26 May 2020

In Japan, Daruma dolls are seen as a symbol of perseverance and good luck. They are daily reminders of an ultimate goal. It is, however, the owner’s responsibility to realise these objectives. The recently published Farm to Fork strategy, part of the Green Deal, might well be described as the Daruma doll of EU food policy.

The Farm to Fork strategy is the start of a process. Together with the biodiversity strategy, it sets high-level objectives for the EU such as reducing the environmental and climatological footprint of the food system, strengthening its resilience, ensuring food security and public health and preserving the affordability of food. Its implementation will be key to its success.

Despite its ambition, systemic obstacles and conflicting objectives might threaten the achievement of its primary goals. Therefore, a dose of pragmatism and realism, together with strong inter-institutional collaboration, will be necessary to ensure the efficient and consistent implementation of the strategy.

Bringing the Farm to Fork strategy to life may indeed take a long time. Just as the owner of a brand new Daruma doll would paint on one eye to indicate the setting of their goal, the Commission has highlighted its intentions for food policy in the years to come. The strategy is nevertheless not currently backed by the force of law. Achieving the objectives will, therefore, depend on the legislation that will be put forward by the Commission and adopted by the European Parliament and Council.

Food policy is a sensitive issue. Food consumption habits help define the multiple identities and cultures in the European Union. As a result, while Member States and the Parliament support the Commission’s overarching objectives, they may have very different views as to how to achieve them. It would therefore come as no surprise if Member States or the European Parliament did not pass Commission proposals or decided not to follow specific aspects of the strategy in their national legislation on expected controversial points. Harmonised front of pack labelling, maximum levels of certain nutrients or agricultural technologies will likely be subject to intense discussions. The agreement to and implementation of all proposed actions are, therefore, not guaranteed. For instance, should the European Commission’s report on genome editing technologies highlight the benefits of new breeding techniques, would Member States embrace that technology?

Impact assessments have still to be conducted on the proposed approach, and some of the measures might well have a different or higher cost than expected. The complexity and breadth of the EU’s ambitions, therefore, require specific attention to the consistency of the proposed measures to avoid conflicting objectives and results.

For instance, expanding organic farming while reducing the use of plant protection products could also have ecological trade-offs. As the Scientific Advice Mechanism (SAM) highlighted in a recent report, the transition to a more sustainable farming system will require intensifying sustainability or, at least, maintaining the present level of yields. Failing to do so could lead the EU down a path to changes in land use or to becoming more dependent on imports and trigger more greenhouse gas emissions. Lower yields could also raise food prices, and an arbitrary reduction of the use of plant protection products could lead to more significant food loss. Science-based decisions will ensure the consistency and coherence of the different measures adopted in support of the Farm to Fork strategy.

Food labelling is another example where specific attention will need to be paid to consistency. Here, the Commission has another opportunity to exercise influence and enact meaningful change. The multiplicity of front of pack (FoP) labelling schemes in the EU has created barriers to the intra-EU trade of food products. The first benefit of a harmonised system would lift those barriers and ease implementation in the single market. This benefit might be partially jeopardised, however, by the intention to further extend country-of-origin labelling, which may de facto incentivise consumers to discriminate against products from other Member States. In addition, no FoP labelling scheme has, so far, proven suitable for universal implementation. Current models tend to focus on individual foods consumed in one meal, rather than addressing the whole diet, including portion size. The model chosen will have a substantial impact, as a harmonised FoP labelling scheme is likely to influence consumer choice, on public health as well as the perception of products, including traditional foodstuffs. It could also be used as a basis for food taxes in Member States.

At this stage, the Farm to Fork strategy looks like a set of Japanese Daruma dolls: a reminder of the final objectives to be achieved, with their different colours symbolising the multiplicity of goals and targets. It is the start of a new, lengthy and complex legislative phase. However, to maintain a thriving food industry and to ensure coherence and consistency, it is of utmost importance to review each impact of the proposed policy measures.


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For more information on how Hanover can help your business navigate these changes, please email Jessica Brobald, Head of Food, Hanover Brussels.