Global Feedback Ltd
Feedback
Feedback is an environmental campaigning charity working for food that is good for the planet and its people.
ID: 074553928144-47
Lobbying Activity
Response to Food waste reduction targets
26 Oct 2021
We welcome the Commission’s Roadmap and the opportunity to submit our response. As a member of the EU’s Platform FLW, we strongly recommend that the Commission models a 50% reduction of FLW (food loss and waste) for all EU member states under Step 2 Option 3 (rather than 40-50% reduction) and puts forward a legislative proposal for all member states to meet a 50% reduction of FLW from farm to fork by 2030, ideally by Q4 of 2022. The EU and member states are already committed to meeting SDG 12.3 to reduce food waste by 50% by 2030; to be consistent with fulfilling this commitment, the Commission should create a legislative framework to ensure members states meet this target. Lower targets proposed in options 1 and 2 are inconsistent with the EU meeting its international obligations to SDG 12.3, and therefore should not be considered for a legislative proposal. If options 1 or 2 are modelled in the impact assessment, we recommend that this be purely in the capacity of a “business as usual” baseline for comparative purposes, not for consideration as EU targets. For member states who have pre-2020 baseline data available, we recommend it be admissible for countries to achieve 50% reduction from a 2015 or later baseline, to reflect existing progress. Achieving a 50% reduction in FLW by 2030 will also help the EU meet its commitments under the European Climate Law, the Global Methane Pledge, the Circular Economy Package, and European Green Deal.
We anticipate that modelling may reveal that voluntary commitments for businesses and consumer education will not deliver reductions at sufficient speed to deliver SDG 12.3. We therefore strongly recommend that it is vital to include in modelling the potential effects of regulation to deliver more ambitious faster-paced FLW reduction – including types of regulation which have not yet been introduced in EU member states – such as mandatory FLW public reporting and reduction targets for food businesses over a certain size, strengthened Unfair Trading Practices regulation, and increased taxes and bans on sending FLW to incineration and landfill. E.g. the UK plans to introduce mandatory FLW reporting for larger businesses.
We strongly recommend the Commission should adopt Option S1 to provide equal treatment for all stages of the supply chain and comprehensive coverage rather than limiting scope to cover retail and consumer sectors only. This is in accordance with guidance from Champions 12.3 that SDG 12.3 should be interpreted as a target to reduce FLW by 50% across the entire supply chain from the point food is ready to harvest or slaughter. EU FUSIONS data shows that over three times more food is wasted in the EU processing sector, and two times more in food service, than in the retail sector. We recommend mandatory MS FLW reporting be extended to include food left unharvested and ploughed back in, and livestock mortalities on-farm, and that MS report by 2024 as baseline data for inclusion in mandatory reduction targets. This is to reflect vital new data: WWF’s recent ‘Driven to Waste’ report is the most comprehensive review of data on primary production FLW to date - it finds that about 150 million tonnes of food is wasted on European farms (14.6% of total production), based on 175 of the most up to date European studies (Tech Report Fig 3 rb.gy/xxz1qd). FUSIONS estimates that EU countries waste 9 million tonnes at primary production were based on only 6 studies pre-2016, are outdated and need urgent updating.
These recommendations have wide support. In 2017, 67 European organisations called for an EU FLW “reduction target of 50% by 2030 to be specified as farm to fork […] binding at EU member state level”. In 2020, many organisations reiterated this policy ask.
We recommend Options E2 and T1/3 hybrid: for all MS to have a legally binding target to reduce their FLW to a uniform kg per capita food waste, set at a level to ensure EU-wide 50% FLW reduction by 2030. Option E1 is also acceptable.
Read full response6 Apr 2021
Feedback welcomes this decision as the first step to ensuring non-ruminants can play a vital role in sustainability through using unavoidable food waste and by-products as feed. However, the authorisation in its current form is limited in its environmental impact and carries with it significant risks of creating food-feed competition – Feedback recommends a number of other policies in order to mitigate these risks and unlock more significant environmental benefits.
