COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste

EN EN
EUROPEAN
COMMISSION
Brussels, 5.7.2023
SWD(2023) 421 final
PART 1/4
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Accompanying the document
Directive of the European Parliament and of the Council
amending Directive 2008/98/EC on waste
{COM(2023) 420 final} - {SWD(2023) 420-422 final} - {SEC(2023) 420 final}
Offentligt
KOM (2023) 0420 - SWD-dokument
Europaudvalget 2023
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1. INTRODUCTION...................................................................................................................1
2. TEXTILES ..............................................................................................................................4
2.1. Facts, figures and context .............................................................................................4
2.2. Problem Definition .....................................................................................................10
2.2.1. What are the problems? 10
2.2.2. What are the problem drivers? 11
2.2.3. How likely is the problem to persist? 14
2.3. Why should the EU act? .............................................................................................18
2.3.1. Legal basis and nature of the legal instrument 18
2.3.2. Subsidiarity: Necessity of EU action 18
2.3.3. Subsidiarity: Added value of EU action 19
2.4. Objectives: What is to be achieved?...........................................................................19
2.4.1. General objective 19
2.4.2. Specific objectives 19
2.5. What are the available policy measures and options? ................................................23
2.5.1. What is the baseline from which options are assessed? 23
2.5.2. Description of the policy options and measures 23
2.5.3. Discarded measures 27
2.6. What are the impacts of the considered policy measures and options?......................27
2.7. How do the options compare? ....................................................................................27
2.8. Preferred option ..........................................................................................................33
2.8.1. Preferred option for textiles 33
2.8.2. REFIT (simplification and improved efficiency) 34
2.8.3. Application of the one in one out approach 34
2.9. How will actual impacts of the preferred option be monitored and evaluated? .........34
3. FOOD WASTE .....................................................................................................................36
3.1. Facts, figures and context ...........................................................................................36
3.1.1. What is food waste and what is the scope of the initiative? 36
3.1.2. Overview of EU action to prevent food waste 37
3.1.3. Amounts of food waste at EU level 39
3.2. Problem Definition .....................................................................................................40
3.2.1. What are the problems? 40
3.2.2. What are the problem drivers? 42
3.2.3. How likely is the problem to persist? 48
3.3. Why should the EU act? .............................................................................................49
3.3.1. Legal basis and nature of the legal instrument 49
3.3.2. Subsidiarity: Necessity of EU action 49
3.3.3. Subsidiarity: Added value of EU action 51
3.4. Objectives: What is to be achieved?...........................................................................52
3.4.1. General objective 52
The links between the problems, general objectives and specific objectives are presented in
the intervention logic in Annex 7. 52
3.4.2. Specific objectives 52
3.5. What are the available policy measures and options? ................................................54
3.5.1. What is the baseline from which options are assessed? 54
3.5.2. Description of the food waste policy options 55
3.5.3. Setting a food waste reduction target 59
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3.5.4. Development of the policy options 61
3.5.5. Discarded measures 64
3.6. What are the impacts of policy options ......................................................................65
3.6.1. Approach to analysis of the impacts 65
3.6.2. Overview of impacts considered 67
3.6.3. Impact on food waste: amount of food waste prevented 68
3.6.4. Environmental impacts 68
3.6.5. Economic impacts 70
3.6.6. Social impacts 75
3.6.7. Impact on SMEs 77
3.6.8. Territorial distribution of economic and social impacts 77
3.6.9. Impact on fundamental rights 78
3.6.10. ‘Digital by default’ principle and digitalisation 78
3.7. Feasibility analysis......................................................................................................78
3.8. How do the options compare? ....................................................................................80
3.9. Preferred option ..........................................................................................................84
3.9.1. REFIT (simplification and improved efficiency) 84
3.9.2. Application of the one in one out approach 84
3.9.3. How will actual impacts of the preferred option be monitored and evaluated? 84
4. CUMULATIVE IMPACTS ..................................................................................................86
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List of figures
Figure 1: Mass flow analysis for textile generation and waste management in the EU (for the
