In reactie op het voorstel van de Europese Commissie bracht de Rli samen met verschillende Europese collega-raden op 31 oktober 2022 een advies uit over een aantal belangrijke aspecten van deze aangekondigde kaderrichtlijn.
Aanleiding en adviesvraag
In mei 2020 presenteerde de Europese Commissie haar "van boer tot bord"-strategie. In deze strategie kondigt de Commissie speciale wetgeving aan, een kaderrichtlijn voor duurzame voedselsystemen. Deze kaderrichtlijn moet bijdragen aan meer samen in het voedselsysteem, van productie tot de consumptie van voedsel, alsook de socio-economische en ecologische uitkomsten van al deze activiteiten op zowel Europees als nationaalniveau.
In 2022 startte de Europese Commissie met de voorbereiding van de kaderrichtlijn. Dit was voor een groep adviesraden, met Rli-raadslid Krijn Poppe als rapporteur, het moment om in het verband van het European Environment and Sustainable Development Advisory Councils Network (EEAC Network) een advies op te stellen gericht aan de Europese Commissie en de EU lidstaten, over een aantal belangrijke aspecten van de aanstaande kaderrichtlijn.
Informatie of reactie
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European society and its food system are facing a triple challenge: 1) guaranteeing a healthy diet for all, 2) mitigating and adapting to climate change, as well as 3) protecting and restoring habitats for their biodiversity and ecosystems services. Although the European food system is robust, it does not deliver sustainable diets, defined by FAO as those with low environmental impacts which contribute to food and nutrition security and to a healthy life for present and future generations.
To tackle the triple challenge in a complex network like the food system, a system approach is needed. At present, there is too much focus on the actors where the problems are observed, but as consumers and farmers are in a dependent position and not able to transform the food system, rethinking the roles of all the actors has to be addressed. Therefore, a Framework Law on Sustainable Food Systems, as proposed in the EU’s Farm-to-Fork Strategy, is required. This could make the system more resilient.
A just transition towards sustainable diets is key. To the extent that healthy diets are not affordable for consumers or a sustainable food policy would result in higher prices for food, compensation should be given by changes in income taxes, minimum wages or social security. Similarly, environmental regulations in the food industry and agriculture should not be shunned for the income effects, which could be compensated by direct support for farms with low incomes and payments for public services. This calls for coherence between the EU’s sustainable food system policy in the Common Market and (social and fiscal) policies in the Member States.
Such a mechanism for a just transition makes a policy on sustainable food systems possible that directs the strong innovation capacity of actors away from ever lower food prices towards more sustainable farming, food processing and food consumption. On average, the share of consumer income spent on food has seriously declined, which gives options to better target the innovation capacity to the reduction of environmental and health costs instead of a further decrease in consumer spending on food. The true costs of food should be reflected in markets.
To coordinate these changes and to overcome silos in policy making, this demands a food system policy with clear objectives that properly balances economic, ecological and social aspects. A food system policy that fosters human and planetary health in a coherent and balanced approach between an agricultural supply policy, environmental policy and food (consumption) policy is a big challenge, given the trade-offs and co-benefits between these policies and with other policies. The framework law is needed to support and guide Member States in steering towards a sustainable food system. A framework law must then be drafted in such a way that Member States remain able to respond to their own unique opportunities and challenges, while keeping the common end goal clear and duly anchored. To govern the food system with the purpose to “ensure sustainable diets”, it could be formulated as follows:
to guarantee a resilient European food system that ensures sustainable diets with low environmental and ethical impacts that contribute to food and nutrition security and to a healthy life for present and future generations by facilitating that
i. healthy, sustainable diets are available for all European consumers at prices that reflect their true cost in line with ‘the polluter pays’ principle.
ii. food is produced in satisfactory quantities, with processes that result in environmental performance that is as best as reasonably achievable and regenerate climate-resilient, healthy agro-systems.
iii. the food system works as inclusively as possible and relations between food chain actors are balanced, which results in livelihoods with fair incomes and working conditions for farmers and workers.
iv. new technologies are developed and best available technologies in relation to climate change and ecosystem services are promoted, respecting the precautionary principle.
A sustainable food system policy should use different policy instruments to balance several objectives. For example, regulation can remove the most unsustainable products from the market. Pricing instruments, with taxes or instruments like the Emission Trading System for greenhouse gases, can lead to innovations. There is no reason why food system actors should be exempted from economy-wide measures like carbon pricing.
To redirect innovation, classification of food into more or less sustainable types of food within a food category is needed (based on a process of certification of all commercial farms) as an extension of methods in organic farming and private label certifications. A classification of farms in (dark and light) green, yellow and orange supports benchmarking, price differentiation and the allocation of advisory capacity, (CAP) subsidies and land. Digitalisation of food chain transactions can support certification and reduce costs.
Certification should be used by food processors and retailers to label consumer products for environmental and social sustainability, in addition to labelling for preventive health. Its usefulness depends on the context of the food environment. Demand for sustainable food can further be supported by rules for public procurement. Food processors and retailers could be instructed to report the sustainability aspects of their sourcing in their ESG reporting. Similarly, the input industry could take responsibility for the sustainability effects of its sales to farmers. Governments can help farmers with eco-schemes, long-term ecosystems contracts and in the land market as well as with knowledge and innovation to become and stay more sustainable.
Rewarding farmers for the costs of their sustainability improvements can be achieved with a blending obligation for food processors. The certification system for raising standards can be used to oblige food processors and traders to buy-in a certain percentage of the most sustainable products and pay farmers a price that offsets the extra cost. This would reward more sustainable producers and raise the average price of the product towards its true cost. Such a system should also include importers and exporters to guarantee a level playing field with third countries and to prevent adverse effects.
Monitoring the impact of sustainable food policies at farm level can be based on the proposed Farm Sustainability Data Network (FSDN) in an integrated way at sample farms, collected in an auditable accounting approach. Monitoring of all individual farms (except the smallest) could be done with an extension of the IACS system that includes the results of the certification process.
The European Union has responsibilities for global resilience, including food and nutrition security and an intact biosphere, and should therefore be active in international policy mechanisms and standard setting. Broad support for a sustainable food policy that redirects innovation in the food system to the current challenges with true costs as a basis for markets can be generated by citizen’s assemblies.
To govern the European food system and align the relevant current EU policies, a coordination group composed of appropriate Commissioners should be established. In addition, a coordination mechanism between the European Commission and the national ministries should be set up that is cross-cutting through the traditional policy domains. Member States have to develop comprehensive national strategic plans for sustainable food systems, including actions in the social domain for a just transition.