It came through dripping, leak by leak, but it’s finally out and there’s no turning back. After months of postponement and much speculation on its content amongst those who, like me, live and breathe food policy, the European Commission flagship initiative Farm to Fork Strategy (F2F) for a fair, healthy and environmentally-friendly food system has finally been published.
The food chapter of the European Green Deal (which promises to make Europe the first climate-neutral continent by 2050), the objective of the F2F is to build a sustainable food system through a mix of legislative proposals and non-legislative initiatives that will be published in the next few months and years to improve lifestyles, health, and the environment.
But what problem is the Commission looking to fix – and should the food industry embrace or fear what’s to come?
Turning wounds into wisdom
While the effects of the coronavirus outbreak in Europe will no matter continue to influence the lives of millions of Europeans for many years to come, in the midst of the crisis many have found themselves – perhaps for the first time – feeling thankful for having food on their plate. The resilience of food systems has been praised left and right. With limited disruptions to the supply chain, food has continued to land on our tables being just a short queue, or one click, away. Those who have been let down by supermarkets, which have struggled to cope with a sudden surge in demand, have even found themselves supporting local farmers and producers, or independent shops, for the first time.
All in all, a success. Except it is not. Demand for food banks has never been higher, farmers are struggling to hire workers and sell their produce. Delivery drivers and shop assistants have been working to ensure life can continue as normal with low salaries and no sick pay. What’s more, we are not only getting poorer, but heavier too. As the F2F acknowledges, over half of the adult population are now overweight, contributing to a high prevalence of diet-related diseases and soaring healthcare costs. Studies are now looking into the correlation between obesity and COVID-19 – with alarming results – and it is reasonable to say that many will emerge from this crisis a few kilos heavier as a result of lifestyle changes stemming from confinement measures imposed across Europe.
Add environmental damage from the use of pesticides, fertilisers and antimicrobials and food waste to the mix to obtain a picture of what the F2F is looking to address.
Change is coming, but slowly
In twenty pages or so, the Commission document outlines three objectives and several legislative initiatives and policy proposals which will be rolled out gradually over the next two to three years (see below). But those familiar with the EU policy process will know that these ambitions will take a lot more than good will to materialise, with contentious issues such as origin labelling and nutrition labelling likely to keep EU civil servants and lobbyists alike busy for the months and years to come.
If you fear that any of these initiatives will impact your business – in the shape of reformulation or labelling costs – it is worth remembering that no policy is permanent or fixed. All are subject to change depending on political pressure and engagement. And some of these may never materialise (if you were there for the debate on setting of maximum and minimum amounts for vitamins and minerals in foodstuffs, you know what I am talking about). Similarly, if you have invested in plant-based products you may have jumped on your chair reading the Commission call for a reduction of red and processed meat, but will the EU meat industry just sit and listen? Unlikely.
I am bracing myself for some interesting debates in the years to come.
The Whitehouse Consultancy is a specialist agency, and have focused on food and nutrition policy for over 20 years. Our team are experts in food law and regulation, providing political consultancy and public affairs advice to a wide range of food manufacturers, distributors and consumer organisations in the EU and the UK on how to shape the policies and regulations affecting their business. More information about our food and drink policy experience can be found here, or, if you have any questions, please contact Viviana Spaghetti at Viviana.firstname.lastname@example.org
Objectives of the F2F
- Reducing the environmental and climate footprint of the EU food system: the aim is to ensure that the food chain, covering food production, transport, distribution, marketing and consumption, has a neutral or positive environmental impact, and helps mitigate climate change and adapt to its impacts;
- Strengthening the resilience of the EU food system by ensuring food security in the face of climate change and biodiversity loss: the EU wants to make sure that everyone has access to sufficient, nutritious, sustainable food that upholds high standards of safety and quality, while meeting dietary needs and food preferences;
- Leading a global transition towards competitive sustainable from farm to fork by tapping into new opportunities: the aim is preserve the affordability of food while generating fairer economic returns in the supply chain, so that ultimately the most sustainable food also becomes the most affordable.
Key legislative initiatives and policy proposals:
- “Proposal for a legislative framework for sustainable food systems” (to be presented by the end of 2023): this proposal will focus on common definitions and general principles and requirements for sustainable food systems and foods; the framework will also address the responsibilities of all actors in the food system. The aim of the framework is to promote policy coherence at EU and national level.
- Contingency plan for ensuring food supply and food security” (to be presented in Q4 2021): this proposal will draw on the lessons learnt from the COVID-19 crisis, and will assess the resilience of the food system. This will include the setting up of a food crisis response mechanisms coordinated by the Commission and involving Member States, which will be comprised of various sectors (agriculture, fisheries, food safety, workforce, health and transport issues) depending on the nature of the crisis.
- “Initiative to improve the corporate governance framework, including a requirement for the food industry to integrate sustainability into corporate strategies” (to be presented in Q1 2021): The Commission has released no further details on this specific proposal, or how it would be implemented. As this sustainability criterion will be mandatorily integrated into corporate strategies, it is likely that the Commission will expect the industry to self-regulate and launch more sustainable practices of its own accord.
