Thank you for the opportunity to comment on the ICN2 Framework for Action zero draft.
We would like to share our comments in respect to question 1.
First, our principal comments relate to chapter 3.4 (International trade and investment).

While we do appreciate that the first paragraph reflects the complex and multifaceted
relationship between trade and nutrition, we find that the second paragraph almost exclusively
approaches the link with trade from the negative perspective, i.e. what trade should not do,
without actually spelling out the positive aspects of what trade can do to improve nutrition. We
are therefore suggesting some editorial changes to this effect, as well as some clarifications in
relation to indirect references to WTO Agreements (eg. TRIPS, Agriculture, SPS, TBT):
Trade and cross-border investment agreements – multilateral, bilateral
and regional – define the international framework of rules within which
countries apply national trade and investment policies. Trade These
policies, in turn, effect the food environment, influencing food prices,
availability, access and consumption as well as nutrition outcomes,
involving food safety, food security and dietary options.
Minimally, trade policies and agreements should ‘do no harm’ to
nutrition. Trade and investment policies can and should be coherent
with, and not undermine be mutually supportive of, national nutrition
strategies. The Multilateral trade agreements – established and
monitored by the WTO – provide sufficient policy space to enable
Member States to address nutrition. These agreements contain
flexibilities that recognize countries' right to implement measures in
order to address legitimate objectives, including to protect public health,
provided they are neither discriminatory nor used to unjustifiably restrict
trade. Trade policy should support nutrition policy and not restrict the
ability to implement effective nutrition policies. The public health
exception to intellectual property rights includes innovations in nutrition
. For example, the multilateral trade framework applying to intellectual
property rights aims to promote innovation and prevent unfair
competition. It specifically recognizes the particular importance of
health and nutrition and provides countries with policy options to
achieve nutrition-related objectives. Food supplies should not be the
subject of export sanctions.
The availability of and access to healthy foods should be ensured
through nationally appropriate combinations of imports and domestic
production based on appropriate policies, and investments in food
production, especially by smallholders. There should be effective
incentives for farmers to produce sufficient healthy foods (e.g., fruits
and vegetables) to be sold at affordable prices. The availability of and
access to unhealthy foods should be effectively regulated and
discouraged. International standards in regulations for nutrition content
to promote compliance with nutrition requirements should be
established, implemented and enforced. Relevant international standards
for nutrition should be developed, and regulations imposing nutrition
requirements should normally be prepared, adopted and applied based
on these relevant international standards.
Second, we would like to add a general comment on chapter 3.3.6 (Food safety and antimicrobial
resistance).

This section has only a very brief paragraph regarding food safety and then gets into
considerable detail about antimicrobial resistance (AMR). Although there is no doubt that AMR
is a serious problem, in terms of the effects on global nutrition, there are much more serious
food safety issues that should be flagged. Microbiological contamination, including e-coli,
salmonella, and mycotoxins etc. pose much more serious health risks to malnourished people,
and more needs to be done to assist governments to ensure uncontaminated food supplies.
The Partnership for Aflatoxin Control in Africa (PACA) could be highlighted as an example - and
many more initiatives of this kind are needed. The overwhelming focus on AMR gives the
misleading impression that these other food safety issues are relatively unimportant.
Third, we have some comments regarding chapter 3.1 (Food systems).

Our comments relate to the paragraph on page 7:
Both traditional and modern supply chains offer risks and opportunities
for achieving better nutrition. Traditional supply chains are the primary
channel through which most low-income consumers purchase food.
Enhancing the efficiency of traditional food value chains can enable
better nutritional outcomes by improving the access of low-income
consumers to safe, nutrient-rich foods, such as animal-sourced foods,
legumes, certain vegetables and fruits.

By putting the word "certain" in front of vegetables, the impression is given that all animalsources foods and legumes provide good nutrition versus only "certain" vegetables. I doubt
this is the intention of the authors, who might either want to move the qualifier "certain" to
before the list of food categories (… such as certain animal-sourced foods, legumes, vegetables
and fruits), or delete it altogether. Nowhere else in the text are only "certain" vegetables
recommended. We would also question the statement that most low-income consumers
purchase food through traditional supply chains. While this may be true in most developing
countries, it may not be the case in developed countries. In fact, it seems that one of the
contributors to obesity among low-income consumers in developed countries is that they do
not have easy access to traditional food supply chains.
These comments have been provided under the WTO Secretariat's own responsibility and are
without prejudice to the positions of WTO members or to their rights and obligations under the
WTO. These comments are non-exhaustive, and any absence of comments should not be
construed as agreement with the concerned text.