and sell creole seeds, preserve native foods, medicinal plants and the planet's biodiversity;

vi) about About the family primacy, mentioned in section iv, must be added that its support in Brazil made possible to learn that it is not just a poverty reduction form, but also constitutes an action that generates a virtuous circle by producing a more diversified food production, protecting the environment and generating market and local economy. Therefore, this virtuous circle tends to improve nutrition: as food becomes healthier, there is a greater supply and diversity of nutrients, more local production systems are protected, traditional knowledge is valued, among other benefits.



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5) Insert the following at the item “Knowledge gaps and areas for future work” (page 91, after line 11):

The theme of Adequate and Healthy Food Human Right (AHFHR) is currently a pillar of the UN Food Security Council reform and a central element to the analysis of the relationship between food-nutrition systems, mentioned in this repportreport at the item 1.1. It is impossible to think such a relationship without considering the AHFHR, because its importance for planning public policies concerning food-nutrition system. It remarks the relevance of directing these public policies to different dimensions of state obligations such as their duty to ensure human rights principles, like transparency and the need for preferential care for the most vulnerable.

6) Insert the following at the item “Public–private partnerships” (page 105, after line 28)

Public-private partnerships may indeed be beneficial nevertheless, it is important to note that this report agenda requires technical expertise coupled with human rights principles political commitment. Therefore, it is essential to protect decisions from conflicts of interest and private sector interference. Otherwise, actors who lead to hegemonic and conflicting nutrition systems will continue to play a decisive role at the decision making process and it will become impossible to overcome challenges in this area of nutrition.

62. Morgane Danielou, Private Sector Mechanism, FranceHLPE-report V0 draft

Nutrition & Food Systems

Comments from the Private Sector Mechanism

The Private Sector Mechanism wishes to congratulate the High Level Panel of Experts to an interesting and multifaceted report. The PSM is grateful for the opportunity to provide input to the report. This contribution brings together the collective inputs of the members of the PSM working group on Nutrition. Members will also submit individually their sector/company-specific comments.

We will start by making some general comments on the report before addressing the questions brought forward by the project team.

The present V0 draft report does not yet identify areas for recommendations, typology of healthy diets and a variety of other sections (such as “conflict of interest”). We understand that the project team is doing its best to move through a time sensitive process. However, we would like to indicate the PSM’s recommendation to submit the next version of the report or currently missing sections of the report through another round of public consultation.

From the point of view of the private sector, there appears to be a certain ideology that has crept into the report negatively affecting the role of the private sector. For example, when discussing pathways forward for emerging countries (Page 9) the report reads: “They do not have to follow the



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long and damaging path that many high-income countries have taken, involving the creation of food systems that maximize profits without an adequate focus on the nutrition consequences.” It is important to note that food systems respond to the stimulus created by regulatory environments. It would be, for instance judicious to put in perspective the low-fat policies that have been promoted in the past twenty years and the impact they have had on diets, nutrition and health. We should encourage nutritionists to be very measured when considering the unintended consequences of the recommendations they make.

In addition, the report demonstrates well that the design and implementation of policies and systems for food and nutrition systems require robust, comparative data over time and across countries. We believe that the report shows the need to establish a global research network to collect, analyze, and synthesize nutrition data.

Finally, we are quite surprised to see the section on “Movements for Nutrition”. This part of te report seems to have been directly sourced from a position by the Civil Society Mechanism. We find this section to be quite out of place and not well justified and would recommend removing it.


The PSM considers this first draft to be a good initial start. However, we would like to see more discussion concerning public-private partnerships, distribution, food quality, food safety and measures to reduce food waste. Malnutrition is a multifaceted issue which is not just “the result of interactions between poor diets and unhealthy environments,” as stated by the draft report (p. 9 line 10)”.

In addition, out of all the sections Chapter 4.2 is the most solutions oriented, whereas most of the report leading up to that chapter is more descriptive. When revising the document and adding recommendations, the report will surely become more solutions oriented. We therefore encourage a second consultation in order to capture ideas on how the solutions provided by the HLPE can be improved further, fulfilling the aims of the report.


Overall, the paper covers many relevant themes around on nutrition and food systems. Although, one may find that it adds little value to existing reports (such as Global Nutrition Report). There are a few areas that the PSM finds to be nor fairly described in the report. We would like to raise them:

International trade and markets

The report often fails to acknowledge that open and well-functioning local, regional and international markets and trade policies are fundamental to food and nutrition security. The Addis Ababa Action Agenda of the Third International Conference on Financing for Development notes that “national development efforts need to be supported by an enabling international economic environment,



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including coherent and mutually supporting world trade, monetary and financial systems, and strengthened and enhanced global economic governance.”20 Trade policy frameworks that foster open, dynamic, and competitive economies increase food security and improve nutritional outcomes.

Trade is an essential tool for ensuring commodities and food can be effectively and affordably distributed when and where they are needed and for promoting economic opportunities for producers21, in particular smallholder farmers and SMEs. Trade also creates opportunities beyond the farm because of the potential for value-added employment in food processing, marketing and distribution22. Trade policies also have a knock-on effect on farmers’ and countries’ decisions to invest in agriculture and to adopt new technologies. For further information about how trade can address nutrition, the PSM would recommend “High Level Task Force on Global Food and Nutrition Security: 2010 Comprehensive Framework for Action.”

Given that the discussion on trade needs to be more balanced, the PSM would like to recommend that Box 6 be revisited. The example of Samoa’s ban of turkey tails does not reflect the current situation. The tariff on turkey tails is no longer at 300 percent. PSM would encourage the writers of the report to revisit this section for accurateness.

The role of the private sector

The report lacks a robust presentation of how the private sector is addressing malnutrition and food security. For example, Scaling Up Nutrition(SUN) is mentioned but there is no mention of the SUN Business Network and its efforts. The paper seems to have a bias against transnational corporations. The private sector is a key actor in providing nutrition from investing in agriculture; to improving the social, economic and environmental practices in farming and the supply chain; to mobilizing, innovating, and finally delivering agricultural products and food. As an employer, the private sector also has a vital role in increasing the livelihoods of society as a way to address poverty, malnutrition and under-nutrition.

To identify sustainable and effective solutions for overcoming obesity, a multi-stakeholder approach is required, where industry should be part of the solution. A comprehensive approach which combines a range of tools is needed to reduce obesity.

Partnerships

The role of the private sector and the role of partnerships have been gaining recognition in the context of development strategies and international policy-making. Agenda 2030 (SDG Goal 2 “By 2030, end hunger and ensure access by all people, in particular the poor and people in vulnerable situations, including infants, to safe, nutritious and sufficient food all year round” and 17 “Strengthen the means of implementation and revitalize the global partnership of sustainable development”), the

20 http://www.un.org/esa/ffd/ffd3/wp-content/uploads/sites/2/2015/07/Addis-Ababa-Action-Agenda-Draft-Outcome-Document-7-July-2015.pdf

21 https://www.oecd.org/agriculture/ministerial/statements/ag-ministerial-2016-summary.pdf

22 OECD 2016 agricultural ministerial summary https://www.oecd.org/agriculture/ministerial/statements/ag-ministerial-2016-summary.pdf



https://www.oecd.org/agriculture/ministerial/statements/ag-ministerial-2016-summary.pdf

https://www.oecd.org/agriculture/ministerial/statements/ag-ministerial-2016-summary.pdf

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report of the Third International Conference on Financing for Development and the FAO strategy for partnership with the private sector provide a clear call to action for delivering global partnerships for sustainable development, and more specifically on delivering on SDG target 2.2: “By 2030 end all forms of malnutrition, including achieving by 2025 the internationally agreed targets on stunting and wasting in children under five years of age, and address the nutritional needs of adolescent girls, pregnant and lactating women, and older persons.”

Collaborations between the public and private sectors can contribute to public health, sanitary measures and above all creating sustainable and nutrition-enhancing food systems to end hunger and all forms of malnutrition as well as supporting and promoting healthy diets.

Partnerships are widely recognized as necessary to increasing the scope of financial and human resources in order to tackle nutritional challenges on a large scale. The private sector often partners with governments and researchers to innovate and create new tools for farmers that improve nutrition. It is essential for all stakeholders work together and develop a global food system that improves people’s nutrition in a sustainable way. The private sector is committed to public-private partnerships that support nutrition strategies and to preserving natural resources to continue to grow food which is necessary for nutrition.

Innovation

The innovation section should note that productivity improvements, which is important to food security, can be promoted by adopting technologies and sharing knowledge as much as new research and innovation. However, governments will need to promote policy and regulatory environments and effective and locally adapted technical advisory and extension services.

The PSM would recommend editing the section 3.2.2 that mentions the use of antibiotics for livestock. The text is currently not aligned with the HLPE report on Livestock where the issue of AMR is addressed in detail. We would recommend either aligning the language or directing the reader to the livestock report.


Overall, the PSM believes that the report does a good job in traversing issues of nutrition (which are also well covered in other reports), however, on the topic of food systems, the definition demonstrates a fairly narrow view of food systems and tends to focus on environmental issues, and does not adequately address issues from the social or economic dimensions.

In addition, there is a lack of consistency in terminology and recommentations throughout the report, which tends to create some confusion. For example, there is a lack of consistency about how animal source foods are represented in the report in terms of the nutrients they provide. In section 3.1.3, authors note that adolescent girls have inadequate intakes of iron, zinc, calcium, vitamin D, folate, thiamin and riboflavin. However, red meat and processed meats, sources of iron and zinc, are identified as “unhealthy” foods in 3.1.1.

The report should stick with diets/dietary patterns and the impacts on food systems. It should avoid focusing on individual nutrients. Terms, such as “healthy” or “unhealthy food” should be avoided.



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The PSM feels that the report gives greater emphasis to consumption rather than production. It should also reflect on how the food system has achieved for the majority of people on the planet to be fed appropriately. In defining food systems, the report seems to give more emphasis to the enviornmental aspect of sustainabiliy to the detriment of social and economic. For instance, Page 14 Figure 1 gives the impression that diets cause environmental impacts, which is a simplification that ignores the interlinked nature of the production and consumption side of food. Rather, consumer behavior in terms of purchasing certain foods is a driver for value chain actors that cause the environmental impact. The environmental impact will also depend on the drivers identified in the figure.

In addition, there is a strong focus on describing the environmental problems related to “industrial” agricultural production, e.g. already in the introduction (pg 9 row 31-34), whereas the environmental impact of inefficient small-scale farming, with high carbon footprints for individual foods, is not mentioned. Despite the focus on problems related to industrial and large scale production, chapter 4.2.2 focuses on changes aimed at increasing production in small-scale farms through sustainable intensification and agroforestry.

It may be good to refer back to the HLPE report Sustainable agricultural development for food security and nutrition: what roles for livestock? to get a balanced description of the sustainability challenges of all agricultural production systems.


Overall, the report does quite a good job at presenting nutrition controversies. However, the PSM would like to raise several key issues that would benefit from further presentation of the various positions of the actors in these controversies:

Sodium, fat and CVDs

Section 4.2.4 is of great interest in highlighting future research needs and raising, for instance, two important issues: sodium and CVD, and saturated fats and CVD. Both are areas requiring a lot of new research, as noted in the report. On sodium, this recent Lancet article ”Associations of urinary sodium excretion with cardiovascular events in individuals with and without hypertension: a pooled analysis of data from four studies23” attracted a lot of attention as it concluded that ”lowering sodium intake is best targeted at populations with hypertension who consume high sodium diets.”

Healthy food options

We note that the report provides a strong focus for systems that promote healthy food options with fruits and vegetables only. We feel that other food groups namely whole grains, dairy, protein also play an essential role and this should be highlighted more in the report.

Considerable emphasis is put on the “culprits” associated with unhealthy diets – sugar, fat, sodium. There is a lack of focus on food systems that promote availability and consumption of beneficial nutrients. Tone is more “restrictive” of unhealthy components vs. “enabling” of healthier choices.

23 http://www.thelancet.com/journals/lancet/article/PIIS0140-6736(16)30467-6/fulltext



http://www.thelancet.com/journals/lancet/article/PIIS0140-6736(16)30467-6/fulltext

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Behaviour change

The role of behavior change nutrition education as a necessary and effective complement to food systems in terms of supporting healthy eating patterns is really not addressed.

Taxation

The report refers several times to taxation systems on sugary drinks and high-caloric-density food, as they have been tried in various countries. The PSM would note that it is fundamental for these case-studies to provide evidence on the impact of these fiscal tools on obesity and NCDs. It would be good for the report to reference several studies done recently for instance:

Zhen C, et al noted that fiscal measures will significantly affect the population with a lower spending power. Some studies show that the taxation is regressive, as the lower and middle socioeconomic group spend a bigger proportion of their income on food taxes than the higher-income population.24 25

2014 study commissioned by the European Commission showed that taxes in some EU countries on foods and beverages considered high in fat, sugar, and salt led to increased administrative costs, declined employment in some cases, higher food prices, with no apparent improvement to public health.26

2014 Obesity Update27, the OECD Directorate for Employment, Labour and Social Affairs reported that their recent work on fiscal policies concluded that taxes on food and non-alcoholic beverages need to be carefully designed to achieve their intended effects. As some of their studies illustrated, the use of taxes for health promotion remains a politically sensitive subject, despite increasing interest by many governments.28

Data

Throughout the report data is given to support points, however the quality and/or uncertainty of the data is not made clear. Is the data strong, is there consensus on the point or is the available evidence weak, emerging or conflicting? Does the data cover all of the topic or is it limited in in scope?

24 Zhen C, et al. Predicting the Effects of Sugar-Sweetened Beverage Taxes on Food and Beverage Demand in a Large Demand System. (2013) American Journal of Agricultural Economics 96:1-25.

25 The European Competitiveness and Sustainable Industrial Policy Consortium, Food taxes and their impact on competitiveness in the agri-food sector, a study. 16 July 2014. http://ec.europa.eu/growth/tools-databases/newsroom/cf/itemdetail.cfm?item_id=7668 viewed August 29, 2016.

26 The European Competitiveness and Sustainable Industrial Policy Consortium, Food taxes and their impact on competitiveness in the agri-food sector, a study. 16 July 2014.

27 McKinsey Global Institute, Overcoming Obesity: An Initial Economic Analysis. November 2014. http://www.mckinsey.com/~/media/McKinsey/Business%20Functions/Economic%20Studies%20TEMP/Our%20Insights/How%20the%20world%20could%20better%20fight%20obesity/MGI_Overcoming_obesity_Full_report.ashx viewed August 19, 2016.

28 Obesity Update. OECD 2014. http://www.oecd.org/els/health-systems/Obesity-Update-2014.pdf accessed 30 August 2016.



http://www.oecd.org/els/health-systems/Obesity-Update-2014.pdf

http://www.mckinsey.com/~/media/McKinsey/Business%20Functions/Economic%20Studies%20TEMP/Our%20Insights/How%20the%20world%20could%20better%20fight%20obesity/MGI_Overcoming_obesity_Full_report.ashx



http://ec.europa.eu/growth/tools-databases/newsroom/cf/itemdetail.cfm?item_id=7668

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Additionally Chapter 4 lists a wide range of examples but many of them have not yet produced any tangible outcomes and as such should be removed from the report as they confuse and detract from the examples where data is evident.


It is also unfortunate that the section on typology is not available for review. This section seems of great importance and interest. The PSM would have greatly appreciated reviewing this typology, in particular, as it would provide a direct link between nutrition and food systems through healthy diets.

The approach by Gustafson et al. (2016) with the seven food system metrics of sustainable nutrition security presented a methodology to define sustainable food systems by combining many aspects. This assessment methodology defines seven metrics, each based on a combination of multiple indicators, for use in characterizing sustainable nutrition outcomes of food systems: (1) food nutrient adequacy; (2) ecosystem stability; (3) food affordability and availability; (4) sociocultural wellbeing; (5) food safety; (6) resilience; and (7) waste and loss reduction. The PSM wonders if there is value for the HLPE for creating a new typology.


Generally, the approach is quite fragmented per driver and missing one global approach for each food system that integrates all drivers. This is necessary in our opinion in order to take into account all the complexities and adopt the right decisions.

We would like to underscore the need to have clear terminology throughout the report; The emphasis should be put on diets, healthy eating patterns, and nutritious or nutrient-rich foods. We feel that the term “healthy foods” has little meaning and is open to broad and varied definition. The report mentions the term “healthier foods”, but does not provide a definition for this category of foods. However, from our point of view it is not foods but diets that should be considered.

Examples of healthy diets, such as the Mediterranean diet and DASH diet, are given throughout the report, but there is no mention of how this has been defined. In the definition of “Sustainable food system” does the term food security include both legs of food quality/quantity and food safety? As we feel that this should be the case.

Science should focus on the components and variability of dietary patterns that avoid chronic diseases rather than focus on single nutrients.

Regional balance: the report discusses the potential for low- and middle income countries that are currently shaping new food systems to influence the future development of those systems. We believe that the report should also cover high income countries with mature food systems, with choices identified and made to change current food systems in a better direction.


We believe the following topics should be strengthened in the final version of the report:



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SustainabilityIt would be useful to further emphasize and clarify that there is a wide range of environmental sustainability performance within all production systems, which depends on management practices and skills.

Food types and CVDWe have noticed that the report references positive research around plant-based diets and decreased risk of CVD and several types of cancer. However, it does not take into account some of the positive research around other commodity products such as dairy and decreased CVD risk.

When discussing the contribution of animals sourced foods to food and nutrition systems the CFS report of 2016 on sustainable agricultural development for food security and nutrition: what roles for livestock? should be referenced.

Dietary recommendationsToday new evidence emerges to suggest that historically dietary recommendations have tended to be too narrow in focus and new suggestions indicate that we need to shift from focusing on single nutrients towards a dietary pattern approach. It would be important for the report to put this aspect in perspective when presenting national dietary guidelines.

Animal Sourced FoodsASF provides nutrients that could be difficult to obtain in adequate quantities from e.g. plant-sourced foods alone, and the importance of these nutrients in relation to certain illnesses. However, the last sentence of Page 48, row 41 concludes that “overconsumption of processed meats and ASF high in saturated fats contributes to increased risk of obesity and NCDs.” And this statement is referenced to two scientific papers. We strongly suggest that this sentence be either changed or removed since it does not reflect the cited references (You and Henneberg, 2016; Bouvard et al., 2015). It is of utmost importance that the HLPE report makes statements and conclusions backed by scientific evidence and in this case this statement is not supported by the noted references. The sentence as it is written in the draft report draws erroneous conclusions regarding the health aspects of AFS. You and Henneberg conclude in their paper that “High meat availability is correlated to increased prevalence of obesity” however in this analysis fish, dairy and egg are not included in “meat”, hence the HLPE reports statement to ascribe effects of ASF to obesity or NCDs are not correct. You and Henneberg 2016 further describe their result “Our results show animal protein (excluding meat protein) is associated with the three stages of BMIs, but not as significantly as meat protein does may be because protein from dairy [73] and fish products [75] don’t contribute to body weight increase.” Additionally, Bouvard et al., 2015 includes only red and processed meat in their analysis, hence also here the reference to ASF (including fish, egg and dairy) are not correct. This reference discusses the impact on red- and processed meat on various forms of cancer, and not NCDs in general. In relation to the effects of dairy products on certain cancers, The World Cancer Research Fund indicates that the evidence for milk inducing a decreased risk of colorectal cancer is probable, this have also been concluded in a meta-analysis (Aune et al., 2012, Ann Oncol. Jan;23(1):37-45.

Cold ChainsPage 98, row28-48: The section mentions the importance of cold chains for vegetables, fruit and fish and we propose to also include dairy as an example of perishable food with a lot of nutritional value. Dairy chains are being developed around the world, providing access to market for small scale



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producers in low- and middle income countries, contributing to better food safety and improved nutrition.


We feel that the most compelling examples given are those that provide the information of what has been achieved. Even if those examples of programs that just started are interesting we would suggest deleting some of these in order to decrease the number of examples. The PSM would like to propose different collections of case-studies:

The PSM hosted last April a Partnership Forum on Nutrition. This event featured over 20 case-studies of nutrition interventions by the private, public sectors and civil society. The report is available here: http://agrifood.net/documents/nutrition/114-report-partnerships-forum-2016-nutrition

FoodDrink Europe has a website with informative overview of over 150 case studies detailing actions undertaken by Europe’s food and drink sector to help fight obesity and related non-communicable diseases www.eatandlivewell.eu

Belgium Stop the Salt Campaign: Successful PPP with confirmed reductions in salt intake levels: http://www.bordbia.ie/industry/manufacturers/insight/alerts/Pages/Upto30lesssaltinBelgianfoodproducts.aspx?year=2013&wk=46

EPODE should be mentioned as a community based nutrition program: http://epode-international-network.com/

School Milk Programs: Around the world, school milk programmes exist to encourage the consumption of milk and milk products by children in order to make a positive contribution to their nutritional status, to address issues of malnutrition and to engender healthy eating habits. As a result of these programmes, the macronutrient and micronutrient intakes of millions of school children around the globe can be improved through the consumption of nutrient-rich milk and milk products. IDF worked jointly with FAO to map out examples of school milk programs worldwide more details can be found here: http://store.fil-idf.org/wp-content/uploads/Publications/Freeofcharge/Bulletin-no480-2015_The-contribution-of-school-milk-programmes-to-the-nutrition-of-children-worldwide.CAT.pdf

10. Section 4.2.2 on “Institutional Changes and Governance Across the Food System Movements for 10 Nutrition” requires more work, and more inclusion of evidence and of the various players. Any inputs on this section are most welcome.







http://epode-international-network.com/

http://epode-international-network.com/

http://www.bordbia.ie/industry/manufacturers/insight/alerts/Pages/Upto30lesssaltinBelgianfoodproducts.aspx?year=2013&wk=46

http://www.bordbia.ie/industry/manufacturers/insight/alerts/Pages/Upto30lesssaltinBelgianfoodproducts.aspx?year=2013&wk=46

http://www.eatandlivewell.eu/

http://agrifood.net/documents/nutrition/114-report-partnerships-forum-2016-nutrition

http://agrifood.net/documents/nutrition/114-report-partnerships-forum-2016-nutrition

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PSM believes that the report is scientifically accurate while making it accessible to non-experts. We believe that the lack of consistency in terminology throughout the report creates, however, confusion and adds unnecessary complexity for the reader, and for HLPE when creating future recommendations. One example is the use of “dietary pattern” vs “eating patterns”, and another relates to the topic of processed foods. Processed foods are not clearly defined in the report, although a good start is given at page 17 row 14-30. E.g. processed foods are discussed in the light of providing benefits to nutrition and food systems through increased access to nutritious foods by enhanced safety and shelf-life; as well as improved palatability and nutrient bioavailability of staple foods, and reduced food loss. In the other end hyper-palatable, nutrient-poor, high-energy processed foods rich in fat, sugar and salt are associated with negative outputs such as increased risks of developing non-communicable diseases. The concept of ultra-processed foods is introduced in table 1, with following statements in page 60 row 22, without any further explanation of the term, in relation to the already mentioned “processed foods”. We believe that this inconsistency needs to be addressed and further clarified.

We fully support chapter 1.1.3 Healthy Diets that comprehensively discusses the complexity of healthy diets. We are impressed by the HLPE approach to include characteristics that goes beyond the single nutrient focus, traditionally used to describe healthy diets to also include the important aspects of taste, balance, accessibility and affordability. However, we see a need to add a definition box of healthy diets/un-healthy diets. Both Diets and sustainable diets are defined in the report (def 4 and 5). The statement “Diets for health contain an appropriate level of food energy, help achieve nutrient adequacy, support growth and maintenance of health across the life course, and reduce the risk of chronic/non-communicable diseases” (page 18 row 41-43) are close to a clear definition. It is important that the meaning of the term healthy diets as described in chapter 1.1.3 is kept throughout the report.


PSM is satisfied with the strong references to biofortification and food safety. Too important issues for improving nutritional outcomes.

The PSM believes that the below topics are not mentioned in the report and would benefit from being included:

Supporting farmers: A more robust discussion on supporting farmers and their local ecosystem is critical. Farmers need a reliable supply of agriculture products that increase the efficiency of their land. They also need better education and training to boost their soil fertility and access to financing to allow access to markets and support any increased agriculture output whether its destination is local, regional or international.

Water access: Water scarcity is also another important challenge particularly in Africa. Roughly 2/3rd of African lands are located in arid or semi-arid areas. Meanwhile in other areas of Africa where there is water, often there is lack of storage and delivery systems. Solutions are needed to reduce water waste and improve supply. Investments in logistics and



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good governance would help with ensuring efficient food production, storage and distribution.

Consumer behavior: Understanding how to drive consumer behavior. (see also Page 61 - graph - how can consumer behaviors be changed) is very important future research areas.

Alternative sources of protein: the need to develop alternative sources of protein. For example on page 109 line 1 there only reference to meat products is made.

The role of fibers: could be expanded further.

There is an unbalance in how the environmental challenges of different production systems are described. The environmental challenges with animal food production systems are mentioned throughout the report, and explored in detail on page 48, whereas the challenges with other food production systems are not addressed to the same extent. This description leads to the erroneous conclusion that animal agriculture, and ruminants in particular, is the only sustainability challenge for current food production systems. We believe a full description of the environmental challenges of all production systems should be provided, including for various crops or production types.

63. Ana Islas, FAO, ItalyThis is a very throrough and complete report of the relationship between food systems and nutrition. I would have liked to also view the chapter on the typologies fully developed. I do, however, have a few comments that are all included in the attached document, mainly related to the consumer/demand side of the report.

Comments in track changes:

http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/HLPE-Nutrition-and-Food-Systems_Draft-V0-24_October_2016AI.pdf

64. Ann Steensland, Global Harvest Initiative, United States of America

Attached are comments on behalf of the Global Harvest Initiative. Our comments address question number 4: Are production systems and their role in shaping diets and nutrition outcomes adequately address?

We feel that some additional work can be done in this area. In it's current format, the report reflects primarily two types of agriculture - "industrial" agriculture and agroecology. In our comments, we express our concerns about the characterization of large-scale production agriculture in the report, especially as it relates to the sustainability of food systems. We offer some data-driven insights, based on data from FAO and USDA, on the relationship between agriculture and sustainability, especially in light of climate change. We encourage the authors to adopt a more nuanced approach to its discussion of agricultural production so that it more accurately reflects the complexities and challenges of producing sufficient nutritious affordable food for a growing world.





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We also offer case studies for consideration that highlight public-private-producer partnerships to increase the productivity, sustainability and nutrition of food systems, while protecting the natural resource base and helping farmers adapt to climate change.

Ann Steensland

Deputy Director, Global Harvest Initiative.

Pg 9, Lines 31-33

“Global food systems from industrial production through excessive consumption and waste, are not sustainable, resulting in significant environmental degradation and pollution, and extensive damage to natural systems.”

This paragraph and other sections of the report create a false equivalency between so-called “industrial” scale agricultural production and environmental degradation and pollution. Scale is not the primary determinant of unsustainable practices and should not be linked in a way that indicates implicit or direct causality. Farmers of all scales cause environmental damage by overusing or misusing inputs such as water and fertilizer or by failing to use soil conservation techniques leading to land degradation.

In many countries, deforestation is driven by small and medium-scale farmers who need the additional land to increase their output. The figure below, based on data from FAO Stat highlighted in FAO’s 2016 State of Forestry Report, shows that between 2000-2010, high income countries (home to most of the “industrial agriculture”), forested area increased, while the amount of agricultural land decreased. These gains in forest area were driven by innovations and practices that allowed farmers to increase the amount of agricultural output by using few resources, including land. See page 21 of the 2016 Global Agricultural Productivity Report.



http://www.globalharvestinitiative.org/index.php/gap-report-gap-index/2016-gap-report/

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There is a similar story for livestock. The figure below from the 2015 Global Agricultural Productivity Report (pg. 57) uses FAO data to show that North America and Europe produce 50 percent of the global milk supply, but have only 19 percent of the global population of dairy cattle. On the other hand, Africa and Asia account for more than 60 percent of the dairy cattle population but produce only 32 percent of the global milk supply. While improvements are needed at all scales of the livestock sector to reduce GHG emissions, improving milk productivity per cow in low and low-middle income countries, where the cattle population is 3 times larger than in high income countries, is urgently needed.





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The chart below shows how milk output and milk productivity per cow have increased dramatically in the U.S. while the number of dairy cows has remained relatively flat. (2015 Global Agricultural Productivity Report, pg. 20) Genetic improvements from R&D, efficiency and better animal care and health practices account for this.





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Throughout the report, there is an assumption that decreasing the scale of production will inherently reduce the environmental degradation attributed to agriculture, an assumption that is not supported by the evidence.

Field to Market’s Environmental and Socioeconomic Indicators Report (2012) shows that in the U.S., resource use per unit of production and greenhouse gas emission per unit of production for six major crops (corn, cotton, potatoes, soybeans and wheat) decreased substantially from 1980 to 2011. (Page 9.)

Cotton is an excellent example of this trend. The U.S. cotton industry is the third largest in the world, generating more than $25 million in goods and services annually and employing some 200,000 people. Since the 1980s, cotton yields in the U.S. have increased by 55 percent, while at the same time, the environmental impact of cotton production has decreased substantially:

acres of land used per pound of cotton produced has declined by 30 percent; total tons of soil erosion per pound of cotton declined by 68 percent; irrigation water per pound of cotton produced declined by 75 percent; energy use per pound of cotton produced declined by 31 percent; and greenhouse gas emission per pound of cotton produced declined by 22 percent.

This is depicted in the following figure for the Global Harvest Initiative’s 2015 Global Agricultural Productivity Report (GAP Report): Building Sustainable Breadbaskets, pg. 35.



http://ww2.fieldtomarket.org/media/2016/06/2012-National-Indicators-Report-Executive-Summary.pdf

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Similar trends can be seen in rice production in the U.S., as demonstrated in the figure from the 2016 Global Agricultural Productivity Report, page 19.

GHI strongly encourages the HLPE to incorporate a more nuanced understanding of the role of large-scale production agriculture into its analysis and to emphasize that improvements need to be made at all scales of production to make our food systems more nutritious and environmentally sustainable.





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Pg. 9, line 34

“Industrial farming practices cost the environment some USD3 trillion per year (FAO, 2015a).”

The above statement needs to be qualified as an estimate and readers should be told to be treat this statistic with a degree of caution. The source of this data, National Capital Impacts in Agriculture: Supporting Better Decision-Making (FAO, 2015), states, “The total environmental costs calculated in this study represent an informed estimate and should be treated with a degree of caution. This is because the calculation of non-market natural capital costs, on a global scale, requires a number of assumptions.” (pg. 8)

The report also neglects to mention some of the practices and technologies that are enabling farmers of all scales adapt to and even mitigate climate change. The infographic below outlines some of these practices. See pg. 17 of the 2016 Global Agricultural Productivity Report.




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Pg. 45, lines 10-15

3.2.1 Biophysical and environmental drivers

Large-scale agricultural producers are not the only ones who misuse or overuse fertilizers and crop protection products. Crop fertilization is one of the most important productivity-enhancing practices for farmers, so it is essential to educate farmers of all scales on how to identify and maintain the right mix of nutrients for their soils and crops. Properly balanced crop nutrition allows plants to use nutrients and water more efficiently, resulting in higher yields. Applying the right amount of fertilizer at the right time helps maximize nutrient uptake and reduce or eliminate nutrient run-off. Rather than condemning large-scale producers and chemical fertilizer products outright, we suggest shifting the focus to the need the need for access to fertilizer and training, so farmers apply the right fertilizer, in the right amount, at the right rate and at the right time. Accessing affordable fertilizer is also essential for small-scale farmers who are diversifying their crops

The 4R Nutrient Stewardship Certification Program in the Western Lake Erie Basin of the United States has helped participating farmers reduce annual nutrient and sediment losses by approximately 7 million pounds of nitrogen, 1.2 million pounds of phosphorous and 488,000 tons of sediment from 2009-2014. (For more see pg. 36 of the 2015 GAP Report.)

Pg. 93, Line 37-38

4.2.1 Technology - New Fortification Technologies – Considerations

“There are ethical issues that need to be resolved with genetic modification.”

This statement is vague and non-specific, without any clarifying information, sources, examples or data. If the HLPE wishes to engage in the debate around GMOs, it will need to do so completely, thoroughly and in a science-based manner. Biotechnology, including genetic modification, is essential to achieving productive, sustainable food systems. The benefits of these technologies are often greatest for small-scale and emerging farmers. On average, GM technology adoption has reduced chemical pesticide use by 37 percent, increased crop yields by 22 percent and increased farmer profits by 68 percent with yield and profit gains higher in low-income countries than in high-income countries. (Wilhelm Klumper and Matin Quaim, “A Meta-Analysis of the Impacts of Genetically Modified Crops,” PLoS ONE 9(11), 2014.)

At the Biotechnology Symposium at FAO in February 2016, Director General de Silva made a strong statement endorsing the important role of all forms of biotechnology, including genetic modification, in achieving global food and nutrition security.

“I am using these words to highlight the importance of considering every possible solution to achieve world food security for all in the years to come. We must count on a broad portfolio of tools and approaches to eradicate hunger, fight every form of malnutrition and achieve sustainable agriculture in the context of climate change… Now it is time to discuss and analyse what agricultural biotechnologies has to offer…Agricultural biotechnologies are much broader than GMOs. Biotechnology gives us options and improves our capacity to act and respond in many different areas. We will address fermentation processes, bio-fertilizers, artificial insemination, the production of vaccines, disease diagnostics, just to name a few.”




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Pg. 98, Lines 4-26

4.2.2 Food System Changes – Production

This section focuses exclusively on the benefits and controversies of agroecological production systems versus conventional production methods. While an important discussion, there are additional paradigms of agricultural systems go beyond debates about whether farmers should be producing maize or fruits and vegetables.

One Health is an increasingly adopted paradigm for public health and agriculture that acknowledges the symbiotic and complex interactions between the health and productivity of humans, animals and the environment. The approach uses integrated risk management with a focus on prevention, intervention and rehabilitation in order to promote health and reduce disease.

One Health also promotes healthy microbiomes – communities of microorganisms that live in or on soils, plans, water, the atmosphere, people and animals. Microbiomes are essential for promoting soil health, maintaining water quality, limiting the spread of infectious diseases, improving human and animal nutrition, preserving the efficacy of tools used in human and animal medicine, and conserving natural resources.

Microbial solutions applied to seeds improve root growth and crop uptake of essential nutrients and water, reducing the burden on the natural resource base. Solutions that improve animal health make livestock more productive and reduce their contributions to GHG emissions, with helping reduce the need for costly medical interventions to address disease. Conservation and precision agriculture practices help soils retain water, reduce costs and improve soil health. Appropriate nutrient application stimulates the growth of nutrient-rich fruits and vegetables while preserving water quality.

