Invitation to an open discussion
on the political outcome document of the ICN
Comment Form
Personal information
Name: Liv Elin Torheim, Oslo and Akershus University College (HiOA); Wenche Barth Eide,
University of Oslo; Sabrina Ionata De Oliveira Granheim, HiOA; Arne Oshaug, HiOA; FIAN
Norway; and Save the Children Norway
Organization: the Norwegian Network for Global Nutrition
Location: Norway
Email: liv.elin.torheim@hioa.no
The Norwegian Network for Global Nutrition, which is a network of academics and NGOs in Norway,
thanks for the opportunity to comment on the zero draft of the political outcome document of the
ICN2. We first have some general comments to make, whereas specific comments to the document
are attached.
1. Nutrition is higher on the global agenda than ever before in history. The ICN2 needs to be a
place to convene, harmonize, strengthen and advance the constructive forces at work, and
be a “leading star”. To achieve this, we believe the commitments described in the policy
document need to be extensively based on previous achievements (such as those mentioned
below), and all relevant global initiatives and actions need to be considered, in particular the
Global Strategic Framework of the reformed CFS which is to be a living annual document, the
World Health Assembly objectives from 2012, the Global Action Plan for the Prevention and
Control of Non-communicable Diseases 2013-2020, the 1000 days initiative of the SecretaryGeneral’s Global Strategy for Women and Children’s Health (WHO, 2010) and the SUN
movement. The only initiative mentioned in the Zero Draft is the Zero Hunger Challenge!
2. The document ought to be based in an expressed full recognition of the human right of
everyone to adequate food and nutritional health and to be free from hunger, as established
and implied in Article 25 of the Universal Declaration of Human Rights (UDHR) Article 11 (1)
and (2) of the International Covenant on Economic, Social and Cultural Rights (ICESCR), Article
24 (c) of the Convention on the Rights of the Child (CRC) and Article 12 (2) of the Convention
on the Elimination of All Forms of Discrimination against Women (CEDAW). Properly framing
the commitments of the ICN2 in a human rights framework will enhance previous
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achievements in (a) defining the content of adequate food as a human right (called for in the
World Food Summit in 1996 and interpreted in 1999 in General Comment No. 12 by the United
Nations Committee on Economic, Social and Cultural Rights); (b) the development by FAO
Member States of the Voluntary Guidelines to support the progressive realization of the right
to adequate food in the context of national food security (2004); and (c) the decisive
integration of food and nutrition as human rights in a range of recent global policy food and
nutrition policy and technical documents from the UN and other stakeholders, in particular
the Global Strategic Framework on Food Security and Nutrition of the reformed Committee
on World Food Security (CFS). Aligning the document to a human rights framework should
recall the framework of corresponding State obligations in general use by the United Nations,
many states and civil society (respect, protect, fulfill (facilitate and/or provide), and which
helps clarify and contextualize the responsibilities of the State; likewise the United Nations
Guiding Principles on Business and Human Rights (UN Human Rights Council, 2011) reiterates
these responsibilities especially that of protect, and the implications for the private sector
companies to respect human rights in their activities and relations and internal risk
accounting, all pertinent to the performance also of food related companies in diverse food
systems. Last but not least the extraterritorial obligations of states, meaning obligations to
protect the human rights, including the right to adequate food and nutrition, of persons living
within or beyond their national boundaries and, therefore, must put into place effective rules
and regulations that ensure that private actors, including transnational corporations, do not
infringe upon these rights (Maastricht Principles ref! 23-27). The rights of women in their often
conflicting productive and reproductive roles need special attention as can be inspired e.g. by
CEDAW and the ICESCR Article 14 which especially focuses on rural women.
Thus the document as a whole needs to be reviewed with a human rights lens, taking into
account the key human rights principles of participation, accountability, non-discrimination,
transparency, human dignity, empowerment, and respect for the rule of law in encouraging
the design of policies and conduct of interventions. FAO has particular competence in this
area and reference should be made to the Organization’s own record and achievements in
developing tools and aids to assist governments and civil society in meeting their right to food
responsibilities.
We also believe the various key human rights instruments that are particularly relevant to the
right to food and nutritional health need to be explicitly recalled, this because of the high
number of Member States that have ratified them and thus are bound by their previous
commitments which will be important in the final negotiations.
3. We appreciate that improving food systems is highlighted as playing a key role to improving
food and nutrition security. Food systems is an important concept but has different
meanings for different people and interests. In this context account must also be taken of
how different food systems and changes in these affect different groups’ very livelihoods,
which will determine the way households access food or resources for food. It is important
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that ICN2 adopts a strong stance on what food systems are expected to deliver; in this
context we refer as inspiration to the very last report to the Human Rights Council by the
UN Special Rapporteur on the right to food, professor Olivier De Schutter: “The
transformative potential of the right to food” where he deals both with these expectations
for, i.a., poverty reduction, and looks at the way forward in terms of reshaping local food
systems, deploying national strategies and shaping an enabling international environment.
(U.N.Doc.A/HR/C/25)
4. However, we also agree with many other commentators that the document fails to take
adequately into account the many other important underlying and basic factors determining
nutritional problems. Key underlying challenges include intra-household distribution and
infant and young child care and feeding practices which should be reflected in the
document; furthermore the need to underline women’s many, often competing, productive
and reproductive roles - as food producers and processors, and in bearing, breastfeeding
and taking care of their children, and at the same time often being discriminated and
economically marginalized in many societies.
5. Important basic causes include gender inequality, inadequate access to education and other
resources, misuse of resources and corruption, and, as has unfortunately been repeatedly
shown in the past and increasingly during the last years – internal conflict, where food even
has been used as weapon which is completely unacceptable and a severe breach of the
human right to adequate food.
6. The key term “malnutrition” is not used consistently throughout the draft. Consider revising
with clear use of the terms undernutrition and malnutrition (as referring to both under- and
over-).
1. Do you have any general comments on the draft political declaration and its vision
(paragraphs 1-3 of the zero draft)?
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We wonder why the initial identification of those who are behind the Rome Accord has not
been inserted in the usual way for intergovernmental conferences in the Zero Draft: is this
reflecting that it will be a multi-stakeholder accord rather than a diplomatic one of Member
States? If so it will weaken the political clout of the Accord and pretend harmonious
agreement where there are in fact deep controversies implied as to what food security and
nutrition systems there ought to be in the future, hiding the need for governmental
regulations and protection from adverse behavior from the private sector where human
rights risks may be potentially implied.
The Rome Declaration from the ICN in 1992 starts with:
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1. We, the Ministers and the Plenipotentiaries representing 159 states and the
European Economic Community at the International Conference on Nutrition
(Rome, December 1992), declare our determination to eliminate hunger and to
reduce all forms of malnutrition. Hunger and malnutrition are unacceptable in a
world that has both the knowledge and the resources to end this human
catastrophe. We recognize that access to nutritionally adequate and safe food is
a right of each individual. We recognize that globally there is enough food for
all and that inequitable access is the main problem. Bearing in mind the right to
an adequate standard of living, including food, contained in the Universal
Declaration of Human Rights, we pledge to act in solidarity to ensure that
freedom from hunger becomes a reality. We also declare our firm commitment
to work together to ensure sustained nutritional well-being for all people in a
peaceful, just and environmentally safe world.
In our opinion, this text is much more committing (“Declare our determination to
eliminate ... and reduce...”) and it states that adequate food and nutrition is a
human right.
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Para 2 states that socio-economic differences exists, but this should be put much more
strongly forward stating that there exists unacceptable differences between rich and poor
countries, but even more so within many countries where the gaps are rapidly widening as
recently reported by World Economic Forum Council on Values (A New Social Covenant,
2014, at http://www3.weforum.org/docs/WEF_GAC_Values_2013.pdf); such gaps severely
undermine poor people’s right to adequate food and nutrition. Some of the most affected
are smallholder farmers, landless, ethnic minorities, dalits, indigenous people, urban poor,
people with disabilities etc, who are much more affected by food insecurity and
undernutrition than other more well-off groups. We refer to the latest report of the Special
Rapporteur on the right to food, Olivier de Schutter on “The transformative potential of the
right to food”, where these issues are adequately described.

