HCWH Europe’s comments on the EC Platform on Food Losses and Food Waste

Health Care Without Harm (HCWH) Europe, as invited stakeholder of the European Platform on Food Losses and Food Waste (FLW), would like to recognise the importance of this process to define a methodology for preventing and reducing food losses and food waste across the EU. HCWH Europe would also like to highlight the important role that the European Union can play in combating food waste, and its commitment to the Sustainable Development Goal (SDG) 12.3:

“[…] by 2030, halve per capita global food waste at the retail and consumer levels and reduce food losses along production and supply chains, including post-harvest losses”.

HCWH Europe would like to provide general comments for the European Commission to contribute to the process of defining a European methodology for preventing and reducing food losses and food waste.  After having attended the first meeting of the FLW Platform that took place in Brussels on 29th November 2016, HCWH Europe provides some key recommendations to be considered in this process.

  • The Platform is lead and organised by DG Health and Food Safety; however, in order to provide a holistic approach to food losses and food waste, DG Environment and DG Agriculture should be involved. The FLW Platform is a requirement of the EC Proposal to revise Directive 2008/98/EC within the Circular Economy Package (CEP), and DG Environment has been leading the draft of that proposal and the debate in the European institutions. DG Environment’s involvement in the Platform is important to keep the actions of the Platform within the scope of the CEP. The presence of DG Agriculture and Rural Development is also important for tackling the problem at the primary production stage where the majority of food losses occur.
  • DG Health and Food Safety will only work towards a methodology addressing food waste, (as mentioned at the first FLW Platform meeting), an international platform will tackle food losses. However, the EC proposal revising Directive 2008/98/EC is clear in requesting the establishment of a European Platform on Food Losses and Food Waste - therefore, both should be tackled in the definition of the methodology.
  • The European Commission has defined different sectors to be considered in relation to food losses and food waste; the healthcare sector falls under the food service sector. However, HCWH Europe believes the healthcare sector should be separate for the specific challenges it faces in relation to food donation, food waste measurement, and food waste prevention and reduction. Further information here.
  • The FLW Platform should work towards a comprehensive food waste definition along the lines of the EU FUSIONS Project food waste definition, an ambitious food waste target of 50% reduction by 2030 (in agreement with the SDG 12.3 food waste target), and a food waste hierarchy that would encourage the use of food waste for high-value applications (such as source of energy) without undermining prevention efforts and phasing out landfill and incineration. However, as a legally binding definition, target, and hierarchy would be preferable, HCWH Europe has also been calling on the European Parliament and the Council to include them in the final legislative text of the Directive amending Directive (2008/98/EC), currently being debated in the European institutions. You are surely aware of the upcoming vote (January 24th) in the European Parliament ENVI Committee on the report and amendments to the proposal for a Directive revising Directive (2008/98/EC). Many of the amendments tabled by the MEPs call for a food waste definition, a food waste reduction target, and a food waste hierarchy.
  • HCWH Europe welcomes the intention of DG Health and Food Safety to draft guidelines on food donation – an important factor in reducing food waste. These guidelines will encourage food donation in Member States that is homogeneous across the EU. There are currently major differences between Member States, underlined by the Comparative Study on EU Member States’ legislation and practices on food donation, commissioned by the European Economic and Social Council in 2014.

In addition, certain open issues should be clarified - should donated food be considered food waste or a way to prevent food from being wasted?  Such clarifications are key in order to harmonise the measuring and monitoring of food waste across Europe and in turn the reduction of food waste. Food safety has been identified as one of the barriers to food donation, (also an issue for the healthcare sector); therefore, it is important that the guidelines on food donation specify when food is safe to donate. In addition, both food donors and receivers should be transparent and liable along the whole supply chain, to make food donation safer and more transparent.

  • Provide clear guidelines for measuring and monitoring food waste, making comparison between country and sectors possible with the resulting food waste data. Sector-specific guidelines would address different types of food waste (e.g. in the healthcare sector: unserved food, untouched food, and uneaten plate waste), what type of food waste is preventable, and what food is wasted the most and why - either in the kitchen, wards and canteens (staff and visitors).

It is important to not only measure the quantity (tonnage) of food that is wasted but also to assess the cost associated to the food that is wasted. Providing guidelines for a monetary assessment of food waste would be very important in evaluating the savings incurred by reducing food waste, and therefore attractive to various actors to use the methodology. It would also be interesting to provide guidelines for an assessment of both the economic cost (i.e. production, transportation, storage, preparation, and disposal of food waste) and environmental costs (i.e. greenhouse gas emission, and water and energy consumption etc.)

A valuable example is the work carried out by the Irish Green Healthcare Programme (www.greenhealthcare.ie), a collaboration of the Irish EPA and the Clean Technology Centre. They have set up a system to measure food waste in approximately 40 Irish hospitals by calculating the weight and purchase cost of wasted food. On average, they estimate the purchase cost of food waste to be at a minimum of €2 per kilogramme. Their calculations only use the purchase cost of food and not other factors such as storage, preparation, human resources, and disposal - important factors for calculating the overall cost of food waste. More information here.

HCWH Europe would like to reiterate that the European Commission should provide clear guidelines on food donation and food waste measuring and monitoring for each sector, and ideally separate the sectors currently under the category of food services, thus providing specific guidelines for the healthcare sector.

HCWH Europe greatly appreciates the opportunity to provide comments to the work of the Commission; we look forward to the development of this work during the future meetings of the Platform.

Preview image: Nick Saltmarsh via Flickr cc