Written Evidence submitted by WWF-UK (FS0067)




In the UK and around the world, food production’s reliance on intensive practices is unnecessarily destroying habitats, decimating species, and accelerating climate change. As a food system, it is also failing on its own terms, it is both volatile and vulnerable to shocks, like the invasion of Ukraine, and focused on producing more food than we need but still failing to feed us.



We must act now if we are going to fix the food system and provide sustainable, healthy, affordable food for everyone. We need to reform our food system, to halt nature loss and ensure the UK leads a global transformation to sustainable food production and consumption. WWF is working towards a food system that is more diversified and diverse and relies less on feed and fertilizer, so it is more sustainable and resilient.

1. How What are the key factors affecting the resilience of food supply chains and causing disruption and rising food prices – including input costs, labour shortages and global events? What are the consequences for UK business and consumers?

Recent crisis in food supply triggered by the invasion of Ukraine have sparked increased concern about food security which sometimes narrows to a focus on maximising current systems of food production. WWF’s approach to food security builds on the FAO definition ‘all people, at all times, having physical and economic access to sufficient, safe and nutritious food to meet their dietary needs and food preferences for an active and healthy life” with the understanding that requires ‘food and production systems do not deplete natural resources or the ability of the agricultural system to provide food for future generations’.

This fuller examination of food security is aligned with the analysis that emerged from in depth analysis of the global food crises in 2007-8 and 2010-12 - UN Global Food Crisis and Food for All. It sadly reveals the global failure to tackle the problems at the root of our volatile and vulnerable food system which is producing more food than we need but still failing to feed us. And the risks to our food system are heightened by the increasing frequency of droughts and wildfires which will trigger more crisis in the food system. Yet each crisis is met with calls for more production via the risky and redundant farming practices that drives more deforestation, climate change, water stress and damages the pollinators and soils our food system relies on.

Much of the current cost of production rises illustrate the fundamental challenges in the system and are driven by the use of fossil fuel energy and artificial inputs. The rising cost of fuel prices (in particular gas) is impacting the cost of fertiliser, which has risen from under £300 to over £1000 a tonne. If high prices persist for another 12 months, the additional fertiliser bill for British farmers could be £760 million, assuming farmers purchase and apply the same quantities of chemical fertiliser as in a normal 12-month period. This is being driven by the war in Ukraine. The knock-on consequences of this could see farmers choosing to plant fewer crops during these high price periods and we are already seeing the increased cost of production reflected in food price inflation in some sectors. Such price pressures are driven by the cost of fossil fuels and DEFRA should be seeking to create the conditions that enable a widespread shift to more regenerative techniques to build soil health and restore nature. Such an approach would help farmers reduce their reliance on volatile-priced artificial inputs, improving productivity and margins without a significant detriment to yields.

This is not a problem of food production. Enough food is produced today to feed everyone on the planet. Ukraine and Russia produce 25% of the world wheat export, but this does not mean that if they halt production, there will be a shortage of 25%. This is because ~70% of wheat is eaten in the country that produces it. Overall, the shortfall would be 6-7%. Furthermore, global stockpiles of food are normal, around 15% higher than in 2011. It is rather an issue with how we are producing and consuming food, including access and distribution.

An increase in extreme weather events globally as a result of climate change is impacting on global food yield meaning there is less food on the global market, impacting cost and security of supply into the UK. This situation is evident in the UK, with this year’s drought causing significant impacts on yields. Livestock farmers are having to feed animals their winter feed already, which could impact feed availability coming into winter. Further, as a consequence of unusual weather patterns associated with climate change, wheat yields in 2018 were 7% below the 2016 to 2020 average, and in 2020 were 17% below that average. We agree with the assessment of the Government’s own UK Food Security Report 2021, over the medium and long-term, climate change poses the biggest threat to domestic and global food security. The degradation of our agricultural soils that have already lost between 40%- 60% of their organic content – at a cost of around £1.2 billion a year, is also undermining our ability to produce healthy, sustainable food in the UK, a problem that will be further exacerbated year on year if no action is taken to transition to regenerative agriculture.

As a result of these factors, UK businesses face supply shortages, and as a consequence are forced to pay higher prices for the foods they source and sell to consumers. The most material risks are empty supermarket shelves and farmers going out of business as they struggle to contend with rising input costs, all undermining our nation’s ability to feed itself. There is no food security without nature. As set out below, unless the UK Government takes action to improve food security through transitioning to more sustainable production and consumption, hard pressed households will continue to face affordability challenges as the unsustainability of the current system leads us into crisis, after crisis, after crisis.

