1^st December 2020

The Common Agricultural Policy (CAP) and the Green Deal (GD) are two of the main flagship European policies that define the current state of play of the institutions. They are different policies, both regarding the timing (the former has been a flagship policy of the EU for almost 60 years, the latter has been defined only since December 2019); and their content (the former regarding altogether food security, food production levels, accessible prices of foodstuff, stable incomes for farmers, environment and rural development, the latter climate neutrality and environmental action).

Yet, the agriculture sector has been found to be one of the main contributors to climate and environmental (C&E) changes. Given the links between agriculture and climate, would it be possible for the CAP to become an instrument of the Green Deal?

Considering this context, the European Parliament’s Committee on Agriculture and Rural Development (ComAgri) commissioned a study on these very links conducted by the INRAE and AgroParisTech. Their researchers assess the proposed GD measures and try to picture scenarios where the CAP adopts them, concluding that, even if this exercise is possible[1], it could be a dangerous move for the whole food-chain given the uncertainties on a number of issues and the weak economic assessments. The study is titled “The Green Deal and the CAP: policy implications to adapt farming practices and to preserve the EU’s natural resources” and can be found here.

All in all, the question that this report tries to answer is “will farmers (and consumers) be willing to bear short-term production and price unbalances for a possible greener future?”

Main Findings

The study outlines that in order to reach the major objectives of the Green Deal related to climate neutrality, biodiversity, health, and resources, the F2FS and the EU Biodiversity Strategy for 2030 set quantitative targets that concern agriculture as well as downstream levels of the food chain (producers and consumers).

Main quantitative objectives

–       Reduction of use in pesticides, fertilisers, antimicrobials

–       Increase of land under organic farming and protected areas

–       Restoration of semi-natural habitats

Non-quantifiable objectives

–       Greenhouse gas (GHG) emissions for agriculture and food systems

–       Animal welfare

–       Circular bio-economy

–       Reversal of overweight and obesity trend

–       Healthier and more environmentally friendly diets

Assessing the main challenges GD for European agriculture and food

The study highlights and analyses the main GD challenges for European agriculture and food by different areas in order to illustrate to what extent evolutions and projections of key parameters (indicators) are aligned with the Green Deal ambition, objectives and the quantitative targets related to agriculture and food.

            Agriculture and Climate

The study says that GHG emission trends in agriculture have slightly increased over the last few years and that agriculture has barely contributed to overall reductions. Even considering the 2013-2018 trend, GHG emissions will not achieve significant reductions. The researchers stress that the whole carbon footprint needs to be evaluated – from production to consumption and for the whole EU system. Moreover, carbon leakage needs to be addressed as, for instance, a reduction in European livestock will lead to an import of animal products from non-EU countries.

            Agriculture and Environment

In terms of agriculture and environment, the study highlights that there are contrasting evolutions between MS in pesticides and fertiliser use. Moreover, the nitrogen balance is increasing and at odds with 50% reduction targets. On a positive note, the sale of antimicrobials has decreased significantly over the last few years and the target could be reached. Regarding organic farming targets, the increase in organic farming is not sufficient to reach the 25% target by 2030. Organic farming overall has environmental benefits through the reduction of chemical pesticide use, mineral fertiliser and antibiotics. However, the impact of organic farming on GHG emissions remains unclear, according to the study. In relation to biodiversity, the study finds that intensive farming is the primary cause of biodiversity loss and stresses the need for a “major leap” in policies. The researchers also point out that the “EU Biodiversity Strategy for 2030 questions the consistency and completeness of legislative proposals of the future CAP with the high level of ambition displayed by the EC in that domain”.

            Circular Bio-Economy

Although the Circular Bio-Economy Action Plan is not directly linked to agriculture and food systems, there are areas in the sector that will be affected such as packaging and recycling.  However, the potential impact of bio-economy is controversial, as it could lead to more land-use, more intensive land-use and more chemical input. Moreover, the researchers present a “domino effect” scenario in which sustainability criteria imposed on one sector can also have limited overall impacts, as sectors are not constrained.

            Food losses and waste, packaging and recycling

There is a significant potential for the reduction of GHG emissions through the reduction of food losses and waste and the researchers stress the fact that these areas should be encouraged for a transition towards more sustainable food systems. However, the study points out that there are large differences in relation to packaging and recycling in the MS and thus a lack of “harmonised definitions and methodologies among MS”.

            Healthy and environmental-friendly food industries and diets

The study stresses that there are currently no quantitative objectives or targets provided for increasing the availability and affordability of healthy and sustainable food options. At the same time, overconsumption and unhealthy diets vs. underconsumption and food insecurity at EU level needs to be addressed, as well as the significant differences in progress and policies among Member States. Similarly, according to the researchers, prices of environmentally-friendly foods and access to environmentally-friendly food items and diets for low-income households have not been sufficiently addressed in the current proposals. Studies outline that EU diets currently show an insufficient fruit and vegetables intake and a high intake of red meat, processed meat and sweet beverages. They warn that any food price increase will have significant impacts on consumers and the composition of diets. At the same time, in terms of climatic and land-use impacts of food diets, the researchers point out that animal-based products are a high source of GHG emissions and agricultural land-use. In terms of food insecurity, the study shows that it is more prevalent among risk groups such as women, older people, out-of-work, people with disabilities, and that it disproportionately affects MS with a high percentage of disadvantaged groups or a lower welfare state.

