Invitation to an open discussion
on the political outcome document of the ICN2
Comment Form
Personal information
Name: Claudio Schuftan
Organization: PHM
Location: Vietnam
Email: cschuftan@phmovement.org
1. General comments on the Draft of the Rome Declaration on Nutrition.
I welcome the opening of the JWG for comments by public interest civil societies. But an econsultation is hardly a way for the needed active involvement of this important sector. We
have submitted a concrete request on how to become an active part of the preparation, the
holding and the post ICN2 process. We are hoping for a positive response.
2. Specific comments on the paragraphs related to the multiple threats that
malnutrition poses to sustainable development (paragraphs 4-10).
Multiple threats of malnutrition are a major challenge to sustainable development
4. Acknowledge that malnutrition, including undernutrition, micronutrient deficiencies,
overweight and obesity, as well as noncommunicable diseases caused by unbalanced diet, has
high socioeconomic and other costs for individuals and families, communities and states;
threatens their health and wellbeing by impacting negatively on human physical and cognitive
development; compromises the immune system; increases susceptibility to communicable and
noncommunicable diseases; and poses heavy burden on societies by restricting the attainment of
human potential and reducing productivity. It also is the outcome of violations of the Right to
Food (RTF).
5. Recognize that the root causes of malnutrition are complex and multidimensional and are
rooted in the chronic neglect of the RTF:
-[a]round physical and economic access to sufficient food, adequate both in quantity and
quality, affordable and culturally acceptable, is a key determinant; compounded and often
aggravated, in a vicious cycle, by non-potable water, poor sanitation, food borne and parasitic
infections, and ingestion of harmful levels of chemical and biological contaminants due to unsafe
food supplies;
Worldwide, poverty is [a] still the major contributor to malnutrition in both rural and urban
areas.
6. Acknowledge that different forms of malnutrition co-exist [with]in most countries; while
dietary risk affects all socio-economic groups, large inequalities exist in nutritional status due to
differential exposure to risk and adequacy of dietary energy and nutrient intake, between and
within countries.
7. Recognize that environmental, [and] soci[et]al and commercial changes [often] have an impact
on dietary intake and physical activity patterns, leading to higher susceptibility to obesity and
non-communicable diseases through increasingly sedentary lifestyles and greater consumption of
ultra-processed foods, that are high in fat, especially saturated and trans-fats, sugars, and
salt/sodium.
8. Recognize that climate change is negatively impacting the quantity, quality and diversity of
food grown and is therefore posing a major threat to food and nutrition security, as well as of
food sovereignty.
9. Acknowledge that current food systems are being increasingly challenged to provide safe and
nutritious food for all to enable healthy diets, due inter alia to constraints posed by resources and
ecological sustainability, to large food losses and waste, [unbalanced] and to distribution and
trade distorting economic actors [measures including] that often use unilateral coercive economic
measures affecting the economic access to food by the lower quintile income groups.
10. Note, with profound concern that, notwithstanding significant achievements in many
countries, recent decades have seen rather modest and uneven progress in reducing malnutrition
and that:
a) the prevalence rate of undernutrition has declined, but absolute numbers remain unacceptably
high with at least 842 million cases in 2011-2013;
b)
c)
d) all OK
e) while dietary risk factors, together with [inadequate] insufficient physical activity, account for
almost 10% of the global burden of disease and disability and different forms of undernutrition
are the biggest underlying cause of death in children under the age of five, causing 45% of all
child deaths in the world today.
3. Specific comments on the vision for global action to end all forms of
malnutrition (paragraphs 11-12).
A vision for global action to end all forms of malnutrition
11. Reaffirm that:
a) the elimination of malnutrition in all its forms is an imperative for ethical, political, social and
economic reasons, paying particular attention to the special needs of children, women, the elderly
and disabled people;
b) a coordinated action of different actors, at international, regional, national and community
levels [should] must be supported, through cross-cutting policies, programmes and initiatives in
the food system, as well as securing universal access to health, to social protection, to education,
to energy, to rural development, to water, sanitation and hygiene, and also providing sufficient
resources for research, making sure international trade is fair consumer protection, transport,
urban planning, and the environment; THIS HAS TO BE REWORDED. TOO MANY THINGS
THAT DO NOT REALLY GO TOGETHER.
3
c) global and national policy coherence to protect nutrition is needed among relevant sectors,
including in ‘free’ trade and investment agreements, in investments that incentivate [for]
agricultural production, food processing, [and] distribution and marketing;
d) the risks linked to higher and more volatile prices for agricultural commodities often resulting
from speculation in the futures markets and their consequences [for] in global food insecurity and
malnutrition, need to be [managed] minimized;
e) improvements in diet and nutrition require strengthening the legislative and regulatory
framework for food marketing, advertising, safety and quality control at national, regional and
international levels, including enhanced engagement and democratization of the Codex
Alimentarius Commission, increased participation of Member States and of public interest civil
societies in the [and] adherence to the Codex Standards and Guidelines.