In the UK, the way we produce food has driven an erosion of our natural capital which we rely upon for a range of vital ecosystem services. In 2018, Michael Gove as Environment Secretary recognised that “The environmental damage we have suffered while inside the Common Agricultural Policy has been significant. Soil health has deteriorated. Farmland bird numbers have dropped. Precious habitats have been eroded.”[1] It has also perpetuated a farming system with huge reliance on artificial inputs like nitrogen fertiliser and other price-volatile commodities such as livestock feeds.

Shifting incentives from these unsustainable modes of production and towards approaches that improve the health of our natural capital can help to avoid the price shocks of the future – by decoupling our food production from that system and fostering a nature-positive agriculture more resilient to inevitable effects of climate change.

2. What is the outlook for UK food price inflation in the short and medium term? What policy interventions should the Government consider to manage these pressures?

According to the Office of National Statistics (ONS) and British Retail Consortium (BRC), food and drink prices are 12.6% higher than last year. Staples such as milk, cereals and pasta have been particularly hard hit, with milk costing 34% more on average and flour rising by 30%. This situation is set to get worse without intervention. Vital to addressing food price rises and improving food security is enabling a transition to low-input regenerative agriculture that reduces our reliance on artificial inputs and fossil fuels, as rising prices of these commodities are directly driving the increases in food prices.


Our current system of support for agriculture (around £3.5billion per annum), regulations, incentives and training can also be reformed to improve food security. Currently, these benefit large land holders and the production of monocultured crops and the industrial-scale animal production that depends upon them for feed. In fact, half our annual wheat harvest – that’s equivalent to 11 billion loaves of bread - is used to grow food for farm animals, rather than growing food for people directly.


It is imperative that this system of support is redirected towards paying public money for public goods to build resilience on every farm, enable the production of more nutritious food, and crucially to ensure the 70% of UK land currently used for farming is helping to achieve the government’s legally binding commitments in the Environment Act on species abundance, water and air pollution and to reach net-zero by 2050.


Government should also introduce regulations to at least halve the 40% of food that is currently wasted in our system – both on farm and post purchase.  There is enormous potential to provide low-cost sustainable and healthy food by reducing demand for animal feed and biofuels that currently account for over 50% of our cereal harvest.


To reduce vulnerability to shocks in the fertiliser market, farmers can be encouraged to adopt the cover crop or grass ley options of the Sustainable Farming Incentive to harness the nitrogen-fixing power of legume crops. However, to reduce nitrogen pollution effectively, this needs to be matched by at least an equal reduction in nitrogen applied in the form of artificial fertilisers/organic manures. Researchers from Iowa State University found that by adding legumes like clover and alfalfa to the classic corn-soybean rotation in the US Midwest, for example, farmers slash fertiliser without reducing overall yields.


3. How are the rising cost of living and increasing food prices affecting access to healthy and nutritious food?

The UK cost of living has hit its highest rate in decades with inflation at a 40-year peak. Citizens cite food, energy and fuel as the main drivers behind the increasing cost of living, with two in five reporting buying less food when they go shopping. Kantar estimates that families’ average grocery bills will rise by £454 this year, with milk and cheese being the biggest driver of price increases. Their prediction rose by a further £70 higher in August, indicating that inflation is increasing at a faster rate than predicted.

But the UK still has the cheapest food in Western Europe, combined with the 4th highest rate of obesity in Europe. The effect of food price increases is comparatively small compared to costs of fuel and heating and household services. People suffer food poverty chiefly as they are on the breadline and are being obliged to spend less on food to accommodate other demands. Households with children are particularly at risk of food insecurity and childhood is a critical time for good nutrition. Furthermore, healthy, sustainable food is perceived as unaffordable.

The immediate needs are therefore for Government to:

4. How will the proposals in the Government’s food strategy policy paper affect: the resilience of food supply chains; the agri-food and seafood sectors?

1. The resilience of food supply chains: The ambition outlined in the Government Food Strategy would go some way to strengthening the resilience of food supply chains. We would encourage the Committee to raise the Government Food Strategy with the new Secretary of State at the earliest opportunity to ensure the recommendations remain Government policy. In particular, we welcomed the following measures:

  1. The commitment to introduce a Land Use Framework by 2023.

        This should align national targets, such as for Net Zero and biodiversity restoration set through the Environment Act, with practical delivery actions at local levels through emerging Local Nature Recovery Strategies (for further detail see our answer to question 6 below).