Impacts of technical solutions of the Green Deal

            Precision farming, Agroecology

The study states that precision farming can be used to reduce the use of pesticides without impacting yields and production levels. This is pointed out as several MS have been found to “overuse” pesticides. Using less pesticides would lead to a reduction of GHG emissions, however, there are currently low levels of adaptation for these new measures among EU farmers due to production risks, investment and new skills needed. Furthermore, the study proposes integrated pest management, nutrient management, organic farming and agroforestry as useful means to protect the environment. Agroecology and organic farming are said to have positive impacts on the environment, but induce a decrease of yields and production levels. On a positive note, the study shows that the sales of veterinary products have dropped significantly (more than 35% between 2011 and 2018) and that the target of a 50% reduction could be reached by 2030.

            Carbon Balance

In relation to carbon balance, the study shows that agroforestry can have significant benefits for carbon sequestration, along with planting hedges, use of cover crops and low or no tillage practices. However, they also state that the implementation costs are high so far. Benefits of food waste reduction are possible lower GHG emissions, as well as the increased use of co-products from agricultural production (e.g. methanisation) which could lead to improved management of nutrients, reduced energy consumption and again, a reduction of GHG emissions. Bio-based products have a high potential for storing carbon, reducing gross GHG emissions and diminishing pollution throughout the production cycle, as waste can be recycled or used as feedstuffs or fertiliser. In terms of food diets, replacing meat with plant-based alternatives would lead to a significant reduction in GHG emissions, land-use and water use. Furthermore, they claim that a food product reformulation as an industry-wide measure (i.e. which does not depend on consumer behaviour) would benefit the entire population.

In relation to the Farm to Fork Strategy, the study stresses the fact that food and nutrition was not or very poorly included in previous proposals, only marginally tackled climate change. In terms of budget, the study highlights that disagreements between council and EP when it comes to budget discussions, make the timeframe of implementation uncertain.

Recommended Policies

The researchers argue that some of the CAP proposals have to be strengthened in order to be “compatible with the GD” and thus would “have the potential to accommodate the GD’s ambitions”. They stress that the June 2018 draft regulations for the next CAP are only marginally consistent with the climate, environmental, nutritional, and health ambitions of the GD.

In order to do that, they claim that the following measures are necessary: enhanced conditionality; compulsory eco-schemes; and the allocation of at least 30% of the Pillar II funds to C&E measures. However, they point out that “much will depend on the actual implementation in National Strategic Plans”.

Researchers found that sound impact assessments of any policy options are crucial in order to identify possible trade-offs between different climatic and environmental objectives. The land issue requires particular attention: the de-intensification of farming practices and systems implicitly included in the Green Deal could require more agricultural land, both in the EU and further abroad, with possible adverse ecological consequences (“pollution leakages”).

That being said, the study reports on three main policy directions that will favour the closing of the gaps between CAP and GD, notably:

–       Efficiency gains policies: where farmers will be incentivised to do technological updates towards digital & precision farming tools and broadband coverage[2]. These measures may reduce C&E impacts (because of reduction of fertilisers and pesticides) while maintaining the yields. The study suggests that while the initial (fixed) investments costs will increase, variable production costs will lower, allowing for a balanced economic outcome.

–       Re-design of the production system: implying the de-intensification of some (conventional) farming practices and the increase of others (notably, organic production). This measure can be beneficial for C&E (in relation to biodiversity, air and water protection), yet, “lower yields induced by less intensive production processes may increase agricultural GHG emissions per product unit”. Overall, this measure will lead to an increase in per-unit production costs that could be repaid in the long-term through productivity gains and restoration of soil fertility. However, that could also lead to diminishing farmers’ incentive to switch towards agro-ecological and organic practices.

This measure is open to controversy, as on one hand C&E objectives could be facilitated, on the other hand public support measure will be essential as the study points out that “subsidies play a key role in sustaining the income of organic farms” and that organic farms are on average less productive (- 9%) than conventional ones, yet they receive + 66% of direct aids. With these numbers, the researchers assume that total payments to organic farmers would have to increase by about €20 billion over the 2021-27 period Pillar I (considering an increase of 517 100 organic farms in the EU).

–       Change in diets and consumption behaviours: the researchers assume that consumers will change consumption habits (without specifying how) towards more environmentally friendly food products. This potential change in purchasing patterns should mean that the consumer is willing to pay a higher price for foodstuff (considering the previous point and the consequent increase in final prices due to more organic farming). Nonetheless, the researchers counterbalance this scenario by foreseeing that, in this context, EU meat production will decrease and will shift more towards import, while the increase of domestic production of fruit and vegetables could lead to negative consequences on C&E and quality of soil given the higher yield productivity.

The study stresses that the higher cost of lower caloric and more balanced diets is a potential obstacle, especially for low-income households. Public policies that increase consumers’ awareness of the health, climatic and environmental impacts of food choices, as well as the modulation of consumption prices, are required in order for consumers to adopt healthier and more plant-based diets.

In a globalised economy, there is as a risk that the more “virtuous” European behaviour would displace the various issues through higher imports and would be worsened by distortions of competition. From this point of view, the elusive “border adjustment” tax and the (barely enforceable) environmental and social clauses in recent trade agreements show little guarantee against a loss of competitiveness. Land use shifts and imported deforestation, biodiversity loss or water depletion would do little to help the planet.

