The sustainability labelling of food, including organic food, informs consumers about the impact behind the production of a given food product. It is important consumers are not misled by these labels.

EU action on sustainability labelling

The Farm to Fork strategy published in May 2020 notes that the European Commission will “make a legislative proposal for a framework for a sustainable food system before the end of 2023”. The aim of this framework is “to accelerate and facilitate the transition and ensure that all foods placed on the EU market become increasingly sustainable”. As part of this framework, the Commission intends to “create a sustainable labelling framework that covers, in synergy with other relevant initiatives, the nutritional, climate, environmental and social aspects of food products”. This sustainability label, or at least the principles thereof, is also expected in 2023, and is led by the European Commission’s Directorate-General for Health and Food Safety (DG SANTE).

The European Commission is also working on an upcoming legislative proposal to help justify (‘substantiate’) green claims and prevent greenwashing. It is expected to reveal the proposal for a “Regulation on Substantiating Green Claims” based on the Product Environmental Footprint (PEF) methodology, under the lead of the Commission’s Directorate-General for Environment (DG ENV), in the coming weeks. While substantiating green claims and sustainability labelling do not aim to address the same problems (greenwashing and providing sustainability information respectively), these two Commission proposals could be heavily intertwined. Indeed, substantiating green claims based on the Product Environmental Footprint (PEF) could legitimise the use of this method also for a sustainability label. As a report by the think tank IDDRI shows, the calculation method behind a sustainability label is a political decision on the desirable future of agriculture production. Methods based on life-cycle analysis, such as the PEF, point towards sustainable intensification by design, and not to a transition of the current food system towards organic and other agroecological practices.

The PEF was not meant to reflect the reality of complex agri-food systems in a holistic way

Initiative on substantiating green claims

Therefore, the Commission’s proposal runs the risk of being misleading and worsening ongoing greenwashing in the food and fashion industries. Together with NGOs, the organic movement has taken a strong stance against this in a recent joint letter on apparel and footwear products and an (earlier) letter on agrifood products. While using the Product Environmental Footprint (PEF) methodology, which is based on a life cycle analysis (LCA) to assess a product’s impact on the environment, may be relevant for manufactured industrial products, this methodology is not adequate to assess the environmental performance of bio-sourced products, such as food products and textiles.

Shortcomings of the PEF for agrifood The Product Environmental Footprint (PEF) is a methodology that aims to evaluate the environmental impact of a certain product, food, and non-food. This tool is based on a life cycle analysis (LCA) and the European Commission has been developing it for about 10 years. The PEF was not meant to reflect the reality of complex agri-food systems in a holistic way. While the product-focused PEF serves well to compare manufactured industrial goods, the approach significantly lags when evaluating the environmental performance of complex agricultural systems, including natural fibre production, in a holistic way. When applied to food, the PEF gives misleading results, since the more extensive the agricultural practice is, the worse it scores, evaluating products as an indicator of yields. For instance, eggs from hens in cages score better than free range eggs, which in turn score better than organic eggs. The same logic applies to agriculturally derived natural products, such as cotton, wool, hemp, jute, kenaf, and flax.

The reason for this bias is the PEF’s inability to consider some key externalities, negative or positive, of different production methods on biodiversity and the use of inputs such as pesticides. Besides, environmental scores based on PEF are unable to distinguish between two products of the same category – they mostly highlight that meat and dairy products have a worse impact than fruits and vegetables. IFOAM Organics Europe has summarized this and other concerns about the PEF in its position paper and in its technical briefing that highlights the limitations of its methodology.

PlanetScore more accurately evaluates the true environmental impact of food products and better considers externalities such as biodiversity, use of pesticides and animal welfare

Alternative means to measure products’ environmental performance

There are other existing initiatives that go beyond life cycle analysis (LCA) that also support the agroecological transition, in line with the Farm to Fork strategy objectives. An example of one of these initiatives is the PlanetScore which was developed in France through a partnership between researchers, the organic movement and civil society, and is currently being tested by many brands and retailers, both organic and conventional, in several Member States. While the PlanetScore is still a work in progress, it more accurately evaluates the true environmental impact of food products compared to other existing methodologies, as it better considers externalities such as biodiversity, use of pesticides and animal welfare.

Author: Eduardo Cuoco, IFOAM Organics Europe Director

Published in the BIOFACH & VIVANESS 2023 Bio Eco Actual Special Edition.

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