A recent Life Cycle Assessment found that when insects are reared on food or feed – that is diverting food that could be fed to humans or directly to livestock such as pigs and chickens – they will “most likely increase the environmental impact” compared with conventional feed sources. Feeding human-edible food to BSF larvae instead of humans causes particularly high environmental impacts – resulting in 17 times higher global warming potential and nearly 20 times higher land use per gram of protein compared with soybean meal. Feedback thus recommends that the EU prohibits feeding insects purpose-grown feedstocks, or by-product and waste streams that are suitable for upcycling into the food system more directly via pigs or chickens. Feedback recommend that the EU legislate for the safe use in insect feed of unavoidable household food waste, manure and other organic waste streams not suitable for processing into pig or poultry feed.
There is a considerable risk that the proposed authorisation will increase food-feed competition, by potentially diverting human-edible food to animal feed. To mitigate these risks, we recommend that the EU regulate the rendering industry to ensure greater transparency – requiring them to publish data such as the volume of different types of meat rendered, its quality, how much is currently wasted, how much is exported for human consumption overseas, and how much human-edible food waste goes to sub-optimal destinations such as animal feed. Publishing of this data will help the EU design policies to ensure that human-edible food goes to humans where possible, and only true by-products and human-inedible food goes to animal feed.
Feedback recommends that the EU should implement legislation limiting the use of human-edible animal proteins for use as animal feed, whilst also promoting policies to incentivise greater nose-to-tail eating, and transitions to less and better meat. As part of this, Feedback recommends that the EU should implement binding targets for member states to halve food waste from farm to fork by 2030, and implement targets to halve consumption and production of meat, dairy and farmed fish.
Maintaining the ban on intra-species recycling significantly reduces the environmental benefits of this revision in legislation – significantly restricting the volume of surplus food that it will be possible to feed to non-ruminants. The EU’s ban on intra-species recycling for non-ruminants is highly unusual– with countries such as New Zealand, Australia, the US and Japan all allowing intra-species recycling for non-ruminants, with no occurrence of TSE in non-ruminants recorded. The EC Scientific Steering Committee and European Food Safety Authority have both previously recognised the lack of evidence for TSE transmission in non-ruminant livestock. Feedback thus recommend that the EU legislate for the safe use of mixed surplus food streams in non-ruminant feed, including surplus food from catering, lifting the intra-species recycling ban for non-ruminants provided that rigorous safety measures are put in place for the safe treatment of this feed in tightly regulated off-farm processing facilities, to guard against other disease transmission such as African Swine Fever. A discussion of the technical and safety aspects of such legislation, including the heat treatment parameters to render feed safe, can be found in the REFRESH Technical Guidelines on Animal Feed and pilot projects are currently taking place in the Netherlands and Australia.
Read full responseResponse to Farm to Fork Strategy
28 Feb 2020
My feedback is submitted both on behalf of myself as an EU citizen (Belgium) on behalf of my organisation, Feedback Global, which is based in London but has developed the below recommendations through involvement with EU-level and national stakeholders in the Netherlands and Spain.
• 16% of the total amount of food that currently becomes waste, could become available to be processed into non-ruminant feed as a result of changing legislation to ensure the safe treatment of such surplus.
• Surplus food feeds could reduce farmer feed costs, land use for European livestock farming, carbon emissions, and deforestation from soy imports. From a food security perspective, surplus food feeds provide an opportunity to decouple some of Europe’s feed supply from global agricultural commodity prices.
• The EC’s Circular Economy Action Plan sets out to increase the use of surplus from the food chain in livestock feed without compromising feed and food safety. In particular, the European Parliament‘s Committee on the Environment, Public Health and Food Safety own-initiative report (Borzan 2017) calls on the Commission “to analyse legal barriers to the use of former foodstuffs in feed production and to promote research in this area” while also bringing “food safety risk down to zero”. It notes “the potential for optimisation of use of food unavoidably lost or discarded and by-products from the food chain, in particular those of animal origin, in feed production”.
• Building on advice from microbiologists, epidemiologists, veterinarians and pig nutritionists, the Horizon2020 REFRESH technical guidelines on animal feed set out the key principles for producing safe feed from surplus food.
• To ensure safety, only omnivorous non-ruminant livestock should be allowed feed made from surplus food that may contain meat. Such feed should be sourced exclusively from specialist licensed treatment plants located off-farm and subject to stringent controls regarding heat treatment, acidification and biosecurity to ensure the feed is free from disease.
