HLPE-Report V0 Draft Report

Comments from Arla Foods, November 2016

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).

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 promotebetter 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 believeanother 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:

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?

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.

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?

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 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.

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

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,

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?

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.

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?

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 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 9row 46 –page 10row 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 complexityof 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.

Page 100, row10-11. Traceability is a requirement for animal foods.

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?

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?

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.

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

There is an unbalance in how the environmental challenges of different production systems are described. The environmental challenges with animal food production systems are mentionedthroughout 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 be assessedinclude pesticide use (fruits and vegetables) and biodiversity loss from land use change (palm oil),

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