This approach offers an opportunity to bring together inter-disciplinary research, knowledge and experience, providing holistic solutions for healthier people, healthier animals and a healthier planet. (For more on One Health, see the 2016 GAP Report, pgs. 40-43)

CASE STUDY SUGGESTIONS

Policies and programs targeting the food system drivers

2015 GAP Report, pg. 36

To help keep phosphorous on farmland and reduce loss to water, The Mosaic Company and The Mosaic Company Foundation are partnered with The Nature Conservancy (TNC) in support of a multi-sector initiative to pilot the 4R Nutrient Stewardship Certification program. The program is governed and guided by the 11-member Nutrient Stewardship Council, a diverse set of stakeholders from business, government, university and non-governmental sectors with a common goal of maintaining agricultural productivity while also improving the long-term quality of Lake Erie and its contributing watersheds. The Western Lake Erie Basin (WLEB) spans 7.2 million acres across Indiana, Michigan and Ohio and provides drinking water to 11 million people and habitat to more than 50 percent of Great Lakes fish species. The 4R Nutrient Stewardship Certification Program encourages agricultural retailers, service providers and other professionals in the Western Lake Erie Basin to



http://www.globalharvestinitiative.org/GAP/2015_GAP_Report.pdf


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adopt proven nutrient application best practices of the 4R concept: Right Nutrient Source (matching the fertilizer type to the needs of the particular crop) at the Right Rate (optimizing the right amount for the particular crop) and Right Time (applying fertilizer when it can be optimally used and avoiding application on frozen ground or when a large rainfall is forecast) in the Right Place (apply precisely where the fertilizer is needed).

Adoption of these best practices helps farmers achieve sustainable plant nutrition management while also considering water quality. The approach also provides a science-based framework for sustained crop production, while considering specific individual farms’ needs. To date, 4R-certified nutrient service providers deliver service to 1,580 farmers on 630,000 acres in the Western Lake Erie Basin. In addition, 50 nutrient service providers have begun the 4R certification process. The Ohio AgriBusiness Association estimates that the program will hit the million acre mark in WLEB-4R certifications by late 2015. Studies show that between 2009 and 2014, the new steps farmers are taking with collaborative assistance of the USDA National Resources Conservation Service have reduced annual nutrient and sediment losses by approximately 7 million pounds of nitrogen, 1.2 million pounds of phosphorus, and 488,000 tons of sediment in the Lake Erie Basin.61

Biotech Maize Reduces Labor for South African Women Farmers

2016 GAP Report, pg. 40.

Women are the quiet drivers of change towards more sustainable production systems and a more varied and healthier diet. Women comprise an average of 43 percent of the agricultural labor force of low-income countries, and up to almost 50 percent in Eastern and Southeastern Asia and SubSaharan Africa. If women farmers could access the same productive resources as men, they could increase yields on their farms by 20–30 percent, lifting 100–150 million people out of hunger. 9

Labor demands on women during peak agricultural cycles of land preparation, planting and weeding actually hinder the ability of farmers to increase crop yields and to diversify their farm operations. Given the important role women small-scale farmers play in agriculture across the African continent, and as biotechnologies begin to be adopted by farmers of all scales, a central question arises: does GM crop technology provide gender differentiated benefits?

South Africa is the only country where small-scale farmers have been growing genetically modified maize, their primary subsistence crop, for more than a decade. In 1988, Bt maize seeds (maize hybrids with a Bacillus thuringiensis gene inserted making them resistant to stem borer pests) were approved. Herbicide tolerant (HT) maize seeds that enabled farmers to fight weeds and improve soil health came on the market in 2003. Then in 2009, a maize variety containing both the HT and the Bt traits (“stacked” maize) was approved and began to be adopted by farmers. By 2012, 85 percent of all maize grown in South Africa was GM: Bt single trait maize covered 29 percent of maize area; HT single trait maize covered 13 percent; and stacked maize with both Bt and HT traits covered 43 percent of all maize area.

The International Food Policy Research Institute (IFPRI) and the University of Pretoria in South Africa conducted research in small-scale farmer communities over eight cropping seasons as well as qualitative research with men and women in separate small groups to examine the relative gender impact of GM maize adoption in Kwa Zulu Natal (KZN) Province. These farmers were selected




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because they had previously participated in demonstration workshops organized by Monsanto in 2001 and had adopted Monsanto maize with Bt, HT and stacked traits.

In comparison with conventional maize producing households, the research found that both men and women preferred the stacked and HT trait maize varieties because these enabled them to save time and labor while providing higher yields. Adult female household members reduced weeding time by 10 to 12 days, a significant time savings that enabled them to spend more time growing nutritious foods or taking care of their families.10 This represents a substantial reduction in physical drudgery, as women normally perform this particular task in the maize production cycle. Women reported being able to spend more time working in their own or community vegetable gardens or on other household work.

Climate Friendly Land Use in Action


Many farmers are eager to adopt sustainable and climate-friendly land-use practices, but need help in planning their farm and forest operations. The goal is to grow more productively on existing land, improve soil carbon retention, and manage water resources effectively rather than expanding production to fragile forests or less suitable soils.

Farmers, conservation organizations, governments and private sector agribusiness have been working together in the Cerrado savanna region of west central Brazil since 2008 on climate-friendly agriculture and land use practices. The second largest ecosystem in Brazil after the Amazon, the Cerrado grasslands is an area of enormous biodiversity, with more than 10,000 plant and animal species. Since the early 1980s, the Cerrado has begun its transformation into a major agriculture zone, with soy and beef production for local consumption and export.

To protect biodiversity and reduce conversion of important natural Cerrado vegetation to agriculture, Conservation International (CI) and Monsanto work with local governments, farmers and communities to prevent illegal deforestation, improve crop yields on existing lands and restore critical areas that, under Brazilian law, should not be farmed. This integrated strategy combining conservation and improved agriculture became known as the “Sustainable Agriculture Landscape” approach. By 2013, the partnership helped create four new protected areas totaling 32,000 hectares, piloted innovative technologies to restore 10,000 hectares and initiated an informal dialogue among producers, government and agribusiness to build alignment and consensus around sustainability challenges and opportunities.

Strengthening the Tomato Value Chain to Improve Nutrition in Nigeria


In Nigeria, nearly 30 percent of children under the age of five are vitamin A deficient, a condition that can lead to blindness and increased risk of disease and premature death.16 Tomatoes are an excellent source of vitamin A and Nigerian farmers produced 1.8 million metric tons of tomatoes in 2010, making their country the 16th largest producer in the world.17 But the tomato supply chain is poorly organized and underdeveloped, and as a result half of the annual tomato harvest never





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reaches the market. 18 Meanwhile, Nigeria imported 150,000 metric tons of processed tomato products in 2014, valued at $160 million.19

The Geneva-based Global Alliance for Improved Nutrition (GAIN) has convened a coalition to develop solutions for reducing tomato losses that are market-based, nutritionally focused, locally adaptable and financially sustainable. The Postharvest Loss Alliance for Nutrition (PLAN)20 brings leaders from government, finance and academia together with representatives from Nigeria’s tomato industry, including aggregators, processors, packagers, and cold chain operators. The Alliance is targeting specific elements in the supply chain for improvement: crating and cooling technologies to protect prevent spoilage; a larger more reliable fleet of transport vehicles; new processing technologies and financing models to increase capacity; and outgrower schemes to link processors with farmers.

Growers, traders and processors also need technical assistance in negotiating contracts, tracking inventories, re-tooling and maintaining machinery, food safety protocols and networking within the industry. Businesses with the capacity to scale-up and innovate are receiving technical assistance and access to grants or affordable financing so that they can experiment with technologies and implement new approaches.21

Strengthening the tomato value chain will not only give Nigerian producers access to a robust and growing market, it will also provide low-income consumers a safe, affordable source of nutritious food that will improve the health of millions of children.

65. Stineke Oenema, UNSCNDear members of the HLPE team,

This is a zero draft of the document, nevertheless it already gives a quite comprehensive overview of issues. I feel this zero draft is promising but would benefit from a more "systemic" view.

I have read quite a few of the comments and since I don't want to repeat others I keep my comment very brief:

The team is still working on a categorisation of food systems. This work may benefit from a report that was published by UNSCN earlier this year: "Investments for healthy food systems", available at: unscn.org. The UNSCN paper about "impact measurements of food systems policies" may also proof useful for the project team. This paper is also available at unscn.org

Related to chapter 4: This chapter would need a strong link to the categorisation of food systems. What is currently lacking in chapter 4 is the analysis of how the examples relate with, fit or don't fit in a certain food system. At this moment the cases and examples are reported on at project level, or programme level at most, without any relation to the entire food system. Not all examples are relevant to all food systems and the question the chapter would need to answer is which examples are capable of tipping food system(s) in such a way that the renewed food system delivers healthy and systainable diets to all people at all times. A related question that needs answering is how much critical mass ( provided through the examples and cases in chapter 4) is needed to create that tipping point.



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Related to the level of "simplicity"of the report: I believe the authors need to take care not to mistake valuechains for food systems. These are two very distinct concepts, where a valuechain can at most be a ( small) part of a food system.

I am looking forward reading a next version of the report.

66. Theresa Jeremias, CARE International, GermanyDear HLPE Steering Committee,

please, find attached comments to the HLPE report on Nutrition and Food Systems by CARE International.

We remain available for further consultations.

best regards

Theresa Jeremias Food and Nutrition Security Advisor(Policies and Programmes) CARE Deutschland-Luxemburg

5 December 2016

CARE Submission to the Zero Draft Report on Nutrition and Food Systems of the High Level Panel of Experts on Food Security and Nutrition

CARE welcomes the open consultation process and the opportunity to provide comments on the High Level Panel of Experts on Food Security and Nutrition (HLPE) V0 Draft Report on Nutrition and Food Systems.

If we are to achieve the new Sustainable Development goal of ending hunger and malnutrition by 2030, particularly in the face of climate change, we must address these underlying inequalities in food systems and scale up investments in nutrition, noting that this requires much more holistic and comprehensive approaches which target those populations who are most in need.

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CARE general reflections on the HLPE V0 Draft Report on Nutrition and Food Systems

CARE congratulates the authors for having taken on the big task to explore the links between food systems and nutrition and for having compiled and analysed tremendous amount of information in this V0 Draft Report. CARE hereby would like to provide some input and reflections with the aim of further advancing this report.

The report should be based on human rights, in particular the Right to Food. The analysis should be deepened by looking at the food system through a “nutrition lens”. This means looking at nutrition throughout the life-cycle giving special attention to vulnerable groups (e.g. pregnant and lactating women and children under 5) which are only mentioned late in the report. This demands an exploration which focuses on gender and power relations at all levels of society. Attention to small



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scale (agriculture) production systems should be strengthened and the opportunity be taken to address critical areas of social norms and barriers or marginalization among small-scale producers who are paradoxically the most vulnerable to chronic malnutrition.

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Comments to the questions offered by the authors


To arrive at a range of sustainable food system policy choices which take into account the environmental and nutritional consequences, it would be helpful to lay out at the beginning of the reports in simple terms what a food system is and what types of food systems currently exist and how they need to be altered to improve human nutrition and health in a sustainable manner with the least negative consequences for the environment prior to the comprehensive conceptual framework presented (e.g. UNSCN 2016 Discussion Paper - Investments for Healthy Food Systems).

Solutions derived from this analysis should be provided more clearly and earlier in the report. The evidence (meaning the case studies) can be presented in a different chapter or shall be cut down to make the report more easily readable.

The paragraphs on the elements of food systems establish the link to diets but not consequently make the link to nutrition. Vulnerable groups like infants and young children under 5, pregnant and lactating women and women of reproductive health should be mentioned earlier as already argued above.

Consumer behaviour is not sufficiently explained and the different strategies to alter diets should be laid out (e.g. SBCC, nutrition education) as it has program and policy implications.


Alternative food production systems (e.g. agroecology) should be explored in contrast to the industrial model as well as further insight given to the topic of food processing.


The food environment should be central to the framework. The elements of the “diets” box in the framework do not correspond with the definition 4 (p.12).

A link should be given from the production system Nutrition should be defined as it might be also useful to explain the concept of healthy diets as this term is used throughout the report without a



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clear definition. One could also contrast it with known unhealthy diets like the Western diet. (answers also Q11)


The production systems deserve more attention as argued above.


More emphasis could be given to the different future challenges of the urban food systems in contrast to rural food systems.


In need of strengthening

In the Natural resource degradation and ecosystems section under 3.2.1 Biophysical and environmental drivers, the treatment of chemical inputs should be strengthened. The paper suggests that the problem with synthetic inputs is pollution only and, though the contribution of agriculture to global emissions is addressed later, the energy-intensity factor and its contribution to GHGs is avoided in the fertilizer point. This section provides space to bring in food sovereignty and human rights as well as adherence to the voluntary guidelines on the tenure of land, fisheries and forests.

CARE welcomes the section on climate change (p.45f.). Climate change is expected to prolong existing and create new poverty traps, the latter particularly in urban areas and emerging hotspots of hunger. Without urgent and ambitious action, the world is at risk of the breakdown of local food systems, migration, and increased risk of food insecurity, particularly for poorer populations, conflict, and the loss of rural livelihoods due to increased water scarcity. Small-scale food producers- and especially women- deserve a new strategy to support their agricultural efforts in the face of climate change. The section provides useful statistics and arguments. CARE suggests to include an analysis and understanding of water insecurity as a driver of risk. Rainfall variability is one of the primary variables of changing climates. Households’ capacity to adapt to changing climate or environment conditions should be included as a variable as well. Increasing incidence of post-harvest loss – or at least complications with post-harvest management as a result of climate change and seasonality should be reflected upon and could be linked to the wider loss and damage agenda: At what point is a climate-affected ecosystem redundant in terms of its capacity to adequately nourish people - and where do these people go and what do they do?

CARE appreciates the section on Gender under 3.2.4 socio-cultural drivers (p.57f.) which lays out important factors related to women’s status and malnutrition and on Women’s empowerment (p.103). Inequality shapes who has access to food and the resources to grow it and buy it. It governs



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who eats first and who eats worst. Women are both key players in food systems and a significant portion of hungry and malnourished populations around the world. Therefore, CARE recommends that a gender lens should be applied throughout the HLPE’s examination of food systems and nutrition. The exploration of actionable solutions must prioritize approaches to promote gender equality, to empower women and realize women’s rights.

In need of shortening

The whole report could be strengthened by linking the section 2 on malnutrition can be weaved into the section on diets. The burden of malnutrition is presented elsewhere and for this report we do need to focus on an analysis of the food system and how it impacts nutrition throughout the life-cycle in particular the vulnerable groups (pregnant and lactating women etc.). The solutions presented in chapter 4 should come earlier and be presented more concisely as they are of utmost importance. They could be immediately provided by “walking through” the food system instead of describing the conceptual framework and then having to repeat the elements in parts again when presenting the solutions later on.

12. Are there any major omissions or gaps in the report? Are topics under- or orver-represented in relation to their importance?

The HLPE report should address more explicitly the role of small-scale food producers in food systems, given the significant role they play in providing food around the world and the fact that they are burdened the most with malnutrition. Small-scale producers already struggle to grow, catch, or buy enough nutritious food because of degraded soil, small land plots, depleted fish stocks, water scarcity, and lack of diverse foods in the market or low incomes. They often lack access to secure land tenure or access to natural resources, financial and extension services, information about weather, post-harvest storage, and markets.

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Specific comments to HLPE Report on Nutrition and Food Systems – Theresa Jeremias, Food and Nutrition Security Advisor, CARE

Introduction

Line 11, p.9: from “farm to flush” instead of “farm to fork” as mentioned in UNSCN report 2016 “Investments for Healthy Food Systems” (p.9) which includes the consumption and disposing of waste and WASH; In addition the utilization / digestion aspect is included (important for EED)

Line 5/16, p.10: “key decision makers in the public and private sectors.. should feel empowered to..” - it is small scale farmers, consumers, women (claim holders) that need to be empowered

Line 17 and 26, p.10: “..to shape their food system” and “nutrition in the food system space”– food system has not been explained in the introduction so it is no clear what kind of food system from the range of options can be meant here and what the food system space is

1.1.1 Conceptual Framework

Line 5, p.13: “the food value chain” – can this definition be in a box as well?



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Figure 1, Conceptual framework:o The name should be “Conceptual framework of food systems for diets and nutrition”

to keep the logical order of the diagram itselfo Link missing from production systems to environmental impactso Include “education” into “demographic drivers”

P.16: In the explanation of socio-cultural drivers: the link should be made to infant and young child feeding practices which are influenced by mothers’ knowledge, attitude and practices

P.16: in the explanation of demographic drivers the link should be made of degree of mother’s education and undernutrition

The explanation make the link to diets but not all the way down to nutrition, which is the focus of the report!

1.1.2 The elements of food systems

p.15, Line 11,: Figure 1 instead of Figure 1.1. p.16, Line 34,: “food acquisition, preparation and consumption” is not reflected as such in

the conceptual framework p.16, Line 39: “farmers” – please distinguish small-scale farmers here as the world’s main

food producers p.16, Line 47: “crops”- which crops are meant here? p.16, Line 48: “.. important for healthier diets is diversification” – please explain what is

meant since before it says that a prioritization of fruits and vegetables will take resources away from production of other crops – yet diversification also includes the increase in production of locally available fruits and vegetables

p.16, Line 51: Storage – can the relation to food loss post-harvest through inappropriate storage or non-existing storage?

p.17, Line 10-13: “healthier diets” – I would say “nutrition outcomes and health” for the link to food safety; you can eat a “healthy” food such as egg or a vegetable when it is contaminated with a bacteria (salmonella etc.) then that impacts your health (diarrhoea, mortality) and can in the long-term affect your gut which in turn affects your nutritional status; the relation between healthy diet and food waste and loss is unclear – would it not be sustainable diet here? The word diet seems to be used instead of the better word “nutrition”.

P.17, line 22: it is a repetition of line 10. – also the concept of a healthy diet is not explained until p.18, but it is used here – should be a definition box

P.18, Line 24 ff.: no mention of nutrition education at schools to inform students / adolescents, and health centres/ antenatal clinics where key information on infant and young child feeding practices are given, yet alone the link to traditional healers, grandmothers, health extension workers etc. who provide information on health and nutrition

P.18, Line 36: “composition, quality and safety” is part of the “diets” box, composition in terms of quantity and diversity- can it be taken out of the food environment box and explained under “diets” (not “healthy diets”)? Otherwise you have a duplication here

Consumer behaviour is not explained and the influence of different actors in the home (grandmothers), community (traditional healers), society as a whole (food industry)



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1.1.3 Healthy diets

Title – why not “diets”? – according to the conceptual framework There are also unhealthy diets like the Western diet which should be mentioned here. This whole section should probably come before the elements of the food systems together

with an explanation of nutrition since the term healthy diets is used before in this section P.19, Line 20: more research is needed – what about the research on (1) changes of diets

after migration and the influence of a Western diet, (2) studies on health benefits of traditional diets?

P.19, Line 24: studies on food processing and preparation – enhancement of bioavailability of certain micronutrients exist e.g. iron and vitamin c

1.2 Typologies of food systems

P.21, Line 9: IFPRI 2015 is not listed in the reference section What about the typology of food systems in the UNSCN September 2016 report on

“Investments for healthy food systems”, table 1., p.11 ? P.23, line 3: “in Chapter 4, we use the typologies” – it looks like the “elements of the food

system are used not typologies since they have not been developed yet

2 The Burden

p.24, Line 16: “unique programmatic challenge” – yes in a way it does, yet the solution to both types of malnutrition is an adequate and appropriate nutritious diet (micronutrient rich, low in sugar etc.) according to the age group which requires behaviour change of caregivers, changes in the food environment, diversification of home food production etc. – the problem is that overweight and stunting are usually not tackled in the same programmes and the global focus is still on undernutrition

p.27, Line 24: Maybe one can provide additional facts here that severe stunting has a higher mortality risks than moderate wasting. Data from Tanya Khara & Carmel Dolan, July 2014 http://files.ennonline.net/attachments/1862/WAST_140714.pdf

2. Severely wasted - 11.6 times more likely to die (9.8-13.8)*

3. Moderately wasted - 3.4 times more likely to die (2.9-4.0)

4. Severely stunted - 5.5 times more likely to die (4.6-6.5)

5. Moderately stunted - 2.3 times more likely to die (1.9-2.7)

6. Wasted and stunted – 12.3 times more likely to die (7.7-19.6)

p.35, Table 2.2. – missing? p.36, Line 8: “Data show”- the 2 billion anaemic, are these not estimates since there is a lack

of data? p.38, Line 10: “food-based interventions”- I assume they will be explained later in the report.

It would be good to reference later sections since that is where the link between food (systems) and nutrition will be explained.

3 Dietary Changes and their drivers

p.41, figure 3.3 – missing?



http://files.ennonline.net/attachments/1862/WAST_140714.pdf

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p.42, Line 20 ff.: I suggest making a table or graphing for the MDD, MAD data. p.43, Line 20-23: Can the data of increases in fruits and vegetables and animal-source foods

(ASF) be shown in more detail? This is quite important information since we face an obesity epidemic worldwide and increased stress on climate due to the consumption of ASF

p.44, Line 28ff: the five animal species and the crops (wheat, rice, maize) mostly consumed in the world – can this be a graph? It strikes me as crucial to understand what is consumed and produced and link it to poor nutritional outcomes – Is that not a key point of the report?

P.46, Line 16: can the link between undernourishment due to climate change (also higher mortality and morbidity) be explained more clearly? What are the assumptions apart from lower food availability?

P.49, Line 28: “healthier food” – I would say increased diversity of foods for healthier diets. Healthy food can also be a fortified product, but we like to see is the increased use of local foods (nutrient-rich varieties). We might need a definition since the term is used later again. (p.51)

P.50, “infrastructure”: Maybe it would be interesting to also mention here that big food companies have a good distribution systems and use existing infrastructure or build new one to reach rural areas and supply these communities with sugary drinks, snacks etc.

P.53, Line 13: the effect of maize price on exacerbating child malnutrition was so dramatic because the Malawian diet is so heavily dependent on maize. Maybe this link can be drawn here to the fact that we mainly consume three crops in the world (wheat, rice, maize)?

P.57, Line 41: “food taboos during pregnancy and lactation” – it would be important to present data in this regard as it is a major barrier to change behaviour and achieve a healthy diet and improved nutrition of this vulnerable group

P.57/58: Gender- it should be mentioned that women make up the 43% of the agricultural labour force, women’s rights are not realized and domestic violence

P.50, Line 27: “the diet was very healthy”- can the diet be described instead of calling it very healthy;

P.66, Food Systems typologies and impact on diets and nutrition –seems to be the key paragraph of the whole report – should be presented at the beginning

4 Garnering quality diets from sustainable food systems

P.67, Line 34: “food system issues”- what are these? P.69, Line 1: “Figure 4.2” – Figure 28? P.69, figure 28: input supply & production - what about feeds for animal production? P.86, Line 4: “nutrition education ..has had limited success”- Is there a need to define this

term? Is there also a need to provide evidence to show the “limited success”? P.86, Line 9 ff. – need for more insight here (box reference also seems incorrect), Behaviour

change communication at community level through “care groups” is used in the SUN movement so it would be important to understand which components may be effective

67. Darinka Anzulovich, COPAL – Coordinadora de las Industrias de Alimentos y Bebidas

Estimados, enviamos de manera adjunta comentarios sobre el documento de referencia.



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Cordiales saludos.

CONSULTA PÚBLICA HLPE – BORRADOR CON COMENTARIOS COPAL

Línea 8, pág. 9 - Si bien el hambre y las deficiencias de micronutrientes están disminuyendo lentamente, el sobrepeso y la obesidad están aumentando rápidamente (IFPRI,2016). Todas las formas de desnutrición son el resultado de interacciones entre dietas pobres y ambientes insalubres. Los sistemas alimentarios rigen los tipos de alimentos producidos y la naturaleza de su viaje de la granja a la mesa a través de cadenas de valor. A medida que las poblaciones se urbanizan, los ingresos aumentan y la industria alimentaria se concentra y globaliza, la longitud de las cadenas de valor ha aumentado. Esto proporciona muchas oportunidades para mejorar o disminuir el valor nutricional de los alimentos. Del mismo modo, a medida que la industria alimentaria se concentra y globaliza en respuesta al aumento del poder adquisitivo, los mercados concentrados y la regulación financiera liberalizada, se generan muchas oportunidades para mejorar o empeorar el valor nutricional de los alimentos.

Línea 31, pág. 9 - La salud ambiental y sus consecuencias económicas son igualmente perjudiciales. Los sistemas alimentarios mundiales, desde la producción a escala industrial hasta el consumo excesivo y los desechos, no son sostenibles, lo que da lugar a una degradación, contaminación ambiental significativa y daños extensos a los sistemas naturales.

Línea 22, pág. 17 - Un aspecto clave para las dietas saludables durante esta etapa del sistema alimentario es la seguridad alimentaria. El procesamiento de los alimentos y el envasado confieren varios beneficios en esta dirección, principalmente la eliminación de los riesgos para la salud asociados con patógenos microbianos. Esta seguridad se amplía mediante el empaquetamiento, lo que evita que el producto de patógenos y otros agentes puedan acelerar el deterioro (Floros et al., 2010). El procesamiento y el envasado se asocian con la reducción de la pérdida de alimentos. El envasado también proporciona medios para transportar información al consumidor (etiquetas), incluyendo fechas de caducidad, etc. Por otra parte, el procesamiento de alimentos puede dar como resultado un menor contenido de micronutrientes en los alimentos y crea alimentos atractivos, con cantidades altas de las grasas, el azúcar y la sal, asociada con el aumento de las tasas de sobrepeso / obesidad y aumentar el riesgo de enfermedades crónicas (Lipinski et al., 2013).

Comentarios: Acordamos con el concepto que se brinda a través de la bibliografía Floros et al., 2010, ya que establece un buen concepto general del procesamiento de alimentos.

El procesamiento de los alimentos engloba un conjunto de procesos realizados en las diferentes etapas de la cadena productiva, transporte, venta y consumo, con el fin de garantizar la vida útil e inocuidad de los alimentos.

Consideramos que el procesamiento de los alimentos genera productos que satisfacen las necesidades de los distintos tipos de consumidores. En este marco, cabe destacar que la industria produce alimentos reducidos en grasas, azúcares y sal. A su vez, consideramos que los consumidores deben estar oportunamente capacitados para tomar decisiones respecto a su alimentación y la importancia de la actividad física.



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Asimismo, la reducción de los micronutrientes en los alimentos, que genera el procesamiento, no es de impacto en el producto final. Gracias a otros procesos tecnológicos existe la posibilidad de aditivar estos alimentos con los micronutrientes perdidos en el procesamiento, incluso incorporar otros nuevos. Por ejemplo, la pasteurización de un producto, puede generar una disminución del contenido de sus micronutrientes, los cuales son adicionados para que se encuentren disponibles a la hora de consumir ese producto.

Línea 36, pág. 17 - Una de las principales preocupaciones aquí relacionadas con las dietas más sanas es la modernización del ambiente minorista que está asociada con la globalización, la industria alimentaria y el comercio. Se documenta que entre otros factores que influyen en los sistemas alimentarios están la publicidad y promoción global de alimentos, así como el crecimiento de empresas transnacionales de alimentos (Hawkes et al., 2009). Esta publicidad global y la rápida difusión de supermercados y cadenas de comida rápida tienen un efecto en el comportamiento de las compras y en los patrones de consumo (Reardon et al., 2003) (Timmer, 2009). La evidencia muestra que la compra en supermercados aumenta el consumo de alimentos procesados (Asfaw, 2008), (Rischke et al., 2015), (Kimenju et al., 2015).

Comentarios: Entendemos que el consumo de alimentos procesados no tiene una connotación negativa en sí mismo. Son las porciones y la alimentación en su totalidad quienes impactan en la salud del consumidor.

Línea 39, pág. 18 - No existe una dieta saludable "ideal" para todos; Sin embargo, existen principios básicos que pueden ayudar a definir las dietas asociadas con la salud. Estos han sido destilados y promulgados por la Organización Mundial de la Salud (OMS) y por muchos gobiernos nacionales. Las dietas para la salud contienen un nivel adecuado de energía alimentaria, ayudan a lograr la adecuación de los nutrientes, apoyan el crecimiento y el mantenimiento de la salud en todo el ciclo de vida y reducen el riesgo de enfermedades crónicas / no transmisibles. Según la OMS, "la composición exacta de una dieta diversificada, equilibrada y saludable variará dependiendo de las necesidades individuales (por ejemplo, edad, género, estilo de vida y grado de actividad física), contexto cultural, alimentos localmente disponibles y costumbres dietéticas "(OMS, 2015).

Comentarios: Asimismo, consideramos fundamental la capacitación de los consumidores, ayudando a mejorar su comportamiento y a tomar decisiones sobre la su ingesta de alimentos, promoviendo una alimentación equilibrada (en calidad y cantidad) y un estilo de vida activo.

Punto 2.3 – Micronutrientes y desnutrición. Sus causas y consecuencias

Comentario: Entendemos que la industria ocupa un papel fundamental en la búsqueda de la solución al problema de la obesidad. Consideramos que el éxito dependerá del trabajo articulado entre los sectores público y privado, gobiernos, sociedad civil, industria y otras partes interesadas, todos ellos comprometidos a resolver este problema global.

En el último tiempo han aumentado los cuestionamientos a la industria de manera significativa, posicionándola como único responsable del problema de obesidad y malnutrición, considerado por evidencia científica como de origen multifactorial.

Consideramos se le está otorgando un rol de espectador y que no se involucra debidamente al sector privado, cuando éste trabaja en la mejora continua, invierte en desarrollo de nuevos productos e



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ingredientes, realiza trabajos de investigación y adopta nuevos procesos invirtiendo en nuevas tecnologías.

Punto 4.1 - Lograr sistemas alimentarios sostenibles y saludables - Esta sección ofrece una visión general de las políticas y programas que se ha demostrado que contribuyen a sistemas alimentarios saludables al tener un impacto positivo en los conductores del sistema alimentario, las actividades de la cadena de valor y actores o entornos alimentarios. La sección incluye una justificación para centrarse en el papel de las políticas y programas para asegurar que los sistemas alimentarios brinden nutrición, una visión general de cómo las cadenas de valor de los alimentos y el ambiente alimentario pueden afectar la nutrición y las dietas. Series de estudios de casos que demuestran los impactos de las políticas y programas sobre la dieta, la nutrición y / o la seguridad alimentaria dirigidos a los diferentes componentes del sistema alimentario. La sección concluye con la identificación de vacíos y áreas donde se necesitan pruebas adicionales.

Comentario: En este contexto, deseamos transmitir que la industria participó de manera voluntaria de iniciativas llevadas adelante por el sector público, aumentó la oferta de productos bajos en calorías y ofrece nuevas alternativas en porciones individuales, mejoras en el acceso a la información nutricional, entre otras acciones.

Asimismo acompaña programas de nutrición y actividad física en escuelas, campañas de educación pública y colabora con la promoción de estilos de vida saludable.

Consideramos que cambiar el comportamiento de los consumidores es un eje fundamental para conseguir el objetivo de acabar con la obesidad.

68. Carlos Monteiro, Center for Epidemiological Studies in Health and Nutrition, University of São Paulo, Brazil

Thank you for your work on this very important subject. Much in the draft is relevant although we are concerned that it does not always stick to its topic, has important omissions, is a bit long, and is often not easy to read. There is a great deal that can be said, but at this stage we have made just a few comments, and please forgive us for these being mostly critical. We are prepared to make more detailed comments, on request.

The purpose of this report is to analyze the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft?

The intention to focus on consumers means that the whole report is skewed. We suggest that this decision is not right. The main drivers of what has now become a global industrial food system are transnational food manufacturing, distribution, catering and retailing corporations, whose impact on food systems and supplies throughout the world is barely mentioned in the draft.

A distinction needs to be drawn between this global system (singular) and the countless regional, national and local systems (plural). The two should not be confused.



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There is a general assumption in the report that everything needs to be changed. This is not right. Certainly the global, industrial food system, which is unsustainable, needs to be restrained. But established appropriate national and local food systems, rather need to be protected and promoted.

The draft is not solution-orientated. Generally it reads like an extended descriptive essay, and in key areas (see below) it is tendentious.


See above. Also, we suggest that the title of the draft is a mistake. Putting nutrition first invites long discussion of what nutrition is (or should be) much of which is contained in many other reports which will be familiar to most readers. We suggest ‘Food Systems and Their Effect on Sustainable Diets’. This would focus the report much more effectively.


The report needs to start by defining what it is all about, and what it is not about. The draft does not do this, and the result is that the report sprawls. For example, it is not clear – and see above – why it begins with a lot of very familiar material on malnutrition of all types. Why does this all need to be said again? We suggest that many people will stop reading at this point.


If by ‘production systems’ is meant the manufacturing, distribution, catering and retailing industries, now dominated by transnational corporations, no, they are not. An impression has been given that coverage of this area has been deemed ‘off limits’ or has been excised.


We prefer the word ‘issues’ instead of ‘controversies’. Just one example that affects our work. The term ‘ultra-processed’ is used several times in the report, without any explanation of what the term means (it is not a synonym for highly processed) and without any reference to what is now an extensive literature, including FAO and PAHO reports, the Brazilian dietary guidelines (which are mentioned) and papers by authors (including the team at the University of Sao Paulo) from a number of countries in high-impact journals.

Also, the account of the nature and impact of processing is unbalanced and inadequate.



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The material so far included is too elaborate. An overall comment – the draft reads more like an academic thesis than an action-orientated analysis meant to help all relevant policy-makers (many of whom are not specialists) and professionals in the field.


The draft is too focused on multiplicity and complexity. Many key points apply to all food systems. These are lost in an understandable wish to cover all cases. Much of this should become appendices.


The draft is far too long. Most of the material in it could be reworked as annexes. The boxed examples and also the elaborate diagrams and other technical material could all be annexed. The report itself should perhaps be no longer than say 40 pages apart from annexes. An executive summary would be very helpful.

The definition of ‘healthy diets’ is inadequate. To be relevant to consideration of food systems, food security and sustainability, a definition needs to include all aspects of health and well-being, the nourishment of future generations and the protection of the living and physical world. We and many others have published on this topic as we can supply a definition on request.

As mentioned, discussion of transnational corporations is omitted. As far as we can see the term is used just once in the report. Given that it is transnationals and the political and economic system that has enabled them to grow exponentially and thus create the global industrial food system, this omission is absurd. There is a very extensive literature on this subject.

There is very little discussion of meals, and freshly prepared meals are not identified as especially healthy. There is a rich literature on this topic.

There is no focus on the importance of family farmers, who supply most of the world’s food, or of the need to protect their rights and livelihoods. Very little of the draft apart from some boxes gives any impression of being written from their point of view. It is strange to read such a long document on food systems with this omission.

There are other omissions, some substantial, some detailed. We will be happy to specify these on request.




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We agree that case studies are valuable and can be illuminating but we think the whole report first needs to be reoriented so as to be a better guide for examples.


Not at this stage.


It is too long, and we suggest that much in it can be made a lot more clear.


See above

Carlos A. Monteiro

Head, Center for Epidemiological Studies in Health and Nutrition, University of Sao Paulo, Brazil

69. Elena Cadel, Barilla Center for Food and Nutrition Foundation, (BCFN), Italy

Dear All,

With reference to the open consultation of the V0 Draft of the Report Nutrition and Food Systems, the Barilla Center for Food and Nutrition (BCFN) Foundation is willing to congratulate for the quality of the present document, and provide a contribution to the elaboration of the report.

As you might know, the BCFN is a private non-profit apolitical institution (www.barillacfn.com). Working as a multidisciplinary and independent think tank the Foundation produces valuable scientific content that can be used to inform and help people to make conscious choices every day about food and nutrition, health and sustainability Some of our works refer to point number 6 of your question list, providing specific approaches for the categorization of the food system. The attached document represents a summary of the BCFN contribution to the CFS Report, with particular relevance to two recently-released outcomes:

The Double Pyramid 2016 – A more sustainable future depends on us, which presents the synthesis of the relationship between food and environment which BCFN has been analysing, with a multi-disciplinary approach, since 2009.

