Effective Approaches to Environmental Labelling of Food Products : Final Report for Project FO0419
The environmental impacts of food production are complex and accumulate throughout a supply chain from primary production to processing, packing, distribution, retail and end use (consumption and waste management). The potential environmental effects are numerous and can have a range of direct and indirect impacts, both positive and negative. There are a number of drivers that can help reduce these impacts including legislative instruments, retail marketing and consumer choices and demand. One driver that has received attention in recent years is the use of product labels, whereby the environmental 'credentials' of a product are communicated to the consumer. This may be on a single issue, e.g. its carbon footprint or on multiple issues (omni-labelling). However, the science and practice of using labels to drive changes in consumer and industry behaviour is complex. There are many issues to resolve including their scientific credibility and robustness, and how consumers understand and use them in practice. Consequently, in response to the above issues and a number of policy drivers, this project was commissioned by Defra. The project was undertaken by the Agriculture and Environment Research Unit (AERU) at the University of Hertfordshire, in collaboration with the Policy Studies Institute (PSI) and the Food Ethics Council (FEC). The objectives of the project were to: • Provide a current view on the use of environmental labels on food (and other) products based on a review of existing literature on industry impacts, effects on consumers and the scientific basis of environmental labelling. • Identify the key issues and challenges associated with assessing, integrating and communicating environmental impacts within the context of what is required for a scientifically credible and robust labelling scheme. • Identify the effectiveness, benefits and burdens of labelling as a mechanism for raising awareness of environmental issues and driving behavioural change , through a consultation exercise with industry and consumer behaviour experts including interviews, a one-day workshop and the use of a multi-criteria mapping (MCM) process. • Identify guidelines for a credible and robust label that is effective and practical for consumers and industry via the development of a framework for practical and effective environmental labelling of food products. • Consolidate the findings of the research and make recommendations on the feasibility of an environmental labelling scheme for food currently and in the future. The literature review showed that the amount of work that is ongoing regarding environmental labelling (also referred to as eco-labelling within this report) is very considerable and interest is growing worldwide. The amount focussing on eco-labelling for food products is also growing but it is relatively small compared to other industry sectors, and especially with respect to outcome-based labels and communicating multiple environmental issues on products. The low number of food eco-labels is due to a number of factors including the diversity of food products and production systems; the complexities of determining environmental impacts, issues involved in communicating environmental information to consumers via product labels including issues of trust, preferences and motivations, and the lack of evidence showing that labels can help deliver environmental benefits. The majority of existing food eco-labels are based on the promotion of best-practice and do not quantify emissions or impacts, primarily for reasons of practicality and cost. Therefore, they do not make claims that any direct, product-specific, environmental benefits have been achieved. Many new schemes and initiatives are following a practice-based approach though there are exceptions, such as Earthsure in the USA, which uses an outcome-based approach. The analysis of the key issues associated with measuring, assessing and communicating environmental impacts considered issues relating to how environmental impacts are communicated. For the majority of impact categories, measurement and assessment techniques suffered from a range of problems including their subjectivity, lack of transparency, uncertainty, unjustified assumptions, data deficiencies, and lack of validation. A considerable amount of scientific development and debate towards achieving standardised techniques for measuring and assessing environmental impacts is required before a robust outcome-based omni-label for food could be a reality (even for food with more simple production chains, such as fresh produce, meat, eggs and milk). The consultation exercise with industry and consumer behaviour experts explored the effectiveness of labelling as a mechanism for raising awareness of environmental issues and driving behavioural change (amongst consumers and industry). It also enabled an assessment to be undertaken of the key benefits and burdens to both consumers and industry of potential labelling schemes. One conclusion arising from this work was that if the primary goal of a labelling scheme is to change industry behaviour across the sector, then labelling would have a limited role to play compared with other policy options, including regulation. By implication, government's role in relation to labelling might be limited to facilitating and co-ordinating schemes emerging from the private and third sectors and/or co-ordinating efforts at the EU level. An alternative is that the primary objective is to change consumer purchasing behaviour where labelling might be seen as a means of engaging consumers with environmental or sustainability messages. If this was the objective, then a balance would need to be struck between sufficiently addressing environmental issues yet not being so burdensome that it was unworkable. A practice-based approach was widely considered legitimate by the experts in pursuing the objective to change consumer behaviour, but this objective was considered a less effective means of achieving substantial environmental improvements than if the scheme objective was to change industry behaviour. It was also agreed that given current levels of public environmental awareness and concern, environmental labels will not be used by all consumers during food purchasing. The