Recommended Measures

The researchers from INRAE and AgriTechParis raise three main questions based on which they make some more concrete recommendations for possible changes in the current CAP negotiations. They question if the GD objectives will actually become binding or if they will remain “aspirational”; they question what will determine the extra payments, and if the proposed indicators will be able to monitor and control the GD.

The researchers stress the introduction of the “polluter-pays and provider-gets” principle proposing a taxation/subsidies system that “requires taxing the main determinants of agricultural GHG emissions and biodiversity loss” and remunerates the actors who will do the opposite; or alternatively by increasing conditionality.

A tool to implement these fiscal incentive/deterrent systems will be eco-schemes, for which the authors suggest eight measures as possible concrete options for this tool.

These are:

–       Option n°1: permanent grassland – to remunerate farmers who do not plough any grassland and de facto turn them into permanent pastures.

–       Option n°2: wetland and peatland – to remunerate farmers who manage/maintain and restore/create wetlands and peatlands.

–       Option n°3: crop rotation – to remunerate farmers who include nitrogen-fixing and/or catch crops in the crop rotation.

–       Option n°4: payments to remunerate higher landscape diversity features on farming soil.

–       Option n°5: pesticides – to remunerate the best performances in the pesticide use for each type of crop.

–       Option n°6: antimicrobials – to remunerate the best performances in the antimicrobials use.

–       Option n°7: livestock – incentives for farmers to report on their emissions related to nitrogen fertilisation practices and cattle herds. They also suggest removing coupled support for ruminant livestock.

–       Option n°8: animal welfare – to compensate farmers who decide to go beyond the law (SMR).

These proposed measures, however, lack economic assessment and precise numbers (i.e. percentages or budget recommendations) and do not seem to consider the impact on small-scale farmers. Moreover, they could help farmers who, despite the loss in productivity, will be compensated by public measures, but not by the market. In fact, a consequence that does not seem to be taken too much into consideration is the lower production that these measures will lead to: will there be enough supply to respond to the increasing demand?

On the topic of governance, specifically on indicators and Strategic Plans, the study expresses criticism on the fact that these measures could be easily dodged due to lax formulation of current proposals. In particular, the fact that “in duly justified cases, the Member States may ask the Commission to approve a CAP Strategic Plan which does not contain all elements” is underlined as a lax formulation that will allow MS too much flexibility and that could lead MS to “cherry picking” CAP instruments. Moreover, “the actual governance scheme […] does not allow the EC to impose MS to suspend payments if there is a lack of actual results”.

On this point, the researchers point out several unresolved issues for making CAP National Strategic Plans (NSP) more consistent with the Green Deal roadmap. In fact, the main issues concerning the Green Deal targets are: first, their legal status must be clarified; second, the ways in which they are calculated are not detailed enough and should be more precisely defined; third, the methods used to define the corresponding national targets are unknown. They also concern the CAP. The performance indicators currently proposed do not make it possible to monitor progress made towards the targets. More generally, the CAP does not allow progress to be sufficiently enforced, reported and monitored, nor does it impose an effective corrective action plan if progress does not occur.

The CAP proposals contain some useful elements in that regard, but so far, mostly on the innovation side. However, the level of ambition of the Pillar 1 eco-schemes and the Pillar 2 agri-environmental and climatic measures is left to Member States, and not all States seem to grant priority to climate issues in their strategic plans.

One main discrepancy between the Green Deal objectives and the CAP proposals is the proposed system of governance. The targets are frequently too loosely defined, allowing an opportunity for Member States to circumvent them, plus there is often a lack of legal basis on which to enforce them. In addition, the indicators proposed by the Commission seem highly ineffective, as do the provisions for withholding payments, with the proposed bonus scheme disproportionate to the challenges at stake. In brief, much of the Green Deal ambition is left to the goodwill of the Member States.

Scenarios

All in all, the study tries to define a possible scenario in which the described measures will be implemented. The researchers assume that the total number of farms remains constant, and that the number of organic farms increases threefold, while the conventional farms decrease proportionally.

A decrease of 15% in the use of fertilisers and of 30% in the use of pesticides is also considered. The authors suggest that the reduction in chemical input use generates a drop in plant yields of 10% and thus resulting in a reduction of the animal production as well (-12% for ruminant meat, – 8% for milk, and -4% for pig and poultry meat as well as for eggs). Moreover, these assumptions will represent a drop by – 4% of the production value, – 10% of the gross operating surplus, and – 15% of the family farm income. Overall, an estimated – €12.9 billion impact on the sector is suggested.

Following these possible changes in the farming sector, while assuming that prices and trade are constant, the study argues that the new organic farms could increase their profit, not because the price premium for organic products will offset the decrease in physical yields, but if the CAP public support is sufficient, i.e. resulting in an increase of €20 billion CAP payments for 2021-27.

At the same time, the average income for conventional farms, which remain conventional, would decrease by 25% per farm (€ -5.740, favourable scenario) or by 42% (€ -9.500, unfavourable scenario).

The study calculates the product price increases that would allow the compensation of farm income drops. In the central scenario, farm-gate price increases required to maintain constant the income of farms that were and remained conventional would range from +4.6 % for farms specialised in Cereals, Oilseeds and Protein Crops (COP) to around +11% for livestock farms specialised either in sheep and goats or in pigs, poultry and eggs.

At the same time, GHG emission reductions are estimated to reach -33.9 MtCO2eq, which is far from the target of a 35% decrease in 2030. These -33.9 MtCO2eq would lead to a 8.7% reduction of agricultural GHG emission (-34 MtCO2eq), mainly thanks to farms that were and remained conventional (-25 MtCO2eq).