- “Develop an EU code, and monitoring framework, for responsible and transparent business and marketing conduct in the food supply chain” (to be presented in Q2 2021): this “EU Code of Conduct” will seek commitments from companies to 1) reformulate their food products in line with guidelines for healthy, sustainable diets; 2) reduce their environmental footprint and energy consumption by becoming more energy efficient; 3) adapt their marketing and advertising strategies taking into account the needs of the most vulnerable; 4) ensure that campaigns related to food prices not undermine citizens’ perception of the value of food; 5) reduce packaging in line with the new Circular Economy Action Plan. The Code will be developed with all relevant stakeholders; the Commission will monitor commitments, and consider legislative measures if progress is insufficient.
- “Launch initiatives to stimulate reformulation of processed food, including the setting of maximum levels for certain nutrients” (to be presented in Q4 2021) and “Set nutrient profiles to restrict promotion of food high in salt, sugars and/or fat” (to be presented in Q4 2022): These two policy proposals are relatively new, as they were not included in earlier leaks of the Strategy back in February 2020. They correspond to the Strategy’s new objective of “reversing the rise in overweight and obesity by 2030” – an aspect which has become important in recent years, given both the prevalence of overweight and obesity in the EU and what we know about their impact on vulnerability to COVID-19. What each policy proposal is set to include is unclear as of yet – and more will be unveiled by the Commission later on. Nonetheless, one specific point hinted at by the communication is that the nutrient profiles will aim to restrict promotion of foods high in salt, sugars and/or fat via nutrition or health claims.
- “Proposal for a revision of EU legislation on Food Contact Materials to improve food safety, ensure citizens’ health and reduce the environmental footprint of the sector” (to be presented in Q4 2022): the EU here aims to improve food safety and public health (in particular in reducing the use of hazardous chemicals), support the use of innovative and sustainable packaging solutions using environmentally-friendly, re-usable and recyclable materials. In addition, under the sustainable products initiative announced in the CEAP, it will work on a legislative initiative on re-use in food services to substitute single-use food packaging and cutlery by re-usable products.
- “Enhance coordination to enforce single market rules and tackle food fraud, including by considering a reinforced use of OLAF’s investigative capacities” (to be presented in 2021-2022): in order to do so, the Commission will work with Member States, Europol and other relevant bodies to exploit EU data on traceability and alerts in order to enhance coordination on food fraud. The Commission will also propose stricter dissuasive measures, better import controls and examine the possibility to strengthen coordination and investigative capacities of the European Anti-Fraud Office (OLAF) on food fraud, including in intra-EU cross border matters.
- “Proposal for a harmonised mandatory front-of-pack nutrition labelling to enable consumers to make health conscious food choices” (to be presented in Q4 2022): we knew that the European Commission was looking at harmonised front-of-pack nutritional labelling for a long time, especially given the relative success of the Nutri-Score labelling system in France. However, the mandatory nature of the labelling system is a surprising element of the communication’s final version, given that on 11th May Health and Food Safety Commissioner Stella Kyriakides said that such a system would not be mandatory.
- “Proposal to require origin indication for certain products” (to be presented in Q4 2022): while the Commission is considering the extension of mandatory origin or provenance indications to certain products, but it has not specified which products yet. These are unlikely to be relevant products, as most of the recent reports suggest a focus on meat and dairy products.
- “Proposal for a sustainable food labelling framework to empower consumers to make sustainable food choices” (to be presented in 2024): as per the document, this is set to be presented in 2024, so further details will be released later on. This will come later than harmonised nutritional labelling, as it will be about developing a new sustainable food labelling framework “integrating nutritional, climate, environmental and social aspects”. It is unclear what labelling on climate, environmental and social aspects will include, but it might include information on mode of production, carbon impact, or references to fair trade. In the same way that the Commission took inspiration of local nutritional labelling system to develop its own proposal, it will “examine ways to harmonise voluntary green claims”. This information might be provided to consumers through other means including digital, in order to improve the accessibility of food information in particular for visually impaired persons.
- “Determine the best modalities for setting minimum mandatory criteria for sustainable food procurement to promote healthy and sustainable diets, including organic products, in schools and public institutions” (to be presented in Q3 2021): depending on how the Commission aims to assess and label the sustainability of food products, this can have a significant impact on how certain products are chosen over others by schools, hospitals and other public institutions. The aim of the Commission, beyond promoting healthy and sustainable diets, is to improve the availability and price of sustainable food.
- “Review of the EU school scheme legal framework with a view to refocus the scheme on healthy and sustainable food” (to be presented in 2023): the EU’s focus will be on strengthening educational messages on the importance of healthy nutrition, sustainable food production and reducing food waste.
- “Proposal for EU–level targets for food waste reduction” (to be presented in 2023): this proposal will set a baseline and propose legally binding targets to reduce food waste across the EU. Under the United Nations’ Sustainable Development Goals (SDGs), The Commission is committed to reducing food waste at retail and consumers levels in half by 2030. In addition to quantifying food waste levels, the Commission will investigate food losses at the production stage, and explore ways of preventing them.
- “Proposal for a revision of EU rules on date marking (‘use by’ and ‘best before’ dates)” (to be presented in Q4 2022): the Commission is worried that misunderstanding and misuse of date marking lead to food waste – it will look at reforming date marketing, based on consumer research, with a view to reduce food waste.