Para 2 further mentions the modest progress on reducing malnutrition, “as measured by
the targets of the 1992 International Conference on Nutrition, the 1996 World Food Summit
and the Millennium Development Goals”. However, these are focused on undernutrition,
and obesity is only briefly mentioned. Other measures should be included to make the
double burden more explicit. This is particularly relevant in a document with a focus on food
systems and value chains, and that does not touch on the discussion of potential conflicts of
interests of different stakeholders involved in such a chain, mainly those closely related to
overweight and obesity.
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Para 3 stating that “The evolution of food (including agricultural) systems -- with innovations
in production, manufacturing, storage and distribution -- has led to enhanced dietary
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diversity, greater consumption of vegetables and fruit, as well as meat and dairy, in
developing countries, although benefits have been uneven” is problematic. The evolution of
the current food systems has also led to mono-culture and reduced diversity, and increased,
and sometimes excessive, use of fertilizers and pesticides leading to environmental damage.
And – the current food system has been promoting large-scale farming (mainly monoculture and cash crops) at the expense of small holder farming (which are more often
agroecological and using intercropping). Increased intake of meat and dairy might be
positive for some groups, but it is probably also a contributing cause of the increase in NCDs,
as well as having major ecological impacts.
2. Do you have any comments on the background and analysis provided in the political
declaration (paragraphs 4-20 of the zero draft)?
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Para 4: Again, it needs to be recognized that the right to adequate food and nutrition is a
human right and with the right to be free from hunger being the only right in the system
being characterized as fundamental. It should be made clear that the States have the
obligation to secure this right for its inhabitants, through three categories of obligations.
These are: (a) to respect the people’s existing access to adequate food; (b) to protect the
people from being deprived of their access to food; and (c) to fulfil the people’s right to food
in cases where they are not able to enjoy this right from own means, either through
facilitate (proactively strengthen their access to and utilization of resources and means) or
through directly providing food or resources for food, including social protection schemes.
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Para 4: here is an example of the inconsistent use of the terms malnutrition. Malnutrition
and obesity are being used as two opposites, therefore it should read undernutrition
instead.
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Para 5: It could be stated more clearly which groups are most vulnerable to undernutrition,
such as pregnant and lactating women, children below 2 years of age, adolescent girls and
the elderly and disabled.
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Para 6 and 7: We suggest dividing into “commitments” and “initiatives”. Regarding
commitments, the global development targets on nutrition, adopted at the World Health
Assembly in 2012 needs to be mentioned and committed to by the States. Regarding
initiatives, the Global Strategic Framework of CFS and the SUN movement should be
mentioned, not only the Zero Hunger Challenge.