Remarks:

• The suggestions made by the researchers on the tools that the CAP could provide to the GD’s objectives implicitly assume the creation of unnatural market situations, notably by subsidising with high amounts of public support activities that would not be able to survive otherwise.

• In order to conduct their study, researchers based their scenarios on some assumptions that might not be verified without increase of public support. This might be the case of the number of farms, prices and trade outcomes that the study proposes.

• In terms of trade, a sharp decrease of exports due to lower production in the EU and higher domestic prices could lead to a higher demand of products produced outside of the EU which could have a heavier impact on the environment. Additionally, a major farm restructuration with less, but bigger farms, could lead to increasing negative impacts on the environment due to the intensification of agriculture.

• Another important issue is the question of the ability of consumers to pay higher prices for more environmentally friendly food products as part of a change in consumers’ behaviour and dietary patterns. Higher prices of EU products could then encourage the promotion of indirectly imported cheap products. These in turn, could have a negative impact on the nutrition of EU citizens, especially those with lower incomes. This essentially creates a notion of “noble” nutrition targeted at a small group of EU citizens who are able to adopt it – a discriminatory scenario, which could lead to a further divide within EU society.

• In conclusion, FE underlines the call of the researchers for the strong need of serious impact assessments on the strategies of the GD concerning agriculture (notably, the Farm to Fork Strategy and the Biodiversity Strategy). These should be based on figures and strong scientific evidence. These, eventually, will help stakeholders understand the changes they are asked to do and will give these strategies serious and concrete legal basis to proceed. All in all, the Commission is in need of a change in paradigm. Its approach should be more based on science and effectiveness so that objective and credible paths should be designed to deliver.

[1] According to the study, in order for the CAP to adapt to the GD objectives, some features of the current negotiation positions at the institutional level should not be changed, namely: the enhanced conditionality, the compulsory eco-schemes, the allocation of at least 30% of the Pillar II to C&E measures.

[2] A policy in this sense can be found in the already agreed (in the ComAgri) Recovery fund for Rural Development, where at least 55% of the funds will be dedicated to investments of this kind.

Public health issues concern people and States. The former is often exposed to an unbalanced and lacking information system, whereas the latter have been trying to fight against spread health problems and diseases, given the top-priority that the matter has gained in most, if not all, governments’ agendas.

Indeed, in past decades public authorities proposed and implemented many policies with the common aim to educate citizens on what are the benefits of a healthy life trying to inverse the (increasing) trend in Non-Communicable-Diseases (NCDs).

Some States have introduced taxation and subsidies policies, some introduced labels on packaging, some others implemented true marketing (advertisement) campaigns, as well as many other solutions[1][4]. These and other practices are valuable, and even if the efforts done can be appreciated, the data show that the tendency did not change: people keep having un-informed purchasing behaviours during grocery shopping, they keep getting sick, and the spread of NCDs is still growing (with the exception of few States[2]). According to the World Health organization (WHO), each year people dying of cardiovascular diseases are 17.9 million (31% of global deaths), and 1.6 million the ones dying from diabetes (3% of the global deaths); in Europe, the proportion is respected [6].

By analysing these figures and trends, it seems that most of public policies implemented so far have had little effect on consumers behaviour and, therefore, on their health improvement[3].

In addition to that, private actors have decided to develop some mechanisms to educate the consumers (sometime in non-explicit forms, such as the usage of nudging strategies), with very mixed results depending on the product and the targeted population. At any rate, private-led methodologies are profit-based; therefore, their main concern is to lead the consumer to increase the consumption of a nutrient or food in a not-always healthy way.

But what if governments started to re-think the issue from a prevention approach, and invested in tools that, eventually, benefitted the public health of citizens, saving, in return, high medical expenses often covered by the public?

Surely, education plays a very important role in this matter: food-educated citizens are able to make better-reasoned choices that lead, eventually, to balanced and healthy lifestyles and reduce the possibility of diseases. However, governments have not invested enough in educational policies (especially in polices that target older population) being, as a matter of fact, a sphere of private life where normally the public powers do not intervene, considering the traditional – and sometime affective – role of the family in educating the youth in this respect.

However, in past years the growing popularity of fast foods, transformed products, frozen and pre-cooked meals [3], together with a reduction of time dedicated to the elaboration of the meal (cooking) and grocery shopping [2; 5] have changed consumers’ food habits. In many member states, the role of the family – and notably related to family’s member behaviour vis-à-vis food and meals – have changed quite dramatically.

Moreover, it has been shown [1] that the financial situation of the individual has an impact on the food choice. Notably, the lower the income is, the lower the educational level is, the more the person buys ready-to-eat meals and “junk food” with low and unbalanced nutritious outlooks. Opposite dynamics have been noticed in middle-high income population.

In this context, in recent years Front Of Package (FOP) labelling systems have been proposed by several public and private entities. Unfortunately, up to now, it is hard to see one of them fitting for a possible European-wide solution: the main problematic is that most of them do not inform sufficiently, do not educate, and create judgmental sentiments towards the food product and, eventually, the final consumer. A scientific-based and informative FOP is of the outmost importance to give consumers the tools to better evaluate the real nutritional quality and value of food in order to make healthier and balanced dietary choices. The problem is, notably, the link between the concept itself of “grading” foodstuff, individually one by one, and the fact that food represents first of all a cultural heritage (in some cases to protect[4]); it is related to pleasure, passion and memories, and it is becoming more and more a shelter for happiness when other services or goods are not affordable, notably for weaker economic classes.

