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Why the climate emergency demands food waste regulation

Martin Bowman is the Senior Policy and Campaigns Manager at Feedback, managing Feedback’s campaigns related to food waste and anaerobic digestion. He was previously the UK coordinator for Feedback’s Gleaning Network and worked on its Pig Idea campaign. He is a contributor to Routledge Handbook of Food Waste, a TEDx speaker, and has helped coordinate several This Is Rubbish campaigns.

Image: US EPA, Food waste piles up, Flickr, US Government Works Licence

Image: US EPA, Food waste piles up, Flickr, US Government Works Licence


An estimated third of the world’s food is wasted – enough to feed billions of people, accounting for roughly 8% of the world’s emissions, and unnecessarily using 30% of the world’s agricultural area. Food waste is therefore a climate and environmental issue – but it is striking that even in the UK, which is often seen as a world leader on food waste reduction, this connection doesn’t seem to be reflected in food and climate policy.

WWF and UNEP recently demonstrated that most countries do not include food waste measures in their Nationally Determined Contributions to the Paris Agreement. (Specifically, only 11 countries mention food loss while none mention food waste. See the box below for Feedback’s opinion on the distinction between these two categories.) The UK’s NDC mentions both food sustainability and general waste reduction but does not set specific targets for reducing food loss and waste. Despite decades of discussion of food waste reduction, action continues to be largely left to the realm of voluntary measures by business and charitable redistribution of surplus food. I’d like to make the case for why this needs to change to realise the full climate potential of addressing food waste, and why food waste is the ideal candidate for a first step towards integrating effective food and climate policy.

A note on terminology: Why Feedback avoids the term “food loss”

As described in the Table explainer What is food loss and food waste?, a distinction is often made between the terms “food loss” (which typically refers to food that becomes unfit for consumption before reaching the consumer and retail stage) and “food waste” (which refers to food that is safe to eat but that is discarded at the retail or consumer stages of the supply chain).

At Feedback, we advocate for the term “food waste” to be applied from farm to fork. The term “food loss” falsely implies that businesses always cause food waste unintentionally. It thus eclipses socio-economic factors such as cosmetic rejections and unfair trading practices, which often cause large volumes of pre-retail food waste as more powerful corporations push the risks and costs of food waste onto their suppliers. Feedback has documented these dynamics in the Global North and for countries in the Global South exporting to the North. The term “loss” thus generally lets large corporations evade responsibility for food waste, emphasising instead the need for individual consumer behaviour change in the Global North and technical fixes in the Global South.

Unfortunately, this damaging distinction has been embedded in Sustainable Development Goal 12.3, which sets a specific goal to halve food waste by 2030 but a vaguer target to “reduce” food loss, despite the FAO’s own data implying the majority of food waste occurs before the consumer stage in both rich and poor countries. Feedback supports Champions 12.3’s best practice guidelines which recommend that this 50% reduction target be applied from farm to fork.

The stunning potential of halving food waste

Feedback recently completed a comprehensive Life Cycle Assessment, which modelled the effects of halving UK food waste through ambitious regulation, planting trees on 3 million hectares of spared grassland, and growing peas and potatoes on nearly 1 million hectares of spared cropland. Astonishingly, we found that this would save and offset the equivalent of 11% of the UK’s total domestic emissions, more than the emissions of the UK’s entire domestic agriculture sector – a sector usually considered difficult to decarbonise – as well as have the potential to produce enough potatoes and peas to feed 28% of the UK population. Some of these savings in emissions and land would occur overseas – reducing the emissions associated with UK food imports, so the savings present an unmissable opportunity to decarbonise UK food supply chains. Note, however, that this LCA did not account for the economic viability of this scale of tree planting, or the fact that some of the grassland spared may not be suitable for reforesting if they are natural grassland, as opposed to areas that were deforested at some point in the past. For more on the distinction between types of grassland, see page 20 of the FCRN (now Table) report Grazed and Confused.

Figure: Halving food waste through ambitious regulation.

