16.1 Introduction
Following the Paris Agreement – the central outcome of the eponymous 2015 climate summitFootnote 1 – the parties decided to implement the objectives envisaged since the beginning of the 1990s via the United Nations Framework Convention on Climate Change (UNFCCC)Footnote 2 as the result of the United Nations Conference on Environment and Development (UNCED) of June 1992.Footnote 3 The set goals are to be achieved gradually between now and 2035 and, within this framework, agriculture and food security featured prominently in the Conference of the Parties (COP) 28 that took place in December 2023. Against this backdrop, precise sustainability policies are remarkably at the heart of the 2030 UN Agenda for Sustainable DevelopmentFootnote 4 and the Governments Step Up Action on Agriculture and Food SecurityFootnote 5 has arisen as a key climate change challenge: food production that reduces carbon emissions contributes significantly to improving sustainable policies and the development of a circular economy is a critical factor in this process. Thus, in order to ensure a sustainable future with low-carbon emissions, it is necessary to outline production processes that are responsible and transparent. For this reason, it is essential not only to identify specific policies that enable healthier and less-polluting production cycles, but also to inform the consumer in a proper way to allow an economic and sociocultural transformation.
A clear example of how sociocultural sustainability can be achieved is the establishment of a comprehensive labelling system that provides not only nutritional information but also data on the environmental impact of food products. Arguably, the progressive extension of environmental labelling from non-food products to food products is emerging as a key factor within the context of climate change policies. In this process, there is a profound interest in identifying new labels, notably environmental labels, with a dual purpose: outlining certifying processes suited to a sustainable and safe development on the one hand, and helping the consumer to make conscious choices when purchasing products on the other.
This contribution aims to explore the possible evolution of a new food environmental labelling system. It analyses the increasing interaction between climate change and food and the implications it may have for labelling. The research first explores the international trajectory and subsequently delves into the implications it may have on the EU’s ecolabelling system.
16.2 Food Security and Climate Change: Towards a Nutritional Environmental Label
Ecolabelling has evolved over time – albeit voluntary, it is progressively expanding to new products. New impetus for such developments has particularly come from the awareness of the link between food security and climate change.
At the domestic level, in 2010 the British Food Standards Agency commissioned a report on the effects of climate change on food.Footnote 6 In 2015, awareness that food production and climate change are closely intertwined arose in the international community, particularly via COP21, and the messaging of both the Food and Agriculture Organisation (FAO) and UN. Indeed, the FAO determined that the food system ‘must be considered in the context of … climate change and the depletion of natural resources’.Footnote 7 As they are ‘major contributors to [greenhouse gas] emissions, amounting to about one-third of global emissions, it is imperative that food systems evolve to sustainably meet the growing demand globally’.Footnote 8 In this context, agriculture emerges as ‘a significant source of greenhouse gas emissions’ and the targets of the Paris Agreement make it ‘essential that agriculture and other land-use sectors be part of the climate solution’.Footnote 9 Indeed, ‘it is increasingly clear that the goals of achieving food security and sustainable agriculture and addressing the challenges of climate change are intertwined and need to be addressed in a coordinated manner’.Footnote 10 Along these lines, in 2019 the newly established Lancet Commission on healthy diets from sustainable food systems,Footnote 11 established under the auspices of the world-leading Lancet medical journal, underscored that the ‘transformation to healthy diets from sustainable food systems is necessary to achieve the UN Sustainable Development Goals and the Paris Agreement’.Footnote 12 Developed countries should therefore ‘share views on how to encourage more balanced diets and minimize emissions per calorie’,Footnote 13 raising the question as to ‘what are the financial and technological solutions for achieving just transition for food security and climate resilient food systems’.Footnote 14
Along these lines, the Intergovernmental Panel on Climate Change (IPCC) adopted a strategy and commissioned a report on food securityFootnote 15 that will be undoubtedly debated in upcoming sessions of the IPCC. The idea that sustainable food systems can contribute to ‘lowering emissions of critical climate-warming gases, including methane and carbon dioxide’ has thus become a cornerstone of the UN 2021 Food Systems Summit. Similarly, the International Food Policy Research Institute (IFPRI) considered that ‘food systems contribute substantially to greenhouse gas emissions and must play a role in mitigation through changes in agricultural practices and land use, more efficient value chains, and reduced food loss and waste’Footnote 16. Food therefore scores high on the COP28 agenda, as demonstrated by initiatives such as FAST (Food and Agriculture for Sustainable Transformation Initiative),Footnote 17 iCAN (the Initiative on Climate Action and Nutrition)Footnote 18, and the Roadmap for More Sustainable Food Systems.Footnote 19