Food labelling might be a controversial tool as it touches the scientific, emotional, and public spheres. It should be seen, though, as only one of the possible methods that governments can adopt to fight nutritional-related problems.

In order to be able to define the tools that the EU should use, first and foremost it is needed to well define the objectives that we want to reach: only by studying what influences them, which difficulties they might lead to, and what expectations governments hope to achieve, the EU can eventually propose a balanced and effective tool. The available options today have been created by surely bright and well-educated people – with noble motivation – but who, however, have considered too often personal returns.

The discussion is now open and new and innovative systems have to be experimented to find a common, harmonized (European) solution.

What’s on the market

Nutri-score[5]: It is the system developed by the French. It values final products with a 5-scale letter/colour design. Many studies have shown that this system is easily recognizable and that it communicates immediately an idea of nutritional value of a food product; nonetheless, it brings to unbalanced results, notably towards products that contain healthy nutrients (if introduced in small doses), and towards products that are intended to be used as components of a meal i.e butter and oils. Moreover, the Nutri-score creates a judgmental attitude in the consumer during the purchasing experience, resulting in a distorted perception of specific products and brands that are already used by some actors as a marketing tool. This system categorises food products in a binary, over-simplistic way (what is “good” vs. what is “bad”).

This approach ignores the principle of the food pyramid. In fact, every food can have its place in any diet as long as it is consumed according to its qualities (i.e. nutritional, cultural and pleasure) as part of a balanced diet. For instance, discouraging the intake of food such as milk because of its high nutritional outlook in fats, without taking into account the positive effects of their essential nutrients such as vitamins, calcium and other minerals is counter-productive. If a person uses this system as the only reference point for his diet it will lead to unbalanced nutrients intake.

Furthermore, the system analyses only some nutrients that can be found in the majority of food products that are partly different from those already considered as mandatory for the nutritional declaration provided by reg.1169/2011 (relating to food information to consumers). This regulation states that additional forms of expression and presentation are possible in order to stimulate the consumer to read the nutritional information and adapt consumption choices to a healthy diet[6].

To be noted that the algorithm was modified recently as an answer to the critics expressed by some countries feeling that its results were detrimental to some of their PDO-PGIs national productions. Moreover, Nutri-score’s point-accreditation system shows some unbalances in the assignation of the categories (letter/color). Notably, the weighting system used to class a product (assigning points) implies that little changes in the points assigned lead to disproportioned change in the classing.

Lastly, Nutri-score grades per 100 gr of food, independently of the average size of the portion of this food eaten by person. Thus, it can lead to a misinterpretation of the value of the intake risking to induce behaviour going against good habits and nutrition (single portions of 400gr labelled as A or B because the Nutriscore is calculated per 100gr, while the same product would be labelled E if the real portion would be at the basis of the calculation).

NutrInform[7]: it is the FOP labelling method proposed by the Italian government. It displays an energy-battery shape that informs about the percentage of nutrients that the product brings per portion (the reference portions have been defined for each product category on the basis of studies conducted by CREA[8] and Istituto Superiore di Sanità[9]), compared to the reference intakes, i.e. the average daily quantities of energy and nutrients recommended by reg.1169/2011. Its supporters argue that it is not discriminatory, since “it does not give good or bad grades”, but offers the consumers a complementary tool in order to understand the mandatory nutritional information required by reg.1169/2011.

The NutrInform label might require more attention and time to read due to the fact that it displays more complete nutritional information about the product. Indeed, the system is based on the general nutritional intake that a person is supposed to introduce in his/her diet on a daily basis. To be noted that these amounts can only be relative because every individual has different needs depending on the age, the sex, the physical activity habits, the metabolism, etc. In order to make sure that the citizens understand the principle of a balanced diet, an additional educational effort from the public sphere would be needed, involving increased time and financial resources.

The Italian method considers the general overview on a person nutritional intake. This concept intends to consider the personal approach to grocery and food, which is not product by product, but a more holistic one. This system using food portions represents a closer-to-reality approach as a measure for nutrients compared to the standard of 100 gr.

Traffic light system[10]: it is the FOP method used by the UK government. As the others, it is not mandatory but many UK supermarket chains and food producers have adopted it. It considers the following nutrients: calories, fats, saturated fats, sugars, and salt, and it displays them in the label, linking the amount of the nutrients to a percentage and a color. The percentage is relative to an adult’s reference intake (GDA)[11], and the color shows weather a product is high (red), medium (amber), or low (green) in fat, saturated fat, sugars, and salt, and how much energies (calories and Kilojoules) it provides.

Keyhole, Choices, Heart symbol[12] – positive logos -: these systems are used in the Nordic countries (Keyhole), Finland (Heart logo), The Netherlands, and Czechia (Choices). Through a symbol (that can be either a green circle with the shape of a white keyhole in the center, a heart shape, or a check) these methods imply the identification of the foods that are considered the “best in class” within their product category. It is applied only to the products that are valued healthy and that comply with one or more of the following characteristics: less and healthier fats, less sugar, less salt, more dietary and wholegrain (keyhole), compared to food products that are not labeled, or, more in general, whose quantity of nutrients remains under a certain threshold. The keyhole does not require the customer to read detailed nutritional information, which makes it easily identifiable and understandable; at the same time, it lacks information that might be of interest to the final user of the product such as the caloric intake.

