1. With respect to the proposed outline and structure of the CoC:
a. Does the proposed outline of the CoC address the issues in an exhaustive and comprehensive way?
b. Are there any particular issues and aspects of importance that you think are not be addressed in the proposed structure?
c. Are there any disadvantages or gaps you see in the current structure?
Feedback recommends that the structure needs to recognize that different sectors of the supply chain affect each other – for instance, as noted below, retailer policy can have significant effects on both their suppliers and their customers’ food waste levels. Therefore, Feedback suggests that each section in 2.2.1 includes recommended measures not just that States and businesses in the sector can take, but that actors in other stages of the supply chain can take which affect that sector.
2. With respect to the content of the different sections of the CoC:
a. What are the general guiding principles that you think are important for section 2.1?
One of the most important guiding principles should be the recommended scope of SDG 12.3. The Champions 12.3 document Guidance on Interpreting Sustainable Development Goal 12.3 (Hanson, 2017) includes the vital recommendation that “one should apply the “halve per capita” in practice to food losses [i.e. pre-retail food waste], as well, not just to food waste” – and that this should cover “from the point that crops and livestock are ready for harvest or slaughter through to the point that they are ready to be ingested by people”. Thus, nation states should set targets to reduce food waste by 50% from farm to fork by 2030, including edible food left unharvested in the fields. Food left unharvested in the fields is currently excluded from compulsory measurement under the Food Loss Index, despite studies (including the FAO’s) revealing that in both richer and poorer countries some of the highest levels of waste occur at this stage. To facilitate its measurement, the FAO should urgently develop a recommended methodology for nation states to measure this food waste, as a means of creating baselines to enable targeted reduction of 50% by 2030.
Hanson (2017) also makes the vital recommendation that food is still counted as waste towards SDG 12.3 if it is used below the point of animal feed on the food waste hierarchy – the FAO should make it clear in their recommendations that sending food to AD, compost or below on the hierarchy does not count as reduced towards SDG 12.3. Ideally, Feedback would recommend that countries are even more ambitious than this for food that is edible to humans – only counting this as reduced if it is prevented or sent to human consumption. However, efforts to reduce food waste by 50% by 2030 should be complemented by efforts to move food waste up the food up the food waste hierarchy.
Feedback recommends that the distinction between food “loss” and “waste” is removed, in favour of the term “waste” being used regardless of which stage of the supply chain food is wasted at. The loss vs. waste distinction implies that developing countries experience primarily food loss in their supply chains as a result of poor technical infrastructure and developed countries primarily experience food waste at retail and consumer level because of wasteful consumer habits. However, retail food waste is generally small, and pre-retail food waste e.g. in agriculture is usually high – in both the Global North and South, as is revealed by the FAO’s own data (FAO, 2011). Moreover, “food loss” implies a technical cause unrelated to human agency. However, Feedback has found evidence that food is often
waste in both the Global North and South due to factors related to unequal power balances in supply chains – particularly within rich countries where the retail sector is concentrated compared with their suppliers, or where farmers in the Global South export to the Global North. Factors such as cosmetic outgrading, overproduction as a result of power relations, and Unfair Trading Practices like last minute order cancellations, often result in large levels of food waste in suppliers. See, for instance (Colbert and Stuart, 2015; Colbert, 2017; Bowman, 2018).
b. What are the specific guiding principles and practices do you think are important for sections 2.2.1(a, b& c), 2.2.2 and 2.2.3?
Section 2.2.1(a)
It is vital to recognize that retailer policy (and the policies of intermediaries) often has a considerable impact in causing food waste in their suppliers, and therefore to provide suggestions for improvements in retailer policy which can reduce food waste between primary production and retail
Examples of measure States could take to minimize the effects retailers have on their suppliers’ food waste are:
· Introduce robust Unfair Trading Practices legislation, to protect suppliers from practices like last minute order cancellations or tightening of specifications which lead to waste. A regulator should be established for this which has adequate powers of enforcement.
· Set up some form of cross-supply chain mediation to explore problems and find solutions.
Examples of measures retails could take to reduce their suppliers’ food waste are:
· Recognise their shared responsibility for the food waste in their suppliers.
· Relax cosmetic standards on core product lines to ensure that no/minimal edible food is rejected on the basis of cosmetic qualities like size, colour or shape. Actively promote diverse produce sizes to customers to reduce fussiness. Do change cosmetic standards at the last minute as an excuse to cancel or reduce an order.
· Do not punish cases of undersupply in suppliers where this has stemmed from natural variation in the weather – as this leads suppliers to routinely overplant to avoid being fined or delisted, leading to gluts and price crashes in good years and much produce being ploughed back in.
