Written evidence submitted by the Friends of the Earth, England, Wales & Northern Ireland (FOW0035)

1. In summary: In the UK we waste over 10 million tonnes of food per year. Yet as part of our commitment to the UN Sustainable Development Goals the UK has pledged to halve per capita food waste by 2030. The only way to achieve this goal is through government action to:

• Set a statutory target to halve per capita food waste from farm to fork in England by 2030, and work with the devolved administrations to agree similar targets, measurement and incentives across all sectors and businesses of all sizes
• Require all manufacturers, distributors and large supermarkets to transparently report data on levels of food waste
• Use fiscal measures to support food redistribution
• Commit to providing segregated food waste collection for 100% of households
• Support the safe use of food waste as animal feed.

And action across the supply chain to:

• Apply the food waste hierarchy.
• Change buying practices to decrease producer-level waste
• Invest in stock control management systems and sales forecasting models
• Collaborate with food redistribution charities
• Adopt a proactive approach to educating customers around food waste

Q1: What is the economic, environmental and social impact of food waste in England?

2. The level of food waste in Britain, and its economic, environmental and social impacts, is substantially underestimated. WRAP estimate that over 10 million tonnes of food are wasted each year in Britain[1]. However, this does not include waste at the primary production level (estimated at around 3 million tonnes), in non-manufacturing supply chains or along supply chains outside of the UK.

3. The environmental impact of food waste is significant, both in terms of the impacts of producing food which is then wasted and in terms of the additional emissions of food disposed of via landfill. It is estimated that between 4.0 and 4.6 tonnes of CO2e are emitted for each tonne of waste[2], suggesting that the impact of this waste in terms of emissions is around 46 million tonnes of CO2e per year[3].

4. Avoidable household food waste in the UK has a water footprint of 5,200 Mm3 (equivalent to 6% of the total UK water footprint), and a land footprint of 19,000km2, equivalent to an area about 91% the size of Wales[4]. The additional environmental costs of food waste – in terms of deforestation, land use change and the impacts of landfill – remain unquantified.

5. Current waste figures ignore 'food surplus' diverted for use as animal feed (amounting to 660,000 tonnes in 2015). Yet this ‘surplus’ also has a clear environmental impact - nitrous oxide emitted through fertiliser use, soil degradation and feed transport emissions all serve to needlessly harm the environment in the same way as other wasted food.

6. Current narratives around population growth suggest a need to dramatically increase food productivity to ensure global food security. However, increasing production without reducing food waste and addressing the 14.5% of global emissions caused by meat production will not tackle the overall environmental impacts of our food system[5].
7. The economic impact of food waste in the UK increases along the supply chain, with WRAP estimates placing the value between around US$1,500 a tonne for manufacturers to US$4,800 a tonne for consumers[6]. They suggest that the value of food wasted in the UK is at least £17 billion each year[7], in addition to the costs of collecting, transporting and treating waste.

8. Direct economic costs are borne by producers, retailers, consumers and local authorities:

• Waste within food manufacturing and retail is estimated to represent foods worth £1.9 billion per year[8]
• The direct cost of avoidable food waste to consumers is estimated at £700 per year for a family with children, and around £470 per year for an average household[9].
• The annual costs to local government of collecting and treating food waste are estimated to be over £300 million[10].

9. The estimated net benefit of food waste reduction schemes in the UK was more than £1.2 billion for household food waste and £230 million for supply chain waste between 2012 and 2015 (WRAP and DEFRA 2013).
10. The social impact of food waste is harder to quantify, however:

• High volumes of wastage at primary producer level have an impact on rural communities who are unable to offer reliable employment to pickers/harvesters (or a regular income to farmers) when order cancellation or cosmetic requirements mean that order volumes fluctuate regularly and without warning
• When consumers see high volumes of food wasted in public and retail spaces, they are likely to ascribe less value to these foods, and hence are less likely to make decisions to buy products or reduce waste based on considerations of the environmental or social impact of production
• Waste food sent to landfill or recycled without proper adherence to the food waste hierarchy takes edible food that could have been used to ameliorate social ills (i.e. lack of access to food due to homelessness or benefit sanctions) and disposes of it in a way that fails to address these issues. Equally, it can be argued that the 47,000 tonnes of food redistributed in 2015 is playing a role in plugging gaps in the welfare and employment systems that would be better addressed directly by government action.
• The food waste infrastructure (redistribution, recycling and disposal) requires resources, capacity and support which could otherwise be redeployed to negate other social issues such as access to healthy, sustainable and affordable food

Q2: What measures could be most effective in reducing food waste by retailers, the hospitality sector, local government, and consumers? These can include redistribution, recycling and recovery, and improved packaging and labelling.