This approach triggers the necessity of installing responsible consumption and production under sustainable development goal 12 and to create a synergy with reduced environmental impact and climate action under sustainable development goal 13.Footnote 20 Central to this strategy is the need to inform the consumer about products that follow high-yielding, resilient and adaptive practices (HYRAP),Footnote 21 particularly via food environmental labelling.Footnote 22 Support instruments are thus being created by institutions directly involved in the sector, claiming a precise role for ecolabels as a solution to climate change mitigation.Footnote 23
16.3 The European Union Trajectory
16.3.1 From the ‘Community Eco-Label Award Scheme’ to the ‘EU Ecolabel’
Environmental labelling has essentially developed as a voluntary, and therefore not compulsory system, including three mechanismsFootnote 24: (a) type I environmental labellingFootnote 25; (b) type II self-declared environmental claimsFootnote 26; and (c) the International Organisation for Standardization (ISO) type III environmental product declaration.Footnote 27 These all contribute to the environmental information process and help to identify and promote environmentally friendly products and services that have a higher environmental performance standard. Given that schemes (b) and (c) provide no certification by an independent body and rely on mechanisms such as information communicated by companies,Footnote 28 this chapter will focus on type I labels, which require certification by an independent body through a series of criteria and assessment and verification requirements.
A clear example of type I labelling is the Ecolabel certification, which has been around for three decades, evolving from the ‘Community eco-label award scheme’ to the current ‘EU Ecolabel’. As far back as 1992, a petition of the EU Council proposed an eco-labelling scheme covering environmental impacts during the entire life cycle of a product.Footnote 29 This established the ‘Community eco-label award scheme’, a system that initially expressly excluded eco-labelling not only for pharmaceutical products but also for beverages and foods.Footnote 30
The importance of improving the regulation of the eco-label system led to a revision of the 1992 resolution, introducing a new scheme based on two regulations that came into force in 2000. In this context, the ‘Community eco-label award scheme’ was revisited via Regulation (EC) No. 1980/2000,Footnote 31 which was later repealed in 2010 by the ‘EU Ecolabel’Footnote 32 ‘for reasons of clarity and legal certainty’.Footnote 33 This gradually extended the range of goods or services so as to encompass drinks and foodstuffs, only excluding medicinal products for human use.Footnote 34 A key feature of the ‘EU Ecolabel’ regulation is that it is not compulsory.Footnote 35 The complexity of this labelling system is progressively increasing, necessitating the creation of a European Union Ecolabelling Board (EUEB) contributing to the development and revision of ecolabelling criteria and implementation schemes.Footnote 36 Group product development is also envisaged; although mostly relating to non-food products and services in the clothing and textile sectors, it also takes in such fields as coverings, do-it-yourself enterprise, electronic equipment, furniture, gardening, lubricants, others household items, paper, and personal care products. Even though Regulation 66/2010 of the European Parliament and Council on the EU Ecolabel is applicable to food (per article 6.5), more care is required for food ecolabelling, not only because information provided to the consumer is a safety requirement,Footnote 37 but also because of the express need not to mislead the consumer.Footnote 38
This further led to the creation of the European Food Safety Authority and to laying down targeted food safety procedures, raising the need for a study in relation to food labelling.Footnote 39 The study was completed in 2011,Footnote 40 and the EUEB supported its findings for food and feed products, despite the opposition of a majority of stakeholders.Footnote 41
16.3.2 Ecolabelling after the Green Deal
With the approval of the Green Deal in 2020, the European Union has clearly moved towards a new market for products that is sustainable and fulfils proper circular economy flows. In this context, the labelling system crosses the challenge of balancing climate change, food security and sustainability. Thus, in November 2022, the European Commission underscored the need to transform the food system via a ‘sustainable productivity growth’ based on technology and innovation for agricultural productivity that address climate change challengesFootnote 42. On this basis, the Commission is considering the need to ‘examine ways to create a sustainable labelling framework that covers, in synergy with other relevant initiatives, the nutritional, climate, environmental and social aspects of food products’.Footnote 43At the same time, the Union adopted a directive on corporate sustainability reporting and the need to provide detailed information on sustainability.
