IFBA Comments on Draft WHO guidelines on nutrition labelling policies

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NCD-Gap Objective

Comments on Key Priority Areas

1

To raise the priority accorded to the prevention and control of noncommunicable diseases in global, regional and national agendas and internationally agreed development goals, through strengthened international cooperation and advocacy.

Strengthen advocacy efforts: Continued and crosscollaborative efforts aimed at raising awareness and engaging all stakeholders will further the agenda of ensuring NCDs remain a priority for governments and the global health community.  The private sector is an essential partner in advocacy efforts dedicated to helping raise the profile of NCDs. IFBA and its members have collaborated with governments, health care professionals, NGOs and civil society around the world in community-based programmes and public education campaigns to promote nutrition literacy andhealthy, lifestyles and raise consumer awareness of healthy diets and physical activity as key components of NCD prevention. We welcome increased opportunities for meaningful participation in building coalitions and alliances to reduce the burden of NCDs.  

2

To strengthen national capacity, leadership, governance, multisectoral action and partnerships to accelerate country response for the prevention and control of noncommunicable diseases.

Accelerate multisectoral collaboration: Achieving the voluntary global targets for NCDs in all countries around the world will depend on a stronger commitment and concerted effort to develop and implement collaborations and public-private partnerships. Since IFBA’s founding in 2008, members have been working with WHO and Member States and sharing their knowledge and expertise to help advance positive public health outcomes.  We believe public-private partnerships represent not only the most cost-effective way to address global health challenges, but are, in fact, the only way to tackle complex global issues.  We know from experience that public-private partnerships work and good partnerships deliver positive change. For example, we have worked successfully with governments around the world to reduce salt, saturated fats and sugar. Our collaboration with WHO and RESOLVE to Save Lives to eliminate industrially produced trans fat from the global food supply has been recognized as a good model of public-private collaboration. We know much more can be achieved with a focus on increasing the opportunities for multistakeholder engagement and are committed to do our part.  We recommend WHO promote and support engagement with the private sector by providing

examples of successful collaborations to assist Member States in applying one of the overarching enabling actions of Objective 2: “Develop and implement a national multisectoral policy and plan for the prevention and control of NCDs through multi-stakeholder engagement.” 

Create an enabling environment for private sector engagement: The private sector is a key contributor to efforts to reduce NCDs. The 2018 UN Political Declaration of the High-level Meeting of the General Assembly on the Prevention and Control of NCDs reaffirmed the importance of engagement with the private sector in order to reach SDG 3.4 target on NCDs and IFBA and its members have implemented a set of actions in support of this goal. We strive to work collaboratively with governments and the public health community to do more.  In doing so, it is critical that Member States see industry as a willing and effective partner. We can do much to encourage and support national NCDs response, but we must find productive ways of working together. Achieving fruitful collaborations requires a systematic approach, an alignment of goals and objectives, clearly defined roles and responsibilities, an agreed set of actions and an enabling environment led by governments. Governments must take the lead in order to articulate and implement

comprehensive strategies for their national priorities and circumstances.  We recommend WHO provide guidance

to Member States, with reference to the WHO Framework of Engagement with Non-State Actors (FENSA) and with due regard to managing conflicts of interest, on how to foster and implement effective collaborations with the private sector. 

3

To reduce modifiable risk factors for noncommunicable diseases

and underlying social

determinants through creation of health-promoting environments.

Encourage adoption of nutrient- and food-based dietary guidelines:  The overarching/enabling actions of updated Appendix 3 on “Unhealthy diet” includes a call to Member States to develop and implement national nutrient- and food-based dietary guidelines. We fully support this recommendation. These guidelines, adopted by many countries worldwide, are wellestablished, science-based and rely on an assessment of the nutritious value of foods and beverages and the role they play in a healthy, balanced diet. We recommend WHO reiterate the recommendation to Member States to develop and implement nutrient- and food-based dietary guidelines and follow the WHO/FAO guidance, Sustainable healthy diets: guiding principles, 2019. 

Ensure all interventions are evidence-based:  We believe that all interventions and guidance tools recommended by WHO in the WHO Global NCD Action Plan 2013-2030 and updated Appendix 3 must be based on the latest science and robust evidence of likely effectiveness. All stakeholders need guidance that is strongly grounded in evidence and all interventions must be designed to achieve cost-effective, measured positive health outcomes. Recommendations based on limited or inconsistent evidence risk promoting policies that are ineffective and can lead to unintended consequences that undermine the objective.  We recommend WHO support further research to close the evidence gaps before making policy recommendations. IFBA and its members remain at the disposal of the WHO and Member States to provide evidence, insights and perspectives on issues relevant to our industry, as deemed appropriate. 

Expand research and policy options on marketing to children:  We all share a goal of ensuring that children are protected from harmful advertising and marketing practices. IFBA recognizes the need for responsible marketing practices, in particular, as regards children and abides by its Global Responsible Marketing Policy, which is aligned with WHO’s 2010 Set of recommendations on the marketing of foods and nonalcoholic beverages to children, and formally recognizes industry self-regulation as a policy option. IFBA’s approach has led to positive changes in the foods that are marketed to children which are, overall, now lower in fat, sugar and salt and provide more whole grains, nonfat dairy, fruits and vegetables, while many other foods are no longer marketed to children at all.  Member States with strong traditions of advertising self-regulation and voluntary industry initiatives have demonstrated substantial reductions in children’s exposure to ads for products high in fat, sugar and salt. Advertising selfregulation is cost-effective, measurable and adaptable for country-specific situations.  We recommend  WHO include self-regulation and co-regulation as among the policy options for consideration by Member States. 

We also recommend WHO support research to better understand the relationship between marketing and health-related outcomes in children, including how marketing can be leveraged for health promotion, as well as empirical research to better understand the impact of different policies to restrict food marketing to children. 

Increase advocacy efforts to support healthy diets:  Behaviour change is fundamental to consumers’ adoption of healthier diets.  However, successfully changing consumer behaviour is difficult to achieve as it requires a whole-of-society approach.  We believe public-private partnerships among Member States, civil society and business, beyond the food and beverage sector and including the media industry and tech companies are critical to developing comprehensive strategies aimed at improving nutrition education and literacy and implementing media campaigns aimed at raising awareness and motivating new behaviours. IFBA members have a wealth of expertise in nutrition science, market research, marketing and consumer insights.  We are committed to sharing our expertise and participating in collaborative efforts to help achieve this intervention.  

6

To monitor the trends and determinants of

noncommunicable diseases and evaluate progress in their prevention and control

Strengthen monitoring and evaluation. A coordinated and systematic process for monitoring and evaluating the impact of NCD interventions provides the foundation for advocacy, policy development and national, regional and global action. Currently, there is a lack of robust, measurable data and data collection processes and uniform tracking systems across countries.  Efforts should be directed at mobilizing the resources and capacity necessary to support a data-driven system to identify the most impactful interventions. In order to provide a complete landscape of NCD interventions, we recommend that reporting and evaluation mechanisms also extend to initiatives undertaken by the private sector.