· Make efforts to flexibly market gluts of produce when weather leads to unexpected gluts.
· Minimize their practice of Unfair Trading Practices, in compliance with and cooperation with the State regulator
Section 2.2.1(b)
It is vital to recognize that retailer policy often has a considerable impact in causing food waste in their suppliers, and therefore to provide suggestions for improvements in retailer policy which can reduce food waste between primary production and retail
Examples of measures retails could take to reduce their suppliers’ food waste are:
· Recognise their shared responsibility for the food waste in their customers, since their policies usually have a large effect on these.
· Extend Best Before Dates where it is possible to do so within a safe level, to prevent edible food being discarded by consumers while it is still safe to eat.
· Sell produce loose where selling it in bags is liable to cause consumers to overbuy and waste the excess
· Sell perishable foods which are likely to be eaten across multiple meals such as salads in resealable packaging where appropriate.
Section 2.2.1(c)
· Food waste prevention should always be prioritized over charitable food waste redistribution, so the two should be listed in different categories.
· Voluntary food redistribution is ultimately a superficial solution to both food waste and food poverty, and ultimately the aim should be to design both out of the system in the first place. As many food poverty academics have observed, some problematic aspects of voluntary food redistribution which have been identified include them being under-resourced, socially stigmatising, patchy in coverage, and vulnerable to fluctuating food stocks according to the availability of food surplus. Most importantly, food redistribution charities do not have the power to guarantee universal access to affordable nutritious food – as embodied in the Human Right to Food enshrined in the International Covenant on Economic, Social and Cultural Rights – and is sometimes used by governments to plug gaps in welfare and employment systems, potentially easing pressure on government to guarantee safety nets.
Section 2.2.2
· There should be a very clear distinction drawn between sending food to animal feed, and sending it to AD and compost. Sending food to AD or compost should not be counted as reduced towards SDG 12.3 under any circumstances, since it is too far down the food waste hierarchy. Sending food waste to animal feed is generally considered as no longer food waste under SDG 12.3 – however, countries should be encouraged to prevent food waste as a priority or send food to human consumption if it is edible. Animal feed and AD/compost should therefore be split into two clearly distinct categories.
Examples of measures to be taken by States include:
· Scale up the amount of unavoidable surplus food which is sent to animal feed. Ensure that it is legal to feed all safely-treated surplus food containing meat to omnivorous non-ruminants like pigs and chickens, once it has been subjected to a safe heat-treatment complemented with acidification in rigorously regulated off-farm processing facilities. For more info, see (Luyckx et al., 2019)
c. Taking into account the need to foster FLW policy coherence, which cross-cutting issues are relevant to the FLW topic, as addressed in section 2.2.4?
National governments:
· Adopt binding statutory targets to reduce food waste by 50% from farm to fork by 2030 (not just to reduce consumer and retail waste by 50% and more vaguely reduce food “loss”). Binding measures should be taken in preference to voluntary agreements.
· Integrate food waste reduction efforts into Intended Nationally Determined Contributions (INDCs) and emissions reduction plans.
· Measure food waste annually at all stages of the supply chain, from the point food is mature enough to harvest through to consumer level – to create baselines for targeted reduction.
· Introduce legal requirement for businesses over a certain size to measure and report their company’s food waste figures, on an individual company basis
· Adequately fund the above measures.
3. Can you provide specific examples of policies, interventions, initiatives, alliances and institutional arrangements which should be considered as best practices in FLW prevention, reduction, food recovery, repurposing and recycling?
· EU Directive 2019/633 introduced an obligation on EU member states to ban 16 Unfair Trading Practices, and to set up regulators to ensure this code is followed. It protects all suppliers in smaller size categories than their buyers, and protects both suppliers within the EU and suppliers exporting to the EU. Other States should move to introduce such legislation, and ensure that the regulatory authority is given sufficient power and funding to effectively enforce the law.
· WRAP’s Food Waste Roadmap provides a good example of ambitious interpretation of SDG 12.3 – targeting a 50% reduction of food waste from farm to fork by 2030. Signatories to the voluntary commitment also individually report their food waste, rather than at an aggregate sectoral level, providing a greater level of transparency, and to reduce their own food waste by 50% by 2030. However, WRAP do not expect 100% participation in this agreement until 2026. Strengthening the voluntary agreement by upgrading it to a regulatory requirement to ensure 100% participation in measurement, reporting and targets would significantly speed progress.
· Japan produces “eco-feed” for pigs by taking surplus food and subjecting it to a safe treatment process (heat-treatment combined with acidification), in specialist well-regulated treatment facilities. EU REFRESH outlines how, with some regulatory strengthening, this system could be adapted to Europe – and to other countries (Luyckx et al., 2019).