The Food Sustainability Index, and the accompanying Fixing Food report, developed by the Economist Intelligence Unit with BCFN, which ranks 25 countries according to their food system sustainability, and is a quantitative and qualitative benchmarking model based on 58 indicators.



http://www.barillacfn.com/

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We hope that both these projects, which are at the core of the research activities of BCFN, can be deemed relevant and appropriate for their scientific contribution to the V 0 Draft Report, and hence be included in the document references.

We remain at your disposal for any additional information you might need.

With Best Regards,

BCFN Research Team

70. Robyn Alders, University of Sydney, AustraliaThe International One Health Ecohealth Congress in Melbourne has included a Food and Water Security Theme for the first time. In the lead up to the congress, a pre-congress workshop on Sustainable Food Systems was hosted at the University of Sydney by the CPC/MBI Healthy Food Systems: Nutrition*Diversity*Safety Node. Workshop participants issued a workshop statement (attached) that endorses key points included in your draft and proposes actions to address these pressing issues. We hope that this statement will contribute to your important initiative.

Secure, safe, sustainable food systems: safe today, optimal for the future

Pre - One Health Ecohealth Congress Workshop

University of Sydney, 30 November – 2 December 2016

Host: CPC/MBI Healthy Food Systems: Nutrition*Diversity*Safety Node

Workshop Statement – 2 December 2016

1. Objective: Access to diverse nutritious food is a right for all.

2. Problem/Evidence: Current systems are not sustainable and ecologicallysound

3. Solution: An integrated approach involving the whole of society is needed.

4. Audience: Planetary health community

Key Points

1. Current food systems are not sustainable, and fail to provide nutritious food and good health for all.

2. We seek consensus on the transformation of food systems to address 21st Century challenges, to ensure good health for our planet and humanity.

3. We must work together as a global society to change our food systems to produce ethical, accessible and nutritious food for all.

4. This is our responsibility to ourselves, humanity and the earth.



http://sydney.edu.au/perkins/research/current-research/healthy-food-systems.shtml

http://oheh2016.org/

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Preamble

Experts from 17 countries across 6 continents representing practitioners, researchers, policy makers and community development workers gathered at the University of Sydney to communicate priority areas in nutritional and environmental health for current food systems. The following statement is intended for the audience of the One Health Eco-Health Congress as well as responsible people at all levels. The Congress delegates are invited to consider this statement and how it could be incorporated as part of a legacy statement of the Congress.

Statement

We believe that food provision is among the most important and complex of human responsibilities. Our current food systems have met many of the challenges of previous centuries, but have had unforeseen consequences. A disconnect between food systems and human needs has both failed to eliminate undernutrition, and resulted in epidemics of over-nutrition and related non-communicable diseases. Locally and globally, food systems lack resilience in the face of environmental change and market fluctuations. They have become vulnerable to the effects of disease and climatic events. Corporate food systems reduce food to a commodity, eroding our social and cultural relationships to the food we eat. Inappropriate production impacts ecosystems (including soil, water, animals and plants) and generates excessive waste. Our contemporary food systems have created staggering human, financial and environmental costs, while support for the kind of research and development essential to overcoming the inadequacies of the current systems has declined markedly. This necessitates a realignment of food systems, in order to provide sufficient, safe and sovereign food within planetary boundaries.

A food system that ensures optimal health and wellbeing for our planet is possible. An integrated approach—one that involves the whole of society—can provide effective and equitable solutions to our contemporary challenges. The dual burden of under- and over-nutrition can be addressed by context-specific nutrition- and gender-sensitive approaches to sustainable food systems. Holistic approaches are key to addressing human and environmental risks associated with food supply. Practical intervention must be underpinned by interdisciplinary research and planning around all aspects of food and nutrition security, from soils, water, food production and processing to market chains, consumers and their health and safety, food wastage, and socio-cultural issues. A planetary health approach to the production of sustainable, nutritious, safe and ethical food, delivered to all with minimal waste, will promote human, animal and environmental wellbeing.

Declaration

We call upon national, regional and municipal governments, UN and international agencies, corporations, landholders, business people, community organizations and citizens to recognize and act upon these facts:



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• That consumption is exceeding the planet’s bio-capacity, thus nutritional inadequacies are related to global resource decline which affects species survival, including the human species;

• That gender, race/colour/ethnicity, poverty and forced displacement are key factors that delimit access to resources and possibilities to achieve optimal nutrition and wellbeing;

• That agricultural, health, environmental and socio-economic policies need to be integrated, recognizing that good food is essential to good physical, mental and cultural health;

• That food production policies need to account for both quality and quantity, society needs to recognize and value the true cost and benefit of quality food;

• That agricultural frameworks, including subsidies and trade agreements, must support the production, distribution and marketing of food that promotes good health, and account for the external costs to communities, public health, the global economy and the planetary ecosystem;

• That transparency, accountability, traceability and proportionality are essential to make decisions that support sustainability;

• That recompense for inputs at all stages of the value chain must be adequate;

• That regulatory frameworks need to align equity, safety, nutrition and ecology;

• That agriculture-related pests, diseases, invasive species and antimicrobial resistance represent key threats to human and animal health that must be urgently addressed;

• That financial and social support structures should be reoriented to recognize and support the role of women in ensuring nutritional wellbeing in their communities;

• That people across the life cycle, including pregnant and lactating women, children, adolescents and the elderly in particular, have specific nutritional needs that must be attended to;

• That all jurisdictions must understand the key importance of water in sustaining life, and negotiate fair use for all stakeholders across the full breadth of the waterscape;

• That we need to reverse the loss of soil and its health; • While supporting the reality and potential benefit of globalization and global trade, that it is

also essential to recognize that local communities will have specific food systems and dietary patterns that may need to be protected;

• Given the importance of food production to local and global wellbeing, to ensure that policies recognize and extend the appropriate allocation of land and its tenure to enable sustainable and diverse agricultural production.

Workshop participants Name Country Dr Danny Hunter Italy



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Dr Jenny Lane USA Dr Amalia Almada USA Prof Hauijun Zhou USA Dr Rodrigo Gallardo USA Prof Richard Kock UK Prof Jonathan Rushton UK Dr Mieghan Bruce UK Tim Stevenson Canada Dr Antonino do Karmo Timor-Leste Dr Joanita Jong Timor-Leste Ms Wende Maulaga Tanzania A/Prof John Msuya Tanzania Prof Eric Mitema Kenya Prof Mavis Mulaudzi South Africa Prof Hester Schönfeldt South Africa Dr Hung Nguyen (invited speaker; no registration fee required)

Viet Nam

Prof Romeo Gundran Philippines Dr Hilda Lumbwe Zambia Ms Chisela Kaliwile Zambia Dr Jaswinder Singh India Mr Cristiano Macuamule Mozambique Ms Chinyere Onyia Nigeria Prof Wiku Baktibawono Adisamito Indonesia Dr Fiona O’Leary Australia A/ProfRobyn Alders Australia Dr Darryl Stellmach Canada Dr Brigitte Bagnol France Julia de Bruyn Australia Prof Tim Gill Australia Johanna Wong Australia Prof Margaret Allman-Farinelli Australia Kim Heasman Australia Stewart Sutherland Australia Sayed Essam Sharaf Alhashimi UAE



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Emma Rooke Australia Kavitha Suthanthiraraj Australia

71. Patti Rundall, IBFAN, United KingdomDear HLPE organisers. IBFAN would very much like to send comments on the Zero Draft and we also have suggestions for case studies. However we have not been able to finish our comment today. It would be very helpful if we could have a little more time. If this is not possible I would just make the following brief observations. This Zero draft covers an impressive range of actions and topics however there are important omissions that lead to several questionable conclusions. The sections on Public Private Partnerships and Conflicts of Interest are missing or lightly touched on. These are cross-cutting issues that will inevitably affect the recommendations. I hope these will be addressed fully in Version 1. On the one hand the report seems to promote fortification and technological approaches, on the other hand it promotes breastfeeding (the perfect food system), bio-diverse, minimally processed, locally sourced foods. The report should acknowledge the need for truly independent monitoring/evaluation, regular oversight by national authorities - especially of the novel technologies. The case study section should include examples of IBFAN, WHO and UNICEF’s work over four decades to protect child health through legislation that incorporates the International Code of Marketing and Breastmilk Substitutes and subsequent World Health Assembly Resolutions. These Resolutions protect the right of mothers to make infant and young child feeding decisions free from commercial pressures.

72. Lidan Du, The SPRING project/HKI, United States of America1. The purpose of this report is to analyse the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft?The draft offered some potentially very useful definitions (well done!) including one for food system. However, the authors did not stick to the definitions consistently in the later part of the report. Otherwise, food system and value chains can be sensibly linked together and the discussion can continue through to the end outcomes of



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interest of this report, which are dietary patterns and then nutritional outcomes. This deviation appears a bit strange as almost the entire discussion of foods system focused on the 5 sets of drivers in the bulk of the report. This separation between food system and value chain is unfortunate in a way that the diagram, labeled as Figure 1, did not seem to clarify the relationship between the two. The report appears to be rather conceptual and heavy on literature review. The solution orientation should be strengthened. The 39 boxes from page 71 to page 91 are good attempts but only some offered effective and practical solutions.2. Do you think that the overall structure of the draft is comprehensive enough, and adequately considered and articulated? Does the draft strike the right balance of coverage across the various chapters? Are there important aspects that are missing? Does the report correctly focus on the links between nutrition and food systems without straying beyond that?The V0 draft is too long. Chapter 2 needs to be shortened and refocused on how nutrition burdens vary according to the different food system typologies – which have yet to be developed apparently. This is such a critical missing piece in the V0, which almost made it too early to share the report for public comment.3. Does the conceptual framework need to be edited? Simplified? Should “the food environment” as defined in the draft be central to the framework? The introduction of food environment was confusing. One reason could be that in the bulk of report the discussions about food environment deviated from its original definition. In addition, there is a lack of clear explanations on how food environment is different from food system and value chain yet also closely linked to both of them. The authors may want to re-evaluate how to articulate these constructs, and redraw the conceptual framework.4. Are production systems and their role in shaping diets and nutritional outcomes adequately addressed?Not very obvious – should be included in the discussion of the food systems if the report sticks to the original definition of food system.5. Does this draft cover adequately the main controversies in the field of Nutrition and food systems? Are there any remaining gaps???6. The project team is working on a categorization of food systems. Are you aware of specific approaches of use in that perspective, and particularly of quantitative indicators that could be used?7. Does this draft adequately show the multiplicity and complexity of diets and nutrition issues across different food systems and specific contexts with a good regional balance?This is where things got tangled, since the typologies of the food system have not been developed. For the next version, there needs to be a clear delineation of how food systems could vary based on likely a country’s economic status. It could greatly help the authors to elaborate on the solutions to address the dietary and nutrition challenges in the different contexts and the readers to find solutions useful to their



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contexts – assuming the target audience is policy makers and program designers in country? 8. What areas of the document are in need of strengthening or shortening?9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win outcomes in terms of addressing the different dimensions of diets for FSN?10. Section 4.2.2 on “Institutional Changes and Governance Across the Food System Movements for Nutrition” requires more work, and more inclusion of evidence and of the various players. Any inputs on this section are most welcome.11. Is the report too technical or too simplistic? Are all the concepts clearly defined?I enjoyed the technical richness, but I think the report should be packaged into different versions to tailor to the needs of different audiences. Most of the HLPE reports were technically sound yet pleasantly succinct. A summary of the full report – if the end report remained long regardless – is what perhaps most readers would need. Then there could be annexes, one of which should be the case studies and examples. The key is that they also need to be grouped consistently with how the other parts of the report are going to be labeled. 12. Are there any major omissions or gaps in the report? Are topics under-or over-represented in relation to their importance?

73. Elle O’Flaherty, United States Department of Agriculture, United States of America

Comments for Written Submission (Please see also attached)


· The United States ultimately had a hard time understanding the objective of the paper. At first it seemed to analyze the impact of the food system on nutrition, with the underlying hypothesis that the characteristics of the food system influence the effects of income growth, demographic shifts, climate change, conflict, etc on nutrition. However, given that the analysis of “food system drivers” in section 3.2 is of the direct impact of income growth, climate change, conflict, etc on diet, without differentiating impacts by type of food system, perhaps our understanding of the objective was incorrect. Is the objective to analyze the influence of different food systems on nutrition or to analyze the drivers of dietary change? The paper does a good job of the later but not the first.

· The objective to “consider sustainability issues” is not well executed. The authors do not attempt to evaluate the systems holistically based on economic, social and environmental sustainability. As a result, their evaluation is often incomplete and biased. We recommend that they



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drop the objective to “consider” sustainability and focus on the primary objective of the paper: namely, the ways in which food systems influence nutrition. (Chapter 4 should be retitled.)

· To be more useful, the case study approach should to be accompanied by an analysis of widely applicable “lessons learned.”


· The draft needs some restructuring. It currently includes two separate frameworks (figure 1 and section 4.1.2) to analyze the impact of food systems on nutrition. This is redundant and confusing. Section 4 should go straight to analysis of policy.

· The long section on the impacts of malnutrition is not absolutely necessary to this report. It could probably be shortened, particularly if this material is already synthesized in another FAO report.

· The section on Income, food prices and volatility reads somewhat like a literature review. Consider synthesizing key findings and abridging this section. Likewise for Population pressure, changing ages and urbanization – very lengthy.


· The conceptual framework should actually be made a bit more complex to allow for more feedback through the system, particularly with respect to consumer choice. While consumer choice is most certainly influenced by the food system the paper does not adequately acknowledge the role of consumer choice in influencing food system.

· The United States does not think “food environment” adds any additional clarity or insight to the discussion that is not captured by the term “food system.” There seems to be enormous overlap between these two terms and we were trying to understand the difference between the two.


· No, the authors should provide a more complete analysis that includes the interaction between producers (value chains) and consumers. Producers, and everyone else along the value chain, must consider consumer demand in making production decisions if they want to stay in business. Contrary to the statement on page 69, value chains do not increase or decrease consumption….they increase or decrease supply. Consumers purchase and consume.


· Many of the controversies are not adequately covered in that the analyses of them are one sided and biased. For example, the section on the impact of trade on diets ignores many of the benefits of trade, including in providing resilience to natural disasters or conflicts. (For example, a 2016 article in the journal Philosophical Transactions of the Royal Society B, “Food system



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consequences of a fungal disease epidemic in a major crop,” looks at the potential consequences of a severe hypothetical fungal disease outbreak. Overall, the results of the simulations “suggest that global trade is critical to allowing the global food system to absorb production shocks, with non-affected regions stepping in to increase exports to make up for losses elsewhere. This makes it critical to avoid following ‘starve thy neighbor’ policies in response to shocks to the food system, as it inhibits its ability to adjust. The interconnectedness of the global system also means that production shocks in one region may have significant effects in importing regions that rely on global supply… Higher prices would disproportionately affect the poor in all countries, and in the face of such shocks it would be necessary to implement policies to help the most vulnerable through targeted welfare investments that supplement incomes, and coordinated market interventions that help ease pressures on raising prices.”).

6. The project team is working on a categorization of food systems. Are you aware of specific approaches of use in that perspective, and particularly of quantitative indicators that could used?

· It is hard to envision how the section on the typology of food systems will contribute to the paper. It seems unnecessary to the objectives, particularly since the proposed indicators are not tightly correlated with nutrition outcomes. In fact, a number of them could have positive or negative effects on nutrition. Packaged foods, for example, could have positive and negative effects (as discussed on page 68).


· No, it does not look at the multiplicity and complexity of diets and nutrition across different food systems. It primarily looks at drivers that are leading to the convergence of food systems and nutrition, relegating most of the discussion of different food systems in different contexts to the section on case studies.

GAPS

· The paper does not address overconsumption, just dietary patterns. This seems like a major oversight since shifting dietary patterns alone cannot explain the large increases in overweight and obesity (as pointed out in the paper).

· Many food system models use economic, environmental, health and social tenets as constructs and a framework for evaluating sustainability. The social construct is not highlighted as a tenet, cost or consequence in this document

· Food waste and food loss management is not described in any of the definitions in Section 1. This is a significant oversight.

· Suggest incorporating the IOM report "A Framework for Assessing the Effects of the Food System" (2015) and/or make reference to the food and nutrition system model.

· Suggest including definition of biofortification – “the process by which the nutritional quality of food crops is improved through agronomic practices, conventional plant breeding, or modern biotechnology.” (WHO)

· References: Many nuanced issues are discussed with reference to literature that is quite dated. Example: P58, the claim that women working outside-home may have a negative impact on



https://www.nap.edu/catalog/18846/a-framework-for-assessing-effects-of-the-food-system

https://www.nap.edu/catalog/18846/a-framework-for-assessing-effects-of-the-food-system

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child’s nutritional status includes references dated 1990, ‘95, ‘99. This report should reflect the latest evidence on nutrition from complementary feeding.

Comments in track changes:http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/HLPE-Nutrition-and-Food-Systems_Draft-V0-24_October_2016%20United%20States%20Comments.docx

74. Florence Tartanac, FAO, ItalyDear colleagues,

Please find below my contribution to the draft paper:

Overall comments:

The paper is quite comprehensive however it still appears as a puzzle of different contributions from different authors, and it is still lacking a real synthetic, logical and comprehensive approach of Food systems and nutrition. As an example, the section on food processing and packaging p 81 is dealing only with food fortification as it seems that the writer of this section is a food fortification specialist. But I hope it is not a decision of the HLPE to say that food processing is only food fortification….

Actually, this is another comment I have that private sector is not well described and presented in all its complexity in the paper. Even if in the introduction and in the framework, private sector is supposed to be the main component of the food system as they are the value actors (represented by the four arrows on the left in the framework p 14), in the text private sector does not receive the same attention and representation (with case studies for example) than other actors such as governments or research. One concrete example, is p 77-line 16 saying that: “The private sector also has a role to play in terms in intervening across the value chain. “ This sentence is under-considering the role of private sector, as , from my point of view, the private sector is the MAJOR PLAYER that intervene in the food value chains, as almost all food value chains actors are private sector, from farmers, to traders, processors, retailers, etc… One of my main suggestion would be to give much more importance to private sector initiatives and experiences in section 4 dealing with best practices.

It should also emphasize that private sector is not only big multinationals, but is mainly represented by small and medium enterprises, farmers and other stakeholders. For example, 80 to 90% of food processors enterprises in developed countries are SMEs and this number is much higher in developing countries if considering the informal sector and all kind of micro and small enterprises in the food sector, most of the time run by women entrepreneurs. It is true that data are difficult to find in particular in developing countries about the importance of SMEs because of informal sector, however data are available in developed countries and could be highlighted anyway.

This low representation of private sector links to very few policy recommendations related with economic development, economic incentives, enabling environment for enterprise and agroindustries development (mainly for SMEs) which from my point of view would be very important for developing and supporting better food systems for healthy diets. The example from GAIN initiative related with Markets Places and innovations (Box 37, p 89) could be a good start to showcase this role of private sector: from my point of view, it should be better placed in the section



http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/HLPE-Nutrition-and-Food-Systems_Draft-V0-24_October_2016%20United%20States%20Comments.docx

http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/HLPE-Nutrition-and-Food-Systems_Draft-V0-24_October_2016%20United%20States%20Comments.docx

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of food processing. Value chains approaches are also missing, in particular nutrition sensitive ones such as developed by IFPRI, IFAD and others (see paper attached ).

Specific comments:

Another issue is that the paper failed to show the link between sustainability of food systems and sustainability of diets which is linked with healthy diets. Topics such as biodiversity, sustainable food production, sustainable food value chains, use of voluntary standards such as organic production, and other private schemes should be highlighted as well as the link with better nutrition and healthy diets.

In the section 4.2.2 related with changes in food systems, too much emphasis is given to modernization with high-tech and too little to supporting existing and healthy traditional and local food systems with alternative systems that already exists such as organic agriculture, innovative markets for sustainable agriculture, short circuits marketing systems, Participatory Guarantee Systems (PGS), Community Based Agriculture (CSA), quality linked to geographical origin and geographical indications. Please see below some publications related with these systems in particular from CFS and FAO-INRA.

Please find below some useful publications where examples and case studies could be taken:

Publications on Geographical indications and Quality linked to Origin:

http://www.fao.org/in-action/quality-and-origin-program/en/

http://www.fao.org/in-action/quality-and-origin-program/tools/linking-people-places-products/en/

Publications on institutional procurement and PAA Africa:

http://www.fao.org/ag/ags/ivc/institutional-procurement/en/

http://paa-africa.org/2014/06/local-food-purchase-from-family-farmers-to-fight-hunger-african-governments-reaffirm-their-commitment/

Publications on innovative markets and sustainability:

http://www.fao.org/cfs/hlfsmall/en/



Project on Biodiversity for Nutrition:

http://www.b4fn.org/

Publication on PPP (for section p 105-line 15)

http://www.fao.org/publications/card/en/c/20e3ff08-df6f-4e48-abd3-037eccdde9df/

Publications on sustainable food value chains:

http://www.fao.org/sustainable-food-value-chains/home/en/

http://www.fao.org/sustainable-food-value-chains/what-is-it/en/

http://www.fao.org/ag/ags/ags-division/publications/publication/en/c/342479/




http://www.fao.org/sustainable-food-value-chains/what-is-it/en/

http://www.fao.org/sustainable-food-value-chains/home/en/

http://www.fao.org/publications/card/en/c/20e3ff08-df6f-4e48-abd3-037eccdde9df/

http://www.b4fn.org/



http://www.fao.org/cfs/hlfsmall/en/



http://www.fao.org/ag/ags/ivc/institutional-procurement/en/

http://www.fao.org/in-action/quality-and-origin-program/tools/linking-people-places-products/en/

http://www.fao.org/in-action/quality-and-origin-program/en/

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Best regards,

Florence TartanacSenior officerMarket Linkages and Value Chains Group

Nutrition and Food Systems Division (ESN)Food and Agriculture Organization of the United Nations

Rome, Italywww.fao.org

Attachment ‘CSF Forty-third session ‘Making a difference in Food Security and Nutrition’:

http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/CFS_2016_43_inf_21_EN.docx

75. Donald Moore, United States of AmericaDear CFS,

Attached please find comments from Global Dairy Platform in response to the electronic consultation on the HLPE Nutrition and food systems, V0 Draft report.

Please do not hesitate to contact me should you require any further clarification

Thanks & regards

Donald Moore

Global Dairy Platform, comments to Committee on World Food Security

High Level Panel of Experts report on Nutrition and food systems Draft V0

General comments: Thank you for this opportunity to provide comments to the recently released CFS-HLPE Draft V0, Nutrition and food systems. GDP would like to commend the HLPE project team for tackling such an important issue and for the content of the report which is a good starting point. Understanding the complexity of food systems and the role they play in nutritional security will be one of the defining issues of our time. GDP believes that everyone should have access to safe, healthy, affordable, tasty food that is respectful of tradition, the environment, animals and the farming families that produce it.



http://www.fao.org/fsnforum/cfs-hlpe/sites/cfs-hlpe/files/resources/CFS_2016_43_inf_21_EN.docx

http://www.fao.org/


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To deliver nutritious, healthy food, the food system needs to be cognizant of issues from both a supply and demand perspective. As such the system needs to consider a vast array of interconnected issues and tradeoffs while taking into account areas where there is a lack of, or conflicting, scientific evidence. The study of food systems by its very nature needs to be inter-disciplinary and those engaged need to be aware of the potential for the unintended consequences of implementing change in one dimension without full consideration of the follow on effects in other parts of the system. Policy makers and regulators need to temper the desire for action with the need for understanding of such consequences. The “best available” evidence is at times inadequate and we caution the CFS about drawing recommendations when such inadequacies are, or should be, evident. Our understanding is that the aim of the HLPE process is to improve the robustness of policy making by providing independent, evidence-based analysis and advice at the request of CFS. With that aim in mind, we would draw attention to what appears to be ideology/opinion which is evident in areas throughout the report. For example,

• Page 9 starting on line 43; When discussing pathways forward for emerging countries: “They do not have to follow the long and damaging path that many high-income countries have taken, involving the creation of food systems that maximize profits without an adequate focus on the nutrition consequences.” An alternative view is that food systems respond to stimulus created by regulatory environments, for example food products that were formulated in response to requirements for low-fat or fat-free regulations.

• Page 9, starting at line 31 “Global food systems, from industrial scale production through excessive consumption and waste, are not sustainable…”

There is no similar comment or analysis of the environmental impact of inefficient small-scale farming, with high carbon footprints for individual foods.

We encourage the HLPE to take care to consider the unintended consequences of any recommendations that are made. The current report is missing some crucial sections; including:

• Typology of food systems • Conflicts of interest • Recommendations



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Therefore, we request that a second round of consultation be held to allow for comments on the complete report once these sections are completed.

Comments on some of the specific questions raised in the covering letter Question:

1. The purpose of this report is to analyse the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft? Response: GDP expected that this report would focus on the study of nutrition taken from the perspective of the food system and that this perspective would distinguish this report from others recently produced. However the draft report does not meet that expectation. With respect to emphasizing solutions, with the exception of some areas in Section 4, the majority of the report is descriptive in nature and does not contain recommended solutions. We expect that as the next version of the report forms there will be more emphasis on the solution aspects and therefore we would like to reiterate our request for a second round of consultation so that we are able to provide comment to the solutions being considered.

2. Do you think that the overall structure of the draft is comprehensive enough, and adequately considered and articulated? Does the draft strike the right balance of coverage across the various chapters? Are there important aspects that are missing? Does the report correctly focus on the links between nutrition and food systems without straying beyond that? Response: The report covers a lot of ground on the topic of nutrition, but does not really address the complex topic of food systems.

Food Systems incorporate supply and demand by integrating food production, processing and distribution with food consumption, disposal and waste. The topic is extremely rich and challenging. Few scientific studies have crossed disciplines and attempted to complete a systems perspective looking at the cause and effect of changes in different parts of the system. Unfortunately the recognition of these challenges and acknowledgement of the lack of scientific evidence is missing in this draft of the report – what happens when we make changes to recommended dietary patterns? To food supply dynamics? To health? To the environment? To the economic well-being of farming families? To agricultural and ecosystem resilience? To rural communities? Little of this is discussed in the current draft of the report.



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3. Does the conceptual framework need to be edited? Simplified? Should “the food environment” as defined in the draft be central to the framework? Response: We believe that the report adequately addresses issues of nutrition, however these issue are already well covered in reports such as the Global Nutrition Report. Perhaps reference to existing reports on nutrition would allow for a more succinct final report. With respect to the treatment of food systems, we find the emphasis in the conceptual framework on “the food environment” has tended to narrow the definition of food systems in a way that reduces the apparent importance of the production issues. Despite the earlier definition on Page 11, the report itself then adopts a narrow view of these production related food systems issues with a primary focus on environmental aspects, and does not adequately address production issues from either a social or economic dimension. For example;

Page 9, starting line 46;

“To be sustainable, food system policy choices have to focus on the environmental as well as nutritional consequences. Different foods require different amounts of energy, water and fertilizers to grow, harvest, process, store, transport, trade, market and retail. Their value chains also generate different levels of greenhouse gas (GHG) emissions. As far as the evidence allows, decision-makers need to know the nutrition and environment consequences of the food system decisions they take.”

Page 10 starting line 21;

“In addition, the UN decade of Action for Nutrition, launched in April 2016, is heavily focused on food systems and a plethora of reports from a wide range of bodies has made the case for food systems that are more nutrition focused and environment friendly.”

However, even in environmental areas the report tends to focus on a limited range of criteria. The FAO definition of sustainable diets stressed the need to protect and respect ecosystems and biodiversity while optimizing human and natural resources. Environmental factors represented only one of the four domains which need to be considered. Comment of Figure 1, in addition to the emphasis of consumption over production, some relationships in figure 1 are not clear, in particular the diagram seems to indicate that diets are the cause of environmental impacts, in fact we would suggest that the issues of food production and diets are much more complexly linked than would appear in the figure.

4. Are production systems and their role in shaping diets and nutritional outcomes adequately addressed? Response:



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As mentioned elsewhere, GDP believes that the report is more concerned with issues of consumption and does not provide a balanced perspective on the role of food production and the attendant socio-economic issues.

5. Does this draft cover adequately the main controversies in the field of Nutrition and food

systems? Are there any remaining gaps? Response: The report does cover many of the controversies on specific nutrients such as sugar, sodium and fat. However we contend that the report should focus on diets/dietary patterns and the impacts on food systems. It should avoid focus on individual nutrients and terms such as healthy or unhealthy food should be avoided.

For example, there is a lack of consistency about how animal source foods are represented in the report in terms of the nutrients they provide. In section 3.1.3, authors note that adolescent girls have inadequate intakes of iron, zinc, calcium, vitamin D, folate, thiamin and riboflavin. However, red meat and processed meats, sources of iron and zinc, are identified as “unhealthy” foods in 3.1.1

We also note that the report provides a strong focus for systems that promote healthy food options with fruits and vegetables only. We feel that other food groups including whole grains and dairy also play an essential role and this should be highlighted in the report.

6. The project team is working on a categorization of food systems. Are you aware of specific

approaches of use in that perspective, and particularly of quantitative indicators that could be used? Response: GDP would welcome the opportunity to understand and comment on this section of the report once it becomes available.

7. Does the draft adequately show the multiplicity and complexity of diets and nutrition issues

across different food systems and specific contexts with a good regional balance?

8. What areas of the document are in need of strengthening or shortening? Response: Throughout the report data is given to support points, however the quality and/or certainty/uncertainty of the data is not made clear. Is the data strong, is there consensus on the point or is the available evidence weak, emerging or conflicting? Does the data cover all of the topic or is it limited in in scope? Is the data global, regional or local?



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Additionally Chapter 4 of the draft lists a wide range of examples but many of them have not yet produced any tangible outcomes and as such should be removed from the report as they confuse and detract from the examples where data is evident.

9. Chapter 4, Section 4.1 contains case studies/examples of effective policies and actions in different contexts/countries across the food system for diets and nutrition. Could you offer other practical, well-documented and significant examples to enrich the report and provide better balance to the variety of cases and the lessons learned, including the trade-offs or win-win outcomes in terms of addressing the different dimensions of diets for FSN? Response: With respect to the specific case studies cited in the draft, GDP has the following observation:

• Page 85, Box 29 The public distribution system in India One of the references cited, to illustrate the benefit of subsidies has a different conclusion than what is presented in Box 29.

From Chakrabarti 2016 (IFPRI): “Overall, we find no evidence that the consumer price subsidy in pulses introduced in different states resulted in improved nutrition in terms of household protein intake.” Further “Whereas the subsidies do appear to have affected pulse consumption in a statistically significant way, the size of the effect is not large enough to make much difference.”

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2779302

10. Section 4.2.2 on “Institutional Changes and Governance Across the Food System Movements

for Nutrition” requires more work, and more inclusion of evidence and of the various players. Any inputs on this section are most welcome. Response: GDP would welcome the opportunity to understand and comment on this section of the report once it becomes available.

Also in Section 4.2.2 are several examples of Economic Drivers, GDP would like to draw attention to the fact that interventions such as taxes and subsidies often do not result in the outcomes as desired by those planning the interventions.

There are few rigorous examples of successful health outcomes due to taxing unhealthy foods/ingredients or subsidizing healthy foods such as fruits or vegetables, and unforeseen and unintended consequences can result. The tax–generated income is not always used for health purposes.

• A fat tax introduced in Denmark in 2011 had little impact on consumer purchase behavior and put an economic burden on the public. After 15 months the tax was



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abandoned. Economic effects were negative; the tax was blamed for rising inflation, Danes purchased cheaper brands or went across the border to shop. At least 10% of the revenues were used for administration costs along with an estimated 1300 jobs lost. Source: IEA Current Controversies Paper No. 42. The Proof of the Pudding. Denmark’s fat tax fiasco. By Christopher Snowdon. May 2013.

• The Healthy Food program in South Africa, funded by a private health insurance company, provided discounts up to 25% for healthy food purchases. Despite improved dietary behaviors such as greater consumption of fruits/vegetables and whole grains, and reduced consumption of high sugar/salt foods, fried and fast foods, there was no evidence of health outcomes such as lower BMI or obesity prevention. Source: Ruopeng An, MPP, MPhila,*, Deepak Patel, MD, MPhilb, Darren Segal, BScc, and Roland Sturm, PhDd. Eating Better for Less: A National Discount Program for Healthy Food Purchases in South Africa. Am J Health Behav. 2013 January; 37(1): 56–61. doi:10.5993/AJHB.37.1.6.

11. Is the report too technical or too simplistic? Are all the concepts clearly defined? Response:

GDP would caution the HLPE from promoting a view that there is sufficient evidence to make decisions in all areas.

For example, Page 10 line 1: • “As far as the evidence allows, decision-makers need to know the nutrition and

environment consequences of the food systems decisions they take.” GDP contends that insufficient evidence exists today in many cross functional areas of food systems and that rather than “educated guesses” the HLPE’s emphasis should be on identifying areas where there is a lack of evidence and promoting the need for research.

In addition there is a lack of consistency in terms and terminology throughout the report and this creates confusion when trying to make sense of some of the topics.

12. Are there any major omissions or gaps in the report? Are topics under-or over-represented in

relation to their importance? Response: As covered elsewhere in our response, GDP would like to see a more complete analysis of the role of food systems balancing the issue of production with consumption. There is little or no attention given to the role of farmers, or the rural communities whose livelihoods depend on those farms.



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76. Janine Giuberti Coutinho, Ministry of Social Development, Brazil

Please find attached suggestions to the Nutrition and Food System v0 draft report from Ministry of Social Development.

Any doubt please contact us.

Janine Coutinho

Ministry of Social Development

Comments on the document “Nutrition and food systems”, produced by the Committee on World

Food Security and Nutrition”- V0 Draft Report

1. APPROACH AND CONCEPTUAL FRAMEWORK

1.1. Page 17 : the document presents the concept of food environment (Caspi et al., 2012) and

discusses the important role of governments in the promotion of access to healthy food.

1.1.1. We suggest the inclusion of food procurement as a governmental strategy to facilitate

the access. In Brazil, there are successful initiatives in this area, such as the National

School Feeding Program (PNAE, in the Portuguese acronym) and the Food Purchase

Program (PAA, in the Portuguese acronym).

1.1.2.The PAA, created in 2003, uses mechanisms of trade that favor the direct purchase of

products from family farmers or their organizations by the government. The products

are then used for the creation of strategic stocks or distributed to the population in

social vulnerability. The data from the program in 2015 show that R$ 576.9 million

(USD 166.5 million) were spent, impacting 95,200 family farmers and benefiting 11,600

entities and 14.8 million people. The program acquired 241,300 tons of food, with

vegetables representing 26% of that amount, milk and dairy representing 23% and

fruits representing 17%. Through the Institutional Purchases modality of the PAA, R$



http://aplicacoes.mds.gov.br/sagi/paa/visi_paa_geral/pg_principal.php?url=abertura

http://www.mda.gov.br/sitemda/secretaria/saf-paa/sobre-o-programa

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44.4 million (USD 12.8 million) were spent on the direct purchase of products from

family farming for other federal organizations in 2015.29,30

1.1.3. The PNAE established in 2009 that at least 30% of the federal budget for the school

feeding program should be used for the direct purchase of products from family

farmers. The data from 2014 shows that 82% of the administrations in both states and

municipalities actually reached the 30% minimum in that year, which amounted to R$

662.1 million (USD 191.1 million), which represents 21.3% of the federal resources for

school feeding. From the amount invested in family farming products, 28.1% was

applied in the purchase of fruits, 21.8% in the purchase of vegetables, 15.3% in the

purchase of dairy products, and 13% in the purchase of grains. The direct purchase

from family farming accounted for 44.4% of the total amount of resources invested in

the purchase of vegetables, 43.3% of the resources invested in the purchase of fruits,

32.5% of the resources invested in the purchase of beverages, 21.5% of the resources

invested in the purchase of dairy, and 19.2% of the resources invested in the purchase

of oilseeds.31

1.2. Page 18 : the concept of “healthy food” (as it is presented on WHO documents) is

inconsistent with the concepts of “food systems”, “sustainable food system” and “food

environment” (page 11) that were initially presented. The concept of “healthy diet” is

presented from a nutritional perspective, totally disconnected from the food system.