These methodologies – called “Positive logos” – shown to be very effective in being recognized and understood, however, neglect the complete nutritional information to the customer. They value the products as a whole, and do not consider each nutrient as a single element. Moreover, they do not take into consideration the diet of the individual and contribute to the creation of perceived “class A” and “B” products.

Milestones for an efficient EU FOP labelling

The issue with the aforementioned and analyzed FOP labeling methodologies is that none of them includes, as far as today, the whole characteristics that a holistic European solution should have, notably:

NON-DISCRIMINATORY: the labelling system should be in line with the requirements provided by reg.1169/2011, therefore, it should aim at only informing consumers. While a labelling system should be informative and easy to understand, it should not result in an over simplistic classification of “bad” and “good” food products.

EFFECTIVE: An EU FOPNL system should be based on portions, in order to better inform consumers over the actual nutritional intake and value of every food. It should be objective and thus not penalize unduly nutritious agri-food products, often used as ingredients in other food preparations or consumed in portions lower than 100 g, as advised by dietary guidelines.

STANDARDIZED: the harmonized methodology should be applicable to the European markets. As a European standard, thus, it is foreseen the need to have common grounds and basics, and to respect general guidelines. In particular, the legislation should outline the basic characteristics that FOP label should follow in every MS, leading to the principle of standardization which would allow the European consumer to recognize the nutritional value of the product/nutrient everywhere in Europe, regardless of the Member State or the distributor. Therefore, such a system should be developed in a way which ensures that specificities of each Member State’s food culture, typical diet and national nutritional guidelines are followed. An EU system should be coherent with the EU policy on EU quality productions (PDOs, PGIs and STGs), which is opposed to hyper-processed foods, have strict product specifications, and should stick to them.

FLEXIBLE: the chosen methodology should foresee a margin of flexibility, within the standards agreed upon, so to respond to different diet habits and national priorities. Flexibility should also allow not to abruptly categorize a product/nutrient as “good” or “bad”, but to inform the consumer about its effects on health and the dosage.

ACCESSIBLE: In order to have a greater impact on societies, the methodology should be designed in a way that everyone could be able to understand them and receive the messages they are supposed to send, regardless of the social, economic, and educational level of the person.

ENGAGING: FOP labeling has been designed as an educational tool. First-time consumers and young adults are often the more receptive at the beginning. It is understood that the effects on the population can only be seen some years from its implementation. Thus, it is of imperative urgency to work on a common methodology that will be able to target also the population that is left behind by the labeling strategy, notably adults, elderly citizens with consolidated eating habits, and consumers who do not have the cultural knowledge to make the choice on what food to buy according to each individual’s particular conditions and state of health.

INCLUSIVE: studies have shown that “improving the heath of the overall population may increase health disparities between social groups” [1], notably, “those who were formerly at a lower exposure to risk derive the most benefits that those who were formerly at a greater exposure to risk”. The European solution should consider the effects that such systems have on the overall society and take a socially-holistic approach. The “leaving no one behind” motto should then be fulfilled at once.

In this context, Farm Europe sets up a dedicated department, EAT EUROPE, with the aim to tackle the most sensitive societal issues, focusing on the role that institutional issues play in citizen’s health, analyzing and defining tools that the EU and its member States could implement in order to prevent their population from habits that could lead to unhealthy lifestyles. It will reason on science and efficacy gathering knowledge of people focusing exclusively on EU common good and ability to deliver.

References:

[1] – Darmon et al. “Food price policies improve diet quality while increasing socioeconomic inequalities in nutrition », International journal of behavioral Nutrition and physical activity, 11 : 60, May 2014, [Google scholar]. Consulted on 17/09/2020.

[2] – Eurostat, “How do women and men use their time – statistics”, April 2019,  Eurostat. Online source, consulted on 23/09/2020: https://ec.europa.eu/eurostat/statistics-explained/index.php?title=How_do_women_and_men_use_their_time_-_statistics&oldid=463738#Participation_of_women_higher_for_cleaning.2C_cooking.2C_laundry.2C_etc

[3] – Grand View Research, “Ready meals market size, share & trends analysis report by product (frozen & chilled, canned, dried), by distribution channel (Supermarket & hypermarket, online retail), by region, and segmented forescast, 2020-2027”, May 2020. Online resource, consulted on 23/09/2020: https://www.grandviewresearch.com/industry-analysis/ready-meals-market

[4] – Mahesh, R., Vandevijvere, S., Dominick, C., & Swinburn, B. (2018). “Relative contributions of recommended food environment policies to improve population nutrition: Results from a Delphi study with international food policy experts”.  Cambridge University Press, May 2018., pp 2142-2148, [Public Health Nutrition]. Consulted on 17/09/2020

[5] – Smith et al, “Trends in US home food preparation and consumption: analysis of national nutrition surveys and time uses studies from 1965-1966 to 2007-2008”, April 2013, Nutrition Journal, US National Library of Medicine – National Institute of health. Online source, consulted on 23/09/2020: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3639863/

[6] – World Health Organization, « Non communicable diseases country profile 2018 », Switzerland, 2018. Online source, consulted on 18/09/2020 : https://www.who.int/nmh/publications/ncd-profiles-2018/en/

Footnotes

[1] High taxes on unhealthy foods, restriction of unhealthy food marketing for children, healthy school food policies, low tax on health foods, FOP, food claim regulations, private workplace food policies, trade policies.

