Minimum sustainability requirements (MSRs) are a form of policy put forward by the European Commission in its Inception Impact Assessment for the Sustainable Food Systems Framework Law and refer to the creation of binding sustainability requirements either for food chain operators or for food products. MSRs could establish a baseline for environmental, social, and economic sustainability. However, there has been some debate about whether and how MSRs should be included in a draft law. This Note makes the case for why an MSR regime should be included in the European Commission’s proposal for an SFS Law and suggests some design principles that could be applied.
- An MSR regime should be included in the SFS Law. On a number of environmental, social and economic indicators, the EU agrifood system is unsustainable. By creating specific requirements through delegated acts for issues that are unregulated, MSRs can contribute to supporting the 2020 Farm to Fork’s vision, although revision of other legislation including the CAP is also necessary. MSRs would provide clear additionality to other voluntary policy pull measures such as labelling and form a critical part of a holistic, whole food chain approach.
- MSRs should be dynamic and address key priorities. Prioritising less regulated but highly impactful sectors in the centre of the food chain is essential. For example, in food processing, minimums could be set for the proportion of energy from renewable sources. Likewise, standards could be set for the proportion of plant proteins in processed foods and meals. The standards themselves should be able to be reviewed when timely in light of new environmental agreements and commitments.
- A workable legal frame for MSRs is feasible, despite some challenges. In order for MSRs to be implemented, the SFS Law needs to set clear and specific enough objectives that are aligned with the Farm to Fork Strategy’s vision and support the creation of delegated acts to lay out operational minimum standards.
- The criteria and design underlying MSRs must be determined with strong input from civil society and other stakeholders. Whilst based on technical criteria, they will help shape the entire food system, with implications for how we produce, process, sell and consume food.