11. Below we have outlined those measures that would be most effective in cutting waste from producer to consumer. We have not focused on efforts at consumer level as much progress has been made in improving packaging and education to prevent spoilage and waste over recent years, and current data on the impact of these changes on levels of household waste has not been updated since 2011. Until new data is available, and given ongoing efforts to decrease consumer waste, the focus must be placed higher up the supply chain.

12. Changes to retailer buying practices:

• The Soil Association estimates that 20 to 40 per cent of UK fruit and vegetables is rejected before it reaches the shops – mostly because they do not match supermarkets’ strict cosmetic standards. This impact goes beyond the UK’s domestic market causing good food to be wasted in exporting countries in Africa and Latin America. E.g. in Kenya, it has been reported that 44.5% of food grown for exports is wasted due to European cosmetic specifications, of which the UK’s standards remain the strictest compared to other countries[11]. Requirements for uniform length in French beans grown in Kenya result in 30-40 per cent of the average bean being discarded – this is a cost that is borne either by the farmer or exporter.

• Since 2009 vegetables that in the past would have been wasted have become the fastest growing sector of the fresh produce market. 300,000 tonnes of produce was saved from being wasted on UK farms between 2012-13[12] by supermarkets agreeing to stock ‘ugly’-looking fruit and vegetables. Tesco, Asda and Morrison’s have already trialled ‘wonky veg’ ranges, with considerable success, demonstrating that consumers are happy to purchase non-uniform products.
• Retailers could go further and agree upon ‘whole-crop purchasing’ contracts with suppliers to ensure no produce is left in the field. The food that would have previously been surplus could be incorporated into existing lines of prepared meals such as soups, ready meals or fruit and vegetable drinks.
• If all retailers and food outlets committed to relax cosmetic standards, not only would more whole items of food be available to consumers, but the unnecessary wastage caused by trimming products for packaging could end.

13. Other retailer actions:

• Some supermarkets have already developed new stock control management systems and employed more accurate sales forecasting models to end waste generated by over-ordering and last minute cancellation, but this must be an industry standard. This can be encouraged through extension of the role of the Groceries Code Adjudicator (see Q4).
• All large retailers should commit to working with producers to tackle losses caused by poor storage or transportation infrastructure.
• The current lack of data and transparency about levels of surplus, ‘waste’ and rejected food from all parts of the food supply system is a huge barrier to tackling waste efficiently. Tesco began to measure and share data on waste levels over three years ago, but other retailers are yet to follow this lead. A sector-wide waste reduction strategy, targeting specific foodstuffs and sections of the supply chain is needed.
• The industry as a whole needs to invest in establishing systems and processes to identify surplus food early and ensure it is diverted to redistribution as far as possible.
• All retailers should adopt a proactive approach to educating customers on the implications of food wastage and shifting expectations away from cosmetic ‘perfection’ in fruit and vegetables. This should include rethinking the use and understanding of ‘best before’ labels.
• Courtauld 2025 outlines a range of further actions which could cut food waste at the retail level and improve implementation of the waste hierarchy in disposal. If all large retailers prioritised implementing these actions and supported smaller businesses to do the same this could have a significant impact on food wasted at all levels of the supply chain.

14. Increased retailer and hospitality industry efforts to divert edible food waste for human consumption:

Food redistribution charity FareShare estimate that they receive only 2 per cent of available edible waste foods. In autumn 2015, Morrison’s committed to ensuring that all edible surplus food at store level would be donated to charity. If this commitment to collaboration with food redistribution charities and food banks was replicated across the retail and hospitality industries, 300-400,000 tonnes of food could be diverted from waste[13].