  1. Funding and investigation of R&D to reduce enteric methane, promote alternative feeds, and improve manure management.

        However, the Strategy includes no steps to reduce the third key driver of agricultural emissions – demand for and production of animal feed, which currently accounts for 40% of arable land use in the UK. This land could be used to produce food for human consumption.

  1. Plans for a Food Data Transparency partnership exploring mandatory reporting (including for scope 3 emissions) and the possibility of mandatory labelling requirements.

        Labelling requirements should be extended to include environmental labelling, based on sound evidence – but this must be in addition to steps to reduce emissions and other environmental impacts related to both production and consumption, the burden of action should not be passed on to consumers.

        Any data initiatives must be multi-metric, including impacts on nature as well as climate, to ensure perverse incentives are avoided.


However, increasing access to nutritious, sustainable food for all, including the most vulnerable, is imperative, and this was not sufficiently addressed in the Government Food Strategy. The following commitments are needed to ensure food supply chains are resilient both now and in the future:

  1. Drive a shift to more plant-rich diets.

        Facilitating such a shift will require policies that improve the food environment to make healthy, sustainable choices easy, affordable, appealing and the norm. Aligning public procurement with an updated National Reference Diet that embeds sustainability as well as health indicators would be a useful first step.

        WWF suggests a reduction in meat and dairy consumption of at least 30% by 2030 would support and enable a net zero and nature positive pathway for UK agriculture and land use. More ambitious reductions would have additional benefits in the UK and abroad.

        A change in diets would strengthen domestic as well as global food security. There is a direct precedent for this; during World War II Britain’s food self-sufficiency rate doubled to around 75%, as less meat and more grains and vegetables were consumed. The increased production of pulses which grow well in British soils and require less space than animal production, would provide increasing quantities of inexpensive, fibre-rich and low-fat home-grown protein on British shelves, helping people to eat both more cheaply and more healthily.

  1. A clear commitment to an agroecological and regenerative future for UK farming.

        Widespread uptake of regenerative farming can achieve balanced outcomes for nature, climate and farmers, but must be accompanied by shifts in diets.

  1. Ensure farmers have the financial support and practical advice they need to accelerate the transition to nature-friendly farming in England.

        The Strategy sets out plans to allocate future farm funding according to demand for new ELM programmes – this must be directly linked to delivery against clear and ambitious environmental and net zero targets to prevent paying money for old rope.

  1. Halve nitrogen waste by 2030.

        The global food system has disrupted the nitrogen cycle. Applying and storing fertilisers and manures leads to nitrogen polluting the air, soil and water, affecting biodiversity and human health, and acting as a potent greenhouse gas. The UK’s overreliance on artificial fertiliser has pushed up production costs, while causing significant environmental harm.

        WWF recommends adopting a holistic approach to cut the use and waste of nitrogen across all sectors, set out in a new Nitrogen chapter in the 25 Year Environment Plan and underpinned by nitrogen budgets.

  1. Make a clear statement on the future of agricultural regulation.

        The Strategy suggests reducing bureaucracy, while maintaining regulation where needed. However, it is far from clear that a firmly, but fairly, enforced regulatory baseline will be in place to ensure future farm payment schemes pay for the delivery of public benefit over and above minimum requirements.

  1. Set out steps to create Core Environmental Standards for trade.

        Such standards should apply equally to food produced in the UK and imported from overseas. This would guarantee that new trade deals would create a market for and support the farmers overseas who adopt more sustainable production methods, rather than simply offshoring the UK’s environmental footprint.

  1. A legally binding target for a 50% reduction in food loss and waste by 2030.

        The Strategy recognises the issue of food waste in homes and sets out plans to consult on mandatory reporting for large businesses – reporting requirements should be extended to all businesses, from farm to fork, by 2025, accompanied by policy protection for farmers from trading practices that increase food waste, such as last-minute order changes or cancellations.

  1. The agri-food and seafood sectors


The Government’s Food Strategy policy paper reiterated the commitment to the Environmental Land Management (ELM) schemes as the key policy mechanism for maintaining domestic production while delivering our climate and environmental goals. WWF supports the vision of sound ELMs to “incentivise methods of farming that create new habitats for wildlife, increase biodiversity, reduce flood risk, better mitigate climate change and improve air quality by reducing agricultural emissions”.  We believe ELMs can achieve these goals whilst supporting food production and nutritional security, particularly if supported by a national land use framework (see our answer in to question 6 below).  The new Secretary of State for DEFRA must urgently recommit to delivery of an ambitious ELM programme across the Sustainable Farming Incentive, Local Nature Recovery and Landscape Recovery tiers.