· Retailers in the UK have launched a variety of wonky fruit and vegetable ranges. For instance, Tesco report that since launching their “Perfectly Imperfect” line, the proportion of their producer’s apples they can take rose from 87% to 97% (Gilbert, 2016). Morrisons launched a wonky fruit and veg range (Pullman, 2015) – a move which was immensely popular and led to increased sales (Butler, 2018). However, ideally supermarkets should use wonky fruit and vegetable ranges to test their customer’s levels of acceptance of cosmetic variety, with a view to eventually relaxing cosmetic standards on core product ranges.
4. How could this Code of Conduct on FLW prevention and reduction be most useful for different stakeholders, especially at national and regional levels?
Feedback recommend that the Code of Conduct on FLW prevention and reduction be used primarily as a means of encouraging States around the world to adopt ambitious food waste reduction legislation and regulation, to ensure they reduce food waste by 50% from farm to fork by 2030, in line with SDG 12.3. Clearly recommending the scope of SDG 12.3 should also be a priority.
Luyckx, K., Bowman, M., Broeze, J., Taillard, D. and Woroniecka, K. (2019) Technical guidelines animal feed: The safety, environmental and economic aspects of feeding treated surplus food to omnivorous livestock. REFRESH Deliverable 6.7. Available at: https://eu-refresh.org/results.
Ms. Jessica Sinclair Taylor
1. With respect to the proposed outline and structure of the CoC:
a. Does the proposed outline of the CoC address the issues in an exhaustive and comprehensive way?
b. Are there any particular issues and aspects of importance that you think are not be addressed in the proposed structure?
c. Are there any disadvantages or gaps you see in the current structure?
Feedback recommends that the structure needs to recognize that different sectors of the supply chain affect each other – for instance, as noted below, retailer policy can have significant effects on both their suppliers and their customers’ food waste levels. Therefore, Feedback suggests that each section in 2.2.1 includes recommended measures not just that States and businesses in the sector can take, but that actors in other stages of the supply chain can take which affect that sector.
2. With respect to the content of the different sections of the CoC:
a. What are the general guiding principles that you think are important for section 2.1?
One of the most important guiding principles should be the recommended scope of SDG 12.3. The Champions 12.3 document Guidance on Interpreting Sustainable Development Goal 12.3 (Hanson, 2017) includes the vital recommendation that “one should apply the “halve per capita” in practice to food losses [i.e. pre-retail food waste], as well, not just to food waste” – and that this should cover “from the point that crops and livestock are ready for harvest or slaughter through to the point that they are ready to be ingested by people”. Thus, nation states should set targets to reduce food waste by 50% from farm to fork by 2030, including edible food left unharvested in the fields. Food left unharvested in the fields is currently excluded from compulsory measurement under the Food Loss Index, despite studies (including the FAO’s) revealing that in both richer and poorer countries some of the highest levels of waste occur at this stage. To facilitate its measurement, the FAO should urgently develop a recommended methodology for nation states to measure this food waste, as a means of creating baselines to enable targeted reduction of 50% by 2030.
Hanson (2017) also makes the vital recommendation that food is still counted as waste towards SDG 12.3 if it is used below the point of animal feed on the food waste hierarchy – the FAO should make it clear in their recommendations that sending food to AD, compost or below on the hierarchy does not count as reduced towards SDG 12.3. Ideally, Feedback would recommend that countries are even more ambitious than this for food that is edible to humans – only counting this as reduced if it is prevented or sent to human consumption. However, efforts to reduce food waste by 50% by 2030 should be complemented by efforts to move food waste up the food up the food waste hierarchy.
Feedback recommends that the distinction between food “loss” and “waste” is removed, in favour of the term “waste” being used regardless of which stage of the supply chain food is wasted at. The loss vs. waste distinction implies that developing countries experience primarily food loss in their supply chains as a result of poor technical infrastructure and developed countries primarily experience food waste at retail and consumer level because of wasteful consumer habits. However, retail food waste is generally small, and pre-retail food waste e.g. in agriculture is usually high – in both the Global North and South, as is revealed by the FAO’s own data (FAO, 2011). Moreover, “food loss” implies a technical cause unrelated to human agency. However, Feedback has found evidence that food is often
waste in both the Global North and South due to factors related to unequal power balances in supply chains – particularly within rich countries where the retail sector is concentrated compared with their suppliers, or where farmers in the Global South export to the Global North. Factors such as cosmetic outgrading, overproduction as a result of power relations, and Unfair Trading Practices like last minute order cancellations, often result in large levels of food waste in suppliers. See, for instance (Colbert and Stuart, 2015; Colbert, 2017; Bowman, 2018).
b. What are the specific guiding principles and practices do you think are important for sections 2.2.1(a, b& c), 2.2.2 and 2.2.3?
