Dear SP4 team,

thanks for sharing the draft document of the CoC with us. I think it is a good idea to have a sum-mary of guiding principles although there is already a lot of information out there which could be implemented. Experiences show that global guidelines are often too general to be implemented on a local or regional basis, thus I keep my fingers crossed that you will find an appropriate way to address the different scales within one CoC. Related to your questions, please let me raise your awareness to some points:

1a and b.) I miss the urgency of data collection in order to fulfil the tasks which are mentioned within the outline. In order to highlight the economic advantages related to FLW prevention to stakeholders or to calculate the basics for public awareness raising campaigns – you always need a good data base which fits specifically into the region.

1c) There should be a section about the interrelation among stakeholders of different levels to raise awareness on that topic, too. Fostering cooperation between levels of the food supply chain is very important to reduce FLW in total and not shifting FLW only from one level to another. At the end of the report, I miss the conclusions or overall recommendations – like a starting signal for the reader to go into practice right now.

2a.) It is good to read that not only SDG 12.3 is mentioned here but also the interconnected goals as this leads to a more holistic approach than other approaches. As often only legal definitions are used to define food waste, the overall goal of conservation of resources and reduction of environmental damage is completely lost.

I see the responsibility of the public sector also in setting framework for effective FLW data col-lection, provide resources to collect data and analyse them and to facilitate further activities based on already available outcomes.

2b.) From my point of view, it is very important to recognize the difference between FLW prevention at source and other activities which just try to make the best of already surplus food. There should be more emphasis on prevention at source although it will not be possible to reduce FLW to zero. I recommend not to rank composting and anaerobic digestion against each other – the most appropriate process for a specific situation/region depends e.g. on the characteristics of the FLW stream and the available infrastructure but I do not think that there is a proven outcome available that AD is always more preferable than composting, is it?

In sections 2.2.1 – 2.2.2 the issue of data availability and reliability should be mentioned. In sec-tion 2.2.1a primary production, pre-harvest losses should be included as they are – among other influencing reasons – partly a product of the current food system (including UTP) and contribute to ineffective use of resources. In order to see the whole picture, human mankind has to include pre-harvest losses to be able to rethink the system and adapt it to current conditions and sustainable practices. Examples of measures should also be given for 2.2.1c.

2c.) Policy coherence is very important but not mentioned as such in section 2.2.4 as only specific examples are mentioned in the draft. Having the whole system in mind is important in order not to miss external effects of business operations and societal activities, too.

Best wishes and all the best for further work,

Felicitas