A/HRC/43/44/Add.6 many positive sides, some of the criteria greatly reduce the ability to benefit from this social welfare tool. During her visit, the Special Rapporteur met with some Italians currently in a state of poverty, who emotionally recounted through personal experiences some of the limitations of the minimum income system. Comments: We’d appreciate deleting this sentence. It is, in fact a general comment based on the experience of a single person that has not been contextualised nor compared with the law provisions. The evidence is, updated data, that the RDC measure has reached in less than one year implementation more than 936 thousand households (a total of 2,403 thousand individuals). This number does not include the beneficiary household with over 65 years old member (the benefit in their case is called Pensione di cittadinanza) and the enrolment of thousands of social workers fully dedicated to the implementation of anti-poverty measures. As the limits are not clear please substitute with: 30. Regardless of the limitations of the measure Although the measure could be further improved and made more effective, the system is a great opportunity to access a support system that, although temporary in the time needed, leads to the end of the reliance on subsidies by providing proper social services job opportunities and initiating a programme for self-sufficiency and economic independence. B. Food aid and redistribution programmes 33. Italy is the second country in the European Union to pass a national law to regulate the loss and waste of more than 100kg of food per person per year. 4 The Legge Gadda (166/2016) facilitates the collection and donation of food surplus by simplifying donations to non-profit entities, incentivizing innovation and requiring local administrations to provide fiscal incentives. In addition, it promotes reuse and recycling and has a dedicated fund for research, information and awareness-raising activities both of the consumers, private actors and the institutions. Public administrations, food actors and data highlight that the law has increased the amount of food available for redistribution.5 34. However, redistribution cannot be considered as a valid long-term strategy against food poverty nor an approach that is compatible with the right to food as an entitlement, a legal obligation of the duty to act in a way that reduces unsustainable practices and tackles both poverty and inequality.6 Although an important and effective quick fix to food poverty, the Legge Gadda should be seen as a temporary solution and implementation of the right to food and the fight against food poverty should not be confused. Comments: Limiting the scope of Law 166/2016 (so-called “Legge Gadda”) to mere redistribution of food and qualifying it as a “quick fix to fight poverty” is factually incorrect. It denotes an approximate and rudimentary knowledge of the regulatory and multi-stakeholders situation in Italy in this area. In fact, the Italian legislation provides an excellent framework for permanent solutions in the field of recovery facilitation, tax incentives for the prevention of food waste, correct information to the consumer and wide, permanent consultation of all stakeholders, through the whole food chain and involving public Institutions, private business and charitable bodies. Therefore, we ask you to delete or substantially revise the sentence “…the Legge Gadda should be seen as a temporary solution and implementation of the right to food and the fight against food poverty should not be confused…”. 4 5 6 4 REDUCE Project (2019). Latour G. (2019) Supermarket e ristorante: cresce la solidarieta’ anti spreco, Il Sole 24 Ore, 8 September. FAO (2018) Food loss and waste and the right to adequate food: making the connection, Rome, 48 pp.