15. Additional local authority support for consumer waste reduction and recycling:

Over recent years there have been moves to cut the amount of household food going to landfill in the UK – by improving food recycling schemes for consumers and encouraging the public to cut waste by buying less food and storing it more effectively (see www.lovefoodhatewaste.com). This led to a 15% reduction in overall household food waste and a 21 per cent reduction in avoidable household food waste between 2007 and 2012.

The reduction in food waste going to landfill saved local authorities around £85 million in avoided landfill tax and gate fees in 2012 alone. The savings in greenhouse gas emissions associated with the reductions in avoidable food and drink waste amounted to 4.4 million tonnes CO2e; the same as would be saved from taking 1.8 million cars off UK roads. This combination of public education and the removal of barriers to recycling and recovery must continue to further decrease levels of avoidable food waste in the home and ensure that unavoidable waste is diverted from landfill.

Q3: What proposals are necessary to further reduce food waste?

16. The UK Government must:

• Set a statutory target to halve per capita food waste from farm to fork in England by 2030, and work with the devolved administrations to agree similar targets, measurement and incentives across all sectors and businesses of all sizes (see Q4). The Scottish Government has already set a reduction target for Scotland, but this does not include reductions in the supply chain.
• Require all manufacturers, distributors and large supermarkets to transparently report data on levels of food waste. This will support WRAP and other organisations in developing strategies to cut waste at source, assess levels of high quality surplus food and improve mechanisms to support redistribution. Transparency within the market will also lead to increased competition, providing a net positive impact for consumers, retailers and suppliers.
• Use fiscal measures to support food redistribution and to promote the application of the food waste hierarchy (e.g. through changes to current subsidy regimes to promote redistribution over anaerobic digestion (AD) – see below – and the introduction of tax provisions relating to wasted food)
• Commit to providing segregated food waste collection for 100% of households, local businesses and public services across England, Wales, Northern Ireland and Scotland, as called for by the REA,[14] who estimate that this will save over £900 per year for some businesses[15]. Subsidies for AD should be limited to the diversion of this type of inedible food waste and should be removed from food grown specifically for use in AD.
• Support the safe use of food waste as animal feed. Prior to the BSE and foot-and-mouth outbreaks of the 1990s and 2000s, much more of our food waste would have been used to feed animals – a practice which is now severely curtailed under EU law. Yet a 2015 Cambridge University study found that feeding our food waste to pigs could save 1.8 million hectares of global agricultural land currently used to produce pig feed[16], while at least 20 times more carbon dioxide emissions could be saved by feeding food waste to pigs rather than sending it for anaerobic digestion[17]. 
• As the UK moves to leave the European Union, Government must support research into new food waste sterilisation technologies to address the microbiological safety of animal feed[18]. This could allow for the identification of safe methods of diversion to omnivorous livestock such as chickens and pigs, and support businesses to apply the food waste hierarchy more rigorously. This would not only ensure that more food could be diverted away from landfill but would also decrease the economic and environmental costs of feeding these animals on imported soy.

17. Food producers, manufacturers, the hospitality industry and retailers must:

• Commit to follow the principles of the Cortauld commitment, take defined steps to tackle food waste in their own supply chain, and to publicly report on progress.
• Invest in stock control management systems and sales forecasting models to help them take concerted action to end over-ordering and the resulting food waste.
• Collaborate with food redistribution charities to support and promote a more equitable system of food storage, retail and disposal that allows for increased redistribution of edible food to people in need.
• Adopt a proactive approach to educating customers on the implications of food wastage and shifting expectations away from cosmetic ‘perfection’ in fruit and vegetables
• Educate consumers as to how to avoid food waste, and support this through promoting buying practices and services which discourage waste. For example, this might include decreasing prices on perishable products rather than offering ‘Buy one, get one free’ deals, or accepting donations of unwanted food for diversion into local recycling schemes.
• Apply the food waste hierarchy, and support innovation to improve diversion of food at the highest possible point of the hierarchy. Suppliers, retailers and the hospitality industry continue to direct unwanted foods to anaerobic digestion facilities which generate energy from breaking down food waste. Yet these facilities recover only a fraction of the energy contained in the waste products they receive. Hence, as it is currently permitted to turn bakery and confectionary surplus into animal feed, all businesses must commit to diverting all such products which are no longer suitable to human consumption into the production of feed, before considering use of AD. 

Q4: How effective are existing voluntary initiatives in England and is there a need for legislation?