1.2.1.We understand that a minimum alignment of those concepts is required. The Brazilian

government adopts the following concept of “adequate and healthy diet”, which was

built with the participation of the civil society at the “III National Conference on Food

29 Food Purchase Program (PAA) http://www.mda.gov.br/sitemda/secretaria/saf-paa/sobre-o-programa.PAA Data. http://aplicacoes.mds.gov.br/sagi/paa/visi_paa_geral/pg_principal.php?url=abertura (in portuguese).

30 The amounts were converted to USD as per the Brazilian Central Bank’s conversion rate as of December 2nd 2016. http://www4.bcb.gov.br/pec/conversao/conversao.asp (in Portuguese).

31 BRAZIL. Ministry of Education. National Fund for the Development of Education (FNDE). 2016. National School Feeding Program (PNAE). http://www.fnde.gov.br/programas/alimentacao-escolar/agricultura-familiar and http://www.fnde.gov.br/arquivos/category/116-alimentacao-escolar?download=10035:nota-tecnica-n-5003-2016.



http://www.fnde.gov.br/arquivos/category/116-alimentacao-escolar?download=10035:nota-tecnica-n-5003-2016

http://www.fnde.gov.br/arquivos/category/116-alimentacao-escolar?download=10035:nota-tecnica-n-5003-2016

http://www.fnde.gov.br/programas/alimentacao-escolar/agricultura-familiar

http://www4.bcb.gov.br/pec/conversao/conversao.asp

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and Nutrition Security”, in 2007. The Brazilian concept approaches the topic in a way

that is both more comprehensive and more consistent with food and nutrition security

issues.

1.2.2.“Adequate and healthy diet is a basic human right. This right implies ensuring permanent and regular access, in a socially fair manner, to food and ways of eating that satisfy the social and biological requirements of everyone. It also takes into account special dietary needs, and the need to be culturally appropriate, and allows for differences in gender, race, and ethnicity. An adequate and healthy diet should be accessible both physically and financially, and harmonious in quantity and quality, meeting the needs of variety, balance, moderation, and pleasure. Furthermore, it should derive from sustainable practices of production and distribution.”32

2. THE BURDEN

2.1. Page 30 : the subchapter on “overweight and obesity and its causes and consequences” does

not link the current setting of the food systems with the outcomes in terms of inadequate

food practices, which result in overweight and obesity.

2.1.1.We understand that unfavorable nutritional outcomes, characterized by the condition

of malnutrition, constitute violations to the human right to adequate and healthy food

and have, among their causes, the shape of the food systems of the countries, i.e., the

way food is produced, processed, traded and consumed. As a consequence, these

outcomes are also a responsibility of the actors that control these food systems. 33,34,35

32 BRAZIL. Ministry of Health of Brazil. Secretariat of Health Care. Primary Health Care Department. 2014. Dietary Guidelines for the Brazilian population. Translated by Carlos Augusto Monteiro. Brasília: Ministry of Health of Brazil, http://189.28.128.100/dab/docs/portaldab/publicacoes/guia_alimentar_populacao_ingles.pdf.

BRAZIL. National Food and Nutritional Security Council (CONSEA). 2007. Relatório da III Conferência Nacional de Segurança Alimentar e Nutricional. http://www4.planalto.gov.br/consea/publicacoes/3deg-conferencia-nacional-de-seguranca-alimentar-e-nutricional/relatorio-final-iii-conferencia-nacional-de-seguranca-alimentar-e-nutricional

33 STEDILE & CARVALHO. 2011. Soberania Alimentar: uma necessidade dos povos. https://www.ecodebate.com.br/2011/03/25/soberania-alimentar-uma-necessidade-dos-povos-artigo-de-joao-pedro-stedile-e-horacio-martins-de-carvalho.

34 STUCKLER D, NESTLE M. 2012. Big Food, Food Systems, and Global Health. PLoS Med 9(6): e1001242. http://journals.plos.org/plosmedicine/article?id=10.1371/journal.pmed.1001242.



http://www.fao.org/3/a-ml542e.pdf

http://www.fao.org/3/a-ml542e.pdf

http://journals.plos.org/plosmedicine/article?id=10.1371/journal.pmed.1001242

https://www.ecodebate.com.br/2011/03/25/soberania-alimentar-uma-necessidade-dos-povos-artigo-de-joao-pedro-stedile-e-horacio-martins-de-carvalho

https://www.ecodebate.com.br/2011/03/25/soberania-alimentar-uma-necessidade-dos-povos-artigo-de-joao-pedro-stedile-e-horacio-martins-de-carvalho

http://189.28.128.100/dab/docs/portaldab/publicacoes/guia_alimentar_populacao_ingles.pdf

http://www4.planalto.gov.br/consea/publicacoes/3deg-conferencia-nacional-de-seguranca-alimentar-e-nutricional/relatorio-final-iii-conferencia-nacional-de-seguranca-alimentar-e-nutricional



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2.1.2.The food systems have never been so concentrated and controlled by so few players:

the thirteen largest industrial food conglomerates in the world36 own 26% of the global

market and 100 direct retail chains control 40% of the food retail sector.37 Given this

concentration of economic power and, as a consequence, political power, it is much

too often the transnational enterprises, instead of the governments, that define and

implement the strategic macro policies of food supply.2

2.1.3. As we face this scenario, we need a faster and more assertive global answer, directed

not only to tackling the different types of malnutrition, but especially to the analysis of

its determinants, with a view to protecting the human right to adequate food of the

populations of the world and guaranteeing the food sovereignty of the countries.

3. DIETARY CHANGES AND THEIR DRIVERS

3.1.1. No comments.

4. GARNERINGS QUALITY DIETS FROM SUSTAINABLE FOOD SYSTEMS4.1. Page 73 : there is a box about Brazil with information about governance. Page 104: Discusses

national experiences on nutrition and multi-sector coordination. The Brazilian experience in

the Interministerial Chamber for Food and Nutrition Security (CAISAN, in the Portuguese

acronym) is a successful example. Suggestions for improvement may be found below.

4.1.1.Brazil´s public system of Food and Nutrition Security is based on social participation through a cross-sector approach. Governance, Transparency, and the Society´s Active Participation as a Protagonist have been, over the past years, the principles by which Brazil´s action is oriented. Brazil has no longer featured in FAO’s Hunger Map since 2014. We have succeeded in fighting hunger, nevertheless we still have to face other dimensions of malnutrition. Today, 52% of Brazilians are overweight and 18% are

35 Food and Agriculture Organization of the United Nations (FAO), World Health Organization (WHO), 2014. Conference Outcome Document: Rome Declaration on Nutrition. Rome: FAO/WHO. http://www.fao.org/3/a-ml542e.pdf

36 Nestlé, Monsanto, Bungue, Dreyfuss, Kraft Foods, Pepsi-Cola, Coca Cola, Unilever, Tyson Foods, Cargill, Marte, ADM, Danone.

37 RIBEIRO, S. 2008. Los que se quieren comer el mundo. http://www.jornada.unam.mx/2008/12/06/index.php?section=opinion&article=029a1eco.



http://www.jornada.unam.mx/2008/12/06/index.php?section=opinion&article=029a1eco

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obese. Besides, 63% of Brazilians do not eat fruits and vegetables on a regular basis and more than 70% of deaths by illnesses are caused by poor nutrition habits. The most vulnerable are the most affected by lack of access to fresh healthy foods. In this regard, we are prioritizing the promotion of adequate food and the fight against obesity.

4.1.2.Brazil, over the forthcoming four years, shall invest approximately USD 30 billion each year by means of its Food and Nutrition Security Plan. The Plan’s main goals are:

4.1.2.1. Access to adequate food for approximately 15 million families within “Bolsa Família” (Family Grant Program), as well as 40 million students who rely on school meals every day.

4.1.2.2. Reduce by 25% those families’ rates of vulnerability through a set of policies that promote rural productive inclusion.

4.1.2.3. Support family farmers through appropriate policies such as access to credit and markets, technical assistance, support for trade and the protection of both production and income, as well as access to water. By 2019 the federal government alone will mobilize approximately USD 780 billion for the purchase of family farmers´ production through public procurement.

4.1.2.4. Promotion and Protection of Healthy Food

4.2. Pages 107-108: in “future research areas and data needs”, especially about “Consumption demand and behavior change”, we suggest progress in the approach adopted. The Brazilian government handles the Food and Nutrition Education (FNE) agenda in a wider manner, from the perspective of the food system, including the whole chain.

4.2.1. Eating is a social practice which results from the integration of the biological, sociocultural, environmental and economic dimensions. The FNE requires, therefore, an integrated approach that recognizes food practices as a result of the availability and access to food, as well as the behaviors, practices and attitudes involved in the choices, preferences, forms of preparation and consumption of the food. Thus, the FNE actions should be based on principles such as: social, environmental and economic sustainability; a food system approach; having the food as a reference; valuing the local food culture and culinary skills; promoting the autonomy of the individuals; and intersectoriality.38

38 BRASIL. Ministerio de Desarrollo Social y Combate al Hambre. 2012. Marco de referencia de Educación Alimentaria y Nutricional para las políticas públicas. Brasília: MDS. http://www.mds.gov.br/webarquivos/publicacao/seguranca_alimentar/marcoEANespanhol.pdf.



http://www.mds.gov.br/webarquivos/publicacao/seguranca_alimentar/marcoEANespanhol.pdf

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4.2.2. In the context of the Human Right to Adequate Food and the guaranteeing of Food and Nutrition Security, Food and Nutrition Education is a field of knowledge and of continuous, permanent, transdisciplinary, intersectorial and multiprofessional practice, which aims to promote the autonomous and voluntary practice of healthy food habits. Its practices should use problematizing educational approaches and resources, as well as assets which favor dialogue with individuals and population groups, considering all the stages of life and the stages of the food systems, as well as the interactions and meanings that make up the eating behavior.

4.2.3. The full reach of FNE requires structuring actions that work as an effective strategy to promote and guarantee health and Food and Nutrition Security, as well as the accomplishment of the Human Right to Adequate Food. On the one hand, it is necessary to institutionalize the actions of FNE in public policies; it is necessary to raise awareness and educate public managers about this subject and the professionals must have autonomy and access to permanent educational processes. On the other hand, it is required that the social value of healthy food practices be recognized and that society embrace and defend the FNE agenda. On the planning and development field, it is necessary to adopt actions based on different types of evidence and to adopt monitoring and evaluation indicators for processes, results and impacts achieved. There is an urgent need to promote dialogue with other fields of knowledge and practices; to establish partnerships and commitments with different media channels and to adopt an ethical commitment among all sectors. Finally, successful experiences need to gain visibility and the different institutions, groups and teams must organize themselves in collaborative networks.

Brasília, December 4th, 2016.

77. Marlene Heeb, Swiss Agency for Development and Cooperation (SDC), Switzerland

Swiss Comments to the HLPE Report and answers to the questions


1. The purpose of this report is to analyse the ways in which food systems influence dietary patterns and hence nutritional outcomes. The objective is to focus on consumers and consider sustainability



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issues. The report aims to be solution oriented and to highlight efficient policies and programs. Are those major objective(s) clearly reflected in the V0 draft?

There are many interesting views and graphics in this report. The reader can understand well the complexity of food systems and especially of how to make them more sustainable and improve nutrition globally.

We particularly appreciate that a focus is given to the links between nutrition and trade policy instruments, bearing in mind their significance in shaping food systems, and yet often not being articulated enough. We are of the view, that all instruments having a particularly negative impact on food systems of net food-importing developing countries should be addressed.

The consideration of nutrition and diets through the report lack the sustainability criteria, in its economic, environmental and social dimension. Yet these criteria are essential elements to apprehend the interconnections and linkages between humans, their health and environment. In order to make food systems more sustainable by policies and programs, it is crucial to include the social and economic dimension of sustainability, and consider the whole food chain, including the production level. Food production - and thus food security - relies on a natural resource bases that is becoming increasingly more fragile and scarce, and that is extremely vulnerable to climate change as well as biodiversity loss.

2. Do you think that the overall structure of the draft is comprehensive enough, and adequately considered and articulated? Does the draft strike the right balance of coverage across the various chapters? Are there important aspects that are missing? Does the report correctly focus on the links between nutrition and food systems without straying beyond that?The following aspects are not stressed enough from our perspective:

Education and Knowledge: Education and knowledge creation of the different actors along the whole value chain is not given appropriate attention, despite its importance to improve nutrition. Enhancing knowledge must encompass diverse aspects such as human rights, safety of workers, food safety, or retail to the final consumers as well as food literacy, cooking skills and the understanding of nutritive value throughout the food chain.

Gender: The section on gender in the report is entirely about women. We consider it important to also reflect about the role of men for improving nutrition. This includes their role for women empowerment but also beyond.

Humanitarian Aid/ Protracted crisis: An important dimension not yet covered by the report is challenges and opportunities for Nutrition and Food Systems in protracted crisis and in humanitarian food aid programs in general.

Farmers and Food producers: Even though the focus can be on consumers, producers are key to any solutions leading to any sustainable and healthy nutrition and food systems.

Investment: the effects of investments into agricultural production, infrastructure and trade on nutrition outcomes should be mentioned and developed further as they form an important part of a favorable or unfavorable food environment.



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Collaboration approach: Multistakeholder initiatives are not yet mentioned, as well as the Sustainable Food Systems Programme of the 10YFP as one key Multistakeholder Programme for Food Security, Nutrition and sustainable food production and consumption.


The causal links within the framework are not very clear (p. 14). It seems diets are only influenced by consumer behaviors which again are influenced by food environment. However, if someone has not access to nutritious food and therefore changes his/her diet this cannot be considered results of consumer behavior only, but the dietary choice is influenced by the food environment on his diet.

We think the conceptual framework could gain significantly in clarity if the “Food Environment” is central to the framework. This may help to show interdependencies and feedback loops in given food system more clearly, cross-sectoral, integrated and therefore comprehensively. And at the same time keep the framework clear and simple not to hamper understanding.

4. Are production systems and their role in shaping diets and nutritional outcomes adequately addressed?We appreciate the link made between agricultural production subsidies, divers primary production and nutrition (p.56) and would suggest to replace the term “agricultural production subsidies” with policy instruments to cover the full range of influencing measures.

However, we think that actors in the production system still don’t get enough focus, such as producers (in particular farmers), investors, and commodity traders. Farmers are at the heart of any sustainable and healthy diets and should be included in this report as producers but also as consumers.


A reflection on marketing/ advertisement of unhealthy food and beverages and the role of media should figure in the section of “economic drivers”, given the importance of these factors in influencing changing diets (p.50).

In the area of sustainable consumption, the importance of label and non label approaches should be explored. For example Multi-stakeholder sector initiatives like the Round Table on Responsible Soy, the Better Cotton Initiative or the Sustainable Trade Initiative can contribute to market transformation by setting new standards for entire sectors. However, other and non-label based approaches to enhance shared/equitable valorization and sustainability should be explored.


Typologies of Food Systems (p. 21 ff)

Appreciating the attempt to categorize Food Systems into typologies, the list of elements relevant to a food system as well as the list of indicators proposed seems not yet comprehensive or representative.



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The table on p.22 may have to better reflect the aspects of a food system influencing consumer behavior and final diet composition, beyond what is currently described as food environment. The policies, programs and institutional actions influencing food environments and thus consumer behavior and diets are not satisfyingly incorporated in the current proposal of elements to be assessed. As this classification will serve to observe trends and changes, it seems crucial to capture this dimension well.

A few concrete proposals on expanding the indicators are mentioned below:

Element Production: As policy instruments are actively shaping agricultural production priorities, volumes as well as production methods, it is crucial to include an indicator assessing the public investment for making primary production more divers and nutritious. We therefore suggest developing an indicator which assesses which policy instruments are existing and putting them into relation to each other regarding financial volume (and possibly also their contribution to world trade): One could imagine the following categories of subsidy schemes relevant for nutrition

- Policy instruments promoting the (over-) use of agricultural inputs (seeds, fertilizers)

- Policy instruments dedicated to support beans, fruit and vegetables production

- Policy instruments dedicated to promote staple crops (maize, rice, wheat)

Element Processing/ Packaging: Fortification may be one cost effective approach to some nutrient deficiencies, keeping fully in mind that malnutrition cannot be mainly approached by filling single nutrient gaps. Furthermore, legislations aiming to avoid the production and presence of unhealthy food items on the market are equally crucial and information on it needs to be gathered.

- Make the “Fortification legislation” Indicator more comprehensive and include salt iodination (besides wheat fortification)

- Assess the existence of legislations which define the maximum content of ingredients classified as unhealthy when consumed in high quantities, such as trans-fat, sugar, sodium, etc.

Element Food access: Besides FIES, there may be an additional indicator which reflects more directly on the accessibility of healthy nutritious food items, like fruit and vegetables. Include the following information in form of indicators:

Number of servings of fruit and vegetables consumed per day

Share of Fruit and Vegetable sales on food sales in general (in volume and financial)

Element Information and guidelines: Food Based Dietary Guidelines (FBDG) are vital not only to shape consumer knowledge, awareness and habits, but also to inform policy measures.



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- Include an indicator on the existence/absence of nationally/regionally adapted FBDG (WHO)

Element composition, quality and safety: The two proposals on assessing percent of calories coming from food groups (1. Fruit and vegetables, 2. Animal protein) are both addressing nutrient adequacy issues, but neglect the dimension of challenges leading towards overweight/obesity. We therefore advocate for identifying an additional suitable indicator which captures the unhealthy share of calories consumed.

- Percent of calories coming from ultra-processed food, Food related to NCD’s (for definitions, see publications of Carlos Monteiro and/or Dario Mozzafarino)


8. What areas of the document are in need of strengthening or shortening

As seen in the section on Typologies of Food Systems, having adequate indicators and data to measure changes in Food systems is vital and yet a big challenge. This report may stress further the need of better and more globally available data on indicator relevant to observe the sustainability of food Systems.

Develop further on the solution of strengthen direct food sales and marketing from producer to consumer to increase food security, nutrition, fair price and sustainability. The impact of well-designed nutritious school feeding programs may also be further elaborated in this view, highlighting on the impact as well as policies required and the potential on supply chains with smallholder farmers in the center.

The importance of responsible investment (in agriculture and food chains) should be strengthened in the report.

A lot of emphasize is placed on various definitions, which is important to understand the background but which leads to some redundancies that should be prevented.



If this report really would like to be solution oriented and highlight efficient policies and programs it has then to include a specific chapter on Collaboration issues and Partnerships, and in particular multi-stakeholder initiatives, as these are essential to address the multiple challenges of food systems and Nutrition. Food systems are simply too big and complex to be tackled by any single stakeholder group in isolation. Moreover, SDG 17 specifically underlines their importance.



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In the area of sustainable food systems, the Sustainable Food Systems Programme (SFSP) of the UN 10-Year Framework of Programmes on Sustainable Consumption and Production (10YFP) represent one of the main comprehensive Programme worldwide and should therefore be mentioned in the document. This Programme is a multi-stakeholder initiative to accelerate the shift towards more sustainable food systems, aiming to promote sustainability all along the entire food value chain, from farm to fork. The Sustainable Food Systems Programme has a network of already more than 100 members around the globe. They work together to develop and implement concrete projects on the ground in the areas of awareness raising, capacity development, facilitating access to knowledge and information, and strengthening partnerships. The Programme will for example disseminate knowledge on sustainable diets, and it will promote information for consumers enabling them to adopt more sustainable dietary habits promote information for consumers enabling them to adopt more sustainable dietary habits. A strength of the Programme is that it brings together existing initiatives and partnerships working in related areas, highlighting success stories and building synergies among stakeholders to leverage resources towards mutual objectives. For further information on the SFSP of the 10YFP: Website: http://www.scpclearinghouse.org/sustainable-food-system; Email : [email protected]

11. Is the report too technical or too simplistic? Are all the concepts clearly defined?The report is definitely not too simplistic, rather too technical, if it aims at addressing new audiences not yet well familiar with the issues.

From a communication perspective, the report is way too long and therefore risks not to be read by the audience aspired. Attention shall be given to make it easy readable and avoid redundancies. An excellent summary will be vital to reach the urgently needed new public outside the nutrition community.


The report and its content shall be well linked into the Agenda 2030 and the agreed SDG’s.

The research chapter 4.2.4, shall stress more on the importance of Systems Level research, like studying the management of food systems, nutrition sensitive value chain approaches, impacts on nutrition outcome of more diverse production systems, impacts of public regulations, potential and impact of private initiatives to improve sustainable food systems and to secure adequate producer and consumer prices for fresh, healthy and nutritious food; produced, processed and consumed in a sustainable way.

Chapter 4.2.1 instead of focusing on technology, could broaden it perspective on a mere innovation perspective, which would include other kind of promising approaches accessible to smallholders too, such as improved varieties of local crops. In or after the chapter “movements for nutrition” there shall be a paragraph expressing the views and possible contributions of farmers and their organizations.

References are partially not very recent, especially taking into account that the report will only be launched in 2017. This can make the report already out of date when it is issued, what is not wanted.

One aspect that should be mentioned and developed is the importance of informal economy and market, including informal production and accessibility of food (outside the usual market) such as






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self-production and informal access to food, for example through exchanges of goods. The question of local self-produced nutritious food (food production for self-consumption) is not mentioned, while it represents a substantial part of agricultural production in Southern or Eastern countries, especially in cities, but also – increasingly –Northern countries, especially those in crisis. This kind of production is also increasingly linked to urbanization as it can now be found on roofs, along roads, in community garden, in parks and vacant land; directly in the land or in various containers. Such production is mainly composed of vegetables but can also include eggs, milk and meat.[1]

Further comments to the draft:

p. 18, line 23: there is a new publication by WHO EURO on this topic: WHO (2016). Tackling food marketing to children in a digital world: trans-disciplinary perspectives.

p. 30, line 19 and page 31, line 5: the numbers on obesity and overweight are not coherent with the introduction chapter (page 9, line 8) or within the chapter due to numbers from different sources. Please make sure that numbers are consistent.

p. 44, line 1-13: For readers not familiar with the concept of planetary boundaries it would be helpful to have a box, illustrating the nine planetary boundaries and the consequences of crossing these boundaries.

p. 46, line 11-19: This is a repetition to page 45, lines 28-34

p. 48, line 10-29: repetitions in line 12f and line 28f

p. 49, chapter 3.2.2: There is not much on research here.

p.50, line 7: In the context of what has been said before, the last sentence of this paragraph is biased, as built environments can also be developed in a way that can favor healthy dietary patterns.

p. 50, section on social networks and movements: this section deals with international policy and collaboration at international level. As it is rather related to politics, one could consider putting it under chapter 3.2.3. Political and economic drivers

p. 66, Figure 26: The graphic is very complex and not easily understandable. The numbers need further explanation for “non-statisticians”.

[1] For more details : [1] Maria Grester Bentaya (2015), in H. de Zeeuw, P. Drechsel, « Cities and Agriculture, developping resilient urban food systems ».

78. John Connelly, National Fisheries Institute, United States of America

Ladies and Gentlemen: Please find attached comments from the National Fisheries Institute regarding food systems and nutrition, as they apply to seafood. We look forward to continuing to be part of this dialogue.

John Connelly

President

National Fisheries Institute (USA)



http://www.fao.org/fsnforum/cfs-hlpe/nutrition-and-food-systems-V0#_ftnref1

http://www.fao.org/fsnforum/cfs-hlpe/nutrition-and-food-systems-V0#_ftn1

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McLean, Virginia

December 5, 2016

Committee on World Food Security High Level Panel of Experts (HLPE) on Food Security and Nutrition Comments re: Nutrition and Food Systems HLPE DRAFT V0 (24 October 2016) ‐Submitted electronically via cfs [email protected]‐

To HLPE members:

The National Fisheries Institute (NFI) appreciates the opportunity to comment on the HLPE draft report on Nutrition and Food Systems. NFI is a non profit organization dedicated to education about ‐seafood safety, sustainability, and nutrition. The diverse members of NFI source fish and shellfish from around the globe to provide families with one of the planet’s most healthful proteins. NFI supports and promotes sound nutrition policy based on scientific research.

After reviewing the draft report of Nutrition and Food Systems, we would like to highlight the following points:

1. Any conclusions about the role of seafood in food systems should prioritize its important role in human health across all ages. Fish/seafood is noted as a food to encourage in each and every international recommendation summarized in Table 1 (page 20). Seafood is a source of protein and omega 3s, which are vital beginning with the first 1,000 days for brain development and ‐continue to play a role in both prevention of malnutrition as well as chronic diseases like heart disease and obesity. The World Health Organization and Food and Agriculture Organization of the United Nations Joint Expert Consultation on the Risks and Benefits of Fish Consumption concluded in 2011 that international health authorities should emphasize not only the “net neurodevelopmental benefits to offspring of women of childbearing age who consume fish, particularly pregnant women and nursing mothers,” but also “neurodevelopmental risks to offspring of women of childbearing age who do not consume fish.” Furthermore, effective messaging should include “the benefits of fish consumption on reducing mortality from coronary heart disease (and the risks of mortality from coronary heart disease associated with not eating fish) for the general adult population.” i

2. The fish based omega 3s, DHA and EPA, should be included as nutrients of concern. ‐ ‐ Along with vitamin A, iodine and iron, deficiency in DHA and EPA fats is a widespread global concern. In addition to the recommendations to include seafood in healthful diets referenced above, the following chart summarizes international omega 3 recommendations‐ ii:



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Very low blood levels of EPA and DHA have been observed in North America, Central and South America, Europe, the Middle East, Southeast Asia, and Africa.394041

3. Because human nutrition and food systems are distinct disciplines, expertise in both is required to result in a balanced report. To address specific food systems, even further expertise in those areas would be required. We recommend the following fisheries and aquaculture experts:

Dr. Ray Hilborn – Fisheries Management, specifically in the U.S. Pacific Northwest

Dr. Victor Restrepo – Fisheries Management, specifically tuna Dr. George Chamberlain – Aquaculture Robins McIntosh Aquaculture, specifically shrimp ‐

We applaud the work of the HLPE committee to address the complex topic of Nutrition and Food Systems and look forward to following the finalization of the report.

Sincerely,

39 Food and Agriculture Organization of the United Nations and World Health Organization. “Joint FAO/WHO Expert Consultation on the Risks and Benefits of Fish Consumption” September 2011. <http://www.fao.org/docrep/014/ba0136e/ba0136e00.pdf>

40 Global Organization for EPA and DHA Omega 3s. “Resources for Healthcare Professionals.” 2014. ‐<http://www.goedomega3.com/healthcare> 41 Stark, K., et al. “Global survey of the omega 3 fatty acids, docosahexaenoic acid and eicosapentaenoic acid ‐

in the blood stream of healthy adults.” Progress in Lipid Research. 2016; 63: 132 152.‐



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Jennifer McGuire, MS, RD Rima Kleiner, MS, RD

79. Tony Prescott, Department of Agriculture and Water Resources, Australia

Please find below, consolidated response from Australia concerning the HLPE (Zero draft) Report on Nutrition and Food Systems.

Thank you for the opportunity to review the zero draft of the Nutrition and Food Systems report. It is clear a lot of high quality work has gone into its development. We look forward to assisting as the report develops.

Globally there has been an increasing focus on the malnutrition challenge – both overnutrition and undernutrition. The Indo-Pacific region is grappling with particularly serious and complex nutrition issues. We therefore welcome the HLPE’s focus on this important issue.

Whilst we recognise the report’s specific focus on food systems, we note that nutrition is a complex issue requiring coordinated action across many sectors including health, social protection, education and WASH (water sanitation and hygiene).

We are generally supportive of the report’s contents and provide comments on specific sections of the report below.

Future Research Areas and Data Needs

We welcome the recommendation in subsection 4.1.1 Knowledge gaps and areas for future work,to undertake further research and data collection on the impact of food systems on nutrition. Despite the links between agriculture and nutrition, the global donor community is challenged by the paucity of evidence on the nutritional impact of agricultural and food security interventions.

Private Sector

Food production and distribution is largely a private sector endeavour. It involves private sector players in various roles along the value chain including as input providers, food producers, traders, processors, transporters, wholesalers and retailers. We therefore welcome the report’s focus on the role of the private sector in ensuring positive nutrition outcomes. Given the important role played by the sector in this area, we suggest including the private sector as a key area of focus in subsection 4.2.3 Nutrition governance, institutions and partnerships. Beyond public-private partnerships, the private sector contributes to positive nutrition outcomes in various ways including by providing investment for improved postharvest and irrigation practices and improved food distribution facilities.

Overnutrition in the Pacific Region

We welcome the report’s focus on the causes of overnutrition and obesity in the Pacific region in section 2.2 Overweight and obesity and its causes and consequences. Section 3.1 Changing Diets –



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what do diets look like currently? analyses the differences in diet between key regions globally but does not consider the Pacific region. Given the challenges of obesity and overnutrition in the region, as outlined in section 2.2, we recommend that data for the Pacific region be included in 3.1.

Also of note is the mention of Australia on pages 20 and 87. Page 20 references the Australian Dietary Guidelines and accurately reflects the guidelines at a high level. On page 87, the Australian Health Star Rating (HSR) system is used as a case study. We are pleased that Australia’s initiatives are being showcased in this publication.

In relation to the HSR reference on page 87, the authors may wish to note that updated figures are now available. The data referenced is correctly sourced from the 2015 Parker and Frith report, however the 2016 Parker and Frith report is now available on the HSR website: http://www.healthstarrating.gov.au/internet/healthstarrating/publishing.nsf/Content/formative-research

Regards and many thanks

Tony

Tony Prescott Policy Officer – FAOAgricultural Cooperation, Capability and StandardsTrade and Market Access DivisionDepartment of Agriculture and Water Resources

80. Isabelle Mialet-Serra Représentation Permanente de la France auprès des institutions des Nations Unies à Rome, France

NOTE DES AUTORITÉS FRANÇAISES

Objet : Remarques sur le draft zéro du rapport HLPE : « Nutrition et systèmes alimentaires »

Nous remercions le HLPE pour cette consultation autour du draft zéro de l’étude « nutrition et systèmes alimentaires ».

Il nous apparaît cependant difficile d’avoir une appréciation globale de ce rapport, puisqu’une partie importante de son contenu n’est pas finalisée (typologie des systèmes alimentaires et recommandations). C’est pourquoi, nous souhaiterions qu’un second "draft" de ce rapport, incluant l’ensemble des parties prévues, soit à nouveau soumis à consultation avant publication du rapport.

D’une façon générale, nous aimerions que ce rapport se réfère davantage aux précédents travaux du HLPE et aux recommandations du CSA, notamment celles sur « Connecter les petits producteurs aux marchés », ou le rapport HLPE sur « Développement agricole durable : quelle place pour l’élevage ?».

Il nous paraitrait fondamental également que le rapport se réfère au Droit à l’Alimentation qui est un des piliers du Cadre Stratégique Global du CSA, et à la mise en œuvre de l’Agenda 2030, notamment sur ce que leur application implique en matière de nutrition.



http://www.healthstarrating.gov.au/internet/healthstarrating/publishing.nsf/Content/formative-research

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Les définitions concernant la malnutrition ne sont pas précises et il est vraiment important qu'une cohérence soit respectée avec les différents programmes qui traitent de ce sujet, en particulier SUN (Scaling up nutrition) et ICN2. Il est important que des indicateurs fiables et universels puissent découler précisément de ces définitions.

Question 2.2

Insister et analyser davantage l’impact des modèles de production et des pratiques agricoles sur la nutrition. L’agriculture sensible à la nutrition reste une thématique encore sous-explorée et pourrait faire l’objet d’analyses plus approfondies.

Question 2.3

Fortification et bio-fortification : il serait important d'analyser dans le document l'accès des plus pauvres aux produits fortifiés ou biofortifiés. En effet, l'existence de monopole sur ces produits peut fragiliser l'accès de tous à ces produits, et plus spécialement les populations fragilisées alimentaires. Ce point sera à prendre en compte lors de la rédaction des recommandations.

Question 2.10

L’urbanisation croissante et ses conséquences sur la nutrition et les systèmes alimentaires mériteraient d’être davantage explorés : infrastructures d’accès, évolution du temps dévolu à la préparation des repas, évolutions des habitudes alimentaires, agriculture urbaine…

Le lien entre le niveau de revenu des ménages et leur nutrition mériterait d’être exploré plus en profondeur. L’augmentation des revenus peut conduire à la fois à une augmentation de la consommation d’aliments nutritifs (fruits et légumes, protéines animales, produits de la mer…) mais aussi à une augmentation de la consommation d’aliments moins nutritifs (produits transformés, sel….).

Les recommandations du CSA sur « Connecter les petits producteurs aux marchés » ont mis en avant l’importance des marchés territoriaux. Il nous parait opportun de différencier les impacts de chaque type de marché (local, national, international) sur les systèmes alimentaires et la nutrition. La partie 3.2.3. semble pour le moment surtout focalisée sur les marchés internationaux.

81. Alena Matzke, NCD Alliance, World Cancer Research Fund International, Switzerland

The NCD Alliance and World Cancer Research Fund International congratulate the authors for a comprehensive V0 draft and welcome this opportunity to comment on the report early enough to allow sufficient time to give proper consideration to the feedback received.

Please find attached our feedback.

Comments on the HLPE Report on Nutrition and Food Systems prepared jointly by the NCD Alliance and World Cancer Research Fund International

We, the NCD Alliance and World Cancer Research Fund International, congratulate the authors for a comprehensive V0 draft and welcome this opportunity to comment on the report early enough to



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allow sufficient time to give proper consideration to the feedback received. Food systems play a critical role in shaping diets and nutrition - two important determinants of diet-related NCDs, including cardiovascular diseases, diabetes and some cancers.

Key messages

1. Set out a vision for nutrition-promoting and sustainable food systems that defies ‘business as usual’. In order to do so it is essential that the authors address controversies head on and take clear positions to encourage fundamental shifts in understanding of the issue and ambitious and solution-oriented policy-making.

2. Focus on the solutions rather than the analysis of the issues. Much of the analysis the report provides has been well documented elsewhere and could be summarized/annexed so that more space can be given to discussion of the solutions.

3. Lay out ambitious and practical recommendations for action. The report should leave policymakers with a clear set of recommendations, practical guidance and a call to action.

4. Make policy coherence more central to the report. The report should emphasize the importance of government leadership in both developing and implementing public policies and in bringing together actors across sectors to foster policy coherence and enable joint agenda setting.

5. Formulate research priorities to reshape food systems. Fundamental shifts in agriculture and food systems require re-orientation of research and investment agendas.

Consultation questions


● The report’s introduction conveys a sense of urgency to address malnutrition in all its forms through systematic and ambitious interventions throughout the entire food system. Unfortunately, this sense of urgency and the critical message that low-and-middle-income countries “do not have to follow the long and damaging path that many high-income countries have taken, involving the creation of food systems that maximize profits without an adequate focus on nutrition consequences” gets lost quickly in the descriptive tone of the current document that fails to lay out ambitious and practical recommendations for action.