Section 2.2.1(a)
It is vital to recognize that retailer policy (and the policies of intermediaries) often has a considerable impact in causing food waste in their suppliers, and therefore to provide suggestions for improvements in retailer policy which can reduce food waste between primary production and retail
Examples of measure States could take to minimize the effects retailers have on their suppliers’ food waste are:
· Introduce robust Unfair Trading Practices legislation, to protect suppliers from practices like last minute order cancellations or tightening of specifications which lead to waste. A regulator should be established for this which has adequate powers of enforcement.
· Set up some form of cross-supply chain mediation to explore problems and find solutions.
Examples of measures retails could take to reduce their suppliers’ food waste are:
· Recognise their shared responsibility for the food waste in their suppliers.
· Relax cosmetic standards on core product lines to ensure that no/minimal edible food is rejected on the basis of cosmetic qualities like size, colour or shape. Actively promote diverse produce sizes to customers to reduce fussiness. Do change cosmetic standards at the last minute as an excuse to cancel or reduce an order.
· Do not punish cases of undersupply in suppliers where this has stemmed from natural variation in the weather – as this leads suppliers to routinely overplant to avoid being fined or delisted, leading to gluts and price crashes in good years and much produce being ploughed back in.
· Make efforts to flexibly market gluts of produce when weather leads to unexpected gluts.
· Minimize their practice of Unfair Trading Practices, in compliance with and cooperation with the State regulator
Section 2.2.1(b)
It is vital to recognize that retailer policy often has a considerable impact in causing food waste in their suppliers, and therefore to provide suggestions for improvements in retailer policy which can reduce food waste between primary production and retail
Examples of measures retails could take to reduce their suppliers’ food waste are:
· Recognise their shared responsibility for the food waste in their customers, since their policies usually have a large effect on these.
· Extend Best Before Dates where it is possible to do so within a safe level, to prevent edible food being discarded by consumers while it is still safe to eat.
· Sell produce loose where selling it in bags is liable to cause consumers to overbuy and waste the excess
· Sell perishable foods which are likely to be eaten across multiple meals such as salads in resealable packaging where appropriate.
Section 2.2.1(c)
· Food waste prevention should always be prioritized over charitable food waste redistribution, so the two should be listed in different categories.
· Voluntary food redistribution is ultimately a superficial solution to both food waste and food poverty, and ultimately the aim should be to design both out of the system in the first place. As many food poverty academics have observed, some problematic aspects of voluntary food redistribution which have been identified include them being under-resourced, socially stigmatising, patchy in coverage, and vulnerable to fluctuating food stocks according to the availability of food surplus. Most importantly, food redistribution charities do not have the power to guarantee universal access to affordable nutritious food – as embodied in the Human Right to Food enshrined in the International Covenant on Economic, Social and Cultural Rights – and is sometimes used by governments to plug gaps in welfare and employment systems, potentially easing pressure on government to guarantee safety nets.
Section 2.2.2
· There should be a very clear distinction drawn between sending food to animal feed, and sending it to AD and compost. Sending food to AD or compost should not be counted as reduced towards SDG 12.3 under any circumstances, since it is too far down the food waste hierarchy. Sending food waste to animal feed is generally considered as no longer food waste under SDG 12.3 – however, countries should be encouraged to prevent food waste as a priority or send food to human consumption if it is edible. Animal feed and AD/compost should therefore be split into two clearly distinct categories.
Examples of measures to be taken by States include:
· Scale up the amount of unavoidable surplus food which is sent to animal feed. Ensure that it is legal to feed all safely-treated surplus food containing meat to omnivorous non-ruminants like pigs and chickens, once it has been subjected to a safe heat-treatment complemented with acidification in rigorously regulated off-farm processing facilities. For more info, see (Luyckx et al., 2019)
c. Taking into account the need to foster FLW policy coherence, which cross-cutting issues are relevant to the FLW topic, as addressed in section 2.2.4?
National governments:
· Adopt binding statutory targets to reduce food waste by 50% from farm to fork by 2030 (not just to reduce consumer and retail waste by 50% and more vaguely reduce food “loss”). Binding measures should be taken in preference to voluntary agreements.
· Integrate food waste reduction efforts into Intended Nationally Determined Contributions (INDCs) and emissions reduction plans.
· Measure food waste annually at all stages of the supply chain, from the point food is mature enough to harvest through to consumer level – to create baselines for targeted reduction.
