Call on the EU to include farms in its food waste measurement!

From 2020 onwards, EU member states will for the first time be required to measure and report their food waste – an excellent step forward. But there’s one problem: the Commission are currently excluding the majority of food wasted on farms from reporting – even though on-farm food waste accounts for between 11-34% of the EU’s food waste, between 10-47 million tonnes of nutritious food. More precisely, the Commission are excluding food that is left unharvested, to be ploughed back in or left to rot in the fields, from measurement. We can’t let all that delicious, nutritious food go to waste!

The consultation closes on 4th April 2019, and will be the last chance to influence the EU’s methodology for measuring food waste for years. If you agree that farms shouldn’t be excluded, please respond to the consultation!

Our guide to completing the consultation:

  1. Click here to access the consultation.
  2. Click on “Give feedback”
  3. Login (if you already have an account) or register (it takes literally 20 seconds)
  4. Copy/adapt our template example response (see below) into the “feedback” box, or even better, write your own
  5. If you agree with our policy brief, and would like to, you can attach it to your submission to back it up (optional)
  6. Fill in the other details and click on submit

Here is our template text for responding to the consultation, to help inspire your response – feel free to copy and adapt this. The more personalized you can make it the better:

We commend the Commission’s recognition of food waste as an urgent issue which needs to be addressed to ensure environmental sustainability – 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.

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,