● The report should frame food systems as a major opportunity for sustainable human and environmental development and focus on harnessing synergistic action across the agriculture, health/nutrition, commerce/trade and environmental sectors. The central question the report should seek to answer is what a good food system looks like and make recommendations for what policymakers need to do to get there. We therefore encourage the authors to provide more detailed and practical guidance on multisectoral collaboration to achieve policy coherence and create win-win solutions for nutrition, agriculture, the environment and the economy. The challenge of food systems that do not deliver adequate nutrition to the world’s population while contributing to climate change



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and environmental degradation on a large scale, is too big and too urgent for the report to avoid taking clear positions.

● In order to strengthen the sustainability dimension of the report, we recommend that it references the Paris Agreement of the Conference of the Parties to the United Nations Framework Convention on Climate Change which sets out a global action plan to put the world on track to avoid dangerous climate change by limiting global warming to well below 2°C. Taking bold actions in the food system is an imperative, not an option and an important means to comply with commitments made against the achievement of the Paris Agreement.

● The report’s recommendations should be underpinned by the recognition that food production needs to shift from food security alone with a focus on quantity and calories to food and nutrition security with a focus on high-quality diets for all within a system in which a) public policies and private sector actions are aligned toward the goal of accessible, available and affordable healthy diets and b) agricultural practices conserve limited water supplies and promote long-term preservation and restauration of soils, forests and biodiversity.

● Given the report´s focus on consumers and the food environment, the authors should include a much more in-depth analysis of the commercial drivers of malnutrition in all its forms and highlight the urgent work that governments must undertake in setting a public policy framework that effectively regulates product formulation, labelling, advertising and promotion, uses context-specific fiscal policies and incentivizes nutrition-promoting private sector actions.


● Currently, it is not clear that the solutions rather than the analysis of the issue are the focus of the report. We propose that the authors consider restructuring the report so that case studies and solutions appear sooner. Furthermore, the report should leave policymakers with a clear set of universally applicable recommendations and call to action.

● Chapters 2 and 3 on the burden, dietary changes and their drivers are too detailed. As much of this content has been well documented elsewhere it should be summarized succinctly and referenced well throughout.

● Policy coherence should be more central to the report since without it, changes implemented to only one part of the food system will be insufficient. In particular, longstanding division of jurisdictional responsibilities within governments and agendasetting – between agriculture, health, social protection and commerce – need to be integrated. The Global Panel on Agriculture and Food Systems for Nutrition’s report Facing the challenges of the 21st century42 provides examples of how actions can be aligned for coherence across food systems (e.g. see table 7.7). The HLPE report should build on this work.

42 Global Panel on Agriculture and Food Systems for Nutrition. 2016. Food systems and diets: Facing the challenges of the 21st century. London, UK. http://glopan.org/sites/default/files/ForesightReport.pdf



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● We propose that the concept of “double-duty” policy actions be discussed in the report based on guidance currently being developed by the WHO. Double-duty actions are those that have the potential to impact multiple forms of malnutrition simultaneously (e.g. undernutrition, NCDs and overweight/obesity), rather than addressing a specific type of malnutrition in isolation. Include examples of double-duty actions as case studies in section 4.1.3. For examples of double-duty actions see brief “Ambitious, SMART commitments to address NCDs, overweight & obesity”.43


● We welcome the emphasis on food environments. However, food environments remain only one component of the food system that affects nutrition outcomes. To ensure accessibility, availability and affordability of nutritious and sustainably produced food, actions across the food system need to be aligned for coherence. For example, policies targeting food environments to influence consumer behaviours will not be effective if policies earlier in the value chain limit the availability of nutritious food.

● The report must include food availability in the definition of food environments. Food availability is distinct from food accessibility and refers to the physical availability of food (in the desired quantities) within the food supply. To be accessible, a food needs to be available within the food supply. Both the food supply and food environments can shape what food is available. Ensure food availability is included whenever food environments are discussed in the report. Currently the report is not consistent in how it describes the food environment’s impact on diets and nutrition. For example, section 1.1.2 does not include availability: “Within the food environment, consumers are influenced by issues of access, affordability and acceptability and by the information available to make choices, be they healthy or unhealthy.” (line 47-48, p. 17) but section 4.1.2 does “The food environment influences diets and nutrition by mediating food availability, access, affordability and acceptability as well as information and guidelines, food composition, branding and quality” (Line 1-2, p. 70).

● More specific comments on the conceptual framework:

○ We recommend clarifying the meaning of the dotted lines around ‘food environments’ within the conceptual framework (Figure 1, page 14).

○ ‘Consumer behaviour’ is described as “choosing where and what food to acquire, prepare, cook, store and eat.” We argue that choice is not an accurate descriptor since people can rarely choose the food environments in which they live, work and play. Depending on the food environment, choice is quite limited.

○ There is overlap in the ‘value chain actors’ and ‘food environments’ (e.g. retail, marketing and advertising). We would argue that retailers, markets, food outlets and restaurants make up a significant portion of the food environment.

43 World Cancer Research Fund International and NCD Alliance (2016). Ambitious, SMART commitments to address NCDs, overweight & obesity. www.wcrf.org/SMART (accessed 28/11/2016)



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● We encourage the authors of the report to consider the analysis and recommendations by the International Panel of Experts on Sustainable Food Systems’ report “From Uniformity to Diversity”44 and the Global Panel on Agriculture and Food Systems for Nutrition “Food systems and diets: Facing the challenges of the 21st century”,45 in order to strengthen section 3.2 Food system drivers that impact diets and nutrition (in particular 3.2.1, 3.2.2 and 3.2.3) and to provide more ambitious alternatives to the ‘business as usual’ approach of industrial agriculture and current food production systems in section 4. Garnering quality diets from sustainable food systems. The viability of transitioning to organic and agroecological food production in light of increasing global population and urbanisation, and relevant case studies, should receive greater attention.

● We encourage the authors of the report to include issues of dietary diversity within food systems that prioritize mono-cropping of energy-dense staple crops, nutrient content of crops grown on soils lacking nutrients and minerals and the link between soil-degradation and nutrient and anti-oxidant contents of produce, as well as agrochemical exposure and their impact on nutrition and health outcomes.

● We recommend that the report focus greater attention on the role of public procurement in institutionalizing healthy, sustainable diets, shaping norms and incentivizing suppliers and contractors to align their value chains accordingly.

● Importantly, the report should issue a clear call to refocus agriculture research agendas and investments around the aim to achieve healthy diets and truly sustainable production systems recognizing that a paradigm shift and fundamentally different approach may be needed.

5. Does this draft cover adequately the main controversies in the field of nutrition and food systems? Are there any remaining gaps?

● The report does not adequately address the impact the private sector has on food systems, in particular food environments. Foods are being processed more than ever before, shifting the value and power within food systems to the middle of the value chain. As such, decisions made by large agri-businesses, manufacturers and retailers are increasingly shaping food systems and influencing the availability, accessibility, affordability and desirability of food.

● We believe that the report overestimates the role of food fortification and product reformulation in shaping healthier food systems. Even though fortified foods can fill certain nutrient

44 IPES-Food. 2016. From uniformity to diversity: a paradigm shift from industrial agriculture to diversified agroecological systems. International Panel of Experts on Sustainable Food Systems. http://www.ipesfood.org/images/Reports/UniformityToDiversity_FullReport.pdf




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gaps in situations where micronutrient-intake cannot be ensured otherwise, fortification should not be a general strategy for achieving healthy diets for all. Food-based approaches should be the first priority in meeting micronutrient intakes and promoting healthy diets. Similarly, reformulation can reduce the levels of saturated and trans-fats, salt and sugar in a product but does not thereby make the product ‘healthy’ albeit admittedly ‘less unhealthy’. Additionally, there are risks to ‘discretionary fortification’, used by manufacturers as a marketing technique, whereby vitamins and minerals are added to products.46 This latter approach is particularly problematic as it can and is being used by companies to brand processed food high in sugars, fat and salt as ‘healthy’ in the absence of sophisticated regulation of health claims. Despite the addition of micronutrients to unhealthy food products these may still contribute to overweight and obesity.

● We believe the report should acknowledge the proliferation of ultra-processed foods in the global food system and their role in contributing to overweight/obesity. Ultraprocessed foods are typically energy-dense, high in fats, sugars and salt, and low in other nutrients, micronutrients and anti-oxidants contributing to growing rates of overweight/obesity and diet-related NCDs. They are products that combine (often cheap and low-quality) processed ingredients and make up a large proportion of calories consumed globally. For example, in the US ultra-processed foods have been found to contribute almost 60% of calories and 90% of added sugars consumed.47 Stricter regulation of health claims on ultra-processed products is required, as are public policies and private sector actions that increase the accessibility, availability and affordability of foods that contribute to healthy diets (instead of ultra-processed foods).

● When referring to alcohol consumption (p. 20, line 12-13), the report should state that drinking any level of alcohol regularly carries health risks and that drinking in moderation only reduces health risks (as opposed to being 100% safe) while still contributing empty calories to the diet. Many people do not consider how many calories they consume through alcoholic drinks and dietary guidelines should aim to dispel common myths about alcohol, clearly state what constitutes “moderation” and point to the possible contribution of alcohol to overweight/obesity and NCDs, in particular cancer. Alcohol consumption is linked to an increased risk of six cancers48 and is classified by the International Agency for Research on Cancer as a carcinogen.49 Additionally, a recent literature

46 Tarasuk, V. (2014) Discretionary fortification - a public health perspective. Nutrients 6(10): 4421-4433

47 Steele, EM et al (2016). Ultra-processed foods and added sugars in the US diet: evidence from a nationally representative cross-sectional study. BMJ 6:e009892

48 World Cancer Research Fund International: http://wcrf.org/int/cancer-facts-figures/link-between-lifestyle-cancerrisk/alcohol-cancer

49 WHO International Agency for Research on Cancer (2012), Consumption of Alcoholic Beverages, IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, Volume 100E



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review published in 2016 concluded that regular moderate drinking had no net health benefits compared to abstention or occasional drinking.50

● A significant barrier to policy development and implementation in some parts of the world has been the misleading portrayal of government interventions such as regulation of product reformulation, advertising, and fiscal policies as “nanny-statism” (e.g. taxes on sugary drinks in the United States). This argument is being propagated by the food and beverage industry to distract from the fact that corporate practices shape food environments and greatly influence consumer choices thereby directly contributing to escalating rates of overweight/obesity and diet-related NCDs. The costs of this epidemic are absorbed by the public, not industry, and public policies to counteract harmful corporate practice are in the best interest of the public.

● We note that the report does not discuss the issue of meat and overall animal-source food consumption. Animal-source foods (e.g. dairy, eggs, fish and meat) can be important sources of nutrients, especially for vulnerable populations such as infants, children, adolescents and women of reproductive age. While some populations continue to have insufficient access to these foods, their consumption has reached unhealthy and unsustainable levels in many countries. In addition, the environmental and climate footprint of livestock is significant. By addressing the overconsumption of animal-source foods, in particular red meat, win-win solutions for health and climate can be created. The report should recognize animal-source food consumption as a critical issue for nutrition and food systems discussing both better access in some parts of the world and approaches to decreasing consumption globally, identify case studies that illustrate shifts toward plant-based diets, and possibly formulate a call for research on the issue.


● The report accurately describes the multiplicity and complexity of diets and nutrition issues across different food systems, but does not adequately address solutions to these issues.

● A good regional balance exists in the case studies highlighted in chapter 4, with over 30 countries included.


● Section 2.2 Overweight and obesity and its causes and consequences does not address the causes of overweight and obesity. Table 3 includes a short list of factors that increase the risk of obesity, but we find this insufficient. The causes of overweight and obesity are complex, resulting from the interplay of a wide range of physiological, behavioural and environmental factors across the lifecourse.51 52 This complexity should be reflected in this section.

50 Stockwell T. et al (2016), Do “moderate” drinkers have reduced mortality risk? A systematic review of meta-analysis of alcohol consumption and all-cause mortality, Journal of Studies on Alcohol and Drugs 77:2, pp 186-198



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● The report should include more information about the impact of food marketing on the food environment, consumption patterns and food systems. Importantly, the impact of digital marketing needs addressing. Children and adolescents are increasingly targeted by highly effective sophisticated and individualised marketing of foods high in fats, sugars and salt through digital media.53 As there is currently little or no effective regulation, there is an urgent need to act as well as to conduct research to understand how to effectively control this rapidly expanding form of marketing. Digital marketing is capable of tailoring its content based on extensive personal data. Children and adolescents are a particularly vulnerable group as they are extremely susceptible to the power of marketing, which is of particular concern as food preferences developed in childhood influence food preferences in adulthood.

● Though the benefits of breastfeeding are discussed briefly in the report (p.34 line 4-7), the report does not include examples of policies that protect and promote breastfeeding. The only mention of breastmilk substitutes is in the context of trade: “Concerns have also been raised about the impact of trade on the availability and promotion of breastmilk substitutes” (p.54 line 39-40). The implementation of the International Code of Marketing of Breast-milk Substitutes and subsequent World Health Assembly resolutions should be included in the report together with policies that protect and promote breastfeeding. Breastfeeding is a highly cost-effective intervention to prevent both undernutrition and overweight/obesity and protect the health of mothers and should be underlined by the report.

● Table 3 (p. 34) needs updating: Diet-related cancers: for the increases risk column add ‘alcoholic drinks’ and ‘adult attained height’ and replace “salt preserved food and salt” with “Cantonese-style salted fish and foods preserved by salting”. For the decreases risk column, add “coffee” and “diets high in calcium” and remove “vitamin C, beta-carotene, carotenoids and folate”.54 Other sections may also require updating as the reference provided in the report is from 2002.

● Human rights based approaches play an important role in ensuring food and nutrition security, as well as challenging the unequal socio-economic dimension of unhealthy diets, in many parts of

51 Swinburn, BA et al. (2011). The global obesity pandemic: shaped by global drivers and local environments. Lancet 378:804-814.

52 Butland, B et al. Foresight tackling obesities: future choices - project report (2nd edition). London: Foresight Programme of the Government Office for Science, 2007.

53 WHO Regional Office for Europe (2016). Tackling food marketing to children in a digital world: transdisciplinary perspectives. http://www.euro.who.int/en/health-topics/disease-prevention/nutrition/publications/2016/tackling-foodmarketing-to-children-in-a-digital-world-trans-disciplinary-perspectives-2016 (accessed 28/11/2016)

54 World Cancer Research Fund International. Continuous Update Project (CUP) Matrix. Accessed 26/11/2016 http://www.wcrf.org/int/research-we-fund/continuous-update-project-findings-reports/continuous-update-project-cupmatrix



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the world and should be given greater priority in the report. The report of Special Rapporteur on the Right to Food Hilal Elver (A/71/282)55 should be referenced in the HLPE report.

● The section on income, food prices and volatility states on p. 51 that “income growth is seen to be playing an essential facilitating role in reducing malnutrition”. We suggest that this statement be more nuanced taking into account that “as income increases, food scarcity diminishes but the cost of many nutritious foods remains high and the ability to purchase foods that do not support high-quality diets increases”56. Furthermore, consumption of “western” diets, including processed food products high in empty calories, is perceived as an indicator of progress and prosperity thus negatively affecting nutrition outcomes.

● In section 4.1.4 Knowledge gaps and areas for future work consider including the following:

○ What kinds of public private partnerships improve diets the most; how to manage conflicts of interest and ensure accountability of all partners?

○ Effective methods for measuring the sustainability and nutritional value of diets.

○ Impact of increased investment in R&D to improve production of nutrient-rich crops (p. 74 raises this issue).

○ Policies that promote sustainable agriculture practices.

○ How to protect health in the context of existing trade and investment agreements. Additionally, how can future trade and investment agreements not only be healthsensitive but health-enabling?

● As mentioned above, we believe chapters 2 and 3 overall could be shortened.


● We commend the authors for including a significant number of case studies of effective policies in the report. Learning from existing implemented policies and programmes is a powerful tool to improve policymaking. Lessons can be learned from both effective and ineffective policies. To facilitate the exchange of this type of information, we recommend including a handful of evaluated policies that were found not to be effective with a brief analysis of lessons learned.

55 https://documents-dds-ny.un.org/doc/UNDOC/GEN/N16/247/21/PDF/N1624721.pdf?OpenElement




http://glopan.org/sites/default/files/ForesightReport.pdf

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● Consider including examples of ‘promising policies’ for every sub-section with a detailed description of the policy (similar to the case studies).

● The overlap between food system drivers/value chain actors and food environments in the area of retail, marketing and advertising is not adequately addressed. We believe policies targeting retail, marketing and advertising should be included under “retail, marketing and advertising” (p.84) instead of “food acceptability” (p.88) to reflect the fact that it’s the responsibility of manufacturers and retailers to responsibly market and advertise foods.

● For examples of implemented government food policies, visit World Cancer Research Fund International’s NOURISHING policy database: www.wcrf.org/NOURISHING.

● Additional case studies to consider including: ○ We note the importance of case studies highlighting comprehensive approaches to protecting and promoting healthy diets and addressing food security and sustainability concerns through a food systems approach. Unfortunately, there are not many examples of countries which are taking a comprehensive approach involving all relevant sectors. This scarcity of examples is perhaps not surprising but should be pointed out by the authors and discussed. ○ We suggest the authors consider showcasing South Korea as an example of a country that has managed to maintain traditional dietary patterns to a large degree and has implemented a number of policy actions to improve the food environment in the areas of nutrition labelling, mandatory nutrition standards in schools, mandatory regulation of broadcast advertising to children for specific food categories, a ban on internet advertising that includes “gratuitous” incentives (e.g. free toys) and a government-led voluntary food reformulation programme.

○ Retail, marketing and advertising (p.84) ■ Include examples of policies that regulate retail environments, and food marketing and advertising: ● Mandatory regulation of broadcast food advertising to children in the UK and South Korea. An evaluation found that restrictions in the UK57 were not strong enough to change the exposure of children to advertising of foods high in fat, salt and sugar. Evaluations of South Korea’s regulation58 59were promising, but also suspected that companies shifted marketing channels to those not included in restrictions. These examples emphasise the importance of developing robust, comprehensive policies that carefully define the age of a child, marketing channels and techniques, audience (e.g. marketing directed exclusively to children as well as marketing with a specific appeal

57 Adams J et al. (2012) Effect of Restrictions on Television Food Advertising to Children on Exposure to Advertisements for ‘Less Healthy’ Foods: Repeat Cross-Sectional Study. PLoS ONE 7(2): e31578

58 Kim S et al. (2013) Restriction of television food advertising in South Korea: impact on advertising of food companies. Health Promotion International 28(1), 17-25

59 Lee Y et al. (2013) Effect of TV food advertising restriction on food environment for children in South Korea. Health Promotion International DOI: 10.1093/heapro/dat078



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to children) and food (e.g. defined as those to be banned and to be promoted using a nutrient-profile).

○ Food affordability (p.84) ■ P.84 lines 19-24. While there is great deal of modelling research that has been conducted to assess the impact of taxes and subsidies, implemented taxes are increasingly being evaluated providing an evidence to draw on. The report highlights Mexico’s sugary drinks tax (Box 27). Additional fiscal policies that have been evaluated include:● Denmark’s saturated fat tax (abolished in 2013)60 61 decreased the sale of twelve taxed food categories and decreased intake of saturated fat. ● Hungary’s “Public Health Tax”62 - decreased consumption of processed foods, especially in poor households. ● Berkeley’s sugary drinks tax 63 - reduced sugary drink consumption in low-income neighbourhoods (population studied). ● Subsidies - consider also including an example of a policy in a highincome country that targets low income populations. For example, New York City’s Health Bucks programme that incentivises customers on income support to purchase fresh fruits and vegetables at farmer’s markets.64

○ Information and guidelines (p.86) ■ Include example of mass media campaign that has focused solely on increasing fruit and vegetable intake (p. 86 line 7) ● Western Australia’s “Go for 2&5®” campaign 65 increased the target audience’s awareness of the recommended servings of fruit and vegetables and resulted in a population increase in fruit and vegetable intake over three years.

○ Food acceptability (p.88)

60 Bødker M et al. (2015) The Danish fat tax—Effects on consumption patterns and risk of ischaemic heart disease. Preventive Medicine 77, 200-203

61 Smed S et al. (2016) The effects of the Danish saturated fat tax on food and nutrient intake and modelled health outcomes: an econometric and comparative risk assessment evaluation. European Journal of Clinical Nutrition 70, 681-68

62 Bíró A (2015) Did the junk food tax make the Hungarians eat healthier? Food Policy 54, 107-115

63 Falbe J et al. (2016) Impact of the Berkeley Excise Tax on Sugar-Sweetened Beverage Consumption. AJPH 106(10), 1865- 1871

64 Baronberg S et al. (2013) The Impact of New York City’s Health Bucks Program on Electronic Benefit Transfer Spending at Farmers Markets, 2006-2009. Preventing Chronic Disease 10:130113

65 Pollard CM et al. (2008) Increasing fruit and vegetable consumption: success of the Western Australian “Go for 2&5®” campaign. Public Health Nutrition 11(3), 314-320.



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■ Consider moving Canadian example to section “Retail, marketing and advertising” (p.84) ■ What people find acceptable is shaped by food preferences. Food preferences are set in childhood, therefore examples of policies working to shape healthy food preferences in childhood should be included here. ● Fruit and vegetable schemes in school: The National Schools Fruit Scheme in the UK 66 increased dietary fruit intake among young children, as long as the fruit provided was free. Increased fruit intake did not persist beyond the duration of the intervention.67 The provision of free fruit in Norway’s School Fruit Scheme 68 was associated with increased fruit intake of primary school children and their parents.

○ Food accessibility (p.89)■ Providing food in schools, hospitals, workplaces and government buildings has the potential to improve diets (p.90 line 2-3), however nutrition standards are needed to ensure the food available in these settings promotes healthy diets. Include examples of policies that set mandatory nutrition standards for foods and beverages available or sold in schools (including canteens, vending machines and other in-school outlets): ● Slovenia’s School Nutrition Law sets mandatory dietary guidelines for all school meals and an evaluation reported high levels of implementation.69

■ Farm-to-school programmes: In Brazil, in addition to requiring at least 30% of the food purchased through the school feeding programme be bought locally, directly from family farmers, the programme mandates a weekly minimum of fruits and vegetables, regulates sodium content and restricts the availability of sweets in school meals. A school procurement law 70 also limits the amount of processed foods purchased by schools to 30% and bans the procurement of drinks with low nutritional value (e.g. sugary drinks).


66 Fogarty AW et al. (2007) Does participation in a population-based dietary intervention scheme have a lasting impact on fruit intake in young children? International Journal of Epidemiology 36(5), 1080-1085

67 Wells L, Nelson M (2005) The National School Fruit Scheme produces short-term but not longer-term increases in fruit consumption in primary school children. British Journal of Nutrition 93(4), 537-542

68 Øvrum A, Bere E (2013) Evaluating free school fruit: results from a natural experiment in Norway with representative data. Public Health Nutrition 17(6), 1224-1231

69 Gregorič M et al. (2015) School nutrition guidelines: overview of the implementation and evaluation. Public Health Nutrition 18(9), 1582-1592

70 Law 11.947/2009 (http://www.educacao.sp.gov.br/a2sitebox/arquivos/documentos/952.pdf; accessed 29/11/2016)



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● Nutrition is a cross-cutting issue, requiring multisectoral action. Government leadership is essential to prioritise policy coherence throughout food systems and to harness the various sectors which influence it. Several countries have bodies that provide an advisory role for improving food and nutrition security (e.g. Brazil’s National Food and Nutrition Security Council (CONSEA), the Finnish National Nutrition Council, the Malaysian National Coordinating Committee on Food and Nutrition) and others focused on preventing noncommunicable diseases (e.g. high-level ‘NCD Commissions’ that coordinate multisectoral collaboration on NCDs). Importantly, these platforms must bring together all relevant sectors for policy coherence and joint action.

● International advocacy and cooperation (p.104): The International Coalition for Advocacy on Nutrition (ICAN) includes a variety of organizations collaborating on advocacy and accountability towards strong financial, programmatic and policy commitments under the umbrella of Nutrition for Growth (N4G). While N4G has been focused on undernutrition the focus of this group is expanding to include all forms of malnutrition.

● National strategies on nutrition and multisectoral coordination (p.104) consider adding examples of national strategies that focus on malnutrition in all its forms (e.g. Brazil’s 2nd National Food and Nutrition Security Plan 2016-2019 71 and Malaysia’s 3rd National Plan of Action for Nutrition (2016-2025)72).


● The report is too long and should be condensed and focus on practical guidance to policymakers and other stakeholders in the food system.

Terminology

We have noted some incoherency with regards to terminology used throughout the report, including:

● Malnutrition in all its forms: We encourage the report to clearly define what is referred to when using the terms ‘malnutrition in all its forms’ and that ‘malnutrition’ in the report is short for ‘malnutrition in all its forms’.

● Overnutrition: We discourage use of the term ‘overnutrition’ and propose that throughout the report ‘overweight & obesity’ be used instead. ‘Overnutrition’ is misleading in that calories consumed leading to overweight & obesity are often ‘empty’ of or low in nutrients other than sugars and fats. Therefore, overweight and/or obese individuals are not only harmed by excess body fat leading to chronic inflammation, hormonal imbalances and metabolic disorders which put them at risk of developing NCDs such as type II diabetes, cardiovascular disease and some cancers, but may also suffer from micronutrient deficiencies.

71 Plano Nacional de Seguranca Alimentar e Nutricional (PLANSAN 2016-2019) (https://issuu.com/informecaisan/docs/plansan_2016-19__10_05_2016_vers__o Accessed 28/11/2016)

72 Forthcoming - the plan adopts a whole-of-government approach and addresses all forms of malnutrition



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● Chronic diseases: We encourage the authors to use the term non-communicable diseases (NCDs) rather than ‘chronic diseases’. Not all NCDs are chronic and importantly some metabolic disorders and diet-related NCDs are reversible when addressed therapeutically early enough.

● Sugar-sweetened beverages: We would prefer the use of ‘sugary drinks’ rather than ‘sugarsweetened beverages’ in line with the WHO recommendations on daily sugar intake which applies to both added and intrinsic sugars.

Specific comments by page/line

● P. 15, line 35-37: It is suggested here that science and technology can help develop more nutritious and healthier foods, including through fortification which can be used to “increase nutrient content of processed food”. We believe that fortification of food should be used to address malnutrition challenges that cannot otherwise be addressed but not as a general strategy to enhance nutrient content of processed food. We therefore suggest that this paragraph be rephrased to introduce specific conditions that would warrant food fortification.

● P. 15, line 45-48: We suggest rephrasing this section as follows: “National level policies involve governments, which could implement strategies and programmes to positively influence diets through fiscal policies (e.g. taxation of unhealthy products, revision of agricultural subsidies), regulation of the sale of unhealthy products in schools and public institutions, public procurement of local and/or organic food, limits on the level of salt and trans-fat in foods, interpretive front-of-pack labelling, and restrictions on food marketing to children and adolescents. Other national policies include land-use and land-tenure laws, and development of physical infrastructure that supports production and promotion of healthy, sustainably grown food, especially by smallholder farmers.”

● P. 16, line 9 - 13: The authors may consider recognizing here that an increase in income also leads consumers to purchase organic food or more expensive plant-based alternatives to meat and dairy.

● P.17, line 22-30: Discuss both the positive and negative potential for packaging to impact healthy diets. For example, though packaging provides media for conveying information to the consumer (labels), it is also a medium for misinformation and/or misleading information (e.g. dubious health claims).

● P. 18, line 5-6: We recommend adding here that exports of fresh fruit and vegetables may lead to “fresh produce and nutritious foods” being unavailable.

● P. 18, line 27: We recommend adding “clear and easy-to-read” before “nutrition labels”. In order for nutrition labels to be “a key source of potentially useful information for consumers seeking to make healthier choices”, in addition to being accurate they need to be clear and easy-to-read.

● P.18, line 34: Consider expanding on what is meant by ‘the food environment within the household’. We suggest adding the following, “The food environment within the household and settings where individuals learn and work such as schools and workplaces, are also critical to diet quality”.

● P. 19, line 4: We recommend adding “minimally processed” before “nutrient-dense foods”.



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● P.24, line 20-22: “Since 1990, the number of overweight children under five in low-income countries has nearly quadrupled, compared with a decrease of 20 percent among uppermiddle-income countries (UNICEF/WHO/World Bank, 2015).” This sentence is inaccurate - there has been no decrease in the percentage of children under five who are overweight in upper-middle-income countries.

● P.30, line 6: The International Obesity Task Force (IOTF) is now World Obesity/ Policy & Prevention 73

● P30, line 12: Include the following reference for how obesity is linked to cancer: World Cancer Research Fund International. Weight and Cancer.74

● P.32, line 8-9: Clarify which diseases have risen exponentially. ● P.33, line 8-13: Prevalence data is given for diabetes, but not for CVD or cancers linked to overweight/obesity. Be consistent across diseases.

● P.33, line 25-26: Being overweight or obese is a major risk factor for NCDs, as such it should be included in this sentence: “The focus to reduce NCDs should be to reduce the incidence of the major risk factors such as overweight and obesity, high blood pressure, unhealthy diets and physical inactivity.”

● P. 34: We commend the authors for not only highlighting the negative impact of energydense, nutrient-poor diets but also expanding on the protective properties of nutritious foods and their role in decreasing NCD risk.

● P.48, line 1: “food systems contribute 19-29% of global anthropogenic greenhouse gases (GHG)” - consider providing a further breakdown (with percentages) of how different components of the food system contribute to GHG (e.g. meat production separate from agriculture, etc).

● P.48: There is repetition in lines 10-12 and lines 26-29.

● P.49, line 19-24: This paragraph overemphasizes the change in activity levels and fails to mention the significant increase in availability of ultra-processed food during this time.

● P.56, paragraph beginning line 44: In order for school meals to have a positive influence on malnutrition in all its forms, nutrition standards are necessary - not only for school meals but for all food available in schools.

● P.60, line 22: Define ultra-processed food.

● P.67, line 37-38: Define nutrition-sensitive policies and how they are different from nutrition-specific policies.

● P.68 Figure 27: “Exit and entry points along the value chain for nutrition”. Consider making the distinction between the ‘nutrition entering’ and ‘nutrition exiting’ points along the value chain in the figure clearer (e.g. using different colours).

73 http://www.worldobesity.org/what-we-do/policy-prevention/

74 http://www.wcrf.org/int/cancer-facts-figures/link-between-lifestyle-cancer-risk/weight-cancer Accessed 28/11/2016



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● P.69, Figure 28: We recommend adding nutrition and food skills education in school to “consumption food utilisation” and nutrition labelling (in addition to food labelling) to “distribution, marketing and retail” in the figure.

● P.70, line 37: We suggest defining “evidence of impact”, for example what is considered an impact (e.g. health outcomes or intermediary outcomes along a pathway of change)?

● P.71: To improve readability of this section, ensure that the sub-headings follow the same order outlined in the conceptual framework. Currently the food environments sub-headings are not aligned.

● P.81, line 6-7: We recommend adding saturated fat and sugar to list of “less healthy ingredients”.

● P.83, line 3-4: We recommend the report avoids using “best buy” terminology as the costeffectiveness of specific interventions varies by country and is only one criteria used when priority setting. The WHO is moving away from “best buy” language.

● P.83: When discussing policies that address diet-related NCDs, include information about sugar reduction strategies in addition to transfat and sodium reduction policies.

● P.87, line 17-18: Consider providing examples or reference examples of where nutrition labelling has resulted in product reformulation.

● P.88, line 19-20: We recommend using stronger language here: “It is likely that sStronger regulatory approaches are needed such as advertising bans to children.” Outline criteria that need to be considered to develop strong regulation (as outlined in our response to question 9).

● P. 91, line 3-4: Consider providing an example of a municipal policy that has improved the provision of food (e.g. NYC food procurement standards).

● P. 96, line 39: Consider adding FoodSwitch 75 to the section that outlines smart apps. The FoodSwitch app is designed to help find out what’s in food and suggest simple, healthier switches.

● P.108, line 22-23: While it’s clear more research is needed to understand the mechanisms of ‘what works’ to effectively influence the food environment to stock/supply healthier food products, in stating “the mechanism of what works is not clear, be it government regulation, industry self-regulation or incentives” the authors do not do justice to what is known. For example, sufficient research has shown that industry self-regulation of food marketing to children does not work.

For further information or clarifications please contact Alena Matzke at [email protected].

82. Marzella Wüstefeld, WHO, SwitzerlandPlease find attached the contributions of the WHO Department of Nutrition for Health and Development to the online consultation on the Zero Draft of the HLPE report on Nutrition and Food Systems.

75 http://www.georgeinstitute.org.uk/projects/foodswitch, http://www.foodswitch.co.uk/




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Thank you for this opportunity to provide comments. We welcome that the Committee on World Food Security (CFS) has decided to play an important role in advancing nutrition within its mandate and added value, in line with the 2030 Agenda for Sustainable Development and the outcomes of the Second International Conference on Nutrition (ICN2). In this context the new HLPE report on Nutrition and Food Systems is timely and highly relevant, and it will be an important basis for future engagements of CFS in advancing nutrition and potentially to its contribution to the UN Decade of Action on Nutrition over the next 10 years 2016-2025.

We hope our comments are helpful and are available for any further clarifications if needed.

e-consultation on the Zero Draft of the HLPE report on Nutrition and Food Systems

Contribution from World Health Organization (WHO)

Thank you for this opportunity to provide comments on the Zero Draft of the new HLPE report on Nutrition and Food Systems.

We welcome that the Committee on World Food Security (CFS) has decided to play an important role in advancing nutrition within its mandate and added value, in line with the 2030 Agenda for Sustainable Development and the outcomes of the Second International Conference on Nutrition (ICN2). In this context the new HLPE report on Nutrition and Food Systems is timely and highly relevant, and it will be an important basis for future engagements of CFS in advancing nutrition and potentially to its contribution to the UN Decade of Action on Nutrition over the next 10 years 2016-2025.

We would like to provide the following overall comments and observations:

We support the nutrition focus on malnutrition in all its forms, in line with the outcomes of the Second International Conference on Nutrition (ICN2) where countries committed to eradicate hunger and prevent all forms of malnutrition worldwide. The accompanying ICN2 Framework for Action (FAO/WHO, 2014), provided sets of policy recommendations for countries to achieve these commitments. Furthermore, we would like to encourage the project team to also elaborate more on the important link of obesity, NCDs and the increased risk of impoverishments of people and families, the various links to poverty and marginalized population groups.

Potential Ref: • http://www.who.int/global-coordination-mechanism/ncd-themes/povertydevelopment/en/ • http://www.thelancet.com/pdfs/journals/lancet/PIIS0140-6736%2816%2932253-X.pdf • http://www.wpro.who.int/publications/docs/poverty_ncd.pdf



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• http://www.un.org/en/ecosoc/newfunct/pdf/discussion%20paper%20on%20ncds %20%205%20may%202009.pdf

ICN2 Rome Declaration on Nutrition and Framework for Action The zero draft report could refer in more details to the ICN2 outcomes. More specific reference could be made to the ICN2commitments, which place food systems in the forefront of relevant international and national agendas across sectors, including agriculture, food, nutrition and public health. Among others, Member States committed to enhance sustainable food systems by developing coherent public policies from production to consumption across relevant sectors to provide year-round access to food that meets people’s nutrition needs and promote safe and diversified healthy diet.