12. Recognize that:
a) international cooperation and official development assistance for nutrition should, as
appropriate, support and complement national nutrition initiatives and measures in the realm of
the right to food;
b) [achieving] Making the right to adequate food for all central is a must in any [requires]
sustainable, equitable, accessible and resilient food system[s];
c) food and agriculture systems (including crops, livestock, fisheries and aquaculture) [systems]
need to be addressed holistically and from a human rights perspective by public policies free from
private sector pressures, including in all that relates to [the] resources and investments, and how
they affect the environment, people, institutions and processes with which food is produced,
processed, stored, distributed, marketed, prepared and consumed;
d) while private investments and markets will continue to [drive] be important for both the supply
of and access to nutritious food, responsible and commensurate public investments and
appropriate needed market regulations in the food, agriculture and other sectors are crucial to
overcoming malnutrition;
e) nutrition improvement requires the provision of balanced and diversified diets based on locally
sourced agricultural, livestock and fisheries products, meeting nutrient requirements of all age
groups and all groups with special needs, and avoiding excessive intakes of saturated fat, sugars
and salt/sodium, and removing trans-fat, the latter requiring regulation of the food industry;
f) food systems need to promote healthy dietary patterns by providing year-round access to safe
and nutritious locally sourced foods including fruits, and vegetables, pulses, whole grains and
animal source foods such as fish, poultry, dairy products and meat while importantly limiting the
consumption of ultra-processed foods that negatively affect nutrition and health;
g) food systems need to address and prevent infectious and zoonotic diseases and to tackle
excessive use of antibiotics in animal husbandry that have led to dangerous antimicrobial
resistance in humans;
h) food systems should be sustainable, importantly based on agro-ecological principles, and
should make sure all components for food production, processing and distribution are accessible
to small producers (including land, soil, seeds, fertilizers, water, energy, harvesting??, storage and
transport) and should further be managed sustainably with due attention to environmental
impacts;
i) more efforts [should be made] are needed to reduce post-harvest losses and food waste
throughout the food chain including consumption as these [can] losses significantly contribute to
reducing sustainability and reducing nutrition security;
j) the United Nations system and the international financial institutions must work more
effectively together in a coherent manner to enhance international cooperation to support national
efforts to accelerate progress in addressing malnutrition always promoting and securing the UN
sanctioned human rights based approach.
k) It is indispensible that something is said about breastfeed in and complementary feeding!!
4. Specific comments in the appropriate fields relating to these commitments
(paragraph 13):
Commitment a): eradicate hunger and all forms of malnutrition, particularly to
eliminate stunting, wasting and overweight in children under 5 and anemia in women;
eliminating undernourishment and reversing rising trends in obesity;
Commitment to action
13. We commit to:
a) eradicate hunger and all forms of malnutrition, particularly to eliminate stunting, wasting and
overweight in children under 5 and anemia in women; eliminating undernourishment and
reversing rising trends in obesity; by when? Isn’t this setting the Declaration up for failure? Can
we be more modest and overachieve rather than too ambitious and underachieve?
Commitment b): reshape food systems through coherent implementation of public
policies and investment plans throughout food value chains to serve the health and
nutrition needs of the growing world population by providing access to safe, nutritious
and healthy foods in a sustainable and resilient way;
b) reshape food systems through coherent implementation of public policies, private sector
regulatory regimes and investment plans throughout food value chains to serve the health and
nutrition needs of the growing world population by providing access to affordable, safe, nutritious
and healthy foods in a sustainable and resilient way; at the same time open up to look at the
problems of the food system from a food sovereignty perspective.
Commitment c): take leadership to shape and manage food systems and improve
nutrition by strengthening institutional capacity, ensuring adequate resourcing and
coordinating effectively across sectors;
c) take leadership who implied here? to shape and manage food systems and improve nutrition by
strengthening institutional capacity, regulations in the food system and ensuring adequate
resourcing and effective coordination [effectively] across sectors;
Commitment d): encourage and facilitate contributions by all stakeholders in society
and promote collaboration within and across countries, including North-South, SouthSouth and triangular cooperation;
d) encourage what does encourage really mean? and facilitate what does facilitate really mean?
contributions by all [stakeholders] claim holders and duty bearers in society [and] so as to
promote collaboration within and across countries, including North-South, South-South and
triangular operations;
Commitment e): enhance people’s nutrition, including people with special needs,
through policies and initiatives for healthy diets throughout the life course, starting
from the early stages of life, before and during pregnancy, promoting and supporting
adequate breast feeding and appropriate complementary feeding, healthy eating by
families, and at school during childhood;
e) enhance what does enhancing really entail? people’s nutrition, including marginalized people
and people with special needs, through policies and initiatives for healthy diets what are these
exactly? throughout the life course, starting from the early stages of life, before and during
pregnancy, promoting and supporting adequate breast feeding and appropriate complementary
feeding, healthy eating by families, and at school during childhood; IBFAN’s apprehensions on
this are not captured here.
Commitment f): adopt and implement a Framework for Action that should be used to
monitor progress in achieving targets and fulfilling commitments;
f) adopt and implement a Framework for Action that should be used as a basis to monitor
progress in achieving targets and fulfilling commitments; Who will do this, by when? How?
Vague as this, it means nothing.
Commitment g): integrate the objectives of the Framework for Action into the post2015 development agenda including a possible global goal on food security and
nutrition.
g) integrate the objectives of the Framework for Action into the post-2015 development agenda
including a [possible] global goal on food security and nutrition security, as well as goals
addressing the social determination of malnutrition.
5. We would also appreciate your vision on policies, programmes and
investment that might help translate such commitments into action.
14. We call on FAO and WHO to maintain the cooperation they offer to support governments as
appropriate, in the development and implementation of their national programmes and plans for
nutrition applied in the spirit of human rights.
15. We recommend the United Nations General Assembly to endorse the ICN2 Declaration and
to declare a Decade of Action on Nutrition. Will the latter really help? We have had other
Decades before… Can we think of something more binding?