[2] Depending on the diseases, different States have different statistics. Yet, Finland and Cyprus show an overall tendency of improvement.

[3] Even if taxes and subsidies have shown to improve some aspects of the nutritional quality of food choices and are considered the most effective amongst the recommended food policies [4], they are not wide effective because of the substitution effect between taxed and non-taxed foods, and due to heterogeneous consumer responses depending on income. Moreover, it has been found that it increases the socioeconomic disparities [1].

[4] Therefore, the label should be coherent with the Union’s efforts to promote and preserve GIs, PGIs, PDOs.

[5] For more information : https://www.santepubliquefrance.fr/determinants-de-sante/nutrition-et-activite-physique/articles/nutri-score

[6] Art.35 of Reg.1169/2011: Article 35 Additional forms of expression and presentation 1. In addition to the forms of expression referred to in Article 32(2) and (4) and Article 33 and to the presentation referred to in Article 34(2), the energy value and the amount of nutrients referred to in Article 30(1) to (5) may be given by other forms of expression and/or presented using graphical forms or symbols in addition to words or numbers provided that the following requirements are met: (a) they are based on sound and scientifically valid consumer research and do not mislead the consumer as referred to in Article 7; (b) their development is the result of consultation with a wide range of stakeholder groups; (c) they aim to facilitate consumer understanding of the contribution or importance of the food to the energy and nutrient content of a diet; (d) they are supported by scientifically valid evidence of understanding of such forms of expression or presentation by the average consumer; (e) in the case of other forms of expression, they are based either on the harmonised reference intakes set out in Annex XIII, or in their absence, on generally accepted scientific advice on intakes for energy or nutrients; (f) they are objective and non-discriminatory; and (g) their application does not create obstacles to the free movement of goods.

[7] For more information: https://www.nutrition.org.uk/healthyliving/helpingyoueatwell/324-labels.html?start=3#:~:text=Using%20the%20government%20scheme%2C%20a,calories%20and%20kilojoules)%20it%20provides.

[8] The Italian Government’s Council for research in agriculture

[9] The main public center for research, control and technical-scientific consultancy in the field of public health in Italy.

[10] For more information: https://www.nutrition.org.uk/healthyliving/helpingyoueatwell/324-labels.html?start=3#:~:text=Using%20the%20government%20scheme%2C%20a,calories%20and%20kilojoules)%20it%20provides.

[11] Guideline Daily Amount

[12] For more information (Keyhole): http://norden.diva-portal.org/smash/get/diva2:700822/FULLTEXT01.pdf

For more information (Choices): https://www.choicesprogramme.org/

For more information (Heart symbol): https://www.sydanmerkki.fi/en/

The Commission proposals on the Farm to Fork and Biodiversity Strategies have been released without any impact assessment – on the agriculture production, on prices, on the trade balance, on food security.

It is worth quickly reminding which their key targets were, to be achieved by 2030:

• 10% agricultural land set-aside
• -20% chemical fertilizers
• -50% chemical pesticides
• 25% share of organic production
• Plantation of 3bn trees
• -50% antimicrobials for livestock

You do not need to be an expert to figure out that the impact of such drastic reductions in just a decade has to be huge.

The Commission was criticised by farmer’s organisations and by EP leading MEPs for the lack of an impact assessment – a normal, obligatory procedural step on other Commission proposals.

The Commission has responded that the impact assessment would still be carried out, but no precise indications on timing and specifics were given. Some Commission officials seemed to say that the impact assessment could be fractioned, which would make it impossible to have a clear view on the real impact; whilst others seemed to be more open to revise the targets if the impact assessment shows how negative the consequences would be.

Meanwhile in its impact assessment of the 2030 Climate Plan, the Commission refers to a Modelling Study conducted to evaluate the impact of the Farm to Fork and Biodiversity Strategies on agriculture, but gives no further details on the results, nor is the study available to the public.

The only impact assessment published so far was the recent ERS/USDA “Economic and Food Security Impacts of Agricultural Input Reduction Under the European Union Green Deal’s Farm to Fork and Biodiversity Strategies”.

Without even taking into account the impact of achieving a 25% share of organic production and planting 3bn trees, the ERS/USDA impact assessment finds that the Commission proposals would reduce EU agriculture production by 12%, increase prices by 17%, reduce exports by 20%, increase imports by 2%, shrink gross farm income by 16%, and increase the annual per capita food cost in the EU by $ 153.

If that were to be the case that would spell disaster for our farmers, wipe out our food security, compromise the food security of many developing countries in particular in Africa, and weigh on the pockets of consumers.

It is high time that the Commission publishes an Impact Assessment on its proposals. It must be comprehensive and independent from political pressure. We have the right to know what we should expect, and the Commission has the duty to come clean on the results and act accordingly.

The European Commission recently published its Renewable Energy Progress Report[1] in which it highlights the positive contribution of domestically sourced biofuels in reducing GHG emissions.

The Commission assessment clearly asserts the sustainability of biofuels produced from EU feedstock, invalidating its concerns relating to land use or food security and demonstrating them to be wholly unfounded in the context of EU climate action. By whatever means of analysis applied, it is unequivocally evident that EU biofuels come with effectively no risk of adverse land use change, i.e. they are effectively zero-ILUC.

Quoting from the Report:

“In recent years, no correlation has been observed between food prices and biofuel demand.”” Most Member States did not observe any impacts on prices due to increased bioenergy demand within their countries.”

