Wasting more than food? Oven ready contributions to emissions reductions targets

For many years at EU and UK level the contribution of waste, including food waste, to greenhouse gas (GHG) emissions has been well understood both in terms of emissions as part of the waste process but also in terms of the emissions associated with the production and transportation of the product. In the EU the implementation of the Waste Framework Directive’s hierarchy of preventing waste and encouraging reuse then recycling prior to recovery and disposal methods has been a longstanding requirement and the same obligations remain the case in the UK today. As waste separation and presentation for collection requirements continue to evolve across the UK, we review a snapshot of the developments at national and UK level and whether these align with UK GHG emissions reduction targets.     

GHG Emissions Reductions Targets

The UK’s GHG reduction target is 68% compared to 1990 levels by 2030 and 77% by 2035. There are also national reduction targets. The Committee on Climate Change recently observed that for the UK’s Third Carbon Budget which covers 2018-2022, (including the pandemic years), whilst the overall reduction for that period was met overall, agriculture emissions have not decreased much. This is stated to be “largely because there has been a lack of progress and extreme uncertainty around policy” and for waste, amongst other points, “there has been insufficient progress on recycling and composting”. Through this lens further measures, albeit at variable paces, could be expected in the UK. A recent judicial review challenge to the failure by the government to ensure the food strategy meets carbon budget targets was unsuccessful but increased attention to the possible contribution by the food and drink sector to emissions reductions.

Waste separation and presentation for collection

The waste hierarchy itself applies to all waste and across the UK. In Scotland since 2012 there has been an express legal duty to take all reasonable steps to ensure the separate collection of food waste produced by the business unless a rural exemption applies. In Northern Ireland subject to certain exclusions, anyone who controls or manages a food business that produces controlled waste must take all measures available as are reasonable in the circumstances to secure the separate collection of food waste produced. From 6 April 2024 in Wales, in addition to other waste streams, food waste from premises that produce 5kg or more of food waste in seven consecutive days must be presented for collection separately.  In England, following consultation, non-household municipal premises, except micro-firms, will be required to make arrangements for separate food waste collections and to present the waste in accordance with new requirements expected by 2025. 

Reporting

The UK government is presently considering its position on mandatory food waste reporting following its decision post public consultation not to bring forward measures broadly supported at consultation and in the face of a possible judicial review by environmental campaign group Global Feedback Limited. The proposal was to require data collection on food waste, monitoring of volumes under the food waste hierarchy for any Food Business Operator, and submission of data to an appointed regulator for publication on the public register. A decision is expected in the next 3 months. In the meantime, food waste reporting is currently done on a voluntary basis by many operators, and according to recent statistics, almost half of all large food businesses in England measured and reported on their food waste in 2022. In the Scottish Government’s January 2024 consultation paper “Scotland’s Circular Economy and Waste Route Map to 2030 Consultation”, one of its priority actions is to develop with stakeholders the most effective way to implement mandatory reporting for food waste and surplus by businesses by 2025/26.

However, food waste reporting cannot be seen in isolation but as part of the broader emissions and sustainability reporting context. In 2022 large businesses in the UK became obliged to report on climate related risk. On food and drink practices specifically, WRAP have released emissions reporting methodology: Food and Drink Scope 3 Protocols that can assist with reporting on Scope 3 emissions as, regardless of the outcome of the government’s consultation, there is increasing expectation for Scope 3 emissions to be included within ESG reporting and greenhouse gas targets. Businesses may also be required to report on food waste where it is material under more general sustainability reporting duties, and one notable example is the EU Corporate Sustainability Reporting Directive (CSRD) which requires reporting and disclosure against European Sustainability Reporting Standards including resources and the circular economy. The UK government has recently sought feedback on the practicalities, benefits and costs of reporting on scope 3 emissions that occur in the value chain when also considering whether to support international sustainability reporting standards.

In the EU, where a GHG reduction target of 55% by 2030 is being overshadowed by a possible 90% target by 2040, the European Parliament is scheduled to vote on its position in relation to food waste reduction targets this month. These proposals for new requirements intended to increase recyclability are contained in amendments to the Waste Framework Directive, and they include quite novel methods of regulation. In particular, local duties for the creation of awareness-raising and behavioural change campaigns and interventions regarding the importance of reduction of food waste production. It also includes actions to address inefficiencies in the functioning of the food supply chain, and initiatives to encourage food donations. These appear to be intended to go towards drivers for change in enabling processing of wastes as resources.

More activity is expected in the next 12-24 months and should be monitored carefully.

This article was co-authored by Laura Hipwell and Olivia Hill.

FOOD WASTE HIERARCHY

PREVENTION: Avoid surplus food generation throughout production and consumption.

RE-USE FOR HUMAN CONSUMPTION: Redistribute surplus food and drink for human consumption through redistribution networks and food banks.

RE-USE FOR ANIMAL FEED: Use for animal feed if no longer intended for human consumption.

RE-USE OR RECYCLE FOR BY-PRODUCTS: Process surplus food to make by-products that keep the high value of the molecule bonds of the material.

RECYCLE FOR NUTRIENTS RECOVERY:  Recovery of substances contained in the food for lower added-value uses such as composting or digestate from anaerobic digestion.

RECOVER WASTE BY LANDSPREADING

RECOVERY FOR ENERGY: Recover energy from waste by incineration.

DISPOSAL: This could be waste incineration without energy recovery, waste sent to landfill or sewer (increasing restrictions apply).