Food waste – improving large food business waste reporting

In an update to the consultation page on GOV.UK, the new Defra Secretary of State, Steve Barclay, said that Defra will “reconsider whether there should be mandatory food waste reporting in the future”.

As such it said the government response to the consultation has been “withdrawn”.

Defra has published its response to the consultation, having made the decision that now is not the right time for mandatory food waste reporting.

Despite the vast majority calling for mandatory food waste reporting for large businesses, Defra has said it will be sticking with a voluntary approach to “avoid measures that would drive inflation”.

We were against the option to mandate food waste reporting. Although primary producers were not included in these proposals, some of our members with secondary businesses, such as large food packing businesses, would have been caught by the proposed changes.

Defra has listened to the NFU's concerns and its response states that the “government is sensitive to the overall burden of regulation on businesses and is seeking to avoid measures that would drive inflation while cost of living challenges remain an issue for many consumers”. It has decided that a “regulatory approach is not suitable at this time, especially when any additional costs may be passed on to consumers”.

According to Defra's impact assessment, the UK currently produces 9.5 million tonnes of food waste every year post-farmgate, meaning the figure excludes food waste arising in primary production, with businesses producing over 2.9 million tonnes of this waste. Most of the food waste is still produced in households.

Post-farmgate our annual waste has an approximate cost of £19 billion and has associated emissions of 36 million tonnes of carbon dioxide equivalent.

Instead of mandatory reporting on food waste, the government plans to encourage more food businesses to report voluntarily. The NFU is supportive of the voluntary approach which is led by the food waste charity WRAP and has a good level of uptake within large food businesses.

The voluntary approach is in place until at least mid-2025 at which point a review will be conducted to assess its effectiveness.

The calls for input on this consultation is now closed.

The NFU has submitted its response, the main points of which are summarised below:

Option 1 – enhance current voluntary agreements by extending the Field Force

We believe that the horticultural, poultry, and livestock sectors may potentially be impacted by any change. While our horticultural members who package their produce will be directly affected, those in the poultry and livestock sectors may be impacted by costs being passed down the supply chain from processors, as a result of increased measurement and reporting costs.

We support the increase in generation of data on the volumes of food waste produced by large food businesses. Option 1, enhancing current voluntary agreements by extending the Field Force, would be our preferred option, as it would provide flexibility and support for those businesses who are not yet measuring their food waste.

Many of our members who could fall under the scope of these changes are already reporting their food waste via WRAP and find this process to work well. Indeed, many large food businesses are already monitoring and managing food waste as a part of good business management, but further tools and investment to support this process would be strongly welcomed.

We recognise that the act of food waste reporting in isolation does not result in reduction of waste, but the practical measures adopted during the process and in the supply chain.

Definitions needed

Consistent definitions of the difference between food waste and food surplus should also be recognised and formalised, to avoid any confusion when measuring this output. We would welcome any expansion of the Field Force that boosted greater sharing and access to alternative outlets for food surplus arising from production and packaging. There is often a gap between the production of food waste and surplus, and outlets available to deal with the volumes and quality produced. The NFU considers further work towards addressing this gap would be an appropriate use of resources.

Option 2 – require food waste measurement and reporting for large food businesses

We feel that Option 2 would be an unnecessary change, as commercial pressures already work to reduce waste to an absolute minimum, and it is unlikely that legislation would greatly impact this.

Extra regulation would not be welcomed by our members, given the already tight margins that many of the growers/processors are working under. In fact, the competitive economic environment is likely itself to be bearing down on food waste, as seen in a recent announcement by a major retailer to include sub-specification fruit and vegetables in their consumer offering.

Other industry issues such as the current labour shortages and the changes to government support for grower/processors mean that many of our members impacted by this would struggle with further legislative burden while these issues are ongoing.

NFU members can read our consultation response in full: Defra consultation on reporting of food waste by large food businesses in England

On 13 June 2022 Defra launched a consultation on improved reporting of food waste by large food businesses in England. 

You can read about the consultation at: Defra | Improved reporting of food waste.

Government proposals

The proposals outline Defra’s plan to legislate for the measurement and reporting of food waste for large food businesses in England.

Although primary producers are not included in these proposals, secondary businesses such as large food packing businesses may be caught by the proposed changes.

Large businesses are defined by the Companies Act 2006 as exceeding two or more of the following criteria within a financial year:

• Annual turnover of £36 million
• Annual balance sheet total of £18 million
• 250 employees

Different options

The consultation proposes three policy options for review:

1. Do-nothing option – this would mean maintaining current measures.
2. Option 1 – enhance current voluntary agreements by extending the Field Force, which is a team of sector specialists, to accelerate the take-up of voluntary measurement and reporting of food waste by businesses.
3. Option 2 – require food waste measurement and reporting for large food businesses.

Option 2 is the focus of most of the consultation and associated impact assessment.

Potential impacts

We believe that option 2 may impact those involved in horticulture or poultry who have large packing businesses alongside their production facilities.

The proposals involve mandating large businesses to measure and report food waste to the Environment Agency, based on the overall weight of any associated waste.

The reporting of the first set of data would be 2024/2025 financial year.