The future of food labelling? Voluntary sustainability food label pilot and proposed metrics

United Kingdom

A voluntary pilot scheme is being launched in the UK this autumn, which allows food business operators (“FBOs”) to include an "eco-score" on the label of their food products, with the aim of allowing consumers to make more sustainable purchasing decisions. Separately, a partnership led by the Environment Agency has recently launched a project to establish standardised metrics to measure environmental performance in the food and drink sector. These initiatives could eventually lead to changes in the way that food products are labelled.

Foundation Earth Front-of-Pack Score

Non-profit organisation, Foundation Earth, has been established to issue front-of-pack environmental scores for food products, where such products are given a traffic light score of A+ to G based on their impact on the environment. Green labels are being issued for products deemed more “environmentally friendly” and red labels for those that are not. The label resembles the colour coding used for front-of-pack nutrition labels, which are also voluntary, but widely used in the UK (in addition to the mandatory back-of-pack nutritional declaration).

When generating the score, Foundation Earth analyses the environmental impact of the food product by conducting a life cycle assessment against four key criteria: water usage, water pollution, biodiversity, and carbon emissions. All stages of the food product's lifecycle are considered as part of this assessment, including the farming of raw ingredients, processing, packaging and transport. The recyclability of packaging is not considered, however, for the reason that it is ultimately the consumer’s choice whether to recycle the packaging or not. Reportedly, the Foundation Earth R&D programme will produce an optimum and automated system for use across the UK and EU by 2022.

Full life cycle analysis is increasingly becoming an important principle in assessing the sustainability of consumer products. One of the key principles of the Competition and Markets Authority's recently published final guidance for businesses on “green claims” (reported on here), is that claims must consider the full life cycle of the product, including its supply chain, as this could impact upon the accuracy of the claim.

Foundation Earth Enviroscore

In parallel with the above scheme, Foundation Earth is running a second pilot, using a method called “Enviroscore” developed by an EU-funded EIT Food consortium of AZTI and Leauven University. The aim of this pilot is to prepare Foundation Earth for a Europe-wide roll out in 2022.

Enviroscore produces a 5-scale label (A-E) to communicate the environmental impact of food and drink products based on the Product Environmental Footprint ("PEF") methodology. PEF takes into account sixteen, more specific, categories during the assessment including: Climate Change, Ozone Depletion, Ionising Radiation (HH), Photochemical Ozone Formation (HH), Respiratory Inorganics, Non-cancer Human Health Effects, Cancer Human Health Effects, Acidification Terrestrial and Freshwater, Eutrophication Freshwater, Eutrophication Marine, Eutrophication Terrestrial, Ecotoxicity Freshwater, Land Use, Water Scarcity, Resource Use (Energy Carries), Resource Use (Mineral and Metals). The PEF methodology was tested between 2013 and 2018, and the European Commission is currently exploring how to use it in policies – the Circular Economy Action Plan includes a proposal that companies should substantiate their environmental claims using the PEF method. Further stakeholder consultations are expected.

Standardisation of environmental performance metrics

Separate to the voluntary pilot schemes, the Environment Agency recently launched a project to establish standardised metrics to measure environmental performance in the food and drink sector with the aim to avoid greenwashing. The aim of the initiative is to help FBOs to communicate their environmental performance more effectively to the public, minimising the opportunity for greenwashing.

One of the big challenges for FBOs is how to effectively communicate their environmental performance that goes beyond legal compliance. Many manufacturers and suppliers have developed and adopted various environmental metrics and it can prove difficult for FBOs to collect and interpret this data. The project therefore seeks to address this challenge by standardising environmental metrics.

The Environment Agency will be working in partnership with various groups including the Scottish Environment Protection Agency, the Northern Ireland Environment Agency, Waste and Resources Action Programme and the British Standards Institute to deliver this project. The intention is for the partnership to work with the Institute of Environmental Management and Assessment, trade associations and private sector organisations to understand and ensure the feasibility of the metrics. The timeline for the delivery of the project is, however, unclear and there is also little indication as to how the results will be used and whether this could lead to mandatory labelling on food products.

Comment

For the time being, sustainability labelling for food products has yet to be legislated on and remains voluntary, notwithstanding sustainability guidance and general consumer protection laws applicable to marketing. The recently proposed Food Labelling (Environmental Sustainability) Bill failed to pass through Parliament, however, in view of the increased focus on the sustainability of food and the notion of empowering consumers to make their own informed choices as to the products they purchase, it is likely that the Government will come under pressure to provide a standardised form of sustainability labelling for food products. The European Union already is moving in this direction, with the European Commission's Farm to Fork Strategy (which aims to make food systems environmentally friendly), containing proposals for a sustainable food labelling framework by 2024 and other initiatives to strengthen the role of consumers in the green transition including revisiting PEFs.

It remains to be seen whether the initiatives will lead to a more unified approach to sustainability labelling for food products and whether mandatory sustainability labelling will be introduced. FBOs should therefore keep abreast of the developments in this area both at UK, EU and certain national Member States’ level and contribute to any future consultations to ensure that any form of sustainability labelling which is developed, is suitable for their products.