Amid other initiatives aiming to accelerate the transition under the Green Deal,Footnote 44 in March 2022 the European Commission adopted the proposal for a regulation on eco-design for sustainable products.Footnote 45 The proposed regulation determines technical standards for sustainability, establishing a ‘digital product passport’ that provides for ‘the setting of mandatory green public procurement criteria’.Footnote 46 This legislative proposal considerably bolsters the importance of the EU Ecolabel,Footnote 47 setting a presumption of product conformity to the ecodesign requirements.Footnote 48 However, labelling continues to be non-compulsory, and the Directive does not apply to food.Footnote 49 Similarly, forthcoming legislation on packaging and packaging waste adopted at the end of November 2022 bears witness to the effort to thoroughly trace the life of a product, environmental sustainability and labelling,Footnote 50 but without express reference to food labelling.
As such, the EU Ecolabel, albeit strengthened via significant legislation and policies after the adoption of the Green Deal, remains secluded from food labelling. It is therefore not yet included in binding regulation, although a trend is emerging towards the inclusion of food products in EU ecolabelling legislation in line with recent international developments, de lege ferenda. Notably, the environmental footprint initiative is a proposal of the Commission that aims to measure and communicate the life-cycle environmental performance of organisations and their food and their products ‘from a supply-chain perspective, including all stages from raw material acquisition through processing, distribution, use, and end of life processes,Footnote 51 and all relevant related environmental impacts (instead of focusing on a single issue)’.Footnote 52 This effort takes place in the context of the implementation of the EU’s Product Environmental Footprint (PEF) in the course of the Environmental Footprint (EF) pilot phase, which is constantly evolving,Footnote 53 and will hopefully lead to a future PEF label also relating to food products,Footnote 54 as provided for in its guidelines.
Domestically, some EU Member States have started to include food in their ecolabelling. Notably, in the light of the EU’s front-of-pack labelling initiatives,Footnote 55 France is considering the possibility of adopting ‘Nutri-Score’ – a key nutrition information labelling scheme – while simultaneously introducing an environmentally considered food labelling hierarchy. Thus, initially, Nutri-Score should have been complemented by ‘Eco-score’, a further food environmental labelling system with the same iconographic structure.Footnote 56 More recently, Eco-score has been partly revised with the new proposal for a different labelling system called ‘Planet-score’.Footnote 57 This is an improved mechanism that takes into account additional indicators including values such as biodiversity, climate, and pesticides.Footnote 58 This model fits into a pathway towards achieving sustainable greenhouse gas emission levels that commenced in 2009 with statutory law Grenelle I,Footnote 59 was subsequently strengthened via statutory law Grenelle II,Footnote 60 and which was completed via statutes on energy transition for green growth,Footnote 61 the circular economy,Footnote 62 and climate change and resilience.Footnote 63
16.4 Conclusion
While environmental labelling was initially designed merely for the purposes of environmental cleanliness, based on the idea of waste prevention,Footnote 64 international regulation is now widening its scope of application with a particular view to spanning greenhouse gas emissions This particularly entails an extension of ecolabelling from non-food to food products, as the food production sector – particularly agriculture – is responsible in itself for one-third of global greenhouse gas emissions. Although the EU Ecolabel Scheme still embraces a restrictive notion of ecolabelling, in the light of evolving regulation in countries such as France, environmental labelling is desirable. It is therefore likely that the EU will de lege ferenda move to an extensive ecolabelling approach, covering both non-food and food products, thereby in part fulfilling the objectives of the Paris Agreement, the UN Agenda 2030 for Sustainable Development and the European Green Deal. In such an evolving framework, it is important to avoid over-information via targeted policies, providing correct consumer information and guaranteeing fair treatment.
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