Para 7: “as well as reverse the rise in obesity and diabetes, as part of the effort to reduce the
overall mortality associated with NCDs.” This text deserves a new paragraph, where the
issues around this problématique can be discussed and addressed in detail, with reference
to the Global Action Plan for the Prevention and Control of Non-communicable Diseases
2013-2020
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Para 8: This is just a list mixing things that do not really fit together. Each of these (human
right covenants; Voluntary guidelines on the RtF; CFS’s strategic framework; and
commitments from the High-level meeting on NCDs) are so important that they need to be
contextualized in proper paragraphs and not just listed like this.

Para 9: We acknowledge the use of “food systems”, but we believe it is inconsistent to first
define the food system as going from production to (individual) consumption, and then to
state that the food systems “determine the quantity as well as quality of the food supply”.
We suggest the statement about quality and quantity should point all the way to the
consumer as well, e.g. by adding “… and the individual food intake.” The extensive use of
“food system” does not take into consideration the health aspect of food, nor healthy diets
and food products such as fish and fresh fruits and vegetables. Neither does it recognize
intra-household food distribution or infant and young child feeding practices, including
appropriate breastfeeding practices, which are much linked to knowledge and resources, in
the household, the community and in the health sector.
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In the discussion about food systems, there is a glaring lack of mentioning small-scale
farmers, and women’s productive roles in agriculture combined with their reproductive roles
and the trade-offs often implied.

Para 10: It should acknowledge the cultural dimension of food. Instead of “avoiding food
processing that reduces or adversely affects nutrition”, we should also avoid processing and
promoting of processed foods that damage traditional food habits, the preparation of
traditional meals, as well as the use of traditional food stuffs.
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Para 11: Nutritional considerations need to be integrated into all policies, and not just
considered.
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Para 12: How should the different sectors work with nutrition? Need some more description
here. In addition, the very concept of “policy packages” may be inappropriate in the context
of adapting the initiatives against undernutrition to the local specificities and demands.