This HLPE report will be an important tool to help operationalising the ICN2 Framework for Action. With this regard, the report should make reference to and address specifically the 9 recommended actions for sustainable food systems enabling healthy diets, and those on trade and investments that are outlined in the Framework for Action. The zero draft report looks into details of supply and demand side factors in country specific contexts. We would welcome a table making the connexion between the ICN2 Framework for Action recommendations and the major elements related to them in the report and final recommendations of the HLPE project team that will be part of HLPE report. We would support the HLPE report takes a balanced approach between food supply side and demand side policies and measures and the interlinkages between both; and furthermore addresses the food environment in adequate terms. One important point would be to analyse the linkages of the production of agricultural commodities with key foods of the healthy diet components illustrated in chapter 3.

Food system typology: The anticipated food systems analysis with their diverse opportunities for impact will be an important element of the report. We would like to recommend two relevant references for this section that are based on the same food system typology with complementary sets of indicators: The Global Nutrition Report 2015 chapter 7 ‘Indicators for nutrition-friendly and sustainable food systems’ (IFPRI 2015); and the UNSCN paper ‘Investments for healthy food systems – a framework analysis and review of evidence on food system investments for improving nutrition’ (UNSCN 2015).

InvestmentsWe trust that the HLPE report will look into the nature of current agricultural investments with concrete data and conclusions on how these could be reshaped to contribute to improve diet quality, rather than only providing sufficient calories. The right agricultural commodities are needed, as food and as ingredients for other food products, to enable healthy diets. This should also include critically analysing the current agricultural subsidies policy and addressing potential ways for redirecting subsidies to directly support the current challenges of the food systems and agricultural sectors.

Sustainable food production and food supply We welcome that the report addresses the production of the foods needed to supply, what the report calls, the ‘Healthy Diet Components’. These include among others



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₋ Fruit and vegetables, and ₋ Oil seeds that can supply unsaturated fats to replace saturated fats and industrially trans

fats in food and food products.

A healthy diet contains a certain amount of fruits and vegetables every day. And the risk factors of premature death and disability include diets low in fruits and vegetables. There are opportunities throughout the food system to overcome supply-side barriers to make fruits and vegetables available, affordable and appealing. Such a focus area would be in line with the mandate of the CFS. We would welcome if the report could develop recommendations on what would be needed to reshape the supply chain of concrete ‘healthy diet components’ such as fruits and vegetables. In this same line, we would also support if the report could address the issues and challenges of the fat supply chain in greater details. Relevant references are available. Evidence based policies We welcome the focus on evidence based policies to address all forms of malnutrition and are ready to contribute with the work that WHO is doing on the analysis of effectiveness and costeffectiveness of policies and programmes. We would like to comment in more details on the table on page 34 (see also below), which seems to be taken from the ‘Report of the joint WHO/FAO expert consultation. Diet, nutrition and the prevention of chronic diseases. WHO Technical Report Series, No. 916 (TRS 916)’ available at http://www.who.int/dietphysicalactivity/publications/trs916/en/ . For now it seems like a mix of presenting dietary exposures and health outcomes. We would like to propose taking a more systematic approach in putting this table together. If exposures are to be modified and others added, what seems to be the case, we would recommend to clearly referencing those.

Healthy Diets

At the heart of the report are healthy diets.

On page 12: we suggest adding a box with the definition of ‘healthy diet’ with reference to the WHO Healthy Diet fact sheet (WHO 2015) before the term ‘sustainable diet’

Page 19 line 1: we propose to use the WHO healthy diet fact sheet (WHO 2015) as reference to the characteristics of diets for health. This fact sheet is the summary of evidence based guidelines. The individual guidelines are available in the WHO e-Library of Evidence for Nutrition Actions (eLENA) at http://www.who.int/elena/nutrient/en/ . In this e-library also further guidelines and evidence for a number of other diet related actions can be found. We would like to highlight that breastfeeding seems to be missing in the list of characteristics.

Healthy diet and adequate nutrition start early in life, and are crucial to ensure good physical and mental development and long-term health. We like to stress the importance of breastfeeding for fostering growth and improving cognitive development, and possibly having long-term health benefits, like reducing the risk of becoming overweight or obese and developing NCDs later in life. In this context it is important to identify and address the relevant food system elements and policies shaping the food environment of young children to enable adequate infant and young child nutrition.



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Reference is made to the Network for Global Monitoring and Support for Implementation of the International Code of Marketing of Breast-milk Substitutes and Subsequent relevant World Health Assembly Resolutions (NetCode: http://apps.who.int/nutrition/netcode/en/index.html), the provided guidance on ending the inappropriate marketing of foods and non-alcoholic beverages to children (WHO 2010), the guidance on ending the inappropriate promotion of foods for infants and young children (WHO 2016). Comprehensive implementation plan on maternal, infant and young child nutrition. WHO 2012. Available at:

http://www.who.int/nutrition/publications/CIP_document/en/

The role of different actors in the food system

We are missing in the zero draft, that the role of the different actors in the food system is clearly address sending a signal to the private sector, to capital markets, to research and development for their contributions to accelerate the shift / reshaping of our food systems into sustainable food systems that provide and enable healthy diets for all.

We like to underline the particular role of the private sector with regard to reshaping the food systems. As outlined on the ECHO report (WHO 2016), the private sector is not a homogeneous entity. It includes among others, the agricultural food production sector, the food and non-alcoholic beverage industry, retailers, catering companies, advertising businesses and the media. It is, therefore, important to consider those entities whose activities are directly or indirectly related to food and beverages for human consumption and nutrition, especially with impacts on the increasing trends of overweight and obesity either positively or negatively. Countries need to engage constructively with the private sector to encourage implementation of policies and interventions. Private sector needs to be hold accountable for their support towards the production of, and facilitated access to, foods and non-alcoholic beverages that contribute to a healthy diet.

Conflict of Interest

Page 106 line 3 ff: a section on Conflicts of Interest is planned. As mentioned in the text on page 106, safeguards against conflict of interest are essential to preserve the independence of policy space from undue influences. There has not been yet an agreed definition of conflicts of interest for the area of nutrition amongst the global nutrition community. Nonetheless, basic elements of conflicts of interest are captured in the following working definition: “a set of conditions in which professional judgement concerning a primary interest […] tends to be unduly influenced by a secondary interest […]”. In response to the emerging challenge of conflicts of interest in nutrition, the Department of Nutrition for Health and Development at WHO headquarters convened a WHO technical consultation on “Addressing and managing conflicts of interest in the planning and delivery of nutrition programmes at country level” in Geneva, Switzerland, on 8–9 October 2015. The meeting report, available at http://www.who.int/nutrition/publications/COI-report/en/ , should help Member States and their partners in their efforts to make informed decisions on the appropriate nutrition actions required to promote the Comprehensive implementation plan on maternal, infant and young child nutrition and to achieve the Sustainable Development Goals. The meeting concluded among others that conflicts of interest need to be examined at several stages in



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the policy process: i. initially, when deciding whether to establish a policy; ii. Second, when establishing a policy and/or set up a programme; iii. Third, when implementing policies; iv. Fourth, when monitoring programmes and evaluating public policies. The first three stages are where there is the greatest likelihood of engagement with the private sector, and in each of these stages there should be an explicit assessment to determine whether there are conflicts of interest and if so, how they should be addressed. Réf: WHO. Addressing and managing conflicts of interest in the planning and delivery of nutrition programmes at country level. Report of a technical consultation convened in Geneva, Switzerland, on 8–9 October 2015. 2016. http://www.who.int/nutrition/publications/COI-report/en/

Impact assessment of policy on diets and nutrition

We would like to encourage the HLPE team to also address the issue of potential impact assessment of policy tools on diets and nutrition. With this regard we like to refer to the work the UNSCN has started on a Nutrition Impact Assessment tool (http://www.unscn.org/en/second_international_conference_on_nutrition/icn2_followup.php ). This could be the basis not only for a potential tool how nutrition could be mainstreamed in CFS work, but also how governance could screen their food policy measures for potential impacts on nutrition.

Finally, to truly move towards sustainable and healthy food systems, the HLPE report would need to address how to establish a process throughout which over the next 10 years under the umbrella of the UN Decade of Action on Nutrition 2016-2025 and beyond, we will be able to truly progress and track progress on the reshaping of our food systems. For that we need a transparency of measurement of progress with milestones and predictable long-term targets. We hope that the HLPE report will contribute to establish the needed multisectoral dialogue to engage in this process.

In the following we are providing more specific comments on particular parts of the report:

Specific comments on Chapter 1

Page 16/17: Page 16 line 33: It says that there are five categories…. In the following text, the fifth category ‘food acquisition, preparation and consumption’ seems missing or is not very obvious to the reader.

Specific comments on chapter 2 – The Burden

We suggest strengthening the introductory part on page 24, with more urgency and more details on the fact that the multiple burdens of malnutrition do occur simultaneously. This chapter seems to single ‘sides’ of malnutrition. It is crucial that we continue to elevate the realities facing governments globally – malnutrition does not happen in a vacuum/silo, neither can the problem be prevented by focussing on addressing only one particular side of it. The world is facing a nutrition crisis, every one of the world’s countries is burdened by more than one form of malnutrition or dietrelated non-communicable diseases. These forms also co-exist within the same country, community, household or individual. http://www.who.int/nutrition/double-burden-malnutrition/en/ .



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Ref.: WHO. The double burden of malnutrition. Policy brief. Geneva: World Health Organization; 2016. Other important reference is the Global Nutrition Report.

We would like to recommend that for all estimates of malnutrition, the latest data from 2016 be used, this is applicable for several data tables and trends in the report. The latest Joint Child Malnutrition Estimates can be found at http://www.who.int/nutgrowthdb/estimates/en/

Section 2.1

For the estimates given on childhood malnutrition, we would advise to use the latest figures that were released in 2016 see at: http://www.who.int/nutgrowthdb/estimates2015/en/

Page 25: - Wasting: the definition of wasting given in the box is not in line with the ICD-11 (International Classification of Diseases, http://www.who.int/classifications/icd/en/ ) which doesn’t include MUAC. MUAC is included in the definition of acute malnutrition.

In more general terms, we would recommend to also define the term undernourishment in the report, as this can easily be confused by professional staff from other sectors with the term undernutrition.

With regard to underweight, that is included in the box on page 25, it is correct to refer to it in the context of the MDGs. On the other hand for the future we may want to point out that the SDG indicators are stunting, overweight and wasting. Underweight is not part of the global SDG framework indicators.

Related to that, it would be good to correct the definitions on p. 25, inside the box: Stunting <-2 SD; Wasting should also be defined as <-2 SD; We would suggest that the box should define stunting and take out the definition of chronic malnutrition. Chronic malnutrition is often used to describe stunting, it is not part of the

International Classification of Diseases (ref.: http://www.who.int/classifications/icd/revision/en/)

Figures 3 and 4 are based on the joint malnutrition estimates work of WHO/UNICEF/WB, so it would be nice to get the full reference in.

Section 2.2

Especially worrying is that childhood obesity is reaching alarming proportions in many countries and poses an urgent and serious challenge to health and development. To address this, the WHO Commission on Ending Childhood Obesity (ECHO) has produced a report specifying which approaches and combinations of interventions are likely to be most effective in tackling childhood and adolescent obesity in different contexts around the world. The Commission report’s recommendations are a valuable reference for the HLPE report. The ECHO report proposes a range of recommendations for



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governments aimed at reversing the rising trend of children aged under 5 years becoming overweight and obese. The ECHO report refers to six main action areas including comprehensive policy measures and programmes that promote the intake of healthy foods and reduce the intake of unhealthy foods and sugar-sweetened beverages by children and adolescents (through, for example, effective taxation on sugar-sweetened beverages and curbing the marketing of unhealthy foods). WHO. 2016. Report of the Commission on Ending Childhood Obesity. Available at http://apps.who.int/iris/bitstream/10665/204176/1/9789241510066_eng.pdf?ua=1

On page 30, in the box of definition 7, we suggest the addition of overweight in childhood here, defined as weight-for-height >+2 SD. This is part of the 6 WHA global nutrition targets, and an important indicator in the global SDG Framework as part of the target 2.2.

More attention should be given to early nutrition, child and adolescent obesity and their impacts on obesity and NCDs across the lifecourse. Furthermore, greater spotlight should be on the role/relevance of maternal nutrition, and nutrition of young girls, in addressing both undernutrition and overweight in subsequent generations.

Risk factors for NCDs at end of page 33 and beginning of 34 are mixed together and not well structured. We would also like to suggest greater discussion on food environments and food systems in this context of risk factors.

We would like to suggest an additional section or mention to double duty actions – those policies, programmes and initiatives which are effective in halting, reducing or reversing multiple forms of malnutrition. Ref Forthcoming: WHO. Double Duty Actions. Policy brief. Geneva: World Health Organization; 2016.

In the table 3 on page 34: The information in this table comes from the ‘’Report of the joint WHO/FAO expert consultation.

Diet, nutrition and the prevention of chronic diseases. WHO Technical Report Series, No. 916 (TRS 916)’’. The evidence for many of these associations is being reviewed currently and some associations identified at the FAO/WHO joint consultation may be modified.

We would like to suggest some further completion of this very valuable table 3 with some more proven details. For a complete overview of evidence-based nutrition interventions and actions with proven impact on the 6 WHA global nutrition targets and the 3 diet-related NCD targets see http://www.who.int/elena/global-targets/en/ and http://www.who.int/elena/titles/summary_eLENA_interventions_linked_global_targets.pdf?ua=1 The table 3, as it stands now, does not distinguish between the different levels of evidence linking these exposures and outcomes specified in the TRS916. Included are those that have both convincing and probable associations based on the evidence (incidentally WHO no longer uses this classification scheme for assessing confidence in evidence; GRADE is now used). As such, we think it needs to be more clearly stated. Alternatively, language can be use such as "may be linked", etc.

More specifics:



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• Energy-dense foods & beverages and micronutrient poor foods shouldn't be separated; document from which this table was extracted indicates "High intake of energy-dense micronutrient-poor foods". Also the TRS916 (on page 63) included a footnote that specifies: "Energy-dense and micronutrient-poor foods tend to be processed foods that are high in fat and/or sugars. Low energy-dense (or energy-dilute) foods, such as fruit, legumes, vegetables and whole grain cereals, are high in dietary fibre and water".

• With regard to Mediterranean/vegetarian diet, it is unclear why this is only related to Type 2 Diabetes and not to obesity and CVD? WHO is currently going through the guideline development process developing WHO guidance on dietary patterns, which explores further relations with this regard.

Specific comments on chapter 3

Chapter 3.1.3. Page 42 line 9/10: It would be best to cite the UNICEF Infant and Young Child Feeding Database at https://data.unicef.org/topic/nutrition/infant-and-young-child-feeding/. They just put out a new publication in October so the statistics quoted in the GNR would be out of date now.

Page 42 definition box: this box should also include the definition of exclusive breastfeeding.

Exclusive breastfeeding" is defined as no other food or drink, not even water, except breast milk (including milk expressed or from a wet nurse) for 6 months of life, but allows the infant to receive oral rehydration solution, drops or syrups (vitamins, minerals and medicines)

Ref http://www.who.int/elena/titles/exclusive_breastfeeding/en/

Specific comments on Chapter 3.2.5

Page 63: Conflicts and social unrest: The text says……. WHO reports that “Over the past two decades, the number of stunted children in conflict-affected countries in the developing world increased from an estimated 97.5 million (equivalent to 46 percent of all stunted children in developing countries) to 12.1 million (equivalent to 65 percent)” (Breisinger et al., 2015). Our comment: The figures do not match. Page 63 Figure 24: Reductions in stunting correlate with conflict: This title is confusing, it should be “Stunting correlates with conflict” or “Reductions in stunting correlate with reduced conflict”.

Page 66 Figure 26: Correlation between violence and hunger. Violence index and hunger index: Definitions would be useful without having to go to the source.



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Specific comments on chapter 4 Specific comments on chapter 4.1.1 and 4.1.2

Page 67 line 36 ff:

It says in the text that. “Although there is strong evidence surrounding the nutrition-specific policies and programmes that could improve nutrition outcomes (Bhutta et al., 2013), less is known about those that are nutrition-sensitive and tackle broader dimensions of the food systems (Ruel et al.,

2013; Pinstrup-Andersen, 38 2013).”

Our comment: There are some good examples where much is known and where evidence exists on effective actions directed at the food system, e.g. reformulation but also other actions identified during the evidence-based revision of the WHO NCD Strategy Appendix 3.

Other relevant reference: Fiscal policies for diet and the prevention of noncommunicable diseases (WHO 2016) available at http://www.who.int/dietphysicalactivity/publications/fiscal-policies-dietprevention/en/

Specific comments on chapter 4.1.3

We understand that this section is still under development, and would suggest including case studies on how regulation on marketing of breastmilk substitutes or food and non-alcoholic beverages to children contribute to improved diets and nutrition. The example of Norway was presented at the International Symposium 1-2 December in Rome.

More details are also at http://apps.who.int/nutrition/netcode/en/index.html and at http://apps.who.int/nutrition/events/2016_2nd_netcode_meeting_6to8june/en/index.html

Specific comments on chapter 4.2.2

Page 104: Social safety nets: This is something that has been used in humanitarian crises which needs to be mentioned (not only in the context of poverty). The term “food system resilience “has not been used once in the document. It would be useful to address this in the document especially in the context of conflicts and crises.

Chapter 4.2.3

Page 104 line 31 ff The report addresses the nexus between agriculture, food, nutrition and health; in this regard we would like to suggest the inclusion of the diet related global NCD targets in this para next to the WHA global targets. These are part of the global monitoring framework for the prevention and control of NCDs (World Health Organization. 2013. Global Action Plan for the Prevention and Control of Non-communicable Diseases. Geneva).



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Page 104 line 43 ff: National Strategies on nutrition and multisectoral coordination Some few country examples with national nutrition strategies are mentioned. However this paragraph should start with a broader overview and acknowledge the fact that numerous countries have developed national nutrition policies and plans of actions - many countries even have multiple generations of National Plans of Action for Nutrition (NPAN) - as result of the first International Conference on Nutrition in 1992 (ICN 1). WHO conducted 2009-2010 the 1st Global Nutrition Policy Review, and results are available in the report published in 2013 and in the WHO Global database on the Implementation of Nutrition Action (GINA) http://www.who.int/nutrition/gina/en/. GINA, which is updated on a continuing basis, contains as of today policy data showing that 119 countries have developed national nutrition policies and plans, and that 121 countries have integrated nutrition components in their health-sector plan. More detailed information at http://www.who.int/nutrition/gina/en/

Currently WHO is undertaking the 2nd Global Nutrition Policy Review, which will be used to further update GINA. Preliminary results had been presented at the recent International Symposium on 1-2 December in Rome.

Page 106 line 6 ff: We would like to suggest that at the beginning of this chapter the UN Decade of Action on Nutrition is referred to. The Nutrition Decade will serve to create a “movement of movements”, a shared, inclusive, and focused space in which all nutrition-related influencers will have the opportunity to converge and catalyse action. Global connectivity across sectors and constituencies is a unique added value of the Nutrition Decade.

Chapter 4.2

Page 92: We would like to suggest restructuring this chapter ‘looking in the future’. It could better start with ‘Food system changes’ (now under point 4.2.2.), followed by the session on ‘technology’ (now 4.2.1). Technologies would serve the anticipated food system changes. In addition, the structure of this chapter could better align with the elements on the figure 1 on page 14, which would make it easier accessible to the reader.

83. Jacopo Valentini, WFP, ItalyWFP’s comments on the HLPE zero-draft report on nutrition and food systems

Cross-cutting comments1. The purpose of the report is clearly stated and successfully illustrates efficient policies and

programmes. The report could do more to include general guidelines for governments and partners in order to contribute more effectively to improved nutrition and ensure the right to food for all.

2. The report is comprehensive and well-articulated with a good balance between technical and more colloquial language. The definition boxes are especially useful.



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3. The conceptual framework (p.14) is overly complex. The framework in the 2013 SOFA is clear. At the very least, it should be simplified visually. Additionally, if “food environments” are indeed central to the framework, they should be addressed in greater depth.

4. The report is strangely silent on the role and impacts of humanitarian crises in defining current and future levels and patterns of malnutrition globally, and thus also about the role of food assistance in addressing drivers and reflections of food systems performance in difference contexts. This is a major gap since more than 125 million people are currently directly affected by humanitarian crises, over 65 million are displaced, 21 million are refugees, 41 million internally displaced, 3 million seeking asylum. WFP itself provided direct food assistance to an average of more than 78 million people per year in 82 countries at a cost of $5 billion per year. The scale of WFP’s food assistance operations confirms that the most basic needs of vulnerable populations caught in the grip of humanitarian crises borne of poverty, violence, and environmental degradation are expressed through food systems that determine and reflect that vulnerability. In extreme cases, food systems are arenas of oppression, subjugation, and abuse of power. The implications for malnutrition are immense and deserve mention in this important report.

5. The issue of typology is fundamental, not only of food systems within and across countries but also of countries themselves based on the performance of their food systems. High-performing food systems support the core functions of food production, transformation, and consumption efficiently (at least cost) and predictably, providing adequate incentives and returns to food producers, processors, and distributors, and delivering sufficient, safe, and nutritious food to well-informed consumers, with minimum delay and spoilage. Such systems also support inclusive structural transformation of economies, boosting productivity and incentives that cut poverty and hunger. But the specter of 800 million chronically hungry people across the globe suggests that structural transformation and the food system transformation that it drives and reflects are not delivering hunger reduction at sufficient scale. A complete analytical effort to develop a comprehensive typology would entail multivariate regression analysis based on comprehensive data at different geographical levels, controlling for a range of factors. Lack of these data precludes such an analysis in most cases. IFAD’s approach to developing a typology for analyzing rural transformation in the 2016 Rural Development Report is illustrative of a compact but informative approach. WFP has also applied this approach in its work on food systems and would be open to sharing the results of preliminary work.

6. The last section on “looking forward” could be strengthened and particularly it should address the role of governments in contributing to improved nutrition and sustainable food systems.

7. The report would benefit from looking more into the importance of partnerships, in particular the role of governments and of the private sector in food systems.

Specific comments1. P.13 line 14: highlight the changing nature of food systems as a result of forces such as

urbanization, income growth, shifting in consumers diets as a result of structural transformation of economies (Reardon and Timmer 2012).

2. Expand on the concept of shocks and flaws in food systems. Many food systems are disrupted by a range of covariate shocks, many are broken due to strife and conflicts. But also in relatively stable context food systems can be deeply flawed: communication, transportation and storage facilities are often poor, commercial markets can be severely segmented or characterized by



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unequal social capital and financial bargaining power. In other words, food systems do not always work in ways that meet the needs of the entire society and of those left behind.

3. P.20, indicators: some additional indicators that would be useful are indicators on storage and distribution captured by the Logistic Performance Index (World Bank and FAO), affordability indicators, captured by Goss Domestic Product per capita as well as the food utilization indicators.

4. P. 41: the paper mentions an increase in consumption of sugar-sweetened beverages. Perhaps it is worth mentioning upfront the successful examples of soda taxes implemented in Mexico, Denmark, the UK, in some localities of the United States and most recently in Ecuador.

5. P. 50, line 9: In this section that deals with infrastructure it would be useful to address the interactive impacts of the physical, economic, social and political isolation that generate “last mile” outcomes for households in both rural and urban areas. Vulnerabilities generated by the “last mile” problem are accentuated by environmental and natural resource degradation, political conflict, thin and scant physical infrastructure and a range of economic shocks linked to macroeconomic policy, trade and globalization.

6. P. 50: Are social networks really at the same level as infrastructure and technology as key drivers of food systems? Maybe they should go under sociocultural drivers.

7. P. 58: when addressing demographic drivers it is worth referring to structural transformation, namely the rising productivities in agriculture and the urban economy, a change in the composition of the economy from a preponderance of agriculture to industry and services, rising involvement in international trade, growing rural-urban migration and urbanization, and the realization of a demographic transition from high to low birth rates.

8. P.68 line 26: In the section regarding value chains it would be helpful to focus more on the key actors and entry points along the value chain, especially producer-traders, trader-processor, retailers and consumers.

9. P. 104, line 42: Knowledge sharing and cooperation between the specialized agencies, NGOs and private sector is key to keep food systems more effective and targeting SDGs. In order to do so it is necessary a focus on partnership at all levels, seeking to leverage the diverse strength and specializations of organizations already working in the field.

The following examples/information has relevance for the Case Studies section:

Below is the breakdown, by value chain category, of some of the nutrition-sensitive approaches already being utilized in the Purchase for Progress (P4P) approach to smallholder marker support being implemented by WFP in partnership with governments and over 500 organizations in 35 countries and worldwide.

Input Supply P4P is collaborating with HarvestPlus in Rwanda, Uganda and Zambia to increase the availability

of micronutrient-rich staple foods. To increase the amount of biofortified seed in circulation, smallholders are participating in multiplication activities, growing the biofortified crops and selling part back to HarvestPlus for re-distribution. They are also retaining a portion for household consumption.

In Rwanda, P4P-supported farmers’ organizations are multiplying beans rich in iron.



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In Zambia, P4P-supported smallholder farmers’ organizations are multiplying maize rich in vitamin A.

In Uganda, HarvestPlus is supporting farmers to grow Iron Beans and Vitamin A Sweet Potatoes. Some of these farmers are also participating in P4P.

Production In Burkina Faso, Liberia, Mali, and Sierra Leone, P4P has encouraged the production and

consumption of a regional variety of cowpea called niébé, which is rich in protein and traditionally farmed by women. This project could have multiple nutritional benefits, by encouraging the consumption of niébé on a household level and by providing women with an increased income, which can allow them to improve their family’s diets.

When coupled with training on good nutrition, efforts to improve women’s agricultural production can empower women to make decisions that deliver improved nutrition outcomes for their households. In countries including Burkina Faso, Ethiopia, Ghana, Kenya, Malawi, Mali, Mozambique, Uganda, Tanzania and Zambia, P4P has provided women farmers with time- and labour-saving technologies to ease their workload. This enables them to dedicate more time to childcare.

In Malawi and Zambia, P4P is working to scale up the production of ground nuts among farmers’ organizations for sale in local markets.

In Afghanistan, the production of soya, which is rich in protein and amino acids, is supported through training.

Through the Purchase from Africans for Africa (PAA) initiative in Malawi and Mozambique, WFP is procuring diverse foods from P4P-supported farmers for use in home grown school feeding programmes, including fruits and vegetables. In Mozambique P4P is also supporting a horticultural farmers’ association, primarily run by women, with the aim of supporting diet diversification.

Food from P4P-supported farmers in Mali is being used to diversify WFP food baskets.

Post-harvest Storage In all P4P pilot countries, food quality and safety is emphasized through training, particularly in

post-harvest handling and food quality standards to reduce the likelihood of occurrences of aflatoxin, which may contribute to stunting in children. Awareness has been raised on family, community and national levels about the dangers of consuming low quality crops.

In Ethiopia, Kenya, Malawi and Zambia, P4P-supported smallholder farmers’ organizations have been trained on food quality standards. Their aggregated maize produce has been tested for aflatoxin by WFP’s hired superintendent prior to concluding any food contract. Read more

In Mozambique, P4P has equipped a university laboratory to test for aflatoxin. P4P in Burkina Faso is working to develop a similar laboratory.

WFP’s Blue Box field laboratory was developed under P4P in Guatemala, to respond to a need for food quality and safety testing, particularly aflatoxin. 25 WFP Country Offices (out of which 13 are P4P) have started to incorporate the Blue Box in relevant parts of their supply chains, including farmer organizations, storage facilities run by WFP and partners and WFP procurement.

WFP has carried out a successful action research evaluation trial on “Reducing food losses in sub-Saharan Africa” with P4P-supported smallholder farmers in Burkina Faso and Uganda. Read more



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Processing GUTS Agro Industry, a private sector food fortification company, is buying grains from P4P-

supported farmers in Ethiopia to produce corn-soya blend (CSB). WFP Ethiopia has also partnered with Pepsi on a project called EthioPEA, which aims to produce a chickpea-based Ready to Use Supplementary Food (RUSF) for treatment of acute malnutrition. If the product is proven effective, the project will build national production capacity for scale up and provide P4P-supported farmers with technical trainings to improve chickpea production.Blended foods using crops purchased from P4P-supported farmers in Kenya have been produced and distributed through the Kakuma refugee camp school feeding program.

P4P-supported farmers in Rwanda have sold grain to MINIMEX, a private maize processor that supplies fortified flours to WFP, and to small-scale processors supported by the Association Rwandaise pour le Dévelopement Intégré.

In Afghanistan, P4P has set up a mobile factory run by a local partner to produce High Energy Biscuits (HEB) using wheat procured from local smallholder farmers. WFP has also been providing assistance to large flour fortification mills, many of which procure grain from P4P- supported farmers. WFP is in the process of supporting capacity building for locally-produced RUSF, providing another fortification market for P4P-supported farmers.

Under the SUN movement, P4P in Guatemala is working to assist smallholders to sell their surplus to millers and processors for the production of nutritious blended foods. Read more

In Kenya and Malawi, nutritious corn-soya blend made from smallholders’ crops has also been procured by WFP.

Procurement/Distribution In Burkina Faso, Honduras, Kenya, Ethiopia, Liberia, Malawi, Mali, Mozambique, Rwanda and

Zambia, P4P-supported smallholder farmers have been linked to home grown school feeding programmes, providing school meals to food insecure students. Linking the surplus crops produced by P4P-supported smallholders to these programmes not only stimulates local economies and provides farmers with a sustainable market, but also promotes attendance among students who receive school meals. Depending on the foods that are sourced, these programmes could also provide a platform for diet diversification and addressing micronutrient deficiencies. Read more

Farmers’ organizations in Kenya have begun selling fruits and vegetables in camp markets, where WFP provides refugees with vouchers for the purchase of fresh, nutritious foods. The Kakuma camp school feeding programme also procures fruit, vegetables, and locally-produced fortified snacks from P4P farmers. The Government of Canada has supported efforts to connect P4P-supported smallholder farmers to large-scale traders who purchase food for school feeding projects around the country.

Through PAA in Malawi and Ethiopia, P4P is supporting local schools and departments of education to buy fruit, vegetables and meat, as well as staple crops, from P4P-supported farmers for home grown school feeding programmes. Read more

In Zambia, P4P is connecting farmers who own cattle to a processing unit to provide milk for school meals programmes. A similar initiative is underway in Burkina Faso.

In Zambia, Vitamin A Maize, a biofortified crop, has been used in WFP’s school feeding programme, and has undergone successful acceptability studies.



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In Kenya, P4P is working with health sector organization AMPATH to combine medical treatment for HIV/AIDS-affected smallholders with support for improved agricultural production and sales to markets. Now farmers who once received food assistance are increasingly supplying food for themselves and the market. Read more

Marketing and Retail In Afghanistan, mass media campaigns and promotions are being implemented on a national

level to increase public awareness and consumption of fortified foods. Marketing campaigns educate people on the importance of fortification for micronutrients consumption, and the Ministry of Public Health has worked with P4P and WFP to develop a “seal” of authenticity for fortified foods that go to market.

In El Salvador, black beans from P4P-supported farmers and being canned and sold to retailers. Consumption and Food Utilization

An agreement with the Children’s Investment Fund Foundation is under discussion in order to utilize P4P’s gender component as an entry point to provide nutrition training to P4P-supported farm families in Malawi.

Through the PAA Africa initiative, nutrition education is carried out in schools implementing home grown school feeding in Ethiopia and Malawi (among others).

In Mali and several other West African countries, nutrition education sessions have been held to encourage the home consumption of niébé.

When introducing Vitamin A Maize to the home grown school feeding programme in Zambia, WFP, in collaboration with HarvestPlus, held cooking demonstrations at school and community levels to illustrate the benefits of orange biofortified maize in comparison to the traditional white variety. The schools later requested orange maize seeds, which were donated by HarvestPlus for planting in their school gardens.

Under the SUN movement in Guatemala, P4P is supporting programmes which assist rural women to create home gardens and mother-to-mother support groups to discuss feeding and care practices.

In Afghanistan, nutrition training is provided to P4P-supported farmers. Women are trained to utilize soya flour rich in protein and amino acids, as well as wheat when preparing naan bread for household use.

Page 11, line 25 – Definition of Food Environment: This definition is different from the definition provided in the GLOPAN Foresight report as well as other recent publications, like the FAO Compendium of Nutrition-Sensitive Agriculture Indicators. Those publications draw largely on the definition provided by Herforth and Ahmed (2015, Food Sec), which considers the food environment as the range of foods that are available, affordable, desirable and convenient. By focusing on characteristics of the physical food, this enables a clearer distinction between the food environment and political/economic/and sociocultural drivers, which may influence the food environment, but are not themselves part of it. This is more or less clear in the framework diagram below, but the definition provided blurs the line.



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7. If there was a discussion among the project team for why this definition was chosen over the Herforth definition, maybe it is worth providing a footnote that explains the reasoning?

8. This comment addresses questions 3 and 11 in the introduction note.

Page 14, Figure 1 – Conceptual Framework: This framework is useful especially because it shows where value chains fall within a food system - and food environments as a key interface between supply systems and consumers. What is less clear are all the individual arrows, particularly from the drivers to value chain choices, food environments, and/or consumer behaviours. Are political & economic drivers really the only ones that affect all three? Wouldn't social networks also affect consumer behaviours? And doesn't urbanization also affect value chain actors’ choices? There is also interaction among the drivers themselves, for example eroded natural resources may affect livelihoods of smallholder farmers, thus impacting those smallholder families' diets.

9. It might be easier just have one multi-pronged arrow showing that all of these drivers can impact 1 or multiple components of the food system.

10. This comment addresses question 3 in the introduction note.

Page 17, line 43 – Food environments: It may also be worth explaining that food environments can be in the market, on-farm, in schools, etc.

Page 18, line 18 – Food environments (food acceptability and preferences): This is another area where the Herforth and Ahmed (2015) definition of food environment seems to depart a bit. They focus on desirability as the characteristics of the food in the food environment (e.g. quality, how they are advertised) which may influence individual consumer preferences, but those preferences are not themselves part of the food environment.

Page 19, line 16 – Characteristics of diets for health: “Adequate and appropriate micronutrient and macronutrient amounts” could be moved further up this list, even to the top, or at least so it is near adequate food energy.



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Page 19, line 18: In this section, it may be worth pointing out already that diets for children 6-23 months need to include foods that are even more nutrient-dense than the foods adults eat, due to their inability to consume the same number of kcal.

Page 22, table 2 – Examples of indicators and data sources for each food system element: Herforth and Ahmed (2015) catalogue a range of tools and indicators that are being used to measure the food environment.

Page 25, section 2.1 – Undernutrition and its causes and consequences: It may be worth stating that MNDs as well can be considered a form of undernutrition. It's understandable, though, that they would also be in a separate section, because they frequently co-occur with stunting and wasting, as well as overweight.

11. Also, the box of “key indicators” might be better labelled key terminology or key concepts. The last three are usually measured as indicators.

Page 35, section 2.3 – Micronutrient malnutrition and its causes and consequences: This section might also mention the importance of micronutrient intake in combination with early childhood development interventions for children beyond the 1,000 days. Black et al (Advances in Nutrition 2015) present some evidence that cognitive development could respond to these interventions after the age of 2, e.g. pre-primary school age. First 1,000 days is still the best opportunity, but nutrient needs continue beyond.