· Introduce legal requirement for businesses over a certain size to measure and report their company’s food waste figures, on an individual company basis
· Adequately fund the above measures.
3. Can you provide specific examples of policies, interventions, initiatives, alliances and institutional arrangements which should be considered as best practices in FLW prevention, reduction, food recovery, repurposing and recycling?
· EU Directive 2019/633 introduced an obligation on EU member states to ban 16 Unfair Trading Practices, and to set up regulators to ensure this code is followed. It protects all suppliers in smaller size categories than their buyers, and protects both suppliers within the EU and suppliers exporting to the EU. Other States should move to introduce such legislation, and ensure that the regulatory authority is given sufficient power and funding to effectively enforce the law.
· WRAP’s Food Waste Roadmap provides a good example of ambitious interpretation of SDG 12.3 – targeting a 50% reduction of food waste from farm to fork by 2030. Signatories to the voluntary commitment also individually report their food waste, rather than at an aggregate sectoral level, providing a greater level of transparency, and to reduce their own food waste by 50% by 2030. However, WRAP do not expect 100% participation in this agreement until 2026. Strengthening the voluntary agreement by upgrading it to a regulatory requirement to ensure 100% participation in measurement, reporting and targets would significantly speed progress.
· Japan produces “eco-feed” for pigs by taking surplus food and subjecting it to a safe treatment process (heat-treatment combined with acidification), in specialist well-regulated treatment facilities. EU REFRESH outlines how, with some regulatory strengthening, this system could be adapted to Europe – and to other countries (Luyckx et al., 2019).
· Retailers in the UK have launched a variety of wonky fruit and vegetable ranges. For instance, Tesco report that since launching their “Perfectly Imperfect” line, the proportion of their producer’s apples they can take rose from 87% to 97% (Gilbert, 2016). Morrisons launched a wonky fruit and veg range (Pullman, 2015) – a move which was immensely popular and led to increased sales (Butler, 2018). However, ideally supermarkets should use wonky fruit and vegetable ranges to test their customer’s levels of acceptance of cosmetic variety, with a view to eventually relaxing cosmetic standards on core product ranges.
4. How could this Code of Conduct on FLW prevention and reduction be most useful for different stakeholders, especially at national and regional levels?
Feedback recommend that the Code of Conduct on FLW prevention and reduction be used primarily as a means of encouraging States around the world to adopt ambitious food waste reduction legislation and regulation, to ensure they reduce food waste by 50% from farm to fork by 2030, in line with SDG 12.3. Clearly recommending the scope of SDG 12.3 should also be a priority.
Bibliography:
Bowman, M. (2018) Farmers Talk Food Waste. Feedback. Available at: https://feedbackglobal.org/wp/wp-content/uploads/2018/02/Farm_waste_rep….
Butler, S. (2018) ‘“Wonky” fruit and veg sales put Morrisons on straight path to growth’, The Guardian, 26 June. Available at: https://www.theguardian.com/business/2018/jun/26/wonky-fruit-veg-sales-… (Accessed: 9 July 2019).
Colbert, E. (2017) Causes of food waste in international supply chains. Feedback. Available at: https://feedbackglobal.org/wp-content/uploads/2017/05/Causes-of-food-wa….
Colbert, E. and Stuart, T. (2015) Food Waste in Kenya - Uncovering Food Waste in the Horticultural Export Supply Chain, p. 28. Available at: https://feedbackglobal.org/wp-content/uploads/2017/02/Causes-of-food-wa….
FAO (2011) Global food losses and food waste: extent, causes and prevention. Rome: FAO. Available at: http://www.fao.org/3/a-i2697e.pdf.
Gilbert, H. (2016) Tesco adds apples & strawberries to Perfectly Imperfect range, The Grocer. Available at: https://www.thegrocer.co.uk/tesco-adds-apples-and-strawberries-to-perfe… (Accessed: 9 July 2019).
Hanson, C. (2017) Guidance on Interpreting Sustainable Development Goal Target 12.3. Champions 12.3. Available at: https://champs123blog.files.wordpress.com/2017/10/champions-12-3-guidan….
Luyckx, K., Bowman, M., Broeze, J., Taillard, D. and Woroniecka, K. (2019) Technical guidelines animal feed: The safety, environmental and economic aspects of feeding treated surplus food to omnivorous livestock. REFRESH Deliverable 6.7. Available at: https://eu-refresh.org/results.
Pullman, N. (2015) Morrisons to launch permanent wonky veg range, Fresh Produce Journal. Available at: http://www.fruitnet.com/fpj/article/167039/morrisons-to-launch-permanen… (Accessed: 9 July 2019).