New IBFAN Comments on WHO's Plan of Action on NCDs and Conflicts of interest

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IBFAN and NGO COMMENTS: (Deadlines - 10th March and 20th March)

1 Third round of informal consultations on the development of a WHO global action plan for the prevention and control of NCDs 2013-2020


WHO is inviting comments which should be sent to  by 10th March

Here is the lead to all the background papers:


CLICK HERE for IBFAN's response

CLICK HERE for a joint response from 20 international and UK based organisations 

CLICK HERE for a response from IASO

CLICK HERE for a short response from the Conflict of Interest Coalition

CLICK HERE for the response from WCRF

CLICK HERE for LINKS to  material you may find useful 


IBFAN's main concerns are:
  • The protection of breastfeeding and optimal complementary feeding needs to be included in the set of actions:
  • There should be clarity on Conflicts of Interest
  • The section of Codex should be expanded
  • The Social Movement is unfeasible and risky



Informal  meetings are taking place to discuss this Plan: NGOs on the 6th March, Private Sector on Thursday 7th March and Member State (MS)  on Monday and Tuesday (11 -12th March) . 


We welcome this important  draft Plan. In it you will see that there are many good things, not least several mentions of breastfeeding (Paras 11and 36a) and 16 references to Conflicts of Interest (5 more than in the previous Drafts). This sounds a lot - but not all are watertight enough for such a tricky issue,  especially when there is so much talk of partnerships. The proposal for a Global Coordinating Mechanism - which includes a "Social Movement on NCDs) -  really needs some work and a specific inclusion of COI safeguards.   

The joint response from 20 international and UK based organisation includes many excellent suggestions for possible amendments such as: 


Para 22  Actions for the Secretariat: 22 c) Policy advise and dialogue: While we welcome the inclusion of the action for WHO “to provide guidance to strengthen governance, including management of potential conflict of interest in  engaging the private sector in collaborative partnerships for implementation of the action plan.” We urge that i) the scope is broadened from a focus on collaborative partnerships to include policy making and implementation ii) WHO develops decision support tools and guidance on governance and managing conflicts of interest, and iii) WHO collates and shares examples of good practice in governance. 


The WCRF response includes many other good suggestions. For example on Page 4 -a proposed amendment to Para 36 a:

 Existing text: Promote, protect and support breastfeeding, including exclusive breastfeeding for the first six months of life, continued breastfeeding until two years old and beyond and adequate andtimely complementary feeding,  WCRF ADDITION:   and, in this regard, strengthen the implementation of the international code of marketing of breast milk substitutes and subsequent relevant World HealthAssembly resolutions”.


The IASO Response too contains good suggestions:  

4.1. Paragraph 8. This paragraph lists some of the key background documents. It would be valuable to include here the Global Strategy on Infant and Young Child Feeding (WHO 2003) in particular because it makes reference to the need to protect and promote the use of nutritious locally produced indigenous foods, which are especially valuable for lower income families without the means or facilities to make use of commercial products. Protecting breastfeeding and promoting appropriate complementary foods reduces the risk of child obesity and the NCDs linked to early malnutrition, and the GAP draft refers in passing to the GSIYCF later in the document (e.g. as part of the life course approach).

4.4. Paragraph 36. It would be helpful to insert three further subparagraphs. “(j) develop strategies to support food and nutrition security through the encouragement of local food production of fresh and perishable foods, in line with recommendations from the GSIYCF, the UN Food and Agriculture Organization and other UN agencies and international organizations.”




2 The deadline for comments the next important consulation is 20th March:

 Public web consultation on WHO’s engagement with non-State actors: 

Here is the WHO text:   In response to the request of the Executive Board of WHO (Decision EB132(11)) to conduct public web-based consultations on the draft principles and policies of engagement with non-State actors, the WHO Secretariat welcomes interested parties to provide comments on the questions and issues related to WHO’s engagement with non-State actors (as outlined at the link below).   The issues in relation to which comments are invited, and the comments submission form, can be found at:

 Inputs received from this consultation will inform the further development of principles, policies and procedures related to WHO’s engagement with non-State actors, including nongovernmental organizations and private commercial entities.  All comments submitted are subject to review by the Secretariat prior to the Secretariat posting them on the WHO website. WHO reserves the right to summarize and/or edit any submission in consultation with the submitting party.





CLICK HERE for an excellent synthesis  in the Lancet Series on NCDs entitled:

 Profits and pandemics: prevention of harmful effects of tobacco, alcohol, and ultra-processed food and drink industries.


"We assess the effectiveness of self-regulation, public—private partnerships, and public regulation models of interaction with these industries and conclude that unhealthy commodity industries should have no role in the formation of national or international NCD policy. Despite the common reliance on industry self-regulation and public—private partnerships, there is no evidence of their effectiveness or safety. Public regulation and market intervention are the only evidence-based mechanisms to prevent harm caused by the unhealthy commodity industries."


The EU Commission allowed a 40 minute discussion on this at the European Platform on Diet and Physical Activity on 28th February.  Along with the other public interest NGOs present, we explained our concerns about how the Platform operates and the risks of using it as a model for public health policy. The food industry claimed  that the Lancet article was not necessarily evidence based or peer reviewed.  They also claimed that  their  voluntary commitments on labelling have triggered the regulatory process, becoming part of  legislation and that if we can find ways to work together  the Platform can become part of a driver  towards tackling obesity and disease.  It seem they see us as being on a "journey together" - something like the current Coca Cola adverts.....


CLICK HERE for  an Open letter to new UN agency chief: No more deals with Nestlé please published in World Public Health Nutrition:


CLICK HERE for a Briefing from Corporate Accountability International:  Standards of Political Conduct for Political for corporations


CLICK HERE for a film about the distribution of money in the US: 


CLICK HERE for a 13minute  film  by AIMi (Indonesia Breastfeeding Mothers Association) the IBFAN group in Indonesia with support from  Save the Children.


CLICK HERE:   for  the Save the Children report:  Superfood for Babies  How overcoming barriers to breastfeeding will save children's lives  and the petition about Nestlé and Danone


CLICK HERE for the  Save the Children films :


CLICK HERE for  a 6 minute student  film about junk food


CLICK HERE for the GAPA Statement of Concern about alcohol policy  

Send your endorsements to Katherine Brown at  or to   




Final response to the WHO Global Action plan on NCDs_080313.pdf653.56 KB
IASO_Response_to_WHO_NCD_draft_Global_Action_plan.pdf450.71 KB
COIC NCDsFriday.pdf153.07 KB
WCRF Int response to WHO revised FIRST draft of GAP, Draft March 8 2013.pdf552.78 KB
IBFAN NCD6.pdf643.52 KB