We would also like to amplify the points raised in the Wildlife and Countryside Link (Link) response to this enquiry – specifically that biodiversity, and climate change mitigation and adaptation underpin food security.

Another point well-made by Link in their response is in relation to speeding up the transition towards a new farming system that aligns with nature to ensure future food security. By contrast, a two-year delay to this transition would halve the contribution of ELMs to the fifth carbon budget (2028-32).

Delaying or reshaping the focus of ELMS to encourage maximising domestic production would be detrimental to its objectives of reversing ongoing soil degradation, reduce GHG emissions and restore the ecosystems that serve both agriculture and wider society. Moreover, it will not help resolve domestic food insecurity. As Former Secretary of State, George Eustice noted on several occasions, that there is no direct correlation between the amount of land farmed and our agricultural output – approximately 60% of agricultural output comes from 30% of land.[2] Therefore, the contention that the ELM scheme will drive loss of productive land and greater food insecurity is false.

The principle of paying public money for the delivery of public goods remains sound, ensuring farmers receive value for delivering environmental and other benefits that are not otherwise rewarded by the market. This approach will work to benefit farmers by enhancing their natural capital and ecosystem services and reducing their reliance on volatile artificial inputs. Using public money to pay farmers to grow food would undermine this approach, and as we have seen in the past can create perverse incentives for harmful practices and overproduction.


One objective of the National Food Strategy is to “deliver a prosperous seafood sector that ensures a secure food supply in an unpredictable world” but the WWF Risky Seafood Business report finds out that the seafood produced in the UK has a high footprint risk when compared with our neighbouring Northeast Atlantic countries although the risk is lower than the producing countries in Asia and Africa[3]. This means improvement on the seafood sustainability will be urgently needed if the seafood sector is to support the NFS.

Furthermore, the report reveals that there are no environmental or social regulatory criteria set for imported seafood apart from ensuring the wild-caught seafood is from a legal source although 81% of seafood by volume eaten in the UK is imported.

WWF welcomes the support from the Government on the UK Seafood Fund to support the levelling up in the seafood sector in the UK but there is need to ensure financial incentives should support the UK seafood sector to improve the sustainability of production, not a simple increase of production.

WWF believes the UK governments should lead the way in filling the current gaps in regulations and standards for both imported and domestic seafood and the specific recommendations for the UK governments are:

  1. Set meaningful and measurable targets for UK domestic seafood production to meet the objectives of the Fisheries Act (2020), and to ensure fish stocks are healthy, fishing does not exceed sustainable limits, the recovery of ETP species including through implementation of Remote Electronic Monitoring (REM) with cameras, protection of biodiversity, and that seafood production progresses towards Net Zero.
  2. Develop a set of core environmental standards for imported seafood alongside those for agricultural products to help deliver a strong and comprehensive sustainable food strategy. The US Marine Mammal Protection Act (1972) provides an example of how this can be done in the context of protecting marine mammals from the impacts of fishing.
  3. Strengthen the illegal, unreported, and unregulated (IUU) fishing regulations to develop due diligence requirements for imported seafood (similar to deforestation risk commodities) and demonstrate leadership in international fisheries management and trade forums.
  4. Provide financial support, for example through the UK’s Blue Planet Fund, to lower income countries and the UK Seafood Fund for UK producers like fishers and fish farmers to help reduce their seafood production footprint and support technical innovations

Additionally, if more sustainable and low footprint seafood can be produced in the UK, there is an opportunity for the UK to increase the self-sufficiency rate of seafood and reduce the reliance of imported seafood.

5. Is the current level and target of food self-sufficiency in England still appropriate?

According to the Government’s own Food Security report, the UK is currently around 76% self-sufficient in foods that can be produced in the UK, although this could be increased if we used more of our land to produce food for human consumption rather than feed for livestock.

It is found that around 70% of UK’s domestic seafood production is exported to international markets particular the EU market in 2019.  At the same time, the UK imported 80% of our edible seafood from overseas. The WWF Risky Seafood Business Technical report finds that UK’s seafood sufficiency-rate was less than 20% implying UK’s seafood security has greatly affected by the external factors4. The war in Ukraine results in the sanction of Russian production, at which is a major producing country of whitefish such as Atlantic cod, Pacific cod and Russian pollock for the UK. Supply and prices of whitefish is therefore greatly affected.

