The European Commission has kickstarted an initiative aimed at making its food system more sustainable, while integrating sustainability into ‘all food-related policies’.
As part of the initiative, the Commission is preparing to implement new rules concerning the sustainability labelling of food products.
In a joint letter sent to the Commission this month, 14 NGOs appealed for ministers to reject the Product Environmental Footprint (PEF), which they claim is being considered by DG ENV as a basis for the upcoming substantiating green claims proposal.
If selected in that context, they stressed, it would also apply to agri-food products and could be taken up by DG SANTE to assess the environmental performance of food in the upcoming sustainability labelling initiative within the Framework legislation on Sustainable Food Systems.
“The PEF methodology is not adequate to assess the environmental performance of agri-food products,” they insisted. “When applied to food, PEF gives misleading results.”
‘The more extensive the agricultural practice is, the worse it scores’
The PEF is a multi-criteria measure of the environmental performance of a good or service throughout its life cycle.
PEF information, according to the Commission, is produced for the overarching purpose of seeking to reduce the environmental impacts of good and services taking into account supply chain activities, from extraction of raw materials, through production and use, to final waste management.
The group of NGOs, which includes The European Consumer Organisation (BEUC), Compassion in World Farming (CIWF), IFOAM Organics Europe, the Fair Trade Advocacy Office, and Slow Food Europe, have ‘serious concerns’ about PEF methodology.
While ‘fully’ supportive of ‘meaningful’ sustainability labelling of food products, they claim ‘product-focused’ PEF was initially designed for industrial goods and was not meant to approach complex agri-food systems in a ‘holistic’ way.
In the letter addressed to Executive Vice-President Timmermans, and Commissioners Kyriakides, Sinkevičius, and Wojciechowski, the NGOs noted the methodology is still relevant for manufactured industrial products, but ‘misleading’ in a food context.
The more extensive the agricultural practice is, the worse it scores, they claim. “For instance, eggs from hens in cages score better than free range eggs, which in turn score better than organic eggs.
“When it comes to agri-food products PEF is predominantly an indicator of yields, favouring the most intensive methods of production while disregarding both a number of positive elements and the negative externalities of the food production process.”
BEUC, IFOAM, and Slow Food Europe respond
For BEUC, current PEF methods tend to favour intensive farming and penalise extensive and organic agricultural practices. “As such, it is ill-suited to assessing how environmentally friendly food products are,” Camille Perrin, senior food policy officer at BEUC told FoodNavigator.
The problem with PEF, we were told, is that it ‘lacks robust indicators’ for several key environmental issues, including land degradation, biodiversity losses, pesticides effects, or imported deforestation.
“It also fails to consider and reflect the positive externalities of agricultural systems.”
BEUC is supportive of developing a method to measure products’ environmental footprints, Perrin stressed, ‘if done right’. “With 57% of European consumers supporting compulsory sustainability information on food labels, this could be a powerful tool towards greener consumption.”
Slow Food Europe, too, is speaking out against PEF. The group campaigns for more holistic EU and farming policy to protect traditional foods and small-scale farmers across the bloc.
“The main concern for Slow Food over the PEF is that it is not designed and equipped to assess the overall sustainability of food, and therefore would not give the right signals to consumers and businesses,” Marta Messa, director of Slow Food Europe, told this publication.
“The PEF generally gives better scores to food products from intensive agriculture and discounts the many positive externalities that organic or agroecological food systems can bring.
“We believe it is incoherent with the vision of food systems that the EU has committed to move towards in its Farm to Fork Strategy.”
IFOAM Organics Europe is similarly concerned that PEC does not adequately account for the environmental impact of food products when it comes to externalities such as the impact of pesticides, the impact on biodiversity, or animal welfare, associate manager Silvia Schmidt explained.
“The PEF can differentiate the environmental impact between food categories, but not within food categories. This is because the PEF does not differentiate well between the impact of different methods of production.
“For instance, an apple with the least environmental impact will have the same final score (A) as an apple with the highest environmental impact.”
When applied to bio-based products such as food, the PEF is merely an indicator of yields, she continued.
Which methodology should be adopted?
In the joint letter, the NGOs state that any future sustainability label must aim to support a transition towards more sustainable food systems, rather than further increasing intensification.
The PEF does not ‘adequately take into account’ impacts on biodiversity nor the use of pesticides: “for instance, the ongoing PEF category rules for marine fish does not include fishing methods (and hence fails to consider fish stocks reductions), so any sustainability label exclusively based on the PEFCR would miss fishing’s most important impact.”
FoodNavigator asked BEUC, Slow Food Europe, and IFOAM Organics Europe whether they favour a particular environmental labelling scheme for food products.
BEUC has not made up its mind just yet. However, a ‘meaningful’ environmental label for consumers should meet some certain criteria, said Perrin. “Notably, such a label should allow for the comparing of foodstuffs within and across categories to steer consumers towards greener products methods (e.g. organic) and more plant-based diets.
“Importantly, an environmental label for food must be closely aligned with the objectives of the Farm to Fork Strategy, including the use of pesticides, fertilisers and antimicrobials, increasing the share of EU farmland under organic farming and improving animal welfare.”
Slow Food Europe, too, has yet to select a preferred scheme. “There are a few labels being developed at the moment in different countries, with different advantages and weakness,” Messa told us.
For Slow Food, it is important that sustainability labelling methods make for ‘transparency, clear’ information that ‘empowers’ consumers to make their own choices.
“It is also very important that such a label take a holistic approach to sustainability and does not nudge consumers to pick environmentally-friendly products at the expense of guaranteeing fair income to [farmers] to ensure good animal welfare consumers.”
Concerning IFOAM Organics Europe’s position on which environmental labelling scheme should be adopted for food, associate manager Schmidt said it favours one that takes into account externalities such as the impact of food production on biodiversity, the impact of pesticides on the environment, and on animal welfare.
“We are not asking to completely set aside the PEF, but to build on it with complementary – yet crucial – indicators that would reflect the environmental impact of a certain food product in a more comprehensive, fair and unbiased manner.”
IFOAM Organics Europe considers PlanetScore to be one of the ‘most developed’ environmental labelling schemes that currently takes such indicators into consideration.
It has also been suggested that PlanetScore, in contrast to life cycle assessment (LCA) and Eco-Score, supports the agroecological transition, and is therefore in line with the Farm to Fork strategy initiatives.
The European Commission did not immediately respond to FoodNavigator’s request for comment.