The Food Foundation                            DEF0041

Written evidence submitted by The Food Foundation


About The Food Foundation

The Food Foundation is a charity working to influence food policy and business practice, shaping a sustainable food system which makes healthy diets affordable and accessible for all. We work in partnership with researchers, campaigners, community bodies, industry, investors, government and citizens to galvanise the UK’s diverse agents of change, using surprising and inventive ideas to drive fundamental shifts in our food system. These efforts are based on the continual re-evaluation of opportunities for action, building and synthesising strong evidence, convening powerful coalitions, harnessing citizens’ voices and delivering impactful communications.


We will be submitting evidence in relation to the question: “In what ways and to what extent are UK value chains (in the form of public procurement, goods, services, or the private sector) contributing to global deforestation?”


The Food Foundation’s Plating Up Progress project assesses major UK food businesses annually against a set of health and sustainability metrics.

Plating Up Progress aims to demonstrate how sustainability and health metrics can and should be used to assess the UK food industry’s progress in transitioning to a healthy and sustainable food system. The project utilises publicly available information to map the current commitments, targets and performance of 11 UK supermarkets and 18 major UK operating caterers, casual dining and quick service restaurant change against 10 metrics relating to shifting towards healthy and sustainable diets.


Disclosure on deforestation risk by the major UK food businesses is not yet universal or of sufficient quality.

One of the Plating Up Progress metrics covers issues related to biodiversity. This metric assesses whether the businesses assessed have targets for, and report on, zero net land-use conversation through their reliance on three key food commodities - palm oil (as a product or ingredient), soy (in animal feed) and beef. 


Maximum scores require time-bound targets and reporting data for at least some segregated certification (palm oil and soy) under RSPO, Pro Terra, RTRS or other recognised certifications. Reliance on mass balance or credits achieves a lower score. Initial steps such as having an appropriate policy or mapping risk on these commodities achieves a lower score still. For beef, evidence of not sourcing beef from South America replaces the reliance on certification.


Our latest 2022 analysis demonstrates that performance on this metric varies between sectors, with supermarkets showing leadership, and contract caterers making less progress. 


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Overall, out of the major food businesses assessed:

-          82% are reporting on and/or have set a target to reduce their reliance on palm oil as a product or an ingredient.

-          62% are reporting on and/or have set a target to reduce their reliance on beef sourced from South America.

-          Less than 60% report some data on certified soy in animal feed in their supply chains or include soy in their deforestation-free commitments. However, none of the companies assessed have a set a target and are reporting against said target.


The analysis shows that most food businesses currently rely on certification schemes such as the Roundtable on Sustainable Palm Oil (RSPO) and the Roundtable on Responsible Soy (RTRS) to assess whether the palm oil and soy in their supply chains are contributing to land-use conversion. Whilst certification schemes have been criticised, they clearly remain the primary approach currently used by businesses to assess supply chain deforestation risk.


In addition, the coverage of deforestation risk disclosure is inconsistent across sectors - with supermarkets tending to disclose data which covers their own-branded products only rather than branded products, and caterers disclosing palm-oil data in cooking oil and margarine only.


Voluntary vs mandatory reporting/transparency schemes

Though voluntary reporting approaches may seem attractive (they give businesses more flexibility and relieve governments of the need for oversight and enforcement costs), a 2015 study of 161 voluntary schemes in the UK, EU and worldwide found that many schemes were undermined by a lack of industry engagement and the consequent lack of a ‘level playing field’ between those businesses that genuinely seek to make progress and those that do not. It concluded that voluntary approaches are generally not appropriate where high participation rates and compliance levels are needed or where timings for action are not flexible (e.g. due to serious environmental risks).


Businesses recognise the potential reputational value of engaging with voluntary initiatives but, when participation would damage their commercial objectives, they face strong incentives to deprioritize their efforts. Slow progress through voluntary initiatives can reinforce low levels of ambition for future progress, as targets are kept low to persuade other businesses to join. By contrast, mandatory measures can quickly and effectively drive-up minimum standards across the board amongst businesses that are less engaged, levelling the playing field and avoiding the risk that ambitious commitments are not backed up with action. Government led mandatory requirements can also help address challenges related to data availability and inconsistent reporting methodologies faced by voluntary schemes.


We would encourage the Government to introduce mandatory reporting requirements for food businesses to improve transparency on the land-use conversation risk from forest-risk communities in their supply chains, alongside the new mandatory due diligence measures which have been introduced to prevent illegally-produced forest-risk commodities being sold in the UK market.


Investor Coalition on UK Food Policy

As part of Plating Up Progress, The Food Foundation has been working with the financial sector to press for greater progress amongst UK food businesses towards healthy and sustainable diets, and for more supportive Government policy to facilitate this shift.  In 2021, a group of investors (facilitated by The Food Foundation and led by Rathbone Greenbank Investments) came together to write a letter to the UK Government in support of the introduction of mandatory reporting requirements for UK food businesses, as recommended by Henry Dimbleby in his independent review of the food system – the National Food Strategy.  They argued that this would facilitate greater transparency and allow investors to better compare data between food businesses on their targets, commitment and progress. The group has now grown into the Investor Coalition on UK Food Policy which includes 23 investors representing £6 trillion in assets under management. The coalition is now working to ensure investors have a seat at the table in the Food Data Transparency Partnership, which was committed to in the Government’s recent Food Strategy, and on subsequent food policy issues. The long-term goal is for the investor coalition to be a positive influence on UK Government food policy to accelerate the transition to healthy, affordable and sustainable diets.


September 2022