Para 13: Talks only about how increased food production can reduce undernutrition, but
need to talk about direct nutrition interventions, breastfeeding, treatment of
undernutrition. It also needs to deal with food processing and its consequences more
clearly.
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Para 14: Mentions the capacity of the consumer to choose the right food, and some about
marketing, but what about regulating the production, distribution and marketing of
unhealthy and healthy foods? What about the industry’s responsibilities? Why is there no
mention of the 2011 UN Principles on Business and Human Rights (“the Ruggie principles”)
and states’ extraterritorial human rights obligations? The International Code of Marketing of
Breast-milk Substitutes should also be referred to here. It should explicitly state that the
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consumer plays an important role in making healthier choices and should be empowered to
it, BUT at the same time this is not the only (and not the major) cause of the current
nutrition problems globally. This paragraph must acknowledge the role an enabling
environment for good dietary habits, and the roles of different stakeholders in such an
enabling environment. The paragraph should also include that governments should not only
facilitate the establishment of healthy food practices, but also protect the food heritage and
food traditions that promote health. In addition, regulation of the marketing of unhealthy
foods is important, but it is not and should not be the only form of regulation to be
considered by governments.

Para 15: Mentions that the State should provide nutritional protection, and this could be
linked to the State’s obligation to fulfil the individual’s right to food through providing
directly to those not able to attain this right through their own resources and means.
Further, interventions and partnerships for improving maternal and child health and
nutrition deserves a full paragraph by itself, with much more details on how this should be
done. The paragraph also needs to clarify what is meant by partnerships and how they differ
from programs and interventions.
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Para 17. What about global leadership?
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Para 18: what about implementation capacity? The document is weak regarding building
capacity on nutrition and establishing a competent workforce to implement the vision that is
being constructed.
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Para 19: The paragraph mentions interaction among stakeholders, which is good and
desirable. However, it needs to be clearly stated that this must be done in a transparent
way, avoiding or minimizing potential, actual and perceived conflicts of interest, so as to not
undermine our own efforts towards good nutrition for all.

Para 20: Monitoring and accountability should be linked to the voluntary guidelines on the
right to food and be based on a human rights based approach. It should make clear that
accountability mechanisms should be in place for all stakeholders involved.
3. Do you have any comments on the commitments proposed in the political
declaration? In this connection, do you have any suggestions to contribute to a more
technical elaboration to guide action and implementation on these commitments
(paragraphs 21-23 of the zero draft)?
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Our general comment to the commitments is that they are extremely vague, and hard to
grasp, measure and monitor.
Furthermore, the commitments are all related to food systems, and none to the health side
of nutrition. This should be better balanced.
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Please provide your comments in the appropriate fields relating to these commitments:
Commitment I: aligning our food systems (systems for food production, storage and
distribution) to people’s health needs;
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What does this mean? It is too vague.
The definition of food system as presented here is very downstream and focused on food
production, storage and distribution. This is undesirable and inconsistent with the entirety of
the document.
The food systems should be aligned with the people´s health needs and culture, as well as a
sustainable environment.
Some present dominating food systems deliver ultraprocessed foods that may have
detrimental effects on nutritional outcome (often obesity) and related effects on health.
Commitment II: making our food systems equitable, enabling all to access nutritious
foods.
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For the food systems to be equitable, there is a need for gender equality, nondiscrimination, agrarian reform with pro-poor redistribution of land, decent work and social
security nets. There should be more specific commitments in this regard.
Right to food impact assessment of policies and interventions in a food system is one way of
directing it in an equitable direction.
Large scale Investments in land (sometimes called land grabbing) can also be a threat to
nutrition. This should be recognized and reference should here be made to the Voluntary
Guideline on the Responsible Governance of Tenure of Land, Forests and Fisheries from the
Committee on Food Security (2012), which will serve to protect the livelihood of vulnerable
households..
Commitment III: making our food systems provide safe and nutritious food in a
sustainable and resilient way;
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Commitment IV: ensuring that nutritious food is accessible, affordable and acceptable
through the coherent implementation of public policies throughout food value chains.
Commitment V: establishing governments’ leadership for shaping food systems.

Add: “in a way that promote good health and nutrition, protecting people’s right to
adequate food.
Commitment VI: encouraging contributions from all actors in society;

Add: “while handling potential, actual or perceived conflicts of interest that may arise from
such contributions”. The management of conflicts of interest, and accountability, must be
clearly stated.
Commitment VII: implementing a framework through which our progress with achieving
the targets and implementing these commitments can be monitored, and through which
we will be held accountable.

How will this be coordinated with all other ongoing initiatives in the international nutrition
context?
22. Commit to launch a Decade of Action on Nutrition guided by a Framework for Action
and to report biennially on its implementation to FAO, WHO and ECOSOC.
23. Commit to integrate the objectives and directions of the Ten Year Framework for
Action into the post-2015 global development efforts.
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