Page 42, line 13: Here would also be a good place to discuss the particular challenges of meeting nutrient requirements of children 6-23 months. They consume smaller quantities and need the same level of nutrient requirements - therefore, their food must be more nutrient-dense per kcal.

Page 45, line 17 – Section on climate change: It may be worth mentioning the evidence from Nepal that household sanitation and (particularly important for this paper) access to local food markets may have protective effects against heightened risk of stunting brought on by negative agro-climatic conditions (Block et al, Climatic conditions and child height, 2016).

Page 50, line 21 – Section on social networks and movements: This section seems to be missing the person-to-person type of social networks that have become so common online. We probably don't have to look far for evidence that Facebook is changing the way food is



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advertised, which is part of the food environment. There are also projects like Digital Green that has been able to use online videos to create a farmer-to-farmer support network (which could be seen as a type of social network).

Page 62, line 19: If it will not be covered instead as part of the food system typologies, it might help to introduce here the food value chain typologies used by Gomez and Ricketts (2013, Food Policy), i.e. modern, traditional, traditional-to-modern, modern-to traditional.

Page 69, figure 29: In this figure, is it true that the programmes and policies aimed at increasing nutrition entering the value chain are also aimed at improving the quality of the food environment? As is now, it seems like the only "food environment policies and programmes" are on the demand-side.

Page 77, line 8 - Policies and programmes targeting the food system activities and actors: WFP has some interesting examples, particularly in Afghanistan, of linking smallholders with agro-processing actors. In Afghanistan, the smallholders supply wheat and WFP has supported millers to purchase this and transform it into fortified wheat flour. See here: http://www.wfp.org/stories/improving-nutrition-fortified-flour-afghanistan.

12. It is interesting because it shows how even when smallholders are producing a staple crop, there are opportunities further down the chain to add in nutritional value as long as the right linkages are being made. This was also backed by national government's fortification policy and support WFP provided in the form of food quality and control standards. We may be able to supply more information about this if it is needed.

Page 93, line 28 – Section on considerations for food technology and fortification: Other issues that may need to be addressed in this section on fortification considerations:

o that staple foods are usually fortified to meet nutrient needs of the general population, while vulnerable groups may need a higher level;

o on fortification vs. biofortification, an important distinction is also that biofortification usually focuses on just one micronutrient, while fortification during processing can include multiple micronutrients.

84. Civil Society MechanismCSM Comments on Zero Draft of HLPE Report on Nutrition & Food Systems (Dec 2016)



http://www.wfp.org/stories/improving-nutrition-fortified-flour-afghanistan

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This document conveys the comments of the Civil Society Mechanism (CSM). Despite the language restriction (the English-only text significantly limits the capacity of non-English speaking constituencies to participate in this important step), this document conveys the collective comments of the broad array of civil society constituencies that actively participate in the CSM/CFS process.

I. OVERARCHING COMMENTS

1. Report’s structure and content is not conducive to inform policy-making

The HLPE has the specific objective to “improve the robustness for policy making” and the guidance note to the consultation response states that the report aims to be “solution oriented and to highlight effective policies and programmes”. Yet solutions aren't addressed until p.67 of the draft report. The report’s exaggerated length and lack of clear focus, makes it unlikely that decision-makers will engage with it, and makes thus unlikely that it will have significant policy impact. Furthermore, due to the lack of flow between and across the chapters there is no clear indication as to what policy recommendations will be suggested and where the report is headed. There is also a notable gap between the analysis of causes, consequences and drivers of malnutrition (chapters 2 and 3) and the conclusions (chapter 4).

The CSM recommends restructuring the report so that the policy implications and options come much earlier in the report, separating more clearly the policy content (upfront) from the supporting evidence. The recommendation would therefore be to move much of the information in Chapter 2 and 3 with regard to the discussion of the Burden and “Changing Diets-what do diets look like currently?” into the supporting evidence section/annex. Similarly, many of the case studies can be moved in the annex while maintaining the analysis and conclusions gleaned from case studies in the body of the report. In order to shorten the document, one could summarize the description of nutritional problems and their consequences as they have regularly been presented in recent years. Then, more time could be spent on elaborating on the drivers of dietary change and the possible policy approaches.

The introduction and initial framing of the report need improvement. There is no adequate contextualization of the nutrition and food system nexus in the broader nutrition policy challenge . In particular, there is no adequate mention of how governance weaknesses, the fragmentation of nutrition policies and programmes, the medicalization of many nutrition interventions and the dis-embedding of nutrition with food, the flouting of legal frameworks and regulations, and the continued violations and abuses of human rights, are actively contributing to shaping the profile of malnutrition. The Right to Food (which should be referred to as Right to Adequate Food in line with the deliberations of the CFS OEWG on Nutrition) appears in a list as a ‘political agenda’; climate change is not even mentioned. As usual, assumed population dynamics and demand/production challenges emerge as primary shapers of the analysis.

In terms of recommendations, the report should formulate the specific priority policy changes that need to be made at the local, national, regional and global level and that would lead to the most sustainable and significant impact in tackling malnutrition in all its forms. It should also stress policy coherence to ensure policies across sectors are harmonized to fulfill the Right to Adequate Food and Nutrition. It is not enough for countries to implement policies in a piecemeal fashion, to ensure



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food system change and nutritional health, there needs to be cross-sector implementation and harmonization of policies.

2. Lack of completeness of Zero Draft

Critical elements in the Zero Draft are missing, rendering the public consultation process ineffective. These omissions make it impossible to get an overall sense of the key messages, recommendations and character of the report as well as the position of the HLPE on specific topics that are of primary concern for the CSM. Omissions include: The Summary and Recommendations (p.8); the sections on food system typologies and their impacts on diets and nutrition (p.21, 66)—which is considered a primary objective of the report; information on SUN in the International Advocacy and Cooperation Section (p.104); Public-Private Partnerships (p.105); Conflicts of Interest section (p.106); “other movements” in the Movements for Nutrition section (p.106), among others. One of the main aims of HLPE reports is to provide guidance on controversial issues to assist the CFS in making decisions that are based on independent evidence, free of conflict of interest, however, most of the controversial issues have been left blank which makes it impossible to predict the types of policy recommendations and final arguments the document will put forward. It is essential to provide further opportunities for public consultation on these missing parts as they will crucially shape the final outcome.

3. Lack of contextualization within CFS Mandate [the progressive realization of RTF]The work of the HLPE (according to the HLPE Key Elements document) is directly linked to that of the CFS with the intention that HLPE studies can be inserted into “a concrete political agenda at the international level”. For this reason, the work of the HLPE must be contextualized within the overall mandate of the CFS, which is to ensure the progressive realization to the right to food. It is essential that the report analyses food systems with an understanding of which food systems (or components thereof) undermine the right to food and related human rights and which systems, in contrast, are compliant with and contribute to the furthering of human rights. Grounding the analysis in human rights, and in particular the right to food, is central for ensuring that the policy recommendations of the report are aligned with the mandate of the CFS.

Given the interrelatedness and indivisibility of human rights as well as the CFS mandate to ensure policy coherence across sectors, it is central that the report’s analysis does not limit itself to identifying which food systems ensure nutritious diets but also takes into account the broader human rights outcomes. This includes the impacts on access and control over natural resources, biodiversity, worker’s rights, women’s rights, children’s rights, indigenous rights and the right to health. A food system that ensures healthy diets but degrades the soil and denies workers a right to a dignified life is not a food system that protects human rights, nor one that should be promoted.

Hence, the analysis (especially conceptual framework, case studies, typologies of food systems and recommendations) must be firmly grounded in the human rights framework present in the CFS mandate and the principle of indivisibility of rights. This will ensure that the food systems that are promoted for health do not have unintended consequences on the environment or people’s livelihoods. Furthermore, it needs to be made clear that human rights violations, including violence against women and ethnic groups, are major causes of malnutrition.



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4. Conceptual framework grossly inadequate to FSN policy makingMany different conceptual frameworks are possible to expose the relations and dynamics that connect food systems with nutrition and diets. The one that has been proposed, while it could be factually correct, is profoundly inadequate to the policy objectives of this process as it does not expose the real tensions that influence dietary choices. These emerge from the tension between the hegemonic global industrial food system, with its homogenising concept of modernity, and the local food systems embedded in their cultural heritage. Diets represent one of the many battlefields between these two alternative approaches to food production, marketing and distribution. While they may at times cohabit, the industrial system tends to squeeze the local food systems through many different points of attrition (from access to resources and inputs to distribution channels). Without excessive generalizations, the two systems have profoundly different health, environmental and livelihoods implications on nutrition and diets. The conceptual framework should expose them and therefore highlight possible hot spots for normative interventions. As it stands, many of the elements of the proposed framework hide these tensions within the various components and do not therefore highlight useful pathways for policy action.

Four immediate consequences become apparent from this critique. Firstly, it is not possible to develop the framework without defining the typology of food systems (see next item 6 below), precisely because the framework is based on the tension between some of these typologies. Secondly, there is an excessive focus on healthy diets rather than on a more holistic understanding of diets (imposed by the FSN focus) that includes the environmental footprint and the livelihoods/economic consequences of dietary choices that provide the feedback loop with production. While this broader understanding of diets is at times mentioned, it is not systematically taken into account. In fact, the report often retrenches on “healthy diets” without examining which diets are sustainable from a Right to Food point of view, or from a sustainable development, climate mitigation, livelihoods support point of view. Furthermore, discussion of healthy diets should mention that freshly prepared meals are healthy and more nutritious than ultra-processed, pre-prepared foods. This distinction is not made.

Thirdly, there is inadequate focus on the nature and characteristics of markets, although they are a key locus where dietary choices are made. Indeed, the increasing acquisition of control over marketing and distribution channels by the industrial system is fundamentally altering the capacity of markets to facilitate direct interaction between producers and consumers. This is not clearly exposed by the proposed framework while having been of the key focus of the most recent set of CFS policy recommendations on connecting smallholders to markets. And lastly, the concept of consumer needs to be problematized and de-linked from monetary purchasing power (as in item 5 below) as consumers include those who consume but do not necessarily purchase their food (for example children who receive free meals in school are consumers but they neither pay nor often choose their food). Furthermore, consumer behaviour is seen as influenced by choice while this is often not the case because consumer choices and behaviours are shaped by structures and environments beyond their control. This should be a re-conceptualized in the report.



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5. Need for stronger focus on groups most affected by malnutrition and food insecurityThe emphasis of the report on consumers is too narrow and does not allow for comprehensive food systems interventions in line with the progressive realization of the right to food. It completely leaves aside the essential role and critical situation of small-scale food producers, especially women producers, which not only produce the majority of the world’s food but are also among the groups most affected by food insecurity and malnutrition. The focus of the report should be on protecting and promoting food systems that are compliant with the right to food, with a particular emphasis on disadvantaged and marginalised groups. In particular, in Chapter 2 (burden), the situation must not just offer regional figures but must show marked differences in indigenous groups, children of peasants and other groups who experience higher stunting and undernutrition prevalence due to political, social and economic marginalization and discrimination. In Chapter 3, the drivers shaping malnutrition of these particular groups must be highlighted and in Chapter 4, solutions must be assessed according to their ability to address the challenges faced by them. Placing those most affected by food insecurity and malnutrition at the centre of the report also implies that their subjective experiences, analysis, and perceptions as to the causes and solutions to their conditions of malnutrition should be equally central to the development of the report’s arguments. This exposes the inadequacy of the almost exclusive reliance on so-called scientific knowledge versus traditional and experiential knowledge on nutrition and diets (as elaborated in item 11 below).

On this issue, there is also a concern with the language used in the report, which is often quite victimizing, rather than portraying those affected by malnutrition as subjects of rights. Rather than referring to “special needs” or “vulnerable groups”, the report should highlight differences in nutritional requirements based on many factors, including age and gender. Similarly, it is not the people that are vulnerable but rather their situation/environment that places them at higher risk/vulnerability to malnutrition. This difference is central as the focus should be on changing the factors that create such environments rather than assuming an ‘assistentialist’ approach of helping the needy. Furthermore, in multiple places and in different contexts (7 times), the Zero Draft refers to “the poor”, which is a depersonalizing pejorative phrasing. What we are really talking about is “those individuals and groups rendered poor by an unfair economic system”. Along the same vein, the report should refer to “disparity reduction” rather than poverty alleviation or reduction.

6. Absence of food system typologies and concern with hinted methodologyAs mentioned in items 2 and 4 above, the lack of food system typologies is one of the major problems of the Zero Draft. However, rather than creating new typologies based on arbitrary indicators (and sources) of food systems, the report should build on existing comparisons between industrial food systems and those based on agroecology and small-scale food producers, recognizing that there exists a global system (singular) and countless regional, national and local systems (plural). Rather than trying to categorize countries’ food systems, the report should concentrate on identifying elements/characteristics in food systems that promote or undermine nutrition, and the policies, which underpin these.

In line with the definition of sustainable food systems in the report, criteria for assessment of these different systems should be the social, economic and environmental sustainability of a food system, its effects on health and nutrition and its alignment with human rights, and particularly its contribution to the progressive realization of the right to adequate food. Table 2 (p. 22) on indicators



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for each food system element should include indicators covering each of these dimensions, e.g. CO² emissions, chemical fertilizer, pesticide and water use, excess of nitrogen from agricultural production, and (agro)biodiversity for the ecological dimension, among others.

Quantitative statistics and indicators are only useful if accompanied by a more comprehensive analysis/explanation of influencing factors (which are often complex), moreover it is essential to look at disaggregated data on how specific population groups are affected by different food systems (see previous item). Furthermore, currently, the food systems typology section at present indicates that the indicators chosen do not include information related to health, diet or nutrition but rather they just identify drivers along the food chain. This begets the question; how will these indicators get us closer to understanding which food systems promote nutritious and sustainable diets?

As included in Table 2, “percent imported foods/total food supply” could be a key variable to characterize the relative mix of food system types from a food security/sovereignty perspective (not just countries and the production element as per Table 2).

7. Over-emphasis on value chains rather than on short circuits and circular economiesThe CSM suggests using the term food or supply chain rather than value chain. Implicit in the term value chain is that value accrues along the chain, which even according to the report is not true. In addition to discussing how value moves along the chain, figures 27, 29 should also indicate for-profit hikes and distortions of food prices that happen along the chain as foods move from producers to consumers. The discussion of value chains assumes linearity and makes no mention of circular value chains and short supply chains (as opposed to retail-driven supply chains) and the benefits of these for nutrition, sustainability and livelihoods. There should be discussion and recommendations relating to the promotion of community supported agriculture, direct consumer-producer relationships, urban agriculture, farmer’s markets and other methods that serve to shorten food chains because these approaches have nutrition, health, economic and sustainability benefits.

Furthermore, the elements of processing that occurs along the food chain are generally viewed positively, despite the recognition even in the report that nutritional qualities are often lost as primary produce moves along the chain. The potential harms of food processing include loss of nutrients such as fibre, phenolics, minerals, healthy fatty acids and vitamins while also leading to the introduction of harmful additions such as sodium, other preservatives, transfats and other compounds (Mozaffarian et al 2016). Despite these nutrition losses, little attention is devoted to avoid/limit processing and reduce distances between consumers and producers.

8. Failure to problematize the industrial food system, incl. Big Food & Beverage Industry The industrial food system should be assessed as a problem rather than a solution to malnutrition . Production processes and agro-ecology based food systems driven by small and medium scale producers must permeate the whole analysis which is currently slanted towards industrial value chains, including and especially Figure 1 and other later figures on food system interventions. The report fails to openly address the profound challenges posed by the industrial, globalized food system. The globalization and increasing concentration of global industrial food system, its lack of sustainability and its impact on the nutritional content of food is superficially mentioned in the



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introduction, but not really developed throughout the report. The dimensions of standardization and growing uniformity of food and diets should be part of the analysis of industrial food systems and value chains to be developed in the report. While pretending to be “neutral” (e.g., p.9 para 2), it is indeed highly political to avoid such discussion. Many sections of the report (pro-liberalization, pro-intensification) are clearly biased towards the continued expansion of the industrial food systems while introducing superficial fixes, avoiding a real debate on the issue. Other parts of the report, while recognizing biodiversity loss, depletion of natural resources, and negative human impact on ecosystems and effects on nutrition, fall short of analysing the underlying causes of these problems, and the role of the agro-industrial food system and the public policies (e.g., subsidies) that support and maintain it. Similarly, climate change is presented as a “given” to which food systems need to be adjusted (“the world is experiencing climate change”), without any discussion on the role of the industrial food system in actually contributing to climate change and environmental destruction. The urgent need to fundamentally transform food systems (rather than adding mere technological fixes) is therefore missed (see UNCTAD review 2013 and IPES report - full references below).

Indeed, there is an emerging consensus on the need for a change of paradigm. Present food systems are dysfunctional because they result in unhealthy diets, unsustainable footprints and impoverishments of small scale producers. They are the outcome of a supply-driven and macroeconomic approach to commodified food, which itself has shaped to a large extent research to date. The research principles agreed upon by IPES-food should lead the way for joint learning to guide food systems transition in the coming years. Despite this, the report is biased towards industrial-scale food production to the detriment of farming families. While increased dietary diversity is certainly needed, priority should be given to making the best of local biodiversity and ecosystems, which should of course be complemented through fair trade of quality products. This contributes to resilience of local food systems: areas most affected by the 2008 food crisis were those most dependent on international trade.

This is one of the central controversies that the report does not adequately confront, but rather falls on one side in its selection of sources. There should be more substance on the food sovereignty debate as well as on systems that are based on small-scale producers. This is a core weakness of the report; small farm-based food systems provide 80% of food in Asia and Sub-Saharan Africa (as referenced) are reduced to allusions to “vulnerable groups” (4.2.2).

In addition to the role played by industrial agriculture in shaping the food system, the Big Food and Beverage Industry and transnational food companies play a pernicious role in shaping consumption practices, the food environment and also shaping food perceptions, preferences, by flooding the market with ultra-processed foods, through their unsustainable production practices and through marketing. The global industrial food system of transnational food manufacturing, distribution, catering and retailing corporations have had a central impact on food systems and supplies throughout the world but its role in changing food practices is barely mentioned in Chapter 3, when drivers shaping diets are discussed. Furthermore, these companies launch campaigns and fund science to frame debates about malnutrition, especially obesity to take the blame for these health problems away from their products. They also lobby governments and actors in the international nutrition space to influence policy-making processes. The power of transnational food corporations is hardly mentioned but it plays a key role in driving and impacting diets and nutrition and must be



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discussed in section 3.2 (food system drivers) and 4.2.2 (food system changes). It also should be referred to in the section on Conflicts of Interest and PPPs.

Lastly, the report needs to give greater attention to the role of ultra-processed foods in the food system. Clear links between the consumption of ultra-processed foods and sugary drinks and overweight and obesity have been established (PAHO, 2015, Montiero 2013). It is important for this relationship to be drawn out to ensure that policies work to curb the availability and consumption of these foods and to ensure front of labelling and marketing restrictions for these foods as well as restrictions on health claims. There needs to be a clear mention in section 1.1.2 (the elements of food systems) of 'ultra-processed' foods and the link to obesity should be more clearly articulated. Currently, the term ‘ultra-processed foods’ is not defined and it is mentioned as if it were a synonym for highly processed foods.

9. Under-emphasis (if at all) on markets and distribution systemsThere should be more critical analysis and of the distribution system (in particular critique of the role of hypermarkets and supermarkets) since they are playing the lead role in shaping both consumption and production. As mentioned in the item #7, it is essential that local markets and short food chains (e.g. farmers’ markets) be protected and supported, especially because they are central in promoting food sovereignty. The shift to supermarkets (including in nutrition CCT interventions) has in many cases resulted in degradation of diets and destruction of local food systems. And importing superhighways have often resulted in depleting communities of the food they produced, thus decreasing home consumption, or isolating them from the national commercial system. There is a need to recognize the vital importance of territorial markets (local, regional, transnational, more or less formal) in food production, in supplying nutrition to vulnerable groups, and in being key in the livelihoods of those most affected by malnutrition and food insecurity. These markets have been recognized in the recommendations of the CFS in October 2016 (Recommendations on Connecting smallholders to markets). They should be given much more attention as key elements of food systems in the report, counter to the focus on value chains that more often than not refer to global value chains based on industrial agricultural models that risk promoting the standardization of agricultural inputs and production, and to the standardization of diets. There is a need to look at territorial and local food systems and how much nutrition they bring to how many people in the world. Territorial markets strengthen women's jobs, prevent rural-urban migration, reduce carbon footprints and can control food losses through community composting.

10. Limited analysis on marketing of ultra-processed foods/beverages and labellingThere needs to be greater emphasis placed on the marketing of foods, in particular, it should be clearly stated that the overwhelming majority of foods and beverages that are marketed to children are ultra-processed foods and beverages which are detrimental to nutritional health and which are produced by transnational corporations not those that are produced locally or sustainably. The document should be aligned with recent documents published by WHO and PAHO (see references at end of document), which discuss the need to regulate marketing to children and adolescents. Furthermore, that all media channels should be regulated (TV, internet, packages, mobile phones, video games, packages, point of sale, billboards and areas where children and adolescents



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congregate). Furthermore, the use of marketing tools that are used to attract children such as the characters, animals, celebrities, freebies, promotions or contests should be banned. Furthermore, the nutritional criteria utilized to regulate what should be permitted to be marketed should be developed free of conflict of interest and follow the WHO-Europe or the PAHO nutrient profiling model. The example of Chile provides an ideal case study for a marketing to children regulation (see specific comments below). Furthermore, the mention of public service advertising to encourage healthy practices should ensure that such advertising is not funded by the food industry or PPPs, which often leads to messages being skewed towards those that promote ‘better-for-you” processed foods rather than natural, fresh foods.

Furthermore, the opportunity of Front-of-Pack Labelling interventions are unduly addressed. The section on labelling (p. 100) discusses many types of labels but not specifically the front-of-pack label which informs/warns the consumer of the quantity of macronutrients in their foods (i.e. saturated fats, added sugars, sodium and calories). It is important to promote policies for mandatory front-of-pack labelling. The case of the Chilean label would make for the most appropriate case study because it offers an easy-to-understand and simple warning label. The front of pack label must be based on nutritional values developed by experts free of conflict of interest, it should follow international standards such as the WHO Guideline for Sugar and the WHO-Europe and/or the PAHO Nutrient Profile Model (see references at end). It is key that front-of-pack labelling regulations are harmonized with marketing regulations to ensure that the same product, for example, that has a warning label on its package for being high in sugar, does not also have images or messages on the box to attract children to these products. In the case of both of these regulations, statutory not self-regulatory agreements should be promoted, as the latter have been shown to be compromised by conflicts of interest.

11. Outdated and simplistic assessment of sociocultural drivers This section needs a total rewrite (also in view of the following comment n. 12). The section compartmentalizes cultural practices as if they were independent from their historical, political and economic contexts. Such an approach to understanding culture has been discarded as early as the 1960s in the social sciences because it tends to blame “culture” for nutritional and health problems rather than seeing these cultural practices as consequences of political-economic circumstances, governmental regimes, power inequalities, marginalization and history. A description of sociocultural practices should be embedded in this understanding, otherwise the section simply serves to “other-ize” and essentialize cultural differences and leads to the assumption that the way to change cultural practices is through educational efforts rather than by addressing the underlying root (political, economic) causes shaping these practices (See Mintz, Scheper-Hughes). Instead of focusing on religion and taboo, this section should discuss how consumer cultures, marketing as well as globalization and narratives of modernity shape consumption preferences and practices.

12. Poor gender analysis & lack of recognition of the centrality of women’s rightsFollowing on the previous comment, the section on gender should address both the issue of women’s rights as well as provide an adequate gender analysis to support the analysis of the report.



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It unfortunately falls short of either of these. The fact that these key issues are addressed within a subset of the socio-cultural drivers does provide a very limiting context for really exploring the centrality of the issue. It would deserve a much more prominent role both within its own merit as well as a transversal issue rather than being locked within a small subset of the flow of the discourse.

Violations to women’s rights are important factors shaping malnutrition. These violations must be mentioned in the report and policies to guarantee women’s rights must be recommended, especially considering that the indivisibility principle of human rights requires that women’s rights be guaranteed to ensure the Right to Adequate Food. A clear recognition of women’s rights is explicitly mentioned in the most recent set of CFS policy recommendations that followed the HLPE SADL Report and the Nutrition and Food Systems report should follow this critical precedent. The realization of women’s rights in the workplace, women’s right to land and natural resources, women’s sexual and reproductive rights, the right to breastfeed, to education and to be free from violence must be discussed in this report to adequately address malnutrition.

Beyond the centrality of women’s rights, it is important to challenge the gendered analysis present in the gender section (pg. 57-58). Explicit in this section is the notion that the work of feeding and caring is “women’s work” and therefore they must be educated and empowered so that they can care better. However, this analysis fails to acknowledge the importance of sharing the burden of care and feeding work across genders and creating the structural conditions necessary for this to happen so that feeding no long becomes the exclusive domain of women. Furthermore, in this section, women’s cultural beliefs are implicitly conceived as the problem causing poor nutrition and thus the solution is conceptualized as education to change these beliefs, however, the structural conditions shaping women’s feeding and caring practices are not exposed. Throughout the Gender section links between women’s educational attainment and reduced hunger are mentioned but the reasons for this link need to be unpacked: why does women’s education lead to reduced hunger? What structural conditions change with educational attainment that could lead to this reduction?

13. Diverse local/indigenous knowledge systems should be featured as key part of the solution rather than the Zero Draft’s strong bias towards technological fixes

The report fails to acknowledge that innovation, technology and knowledge are not just created through traditional academic and/or laboratory research but rather in real life situations. There is a diversity of indigenous knowledge of land, seeds, agroecological methods, and culinary techniques that are constantly evolving in relation to new experiences. Thus, in Chapter 4, the solution to achieving nutritious and sustainable diets should not be framed solely by the need to develop new technologies but also the need to protect, promote, respect and disseminate existing indigenous knowledge systems. Similarly, these knowledge systems which develop and evolve outside of academia must be mentioned in Chapter 2, as drivers of food systems because they inform the production work of many small-scale food producers. A deeper understanding of the traditional/indigenous practices, which contribute to sustainable and healthy diets should be identified as a key area for future research and knowledge building within the report. Apart from technology-driven approaches, holistic approaches to sustainable and healthy diets, based on traditional knowledge and indigenous food systems should be included, such as integrated farming systems, (Klizing et al. 2014) and the contribution of indigenous trees to nutritional health (Kehlenbeck et al. 2013).



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In complete tension with the previous point, the Zero Draft features a strong bias towards science and technology as solutions to healthier diets, thereby failing to recognize and provide options for addressing the root causes of the problem – which do not lie in lack of nutritious varieties or knowledge on how to produce these. (p. 15). There is a move towards innovative ‘nutrition-smart’ 'quick fix' solutions (P 96), bio-fortification (Page 75 Box 8), micronutrient fortification, GM and other technologies (Page 92, 93), however, technologies that rely on and are favored by transnational corporations that are likely to fundamentally change consumption patterns towards processed foods and snacks and not to generate nutritious and sustainable food systems. The report’s emphasis on possible technological solutions, including fortification and food processing, reflects the significant funding bias of recent research. These can certainly play a supporting role but have not proven to contribute to sustainability. While we recognize the valuable contribution that technology and innovation can make to nutritional outcomes, there is a need to redress the balance, so that traditional practices and knowledge systems which have evolved over millennia and contribute greatly to food security and nutrition are given much greater attention and afforded the recognition and protection they deserve. Moreover, it is central that the report includes a comprehensive analysis of the risks associated with the different technical approaches outlined (see also specific comment). Approaches to address malnutrition should be assessed in terms of the risks and benefits associated with them, within the broader human rights perspective outlined above.

14. Failure to juxtapose the paradigms of agro-biodiversity and food fortificationThe Zero Draft fails to articulate a proper discourse that juxtaposes and analyzes the two critical and opposing paradigms: diversified diets based on agro-biodiversity and increasingly homogenous diets largely composed of industrial products based on large scale agriculture of very few crops. Once again, this is easily conducible to the proposed food system typologies that have been earlier proposed. It is the reduction of biodiversity and nutritional content that is inherently consequent to the industrial system that generate the nutritional deficiencies that are claimed to require food fortification. The industrial system claims to offer food fortification as the solution to a problem it has itself generated and, by doing so, it continues to phagocytize local food systems that rather offer deeply rooted solutions based on agro-biodiversity.

With respect to biodiversity, the importance of intraspecific diversity is mentioned on p.15 but then never returned to. In chapter 3 (p. 44), there is a mention of humans working with 7000 plant species. That is exactly what the formal industrial agriculture/plant breeding system has produced. But, it has been widely documented that farmers, through peasant agriculture and through developing and keeping their own varieties (which are often outside the 'formal' breeding system, and therefore referred to as 'informal or farmers' varieties'), have bred about a million varieties of crops. This has huge implications for dietary diversity and the potential for human nutrition (not to mention identities and cultures). This is a critical argument for supporting the peasant, biodiverse, agro-ecological approaches to nutrition and should be clearly exposed by the report, particularly though not exclusively when discussing agroecology. This is also directly related to climate change: there is utmost need for all the diversity and nutritional variety of farmer bred crops, and their wild relatives, in order to find the varieties that are not only nutritious, but are able to cope with drastically changed growing conditions.



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Within this same discourse, the Zero Draft fails to produce an in-depth analysis of the real determinants of micronutrient malnutrition (Chapter 2.3, p. 35-38) and does not clarify that nutritional deficiencies are rarely focused on single nutrients. Generally, nutrition insecure groups lack far more than Vitamin A and other prominent Micronutrients (iron, iodine, zinc). There have been identified at least 19 micronutrients with direct influence on physical and mental development and the immune system and often operate in association with each other. So far, we just know the clinical symptoms of a few of them, but other micronutrients could have considerable influence on our nutrition well-being. The fact that hidden hunger is most frequently described by Vitamin A, iron, zinc and iodine deficiencies is due to the fact that they produce a typical clinical picture. However, these prominent micronutrients are to be understood as lead substances for the lack of foods from certain food group (see e.g. Biesalski, Hans Konrad. 2013. Hidden Hunger). The real challenge is to address these complex problems not by reducing them to single nutrients but by a variety of approaches which should be reflected in chapter 4.Regarding fortification and bio biofortification, not only the Zero Draft fails to properly contextualize these methods within the tension between different food systems, as earlier explained. It basically gives them for granted with limited problematization and in-depth analysis. In this respect, the report should unambiguously clarify that balanced and diversified diets supplying adequate nutrients are generally not only the preferred, but also the most effective and efficient long-term way to prevent micronutrient deficiencies for most groups, with few exceptions made such as for pregnant and lactating women, populations with specific needs (e.g. people living with HIV/AIDS or other chronic diseases), and countries where the soil does not contain iodine (e.g. remote countries, far away from the oceans). Furthermore, the report needs to clearly distinguish between food fortification (flour, iodized salt, etc.) and approaches to conduct biofortification (conventional breeding, GMOs, boosting the soil nutrients through fertilization, natural or synthetic), given the difference between the content, process and issues related to these two fields. The report then needs to clarify the differences between crop fortification, agronomic fortification and biofortification, and mention all the concerns and issues related to each of these methods. More specific comments are included in the following section.

15. Case Studies: Issues of inclusion and depth of analysisFirst of all, there is an issue of inclusion. There should be a better balance of case studies from civil society, including research and experiential knowledge of communities themselves, as explicitly recognized by the CFS Nutrition document.76 The case studies should include examples of food systems that provide good nutrition, among other positive social outcomes, and need to be protected/supported by governments, such as indigenous food systems, community-supported

76 Para 12: HLPE reports, including the forthcoming report on Nutrition and Food Systems, will play a key role by providing independent evidence-based information based on existing high quality research, data, technical studies and experiential knowledge.



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agriculture, and food systems based on agro-ecology and small-scale food producers. The section notes that consultations with experts in the field have taken place to collect the case studies. It would be good to clarify with whom, and in particular how far social movements and groups most affected by malnutrition have been consulted. The focus on innovation and technology in this section (and throughout the document) must be challenged. Promoting good nutrition does not necessarily require “innovation” but can be very simple measures, such as the regulation of marketing or support for territorial markets and local small-scale food producers. The case studies should moreover include initiatives by small-scale food producers, consumers, etc. themselves, indicating measures that States could take to support these. While there are several case studies on fortification and bio-fortification, there is no single case-study on promoting agroecology, community supported agriculture, access to land (e.g., via agrarian reform), or territorial markets (aside from examples regarding public procurement from local farmers). Public procurement - and in particular school canteens – are indeed key entry points for promoting more healthy and sustainable diets. This is increasingly being done all over the world: Brazil’s home-grown school feeding programmes, school canteens in Copenhagen, etc. The role of HORECA (https://en.wikipedia.org/wiki/Horeca) is also essential and should be mentioned. The lack of case studies on more holistic policies that address structural causes of malnutrition therefore needs to be addressed.

Furthermore, the case of Chile combining marketing regulation, labelling and taxation should be included as a very comprehensive example for demand side policies for healthy diets, (presented by G. Girardi at the International Symposium on Sustainable Food Systems for Healthy Diets and Improved Nutrition, 1-2 Dec 2016). This is a preferable case study to that of the Australia labelling system and the Quebec marketing regulation that are now described in the case study section of the text. On page 73, the National Food Security Act of India should be included as a box since as it is an attempt at better food provisioning and provides a justiciability framework for grievance redressal in case of the denial of entitlements.

Secondly, there is lack of in-depth analysis of the case studies. Purpose of the case studies should be to provide policy guidance to States based on concrete examples. Instead of having 40 case studies there should be a selection of fewer case studies that provide more in-depth analysis of the factors that contributed to outcomes and limitations of the study. Currently the case studies are very superficial and do not provide sufficient details to inform policy choices. The case studies should not stand on their own but rather provide illustrative examples to policy options discussed in the report. Hence, the section should provide more detailed analysis of possible policy options to improve nutrition through food systems interventions bringing in some case studies to illustrate these.

16. Governance, including Conflicts of Interest & Public-Private PartnershipsThe issue of governance is central to the topic of food systems and nutrition. Governance is mentioned in 4.2.3 but the CSM suggests that governance be discussed much earlier in the document, in the food systems drivers’ section (3.2), perhaps under the section “political and economic drivers”. The topic of governance, and the related topics of i) conflicts of interest, which



https://en.wikipedia.org/wiki/Horeca

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challenge democratic governance in the public interest, and ii) the failure to protect human rights, and iii) the need for social participation to have effective, participatory and democratic governance should be discussed in section 3.2. These elements of governance are crucial to ensure nutrition.

Within the discussion on governance and public policies, the topic of conflicts of interest is of central concern to this report and to the CSM because conflicts of interest jeopardize the food system and shape its impacts on nutrition in a variety of ways. It is essential that the governance of food systems always ensures that food security, food sovereignty and the right to food are primary objectives of the food system not corporate profits. Governance and regulatory measures must ensure that this mandate of ensuring the public’s right to food and nutrition is considered above any other economic or commercial interest. Conflicts of interest arise when public interactions with the private sector undermine the primary interest in ensuring nutrition for the population. Conflicts of interest serve to deteriorate the effectiveness, integrity, independence and trustworthiness of public institutions and challenge democratic, evidence-based governance processes. It is essential that conflicts of interest be ensured against through safeguards and policies such that corporations do not have undue influence on food and nutrition policy.