Image source: Feedback (2020), Bad energy: Defining the true role of biogas in a net zero future. The UK’s current voluntary food waste targets aim to halve edible food waste only, using a baseline of 2007 onwards and excluding primary production from concrete targets. An ambitious regulatory target aims for 50% reduction of all food waste (in practice, a greater than 50% reduction of edible food waste) from farm to fork against 2015 baselines.


As this analysis lays bare, food waste is not only an emissions problem, but also a land use problem: in simple terms, millions of hectares of land, both in the UK and abroad, are used to grow food that is never eaten. At a time when we need to be reining in agricultural expansion, and freeing up land for carbon dioxide removal and nature restoration, this is indeed worrying. The UK’s failure to protect our natural habitats is stark, with the government’s own self-assessment indicating we are failing to meet 14 out of 20 biodiversity targets agreed ten years’ ago at the Convention on Biological Diversity.

The implications of food waste for agricultural land use also pose important questions for how we think about and measure productivity in a climate- and nature-sensitive way. Feedback has proposed that agricultural policy should prioritise delivering the greatest nutritional value (i.e. the production and consumption of foods which are directly beneficial to human health), for the least environmental impact (on soil health, water use, Greenhouse Gas emissions and local pollution, for example through nitrate fertilisers). In this formulation, food that is grown but not consumed is a direct drain on the UK’s agricultural productivity.

But significantly, these considerable potential savings are not the same as the food waste reductions that can be expected from the UK’s current progress. Feedback modelled a second scenario in which the UK achieves the aims set out by its current voluntary food waste commitments, and found that at best they will achieve only a 4% reduction in the UK’s total emissions, compared with an 11% reduction in the ambitious regulatory scenario mentioned above – even assuming that all of the grassland spared by this is afforested.

Figure: UK's current voluntary food waste reduction targets

Image source: Feedback (2020), Bad energy: Defining the true role of biogas in a net zero future.


The limits of voluntary action

To date, the UK’s approach to food waste reduction has been primarily business-led, coordinated via a series of voluntary agreements hosted by WRAP. Over the years these have contributed to considerable change: there are now around 261 businesses signed up to the latest iteration of these agreements, the Food Waste Reduction Roadmap. Significantly greater progress has been made than in countries which lack both voluntary agreements and ambitious regulation, especially at household level.

However, as with all approaches, there have been limitations, and there is now a case for scaling action up a level by shifting to a regulation-led, rather than voluntary, approach. Here’s why:

  • Low participation rates: Voluntary commitments come with the risk of low participation – and the UK government has had to intervene to boost signatories to the voluntary agreements. There is still particularly low coverage in the primary production and catering sectors. Of those signed up, a third have not yet provided any evidence that they are implementing any change, and nobody has disciplinary powers to punish this, creating a strong risk of free riders slowing progress. Low participation creates negative knock-on effects, as conveners keep the ambition of targets lower in an attempt to persuade reluctant businesses to join by making the targets less ambitious. For example, the RSPB has found evidence that voluntary agreements frequently set low targets and are held back by low rates of participation. Feedback has heard from several businesses that the UK’s voluntary targets to reduce food waste by 20% by 2025 under Courtauld 2025 were not set at a higher 30% level for fear that businesses would not sign up. Despite the lower target set, intervention to boost participation was still required.
  • Lack of transparency: Ten years since the UK’s first voluntary food waste agreement, only 60 businesses in the UK have publicly reported their food waste data (nearly all of them Tesco suppliers) – less than 10% of the businesses responsible for most of the UK’s food waste. Seven years have passed since Tesco led the way by reporting its food waste figures for the first time, and sustained campaigning and threats of regulation have raised great pressure on food businesses to publish data since then. But without a level playing field, companies appear afraid or unwilling to publish their data, and progress is slow.
  • Slow pace of change: The rate of food waste reduction under the UK’s current voluntary commitments has been distinctly underwhelming. Between 2011-18 UK food businesses (retail, manufacturing and catering) reduced their food waste by only about 1% per year, seven years for a decrease from 3.11 to 2.88 million tonnes. The UK’s voluntary commitments set out for this to be reduced to 2.34 million tonnes by 2030 – a slightly higher ambition of about 1.5% per year reductions. It is not unreasonable to suppose that faster change might be achieved.
  • Exclusion of waste at primary production: Measuring food waste on farms is tough, but ignoring it is more problematic still. Current estimates indicate that more food waste and surplus probably occurs on UK farms (about 3.6 million tonnes, i.e. 7.2% of food harvested) than in retail, manufacturing and catering businesses combined. Once primary production food waste is factored in, businesses (farms, factories, retail and catering) in rich countries like the UK waste as much as households. But without data, it is locked out of UK reduction targets. Voluntary approaches have failed to get to the bottom of waste at primary production across the sector, with few producer businesses participating and little sense of progress.