Circular animal feed – ecofeed – does not require the relaxation of any regulation or biosecurity practice necessary to maximise feed safety. With carefully thought-through regulation and tight official controls of specialist licenced ecofeed treatment plants, we can fulfil both our ambitions for circularity in the food-feed sector and guarantee maximum feed safety. In other words, regulating for the use of surplus food in feed does not imply relaxing safety standards. African Swine Fever is easily destroyed through heat treatment and all efforts to prevent the spread of ASF through accidental or illegal feeding of untreated surplus food should continue.
Expert panels held by REFRESH with participation of a former EFSA Feedap scientific panel member have confirmed that it is technically feasible to produce safe feed from animal protein-containing surplus food. The buy-in of key government authorities, feed and food companies in the Netherlands demonstrates that this position on the technical feasibility of safe ecofeed is now starting to gain traction with various important stakeholders. A multi-stakeholder roundtable with government and industry stakeholders in Catalonia – Europe’s most important pig producing region – hosted by the Catalan government in June 2019 also pointed to an increased interest in ecofeed.
The EU is unique in having taken a precautionary approach to TSE in non-ruminants as there is no intraspecies recycling ban for non-ruminants in countries such as the United States, New Zealand, Japan and Australia where pigs may be fed protein of porcine origin either as part of heat-treated surplus food or as meat and bone meal of porcine origin.
Full REFRESH report available at https://eu-refresh.org/technical-guidelines-animal-feed
Read full responseResponse to Establishment of a methodology of measurement of food waste
26 Mar 2019
We commend the Commission’s recognition of food waste as an urgent issue which needs to be addressed to ensure we avert global climate disaster – and the obligation on member states to measure food waste is an excellent step in this direction.
However, we are concerned that food that is ploughed back in or left to rot in fields has been excluded from EU measurement. Between 11-34% of EU’s food waste occurs at primary production level, and the majority of this is left in the field. Harvest food waste is food that is mature enough to be ready to harvest, but wasted at the harvest stage through being left to rot or ploughed back into the field. It is vital that the EU provides guidelines to enable member states to at least voluntarily report their harvest food waste. Feedback have experienced the huge quantities of food wasted on farms first hand through our Gleaning Network and research reports.
Additionally, the Commission needs to urgently clarify that food wasted at later stages of the supply chain, but then returned to their agricultural suppliers to be ploughed back into the field, should be measured as food waste at the stage of the supply chain where it is wasted, before it is returned to the farm. Otherwise, this is a significant loophole which could perpetuate and worsen the current situation of companies dumping food waste on their agricultural suppliers.
If it is not legally possible to include harvest food waste in compulsory measurement, the Commission should:
• Add harvest food waste as an additional point (f) under Article 3 which member states can voluntarily report on – defined as edible food that is mature and ready for harvest but wasted at the harvest stage by being ploughed back in or left to rot in the field
• Provide examples of some means of harvest food waste measurement in Annex III and IV – such as physical measurement, crop-cutting surveys or visual assessments.
• Recommend as best practice to member states that they measure and report harvest food waste
• Fund several member states to conduct pilot studies of harvest food waste in their countries
Please find in attachment a policy paper produced by Feedback and Safe Food Advocacy Europe, detailing the argumentation supporting our view on this draft.
There are many cases of farmers who are forced to plough whole fields of produce back into the soil, or leave thousands of tonnes of their produce in the field due to factors like cosmetic outgrading and last minute order cancellations from retailers each year. Measuring harvest food waste would help EU farmers avoid the costs of food waste, reduce Unfair Trading Practices and carbon emissions, liberate nutritious food for EU food security, and save valuable land. Separating farm food waste from the Waste Framework Directive would force member states to treat farm food waste in silo, punishing farmers for food waste which is often the result of retailer policies. Not providing guidelines for measurement of harvest food waste will send the message that this is insignificant, inhibit member state measurement and reduction of this food waste, and harm farmers and the environment.
Yours sincerely,
Martin Bowman
Policy Officer and Campaigner
Feedback Global
Read full responseMeeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and SAFE
6 Dec 2018 · Statement on food waste measurement methodology