18. WRAP coordinate a number of voluntary initiatives, including Courtauld 3, which aimed to reduce waste in the UK grocery sector and homes, and the consumer-focused Love Food Hate Waste campaign. Together, these recorded an overall reduction in food waste of 1.1 million tonnes between 2013 and 2015. Other voluntary measures, such as the Hospitality and Food Service Agreement (saving 15,000 tonnes of waste between 2012 and 2014), have also made steps towards decreasing levels of needless waste in the food system.
19. The current iteration, Courtauld 2025, offers a ten year plan for collaborative action among producers, suppliers and retailers to tackle food waste as part of a broader industry framework to address sustainable food consumption and production[19]. Yet, over the next decade the initiative aims for only a 20% reduction in UK food waste – which would still leave over 8 million tonnes of food wasted by 2025.
20. FareShare, the food redistribution charity, have noted that currently only 2% of edible wasted food is redistributed. If even 25 per cent of edible surplus food were redistributed for human consumption, this would amount to a £250 million investment in UK charities - while also ensuring everyone in the UK could access adequate food. However it seems unlikely that a shift of this magnitude will be achieved without legislation requiring retailers and the food service industry to ensure that 100% of edible food waste is redistributed where redistribution mechanisms exist.
21. So, despite this plethora of voluntary initiatives, there is still much work to be done, the speed with which early reductions took place is unlikely to be replicable without further incentives and penalties across the supply chain as well as within homes. Alongside this, prominent retailers and chefs have called for legislation in both food and packaging waste as the only way to spur further action and ensure a level playing field for businesses[20]. Legislation is the only way to embed a holistic approach to food waste from farm to fork.
22. A Food Waste (Reduction) Act would give current efforts to reduce food waste a statutory structure to work within, and ensure that action is taken by actors across the supply chain and not just the ‘big six’ supermarkets. This Act should:

• Build upon the Food Waste (reduction) Bill[21] tabled by Kerry McCarthy MP during the 2015/16 parliamentary session.
• Require all manufacturers, distributors and large supermarkets reduce their food waste by at least 30 per cent by 2025, including through redistribution to charitable organisations.
• Learn from positive action around the world (see Qu 5 below).
• Strengthen the powers of the Groceries Code Adjudicator to ensure fair dealing right across the supply chain, and help end avoidable food waste caused by uncompensated order cancellations, last minute changes to forecast volumes or specifications, and retrospective changes to supply agreements.

Q5: What are the comparative approaches to reducing and managing food waste in the devolved nations, and across Europe?

23. The devolved nations have taken a broadly similar approach to England in tackling food waste generated across the supply chain. However, where action is devolved – ie around local authority approaches to the disposal of consumer and municipal food waste – both Scotland and Wales have evidence of substantial improvements in recycling rates as result of higher prevalence of household food waste collections. Currently, across Scotland and Wales 91% and over 99% of households respectively are provided with kerbside food waste collection, while in England this figure is just 62%.

24. Earlier this year, the Scottish government established a national food waste reduction target of 33% by 2025[22]. While the target is not statutory, along with tougher regulations on the disposal and recycling of food waste by businesses, it puts Scotland on track to meet the UN Sustainable Development Goal of halving food waste by 2030.

25. Across much of Europe other nations are passing measures requiring action on food waste. This statutory approach may soon be enshrined in the EU’s Circular Economy Package (CEP) (and more specifically the Directive 2008/98/EC on waste), presenting a historic opportunity for Europe to set the bar high for food waste reduction.

26. Positive approaches which might be replicated in the UK include:

• France: a new law, the Loi Macron, requires supermarkets of over 400m2 to enter into formal agreements with redistribution charities, striving to end food waste in the retail sector – or face a fine[23]. The law has also made it easier for manufacturers to donate unwanted food directly to charity. Previous legislation provides companies with tax breaks for donating edible foods for redistribution rather than Anaerobic Digestion, thus promoting the correct usage of the food waste hierarchy.
• Italy: legislation passed in August 2016 launched a range of funded programmes to reduce food waste in schools, hospitals and public canteens. The Sprechi alimentari[24] also offers tax breaks and other financial incentives to businesses to donate food to charities, and removes regulatory barriers to food donation. 

September 2016