Time for regulation

We believe a faster pace of change is possible by turbo-charging food waste reduction efforts through regulation. It is clear that we have reached the limits of what voluntary action can achieve, and the huge potential benefits of faster action on food waste should compel us to raise our ambition. There are some benefits that only state action can unlock – such as tax penalties, regulations and funding of primary production food waste measurement.

The tide seems to be turning with increased desire for regulation. Tesco has taken the unprecedented move of calling on the UK government to make it compulsory for UK businesses to publish their food waste data, and the UK will soon be consulting on whether to introduce mandatory food waste reporting. WRAP, the convenors of the UK’s voluntary food waste agreements, recently said: “Now is the time to get your act in order because mandatory reporting is coming. It’s not a question of if it’s a question of when”. The government has also promised a consultation on legally binding food waste targets.

Here’s our prescription for food waste action proportional to the climate emergency:

  • A good starting point for regulation would be for countries to adopt an ambitious food waste goal in their Nationally Determined Contributions, including a national binding target to reduce food waste (both edible and inedible) by 50% from farm to fork by 2030, against 2015 baselines.
  • Making it compulsory for food businesses to report their food waste would bring real accountability to spur faster change, as well as help the government set national baselines to measure progress against.
  • Increasing taxes on sending food to landfill and incineration in the short term, and banning food waste to incineration and landfill by 2030, would speed movement of food to better uses.
  • Greater government funding for food waste prevention, which is currently extremely low and largely left to businesses, would make a huge difference. Rather than focusing on food redistribution efforts, which often act as a short-term sticking plaster for both food poverty and waste, countries should focus on designing both food poverty and food waste out of the system in the first place. For instance, poverty can be reduced through more equal distribution and redistribution of wealth, increased minimum wages, stronger social welfare systems and strengthened public services.
  • Making it compulsory for food businesses to join (currently) voluntary agreements, and introducing penalties for insufficient action, would prevent free riders, level the playing field for businesses, and prevent businesses from dropping out if ambitious measures are proposed.
  • Introducing and strengthening the powers of ombudsmen such as the Groceries Code Adjudicator would protect suppliers domestically and overseas from Unfair Trading Practices, which allow powerful buyers like supermarkets to pass the risks and costs of food waste onto their suppliers through means such as last-minute order cancellations and cosmetic rejections.
  • The race should also be on for governments to fund measurement of their nations’ primary production of food waste, and integrate this into national reduction targets – this would be a break-through because no country in the world currently has yet robustly measured food wasted in the field on farms, which is crippling global efforts to tackle it. This is despite the FAO having previously estimated that more food may be wasted in primary production than any other sector globally. Studies from California to the UK to Senegal have found that food waste on farms is likely to occur at stunning levels.
  • Supporting diverse and localised shorter supply chains would diffuse the power of supermarkets to push food waste onto their suppliers, as well as put more power in the hands of local communities to ensure wider food access.

No country to date has introduced most of these measures. But this makes it all the more important that we test them out, be that in the UK or elsewhere, to see whether they work and other countries can replicate them. Regulation has yielded huge progress in other spheres – for instance, with the introduction of the plastic bag tax, the number of plastic bags given out in the UK fell by 95% in 5 years, after years of sluggish industry progress. The huge potential benefits of more ambitious food waste reduction for global food security, land use and climate change mean that business as usual will not do – we need to expand our imagination of what is possible.

For more information, see Feedback’s recent Policy Brief: When there’s no waste, there’s a way (to net zero). See also the Table explainer What is food loss and food waste?

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