“Several Member States point out that all agricultural production is regulated with respect to environmental impacts and therefore consider that no more impacts should be expected from biofuel crop production than from other crop production.”

It couldn’t be clearer: earlier predictions of Commission policy makers for EU sourced biofuels in 2020, pointing to higher food prices or adverse land and environmental impacts, were plainly incorrect and should be revised.

These predictions had no factual basis, yet they have served very well the interests of the still growing fossil fuel industry, the source of all GHG emissions in the transport sector; and the interests of imported biofuels, whose linkage to deforestation is not adequately checked.

The Commission goes further in the Report in pointing out the benefits of EU sourced biofuels:

“It is estimated that the biofuels industry employed 208,000 people in 2018, being the third largest renewable energy job creator after wind energy and solid biomass (314,000 and 387,000).”

“According to information reported by Member States, total emission savings from the use of renewables in transport in the EU amounted to 45.6 Mt CO2eq in 2018.””… given the overwhelming share of biofuels in the RES-T (89%), it is reasonable to assume that the emission savings result largely from the use of biofuels.”

Thus far the Commission recognises the importance of EU biofuels to the economy, and to reducing GHG emissions. Thus far we agree with their findings.

Unfortunately however, the Commission loses sight of these findings in the rest of the report and in recent communications on aviation biofuels, in the Taxonomy secondary regulations and the Green Deal: it persists with its intent to limit the contribution of conventional EU biofuels.

The negative impact of trying to minimize the use of EU biofuels is twofold: it makes it more difficult to achieve the targets of transport decarbonisation, as advanced biofuels are often more expensive and in shorter supply; and it increases deforestation, as it promotes imports of palm oil to produce biofuels, and of soybeans that would otherwise be replaced by the high protein by-products generated by EU biofuels.

At no time was there a scientific or evidential basis for the Commission policy to phase-out or cap EU crop biofuels and the positive performance of these renewables over the last decade has illustrated that the policy was wrong.

The Green Energy Platform and its peers across Europe will be key partners in the achievement of the Green Deal objectives.   To be successful that partnership must rest on a foundation of truth and a true understanding of the workings of renewable energy systems.

We call on the Commission to come forward now with scientific and evidential justification of its continued opposition to EU crop biofuels in the framing of the Green Deal policy programme, or to set about correcting its position.

Green Energy Platform is a group of companies, mostly family owned, that make biofuels – and other bioproducts – with materials sourced from European farms. We make biodiesel, bioethanol and biogas- in each case both conventional and advanced. We care about the climate. We care about Europe- its economy and its environment. We are proud of what we do. We have contributed to climate action and economic development over the past decade. We are transparent. We believe in accountability.

[1] https://ec.europa.eu/energy/sites/ener/files/renewable_energy_progress_report_com_2020_952.pdf

In a Fact-Sheet published this week “Working with Parliament and Council to make the CAP reform fit for the European Green Deal” the Commission tries to re-write the history of the latest CAP reform.

The Commission criticises the European Parliament and Council positions because they ask for flexibility in the implementation of eco-schemes and that according to the Commission could lower resources for climate and environmental benefit.

The Commission seems to forget that it proposed total flexibility for the implementation of the eco-schemes, without any ring-fencing of resources, contrary to the positions of the EP and Council. In fact what the Commission proposed could lead to fewer resources for climate and environment, and in any case make it impossible to attain EU wide objectives.

The Commission also criticises the co-legislators for watering down the performance framework of the reformed CAP. The Commission seems to forget that it did not propose a single performance indicator to be monitored, all the targets proposed were no more than statistical outputs.

We could go on giving more examples, as the Commission left to Member States the design of the national and regional policies, including basic conditionality requirements like the definition of rotation.

The fact is that the impact of the Commission proposal on the climate and environment was a black box.

The Commission seems to attempt to re-write the history to find a new legitimacy to impose its own Green Deal objectives and align the CAP with the Farm to Fork and Biodiversity Strategies. The reasoning of the Commission is that the Green Deal objectives were agreed by all, but unfortunately “certain aspects of the positions of the legislator do not match with the shared objective that the new CAP delivers on the Green deal objectives”, and therefore the Commission is entitled to “verify coherence of the Strategic Plans with the Green Deal targets”.

We see in the Commission position two serious issues of legitimacy. Firstly, only the Green Deal overall objectives of reducing GHG emissions are shared at this stage. The Commission objectives in the Farm to Fork and Biodiversity Strategies were not agreed. There isn’t even a legislative proposal. Thus the Commission lacks institutional legitimacy to try to impose them through the approval of the CAP Strategic Plans.

The Commission also lacks the policy legitimacy to impose those targets (10% agricultural land set-aside, -20% chemical fertilizers,-50% chemical pesticides, 25% share of organic production, plantation of 3bn trees, -50% antimicrobials for livestock), as the Commission did not make a prior Impact Assessment of these far-reaching proposals, nor did it publish studies on their impact so far.

According to the sole Impact Assessment published, by the USDA, it would be a disaster for the agriculture sector, for EU consumers and food security (it would reduce EU agriculture production by 12%, increase prices by 17%, reduce exports by 20%, increase imports by 2%, shrink gross farm income by 16%, and increase the annual per capita food cost in the EU by $ 153).

In this context, it is high time that the Commission publishes an Impact Assessment independent from political pressure, and without delay releases the evaluation study on the impact of the Farm to Fork and Biodiversity strategies on agriculture, as it referred to in its impact assessment of the 2030 Climate plan.