project findings were consolidated into a framework for effective and practical environmental labelling for food products. The purpose of this framework is to provide a basis for identifying opportunities to improve existing (or designing new) labelling initiatives from the perspective of practicality and effectiveness. The framework consists of 14 guidelines that together seek to ensure that any labelling scheme developed has clear objectives, that the drivers and mechanisms by which those objectives are delivered are understood, that the scheme is practical and cost effective and, finally, that aims and outcomes are clearly communicated in a manner that is best suited for its intended audience. The framework has been illustrated using four different labelling schemes as examples to demonstrate how the guidelines can be applied. Our principal conclusion from the work that has been undertaken in this project is that we do not believe that the science is sufficiently robust to develop an outcome-based, environmentally broad, omni-label at this time. Additionally, the costs that such a scheme may incur could be unacceptably high in relation to the potential benefits that could be realised, particularly since there is lack of evidence on how effective labels are as a tool to stimulate change. There will continue to be a role for environmental labelling alongside other initiatives to improve the sustainability of food production and consumption. For example, within industry, food chain information, including environmental impact data, can be valuable to help manage issues and identify areas for improvement, and for consumers, labelling can educate and empower them to make informed choices through provision of information in relation to food. However, efforts to reduce the environmental impacts of food should not focus primarily on labelling as this is unlikely to deliver desired outcomes on its own. Labelling should be part of an integrated suite of initiatives, including government regulation and industry schemes, designed to bring about the delivery of desired outcomes. There are a number of existing initiatives with respect to labelling both within industry and more internationally, such as within the EU. Therefore, the main role for government in relation to environmental labelling should be to harmonise and improve existing schemes rather than develop a new outcome-based omni-label. On this basis, we have formulated a number of recommendations for potential ways forward. These have been split between those that apply to businesses and third sector organisations involved in labelling and those that apply to government, though a number would in practice involve these sectors working together: Businesses and third sector organisations: 1. The framework developed in this study should be used to identify potential improvements in existing schemes or to develop new schemes, helping to ensure that schemes are practical, effective and honest and can withstand scrutiny by consumers and trading standards. 2. If the primary objective is to improve environmental performance within the industry, labelling schemes should be linked to actual environmental performance and outcome-based measurement. 3. Monitor the effects of schemes against their performance objectives and make the findings publicly available to facilitate research and scrutiny and share best and successful practice. 4. Ensure schemes are sufficiently flexible to reflect site-specific needs and priorities within the performance metrics used. 5. When designing and implementing schemes, consider multiple environmental impacts and wider sustainability issues such as economic and social considerations (Guideline O1) and undertake impact assessments to identify any potential positive or negative impacts (e.g. unemployment). 6. Participate and engage in initiatives that support consumer understanding of environmental labelling, for example by promoting awareness of specific impact categories. 7. Participate and engage in initiatives to harmonise methods, standards, metrics and communication used in environmental labelling. Government: 8. Work to improve environmental labelling, through supporting scientific development and debate towards achieving standardised techniques for measuring and assessing environmental impacts. 9. Work with schemes to ensure labelling is always presented in context with respect to other initiatives that are in place to tackle impacts arising from food production. 10. Play a leading role within UK, EU and international initiatives to harmonise approaches to labelling, seeking to co-ordinate and facilitate action by businesses and other stakeholders. 11. Explore with stakeholders the potential for government to assist in co-ordinating efforts to pilot improved environmental labels that address key limitations identified in this research. 12. Explore with stakeholders the potential for financing co-ordinated research and harmonisation. A number of the recommendations involve industry and government working together (Recommendations 6, 7, 8, 9, 10, 11 and 12). One approach to these would be to undertake one or more collaborative pilot projects to explore key scientific and socio-economic challenges associated with understanding and communicating the impacts of food products using environmental labels. This work would identify a product that has a relatively small and contained production chain (from farm to fork) which has the potential to be studied in detail, for example, local fresh produce; exploring what outcome-based metrics can be measured and the site-specific nature of any impacts; identifying the practicality and costs of undertaking the measures, including any socio-economic impacts; identifying other initiatives that are in place which also tackle the same issues; and communicating the information liberated from the study on an experimental label. Over a period of time a number of impact categories could potentially be addressed, which would be a step forward to improving the science required for omni-labelling, which this study has identified as lacking. It will also provide a much clearer picture on how effective and what influence labelling as a tool can have with respect enabling progress towards more sustainable production and consumption in relation to other initiatives such as government regulation.