One way in which conflicts of interest manifest themselves are through public-private interactions. Such interactions take many forms, for example government lobbying by corporate groups/associations; corporate funding of government officials/campaigns/programs; private funding of nutrition or agricultural/food systems research, the involvement of corporations or privately funded organizations and philanthropies in policy-making processes (design, implementation and evaluation); and corporate funding of programs, interventions and educational campaigns to address malnutrition or impact the food system. Voluntary self-regulation is another form of PPP in which the industry enters into agreement with the government to regulate, evaluate and monitor its own practices, these efforts have proven ineffective and serve to delay and inadequately replace statutory regulation. These concerns must be described in this section and recommendations put forth to avoid CoI.

PPPs per definition create financial and/or other economic dependencies of public institutions on private sector actors and will thus by definition create an economic, and a social and institutional, incentive for public institutions to align their policies with the commercial interests of private sector actors. Such an alignment will always compromise the objectivity and independence of public institutions. This must be highlighted in the section. Furthermore, this section should identify the roles of the public and the private partner(s) and address the challenge of conflict of interest (see Jonathan H. Marks. 2014, full reference below).

The PPP section also does not mention human rights risks associated with these partnerships, nor the need for HR impact assessments/ monitoring/ accountability mechanisms, conflict of interest policies and criteria for partnerships (with whom, in what role can participation take place). These issues need to be firmly described in the PPP and conflicts of interest sections.

II. SPECIFIC COMMENTS ON SECTIONS AND/OR ISSUES



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- Terminology and Definitions:

o A definition is necessary for “nutrition sensitive” as this approach is mentioned in the draft many times;

o There are very serious issues with the definitions of malnutrition and acute malnutrition, and acute malnutrition and wasting are often confused. In addition, the situation of undernutrition is sometimes viewed too positively because of an overall focus on stunting in the report, without taking into account wasting. The description of obesity and overweight must also be more rigorous in terms of indicators used and populations described;

o Most of the research reviewed mentions country data. There are several references to low and middle-income countries. The SDGs and Agenda 2030 have recognized the need to move beyond this simplistic classification;

o The CSM suggests using the term “sugary beverages” rather than sugar-sweetened beverages to align with the new WHO report (2016) “Fiscal policies for Diet and Prevention of Noncommunicable Diseases (NCDs)”;

- Policies to promote breastfeeding: Breastfeeding and appropriate complementary feeding are mentioned but not acknowledged as an important element of the food system nor is breastfeeding considered in the frame of human rights (UN, 2016). Breastfeeding is an extremely important element in reducing obesity as well as undernutrition. The role of exclusive breastfeeding in improving nutrition and the impact of the availability and marketing of breastmilk substitutes on dietary changes need to be acknowledged in Chapter 3. Food system typology indicators should include breastfeeding indicators. There is little or no emphasis on the importance of translating the International Code of Marketing of Breast-milk Substitutes and Resolutions into statutory legislation, the need to stop harmful marketing and for WHO’s clear call to stop corporate sponsorship of health workers. These should be mentioned as key measures to promote to improve food systems. Furthermore, the report should explicitly warn against agreements between the government and industry, which would enable the industry to self-regulate aspects of the Code, as these have been proven ineffective;

- Processing and food loss: The statement “Processing and packaging are associated with reduced food loss” (p. 17, line 25/26) should be qualified. Quality standards for processing and packaging which refer to aesthetic criteria may even increase food loss. See the example of how appearance quality standards in supermarkets for fresh products lead to food waste (FAO 2011);

- Innovation and research drivers (p.74): To assess who is driving the R&D agenda it is important to present data and trends on public and private sources of investment in R&D. Also, data and trends should be presented for investment in R&D focused on staple crops vs. other crops;

- FDI and Trade: Foreign direct investment and its impacts on nutrition and food systems more broadly (e.g., by destroying local markets/ small producers + venders) is not dealt with at all and an overly positive picture of trade presented (“Trade policies that enhance liberalization and globalization should be promoted while the counter-cyclical trade policies and the banning of food exports should be eliminated” p.100). Highly specialised industrial agriculture and export-



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oriented farming is brought up without any assessment of what this means for FSN. Also in Chapter 3, the impacts of trade on biodiversity are mentioned as being both negative or positive, but evidence shows that international trade is favouring a few agricultural/plant varieties, creating uniformity and therefore adversely affecting biodiversity. The IPES-Food panel demonstrates this in their report 'Uniformity to Diversity’ and this logic should be followed (iPES 2016);

- Power relations in food system: Power relations within the food system and who controls the food and access thereto are completely left out of the picture. Small-scale farmers and agroindustry are all reduced to “value chain actors” with no consideration to the power relations between them and the impact these have on food security and nutrition. These relationships and power differentials need to be flagged;

- Independent Evaluation and government-led initiatives: If this report is to have value it must address the need for truly independent monitoring/research, regular oversight by national authorities - especially of the new technologies. Furthermore, it must warn against voluntary agreements and privately funded initiatives and programs which can be ‘here today’ gone tomorrow. Governments should be encouraged to establish policies that incorporate good (independently) proven interventions that may not show a return immediately;

- Social Networks and Movements beyond UN and development cooperation: In the Social Networks and Movements section (p.50) and the Movements for Nutrition section (p.106) there should be additional mentions of the multiple movements that work to promote health, sustainability and livelihoods across the full spectrum of spaces – from agriculture to sustainable and healthy diets. While the extensive space provided to the CSM and the ICN2/Nutrition CS Group might be appreciated, these often only represent to tip of iceberg when it comes to the variety of forms of producers and citizen’s mobilization. Furthermore, critiques of the SUN movement, in particular due to the influence of the industry in shaping its agenda, should be properly acknowledged (Schuftan 2013);

- Fiscal Measures: The term “fax tax” should be avoided, the term fiscal measures or tax on unhealthy foods/beverages could be used instead. In line with the recent publication by WHO (2016) a 20% tax on sugary drinks should be recommended, to ensure that proposed taxes are high enough to be effective in reducing obesity and diabetes cases. The example of Mexico might be more well/suited as an example (p. 101) than Australia since it is already in effect. The suggestion that poorer people’s pockets are hit the most needs to be qualified, these groups are also more likely to suffer from obesity and diabetes (in essence the burden of obesity and NCDs is regressive), and more likely to experience financial turmoil as a result of diabetes treatment costs, thus they have the most to gain from a tax;

- Link between income and diets requires analysis: The link between income level, diets and nutrition must be further explored, including in terms of forward-thinking: If changes in economic status lead to both an increase of consumption of healthy food (fruit, seafood, milk) and unhealthy foods (processed meat, sugar-sweetened beverages, red meat, sodium), and to an overall increase of food intake, what does that mean both in terms of nutrition, and in terms of sustainability in a world expected to reach 9 billion inhabitants in 2050? Analysis and policy recommendations must be made to address this;



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- Costs of healthy diets: The assumption that healthy diets are more expensive (p. 51) needs to be substantiated: the issue is not to compare a mass-produced commodity with the biologically produced equivalent, but to look at the food budget as a whole: cutting down on meat, dairy products, processed foods and soft drinks helps to reallocate household resources to better quality pulses and vegetables. In general, households have never spent such a small portion of their budget on food anyway and this cannot be sustainable;

- Drivers of food price volatility: Some of its drivers (biofuels production, financial speculation on agricultural commodity futures) of price volatility are mentioned, but others are not (i.e. link between unrelated physical markets such as oil and corn through biofuels production and financial speculation, lack of global governance of food markets, trade liberalization, low level or absence of food stocks and food reserves);

- “Input supply” Value Chain: In figure 27 (Chapter 4.1.2) on the “maximize nutrition exiting the value chain”-side another factor should be added to the “input supply” link in the value chain which is the reduction of diversity of seeds (and animal breeds) due to concentration processes in the agricultural input industry (Wesseler et al. 2015, see full reference below);

- Chemical Inputs & GHGs: In the natural resource section the treatment of chemical inputs is weak; the paper suggests that the problem with synthetic inputs is pollution only and, though the contribution of agriculture to global emissions is addressed later, the energy-intensity factor and its contribution to GHGs is avoided in the fertilizer point. Here, a point should be made on the need for adherence to and coherence with the “Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security”;

- Diets, health and climate change: With regard to impacts of diets on health and climate change (p. 48), we recommend to take into account the study Springmann et al. 2016, see full reference below;

- Urbanization is mentioned as an important driver of food systems and diet changes, yet there is no mention of how urban and peri-urban agriculture could be part of the solution, nor recommendations for public policies on this topic;

- Food acceptability and marketing (p.88): The implementation of marketing regulations to prohibit marketing to children is crucial. In addition, adults in all countries are confronted with contradicting and confusing messages on what a healthy diet is. Country-specific evidence-based dietary guidelines, the promotion of consumers’ right to information as well as policies regulating nutrition declarations/disclaimers and the marketing of ultra-processed food (to all age groups) need to be promoted;

- Reducing over-consumption of ASF is a win-win-win: The report should address over-consumption of ASF (animal sourced foods), especially processed ASF, as part of the response to malnutrition from obesity in the HLPE report 12, with ways to address the marketing; subsidies, production; processing; retailing and psychology of over-consuming ASF, particularly processed ASF. A greater focus is deserved on ways to reduce over-consumption in high-consuming populations, and avoid the uptake of high consumption in growth areas. Reducing obesity through reducing the



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consumption of ASF (processed and non-processed) will bring many benefitsK;

- Higher welfare farming produces food of higher nutritional value: Research shows that animal sourced foods (ASF) from higher welfare farms (e.g. free-range/organic with slower growing breeds, space to roam and access to forage) tend to be of higher nutritional value than intensively farmed ASF (Pickett 2012). Data show that the iron content was higher in free-range/organic pig-meat, chicken and trout than intensively farmed counter-parts. Similar results were found for levels of carotenoids and vitamin E, in beef, pig-meat, chicken, milk and eggs. Also, the proportion of Omega-3 to Omega-6 was consistently better in free-range/organic/slower-growing lamb, beef, pigs, chickens, trout, milk and eggs from higher welfare farm systems than industrial farm systems. Other nutrients have not been examined yet;

- Nutrition-smart accessibility: The section on Nutrition-smart accessibility through technology (p. 96) should also address the risks, e.g. in terms of privacy loss, with which it is associated;

- Food fortification: In addition to the profound critique exposed within the overarching comments, there is a need to detail the issues and concerns that still exist around fortification (once clearly politically located with the discourse of the report), and clarify the context of its use:

o Does the report consider fortification as a temporary solution, in this case appropriate for what situations? Fortification and supplementation do not address the root causes of malnutrition. Therefore, the need to invest in healthy and sustainable food systems based on human rights should be stressed within this report;

o The report should fully expose the challenges related to technological issues, such as appropriate levels of nutrients, stability, bioavailability, nutrient interactions, physical properties, and describe and analyze the risk that foods fortified with micronutrients may not fully meet the needs of certain nutritionally vulnerable subgroups such as pregnant and lactating women, or young children. For example, infants and young children, who consume relatively small amounts of staple foods are less likely to be able to obtain the recommended intakes of all micronutrients from universally fortified staples or condiments alone;

o The report, rather than simply addressing the claimed benefits as in the current section, should address the risks of fortification, e.g. with regard to overweight and obesity. Fortified cookies, for example, can even contribute to worsen diets as these cookies might be promoted and considered as healthy while containing high amounts of fat and sugar. The US example on fortification of foods with folic acid might help preventing sever problems for unborn babies, but it might also cause problems for other people within the population as it might mask a deficit of vitamin B12. The unspecified fortification of foods does pose risks, while a target group oriented supplementation of certain minerals and vitamins is often possible. These aspects need to be discussed in the report;

- Crop fortification/biofortification: The section should explicitly address the risks related to biofortification, among them the reduction of agrobiodiversity and, as a consequence, dietary diversity due to the promotion of biofortified staple crops replacing other micronutrient-dense



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crops such as pulses, vegetables and fruits. The additional risks and trends associated with genetic modification need to be addressed, among them ecological effects due to pesticide and herbicide resistances; corporate control of agricultural inputs and unpredictable health risks. The report’s recommendation to put more attention on food-based solutions could include the promotion of biofortification based on traditional breeding practices, at the exclusion of GMOs and soil fertilizations with large quantities of synthetic fertilizers, and with a particular emphasis on the analysis and promotion of existing vitamin A-rich traditional crops and varieties. Furthermore:

o Box 8 and 9 (including Africa orphan-corps) are very much in favour of biofortification and need to be counterbalanced with examples explaining the risks and doubts related to biofortification, including the issue of quality and safety of biofortified food;

o Risks and concerns linked with biofortification must be more detailed: “However, promising as it is, biofortification presents some limitations (Bouis and Yassir, 2011). Much more evidence still needs to be provided before the efficiency and effectiveness of biofortified crops in reducing micronutrient deficiency are proven (Allen et al., 2011; Ceccarelli, 2014). Biofortified crops must be acceptable by consumers in target regions where people are afflicted with micronutrient deficiencies (Bouis and Ross, 2010). It is important to ascertain to what extent the modified nutrient is bioavailable and remains stable with time, processing, and storage (FAO/WHO, 2010). Moreover, not all of the micronutrients in plant are bioavailable to humans who eat these foods (Bouis and Ross, 2010)”;

o The report should analyze the concern that biofortification is usually developed with international laboratories, with poor involvement of national research centres, and its role in fostering further economic concentration of the productive systems.

III. SUGGESTED READINGS

Food Systems & Agroecology

Foresight, Food systems and diets: facing the challenges of the 21st Century, http://www.glopan.org/foresight-project.

iPES. From Uniformity to Diversity: A paradigm shift from industrial agriculture to diversified agroecological systems, http://www.ipes-food.org/images/Reports/UniformityToDiversity_FullReport.pdf.

iPES. Food and the new science of sustainable food systems: Who shapes food systems, and who has a say in how they are reformed?, http://www.ipes-food.org/images/Reports/IPES_report01_1505_web_br_pages.pdf.

De Schutter, Agroecology and the Right to Food, UNHRC. http://www.srfood.org/images/stories/pdf/officialreports/20110308_a-hrc-16-49_agroecology_en.pdf.

De Schutter. Fisheries and the right to food, UNHRC. http://www.srfood.org/images/stories/pdf/officialreports/20121030_fish_en.pdf.

De Schutter. Guiding Principles on Human Rights Impact Assessments of Trade and Investment Agreements, UNHRC. http://www.srfood.org/images/stories/pdf/officialreports/20120306_hria_en.pdf.



http://www.srfood.org/images/stories/pdf/officialreports/20121030_fish_en.pdf

http://www.srfood.org/images/stories/pdf/officialreports/20110308_a-hrc-16-49_agroecology_en.pdf

http://www.srfood.org/images/stories/pdf/officialreports/20110308_a-hrc-16-49_agroecology_en.pdf

http://www.ipes-food.org/images/Reports/IPES_report01_1505_web_br_pages.pdf

http://www.ipes-food.org/images/Reports/UniformityToDiversity_FullReport.pdf

http://www.glopan.org/foresight-project

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De Schutter. The Right to an adequate diet: the agriculture-food-health nexus, UNHRC. http://www.srfood.org/images/stories/pdf/officialreports/20120306_nutrition_en.pdf.

De Schutter, Seed policies and the right to food: enhancing agrobiodiversity and encouraging innovation, UNHRC. http://www.srfood.org/images/stories/pdf/officialreports/20091021_report-ga64_seed-policies-and-the-right-to-food_en.pdf.

Pat Mooney and ETC Group. 2015: The changing agribusiness climate: Corporate concentration, agricultural inputs, innovation and climate change, in: Canadian Food Studies/RCÉA – Special Issue Vol. 2, No. 2, pp. 117–125.

UNCTAD. Wake up before it is too late: Make agriculture truly sustainable now for food security in a changing climate, http://unctad.org/en/PublicationsLibrary/ditcted2012d3_en.pdf.

Justus Wesseler, Alessandro Bonanno, Dušan Drabik, Valentina C. Materia, Luca Malaguti, Marcel Meyer, and Thomas J. Venus. 2015: Overview of the agricultural input sector in the EU. http://www.europarl.europa.eu/RegData/etudes/STUD/2015/563385/IPOL_STU%282015%29563385_EN.pdf; Pat Mooney and ETC Group. 2015: The changing agribusiness climate: Corporate concentration, agricultural inputs, innovation and climate change, in: Canadian Food Studies/RCÉA – Special Issue Vol. 2, No. 2, pp. 117–125.

13.

Global Industrial Food System

KD Brownell & KE Warner. The Perils of Ignoring History: Big Tobacco Played Dirty and Millions Died. How Similar is Big Food?, The Milbank Quarterly, 2009, 87(1): 259-294.

Center for Science in the Public Interest. Carbonating the World: The Marketing and Health Impact on Sugar Drinks in Low- and middle/income countries, 2016.

N Freudenberg. Legal but Lethal: Corporations, Consumption, and Protecting Public Health, U Oxford, 2014.

M. Nestle. Food Politics: How the Food Industry Influences Nutrition and Health, U. California, 2002.

M. Nestle. Soda Politics: Taking on Big Soda (and Winning). U. Oxford, 2015.

Food fortification

Allen, L., de Benoist, Dary, B.O., Hurrell, R., 2011. Guidelines on food fortification with micronutrients

Burchi, F., Fanzo J, Frison E, 2011. The role of food and nutrition system approaches in tackling hidden hunger.

Villar J L, Tackling Hidden Hunger, Putting diet diversification at the centre, Third World Network, 2015

Biofortification



http://unctad.org/en/PublicationsLibrary/ditcted2012d3_en.pdf

http://www.srfood.org/images/stories/pdf/officialreports/20091021_report-ga64_seed-policies-and-the-right-to-food_en.pdf

http://www.srfood.org/images/stories/pdf/officialreports/20091021_report-ga64_seed-policies-and-the-right-to-food_en.pdf

http://www.srfood.org/images/stories/pdf/officialreports/20120306_nutrition_en.pdf

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Bouis, H.E., Welch, R. M., 2010. Biofortification—A Sustainable Agricultural Strategy for Reducing Micronutrient Malnutrition in the Global South

Bouis, H.E., Islam, Y., 2011. Biofortification: Leveraging Agriculture to Reduce Hidden Hunger Allen, L., de Benoist, Dary, B.O., Hurrell, R., 2011. Guidelines on food fortification with

micronutrients Bouis, H.E., 2015. Improving Nutrition through Agriculture: Cost-Effectiveness of

Biofortification FAO/WHO, 2000. Safety aspects of genetically modified foods of plant origin. Report of a

Joint FAO/WHO Expert Consultation on Foods Derived from Biotechnology,WHO Headquaters, Geneva, Switzerland, 29 May to 2 June 2000. Geneva, World Health Organization, 2000

Ceccarelli, S., 2014; GM Crops, Organic Agriculture and Breeding for Sustainability

Breastfeeding & Complementary Feeding

OHCHR. Joint statement by the UN Special Rapporteurs on the Right to Food, Right to Health, the Working Group on Discrimination against Women in law and in practice, and the Committee on the Rights of the Child in support of increased efforts to promote, support and protect breast-feeding, 2016. http://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=20871&LangID=E

Union of Concerned Scientists. Hooked for Life: How Weak Policies on Added Sugars are Putting a Generation of Children at Risk, 2016. http://www.ucsusa.org/center-science-and-democracy/fighting-misinformation/hooked-for-life-weak-policies-added-sugar#.WE1u7RRfOE4

14.

Climate Change

H. Charles J. Godfray, Mike Rayner, and Peter Scarborough (University of Oxford): Analysis and valuation of the health and climate change cobenefits of dietary change, 2016.

Conflicts of Interest & PPPs

Jonathan H. Marks. 2014. Toward a Systemic Ethics of Public-Private Partnerships related to food and health. In. Kennedy Institute of Ethics Journal Vol. 24, No. 3, 267-299.

Judith Richter: Conflicts of Interest and Policy Implementation: Reflections from the Fields of health and infant feeding.

Marks, J. H. (2014). "Toward a Systemic Ethics of Public–Private Partnerships Related to Food and Health." Kennedy Institute of Ethics Journal 24(3) (updated and expanded version of Marks (2013)

Carlos A. Monteiro et Al: The Snack Attack Peters, A. & L. Handschin eds. (2012). Conflicts of interest in global, public and corporate

governance. Cambridge & New York, Cambridge University Press On corporate influence and PPPs the Global Policy Forum has published several reports

recently that can be found here: https://www.globalpolicy.org/corporate-influence.html



http://www.ucsusa.org/center-science-and-democracy/fighting-misinformation/hooked-for-life-weak-policies-added-sugar#.WE1u7RRfOE4



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Lesser et al. Relationship between funding source and conclusion among nutrition-related scientific articles. PLOS Med 2007; 4(e5).

Bas-Rastrollo M et al. Financial conflicts of interest and reporting bias regarding association between sugar-sweetened beverages and weight gain: a systematic review of systematic reviews. PLOS Med. 2013: 10(12): e1001578.

15.

Gender

De Schutter, Gender and the Right to Food, UNHRC. http://www.srfood.org/images/stories/pdf/officialreports/20130304_gender_en.pdf.

16.

Holistic Approaches Based on Traditional Knowledge

Anke Klitzing, Anshuman Das, Dr. Moussa Bonziet al. 2014: Promoting best practice in agriculture. Welthungerhilfe http://www.welthungerhilfe.de/fileadmin/user_upload/Themen/POWA/Agriculture-Best-Practice_Welthungerhilfe_Burkina-Faso_Ethiopia_India_Europe_01.pdf)

17.

Kehlenbeck, K., Asaah, E. & Jamnadass, R. 2013. Diversity of indigenous fruit trees and their contribution to nutrition and livelihoods in sub-Saharan Africa: examples from Kenya and Cameroon. In J. Franzo, D. Hunter et al., eds. Diversifying food and diets: using agricultural biodiversity to improve nutrition and health issues in agricultural biodiversity. London, Earthscan, pp. 257-269.

Sociocultural Drivers of Malnutrition

Scheper-Hughes, N. Death withoutweeping: The Violence of Everyday Life in Brazil. Berkeley: U. California, 1992.

Mintz, Sweetness and Power, Penguin: New York, 1985.

SUN (Scaling Up Nutrition)

C. Schuftan & Ted Greiner. The Scaling Up Nutrition (SUN) Initiative, 2013.

Ultra-processed foods & marketing, taxation and front of labelling regulations

Gustavsson et al. Global food losses and food waste – Extent, causes and prevention. Rome, 2011. http://www.fao.org/docrep/014/mb060e/mb060e.pdf

Kelly B, Hugues C, Chapman K, Chun-yu J, Dixon H, Crawford J, King L, Daube M, Slevin T. Consumer testing of the acceptability and effectiveness of front-of-pack food labelling systems for the Australian grocery market. Health Promotion International. 2009; 24(2): 120-128.



http://www.welthungerhilfe.de/fileadmin/user_upload/Themen/POWA/Agriculture-Best-Practice_Welthungerhilfe_Burkina-Faso_Ethiopia_India_Europe_01.pdf

http://www.welthungerhilfe.de/fileadmin/user_upload/Themen/POWA/Agriculture-Best-Practice_Welthungerhilfe_Burkina-Faso_Ethiopia_India_Europe_01.pdf

http://www.srfood.org/images/stories/pdf/officialreports/20130304_gender_en.pdf

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Louzada et al. Ultra-processed foods and the nutritional dietary profile in Brazil. Rev. Saúde Pública vol. 49, 2015.

Mandle J, Tugendhaft A, Michalow J, Hofman K. Nutrition labelling: a review of research on consumer and industry response in the global South. Glob Health Action. 2015; 8:25912.

McKinsey (Healthy, wealthy and (maybe) wise: The emerging trillion-dollar market for health and wellness, May 2012. https://www.mckinseyonmarketingandsales.com/sites/default/files/pdf/Consumer_Health_Wellness.pdf

Monteiro et al. Ultra-processed products are becoming dominant in the global food system, Obesity Reviews, 2013, Nov. 14, suppl. 2:21-8.

Mozaffarian et al. Dietary and Policy Priorities for Cardiovascular Disease, Diabetes and Obesity: A Comprehensive Review, Circulation, 2016. http://dx.doi.org/10.1161/CIRCULATIONAHA.115.018585

Pan American Health Organization. Nutriment Profile Model, 2015. http://iris.paho.org/xmlui/bitstream/handle/123456789/18621/9789275118733_eng.pdf?sequence=8&isAllowed=y

Pan American Health Organization. Plan of Action for the Prevention of Obesity in Children and Adolescents, 2014. http://www.paho.org/hq/index.php?option=com_docman&task=doc_view&Itemid=270&gid=28890&lang=pt

Pan American Health Organization. Recommendations from a Pan American Health Organization Expert Consultation on the Marketing of Food and Non-Alcoholic Beverages to Children in the Americas, 2011.

Pn American Health Organization. Ultra-processed food and drink products in Latin America: Trends, impact on obesity, policy implications, 2015.

Pickett, H. Nutritional Benefits of Higher Welfare Animal Products, 2012. Pp1-43. https://www.ciwf.org.uk/media/5234769/Nutritional-benefits-of-higher-welfare-animal-products-June-2012.pdf (For a quick guide to the results, see summary table 3 on page 33.)

WHO, Fiscal policies for Diet and Prevention of Noncommunicable Diseases (NCDs), 2016, http://www.who.int/dietphysicalactivity/publications/fiscal-policies-diet-prevention/en/.

World Health Organization. Guideline: Sugars Intake for Adults and Children, 2015. http://apps.who.int/iris/bitstream/10665/149782/1/9789241549028_eng.pdf?ua=1

World Health Organization Regional Office for Europe. Nutrient Profile Model, 2015. http://www.euro.who.int/__data/assets/pdf_file/0005/270716/Europe-nutrient-profile-model-2015-en.pdf?ua=1

World Health Organization Regional Office for Europe. Tackling food marketing to children in a digital world: trans-disciplinary perspectives, 2016.



http://www.euro.who.int/__data/assets/pdf_file/0005/270716/Europe-nutrient-profile-model-2015-en.pdf?ua=1

http://www.euro.who.int/__data/assets/pdf_file/0005/270716/Europe-nutrient-profile-model-2015-en.pdf?ua=1

http://www.who.int/dietphysicalactivity/publications/fiscal-policies-diet-prevention/en/

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85. Pete Howson, DFID, United KingdomApologies for the late reply. Please find attached my comments on the report. It's a great start and DFID welcomes the effort of the HLPE for tackling such a vast and important topic.

Thanks,

Pete Howson

Livelihoods Advisor, DFID

DFID welcomes the HLPE report and the effort to shine a light on the importance of food systems in the nutrition debate. Given that this is the first draft we think that the HLPE have laid a solid foundation to build on. The draft gives a good background on the core malnutrition issues, with a level of detail and data that portrays the reality of this global issue. The conceptual framework is not overly complicated and does a good job of incorporating the various elements of the food systems in to a visual graphic. The technical detail which follows provides the reader with the nuts and bolts required to understand the framework well. However, there are areas of the report which require further work if the authors are to achieve the “solutions orientated” aim the report sets out.

The report should consider if focusing their main objective towards consumers is the right approach for a food systems report, bearing in mind that small holder farmers are both producers and consumers. Whilst the report provides a number of clear case studies, it is difficult for the reader to pull out “what works and what doesn’t”, in the policy space. Generally, the structure is a little top heavy on the background information and drivers of food systems covered in chapters 1, 2 and 3. Chapter 4 is a relatively short chapter in comparison to the rest of the report and is arguably the focal chapter as it contains efficient policy case studies and the future outlook, providing suggestions on research and partnerships etc. The report is also missing a few key elements around recommendations or calls to action. If the HLPE report is designed to be “solutions orientated” can we incorporate the tools within the Global Panel‘s Foresight report? These were designed for the purpose of making food systems nutrition friendly and would help to support policymakers to make key decisions.

The conceptual framework does a good job of incorporating all the elements of the food system within a one page graphic. The FAO definition on nutrition security is about access and affordability so it is important to have this as a central part of “the food environment”. Whether other areas within the food system are neglected because “the food environment” takes centre stage is debatable. Perhaps it would be possible to have individual conceptual frameworks or pathways for specific topics. For example, pathways of influence to trade and nutrition, which could provide policy makers with a visual representation of where the gaps are or where there is potential for policy coherence.

A final comment on private sector – given that the private sector are such a centre piece to the food system / nutrition debate, the report could set out a clearer approach on how to engage the private sector more effectively, what incentives are needed, where the conflicts lie etc.

Thanks,

Pete



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86. Corrado Finardi PhD- Coldiretti Italian Farmers Union –University of Parma- food Sciences Dept.- Lecturer

I thank FAO to give the opportunity to contribute at an early stage to this purposeful document, which allows a progression of terms, visual and insights onto the current and coming food systems. While a number of drifts are apparent out there- such as climatic change, nutrition transition – i.e., to animal protein and fats in developing countries, to vegetable- based diets in Western ones-,

Transnational institutions experiment a number of challenges due to several factors. In particular, geopolitical instability and turmoil in wide parts of the planet; the uncertain recourse to trade agreements on a bilateral basis as key feature of the new multilateralism; the coming back of some sort of world equilibrium, in amidst cold war scenario and multi-centric power allocation- all of these pose new questions to the prevalent and yet imperfect world food equilibrium and – most of all- framing of the possible solutions and interventions.

We provide hereinafter basically 2 kinds of suggestions, the first one more conceptual and the second one related to mere formal aspects. Eventually, we believe that a better overall glossary could help greatly in a correct framing of the problems at stake ad possible solutions.

Also we believe that the food value chains should be mirrored better in the risks they currently present: with less choice for consumers, more fragile food security and inherent biological hazards (ie, antimicrobial resistance, loss of biodiversity, spread of diseases at a faster pace due to commoditized food chains, etc).

In particular, the merges and acquisitions process by huge transnational structures, which is on-going, pose serious risks in terms of food safety and food security governance- risks for which there is a lack of tools (political, institutional and economical) for proportionate contrast.

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Line 4 p. 9. “malnourished”. As we intend to comment further, this term without introduction or explanation at the very beginning, may create confusion and it seems not able to face different problems with different genesis and solutions. So we suggest a “In brackets” use of this word, if authors intend to continue using it (“malnourished” encompasses very divergent problems such as lack of energy intake and excess of; or the mix between excesses of caloric intake and micronutrients deficiency).

Footnote1 p. 9. And line 2 p. 9. We hence question the usefulness and conceptual validity of the term “malnutrition” which is comprehensive of a wide array of phenomena needing different tools for solution. In fact, equaling overweight and obesity to micronutrient deficiency or lack of enough energy intake is somehow problematic in our perspective and does not help addressing the issues at stake, the way they develop, the reasons-why, and may offer limited clues in further problem solving. So we propose to better clarify or reformulate the initial period “Malnutrition in all its forms” in order to reach an overall clarity, better without explanatory footnotes.



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Line 10 p. 9 we suggest to refer expressly to “unhealthy food environments”, since it is going to be better explained in the glossary and it Is a key concept in relation to the draft document.

Line 10 p. 9 it may need attention the “poor diets” wording, which suggest exclusively a lack of micro-macro nutrients or energy and not an overall disequilibrium or lack of variety of the diets as such.

“Unpaired” diets may work better (?)

Line 15 p.11.

Definition 1 Food System

We propose the different wording

“A food system consists of all the elements (environment,rural territories and landscape people, inputs, processes, knowledge and technology, infrastructures and environmental facilities institutions, etc) and activities that relate to the production, processing, distribution, preparation and consumption of food, and the outcomes of these activities, namely nutrition and health status, socio-economic growth and equity and environmental sustainability.

Food systems encompass also the cultural framing and promotion (i.e., marketing) of food in order to make it acceptable and perfectly legitimate in any given context.”

Rationale for consideration: under Food System definition, we suggest a different use of “environment”, due to the ambiguity it may bring due to its reference to landscape, territory, and other anthropic factors. Also, it needs proper consideration that under Definition 3- “Food environments” a definition of “environment is provided. To provide clarity we believe that an unambiguous use of wording should be used whenever possible- hence generic terms such as “environmental” should be avoided.

Line 21 p. 11


“A sustainable food system (SFS) is a food system that ensures food security and balanced nutrition for all and everywhere in such a way that economic, institutional, social and environmental bases to generate food security and nutrition of future generations are not compromised”.

Rationale for consideration: Institutions and capacity building are key to achieve a correct understanding of how food systems operate, and to ameliorate the overall status of sustainability in all its features.

Line 25 p. 11 Definition 3 Food environments


“Food environments refer to the physical, economic, policy, institutional and socio-cultural surroundings, opportunities and conditions that influence food choices and nutritional status (…)…”

Rationale for consideration: here again we feel useful to insert “institutional”, while “policy” as a particular feature under the wider institutional framing.

Line 1 p. 12 Definition 4 Diets

We propose the different formula



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“Diets comprise the individual foods that a person consumes on a given day, week or onth, in a habitual way that forms a dietary pattern refer to a habitual way by which the individual foods enter dietary patterns on a continuous temporal basis (day, week, or month). Diets that are considered nutritious and sustainable are those with lower environmental impacts and contribute to food and nutrition security and to healthy life for present and future generations.

Diets depend not only on food (mixes) but also on ways of processing, transforming, cooking, preserving and storing, as well as serving foods, along with the cultural dimension of sharing meals (conviviality)”.

Rationale for consideration: the ancient Grecian word for “diet” (diaita) refers primarily to the habit under which foods are consumed, more than on individual foods in themselves. It implies not only a social dimension but also a prevalent aspect of combining foods.

Line 21-24 p. 12

Under the enumeration of the numerous factors affecting food systems, still lack the “insitutions” which is indeed a different feature from “political” and “economic”. It could be helpful to add it.

Line 14-18 p. 13. The contributions of Francisco Varela, Humberto Maturana, and more on the sociological side, Niklas Luhmann, (Soziale Systeme - 1984) can be added to explain the interaction across systems and mutual perturbation.

p. 14 graph.-FIGURE 1

To our limited understanding a better highlighting of the features of marketing under “food acceptability and preferences” in turn under “Food Environments” is desirable.

Under Food Environments also, under “information and guidelines” it could be nuanced the difference between public and private ones (i.e, public health authorities or instead, voluntary private guidelines or messages even in the shape of “demi-marketing”).

p. 15 ll. 28 and fw. We propose to reformulate as follows “Innovation is generated through research, but also by less visible enginees such as gradual improvement, technological spillover from other domains, rate of adoption of parallel technologies, shaping the anthropic environment. Also the cultural dimension, habits and uses have a role in favoring innovation adoption “

p. 15 ll 40 to 48. We suggest to add the “institutional drivers” in the paragraph title and at ll.40, “Political, economic and more broadly, institutional drivers…”

In fact, “institutions” are a bundle of shared societal expectations driving behaviors and take the form of norms, prescribed courses of action-habits, as well as other consensual procedures to allocate resources, power and goods. Basically (sociological thinking considers) institutions as norms to behave in a predictable manner and geared inside formalized structures

p- 18 ll. 43, “Food Environments”, at ll. 46, we suggest to include also “citizens” as key to define “food environments”. In fact, citizens increasingly may shape food environments, for instance by social media, blogging, on line polls and surveys, (ie, change.org). In fact, since food requires a wider institutional framework inside which is “made available and accessible”, also citizens may have a clear role in shaping food environment, and not only as consumers.



Proceedings / 274

p.19 ll 27 and fw. It seems it lacks a clear explanation of the ultimate goal of the FBDGs. Examples aslo could help.



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