Additionally, UK consumers have strong preferences for the species they like to eat, built up over many years. Although the WWF Risky Seafood Business report identifies that approximately 124 species or species groups were imported to the UK, the so-called ‘Big Five’ species of haddock, cod, salmon, prawn, and tuna make up around 62% of the UK’s seafood consumption5. It is also found that UK consumers are relatively risk-averse when it comes to choosing seafood, with habitual behaviour and safe choices as key drivers for such preferences6. It also revealed that consumers were interested in supporting locally produced seafood but there is limited evidence to prove locally produced is equivalent to sustainable. There is a need to diverse the seafood consumption behaviour from the ‘big five’ species to other low footprint seafood species7.

If more sustainable and low footprint seafood can be produced in the UK, there is an opportunity for the UK to increase the self-sufficiency rate of seafood and reduce the reliance of imported seafood.

6. How could the Government’s proposed land use strategy for England improve food security? What balance should be stuck between land use for food production and other goals – such as environmental benefit?

The UK government has set a target to reach net zero by 2050 and has proposed several nature targets under the Environment Act, including a target to halt the decline in species abundance by 2030. Agriculture and land use sectors are critical to delivering these goals, yet there are many other demands on land use including food production, forestry, housing, use of land for energy generation (biomass growth; and renewable generation situating) and enabling public access to nature. The way we use land (and what we eat) needs to change in order to reconcile these pressures. There is ample evidence to suggest this is achievable and, in many cases, land use functions can be complementary rather than competitive.

Investment in nature-friendly farming has been shown to help maintain and even improve yields (for example, one study showed that organic systems have the potential to produce yields up to 40% higher than conventional systems in times of drought; another demonstrated that managing 8% of a farm for nature helped to maintain and even enhance yields of some crops and led to no loss in economic or nutrient value). Another study has shown that we can shift to sustainable farming systems in the UK without losing our current levels of self-sufficiency, if we also reduce the UK’s consumption of meat, dairy and eggs.

In a UK context, our Land of Plenty report set out the WWF’s vision for how we see the UK landscape deliver for climate, nature and people. This showed the opportunity for nature, climate and food production of encouraging a more agroecological system, better addressing nitrogen waste on farms, shifting diets, agri-carbon markets and deployment of nature-based solutions like peatland restoration and afforestation. It also highlighted that currently, there is no policy or planning mechanism to reflect this thinking and deliver a nature-positive net-zero food system: a land use framework (LUF), as proposed by the Government in its food strategy policy, would play this role.

Guided by national targets and evidence, an overarching LUF would bring together policies on nature, climate, and food. It would set out a series of common principles for land use decision-making that could be implemented locally in a way that aligns with local opportunities and priorities. In addition to these principles, a LUF should incorporate a National Rural Land Map with data on the productivity of agricultural land and priority areas for environmental restoration or protection, including areas particularly affected by pollution.

Together, these principles and evidence would help avoid sub-optimal decisions in land use, for example using our most fertile land for solar farms or plantation forestry, or contributing to food-feed conflict.

We have been building our evidence base on delivering this over the past year. For example, in Our ‘Future of Feed’ report, we show how improving the efficiency of the UK’s livestock feed can make better use of land. The UK’s current livestock consumes the equivalent of 10.7 billion loaves of bread and 5.8 billion bowls of porridge per year. Instead, these could credibly be fed through an increasing proportion of low opportunity feed like grass, crop residues, food by-products and food waste, as well as innovative feed like insect meal. To totally switch to low opportunity cost feed, there would need to be a decrease in the size of the livestock population, which would then free up more land for nature-friendly, low carbon farming.

We are also currently examining the role that biomass and bioenergy could play in the UK’s net zero pathways. In 2021, an estimated 121,000ha of land was used to grow biofuel crops. By 2050, the CCC envisages this increasing to between 0.7-1.4mn ha. Clearly, this will have an impact on our ability to grow sufficient food as well as provide space for nature and other climate solutions.

Finally, a land use framework would help deliver on Government’s commitments an efficient and cost-effective way. It would help to reduce conflicts over land use by enabling better collaborative decision-making and pooling of data, knowledge, and skills, thus saving time and money. Importantly, it would integrate with national policies and incentives schemes like ELMs to ensure they deliver food security while meeting the Government’s climate and nature commitments. In addition to public incentives, a LUF could help provide more clarity around best practice and guidance to investors around land use, driving funding in support of transparent, fair, and sustainable private markets for nature recovery and climate mitigation.


The new ministerial team at DEFRA should be urged to recommit to the development of a meaningful land use framework.

September 2022



[2] Farming reform is a big post-Brexit prize we should be careful not to lose – Inside track (greenallianceblog.org.uk)

[3] https://www.wwf.org.uk/sites/default/files/2022-08/WWF_Risky_Seafood_Business_Summary_Report_2022.pdf