status quo reference year 2019). The mass flows in each node are expressed in
Mt/year 9
Figure 2 - Mass flow analysis for textile generation and waste management in the EU (for the
baseline scenario for 2035). The mass flows in each node are expressed in Mt/year7117
Figure 3 - Problem tree and intervention logic for textiles 21
Figure 4 – Boundaries of food waste as defined in the WFD (2018). Adapted from Sanchez
Lopez et al. (2020) 36
Figure 5 - Estimated food waste generation in the EU in 2020, Eurostat 39
Figure 6 - Food waste by sector of activities by Member State, 2020, Eurostat 39
Figure 7: Problem tree and intervention logic for food waste 53
Figure 8 – Food waste quantities in the baselines 2020 and 2030, and in scenarios 2030 68
Figure 9 – Income changes in the EU27, Options compared to baseline (2030) for different
actors 70
Figure 10 – Food expenditure shares and percentage change deviations in food expenditure share
scenarios vs baseline 2030 75
List of tables
Table 1 – Mapping of the main links of policy priorities to the WFD 1
Table 2 – Impacts of considered policy measures 29
Table 3 – Comparison of options 31
Table 4 – Savings of GHG emission, MAGNET model results, scenarios vs the baseline 69
Table 5 – Environmental savings linked to food waste reduction according to the bottom-up
analysis (the values in brackets are the % savings compared to the impact of food
waste in the baseline) 69
Table 6 – Adjustment costs per sector of the food supply chain 73
Table 7 – Main economic impacts 73
Table 8 – Social impacts 76
Table 9 – Overview assessment of the feasibility of different policy options (target levels to be
achieved by 2030) 80
Table 10 – Comparison of food waste reduction policy options 80
Table 11 – Overview of net benefits in monetary terms (and cost-benefit ratio) 82
Table 12 - Cumulative impacts of the preferred options for both textiles and food waste 86
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Glossary
Term or acronym Meaning or definition
Closed loop recycling Recycling process that aims to reach a sustainable supply
chain in which all elements used to produce a good can
become part of a new equal or similar product without
losing their properties.
COP15 The 15th Conference of Parties to the UN Convention on
Biological Diversity adopted the “Kunming-Montreal
Global Biodiversity Framework” (GBF). Target 16
includes halving global food waste by 2030.
Disposal Any operation which is not recovery even where the
operation has as a secondary consequence the
reclamation of substances or energy1
.
EEA European Environment Agency
EPR Extended producer responsibility
ESPR Ecodesign for Sustainable Products Regulation
legislative proposal by the European Commission
Eurostat Eurostat is the statistical office of the European Union
situated in Luxembourg. Its mission is to provide high
quality statistics for Europe.
GHGs Greenhouse gases
HH Textile Hydrostatic Head Textiles are fabrics used in textiles to
make the clothing item waterproof against liquids trying
to pass through the fabrics.
JRC Joint Research Centre
Open loop recycling Recycling process which serves as to either convert the
elements composing a used product into raw materials
for a new good or into waste product.
PC Public consultation
PRO Producer responsibility organisation
Proximity principle Wastes should be disposed of as close to the source as
possible.
Recovery Waste operation the principal result of which replaces
other materials which would otherwise have been used
to fulfil a particular function, or waste being prepared to
fulfil that function2
.
Recycling Any operation which reprocesses waste materials into
useful products, materials or substances.
SCIP Database for information on Substances of Concern In
articles as such or in complex objects (Products)
established under the Waste Framework Directive.
SDG Target 12.3 United Nations Sustainable Development Agenda 2030,
includes a target (Sustainable Development Goal (SDG)
1
Annex I of Directive 2008/98/EC on waste sets out a non-exhaustive list of disposal operations.
2
Annex II of Directive 2008/98/EC on waste sets out a non-exhaustive list of recovery operations.
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12.3) to halve per capita global food waste at the retail
and consumer levels and reduce food losses along
production and supply chains, including post-harvest
losses, by 2030.
Separate collection The collection where a waste stream is kept separately at
the point of its generation and collection by type and
nature so as to facilitate a specific instrument. See Article
3(11) of the Waste Framework Directive.
Self-sufficiency principle At Community and, if possible, at Member State level.
Member States need to establish, in co-operation with
other Member States, an integrated and adequate
network of waste disposal facilities. See Article 16 of the
Waste Framework Directive.
UN United Nations
Waste hierarchy principle Waste hierarchy is the five-step EU waste management
principle established under Article 4 of the Waste
Framework Directive that orders from most to least
preferred the methods of managing and disposing waste
as it follows: i. prevention, ii. preparing for reuse, iii.
recycling, iv. recovery, and v. disposal.
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1. INTRODUCTION
This impact assessment (IA) studies a possible revision of the Waste Framework Directive3
(WFD) to contribute to the ambition of the European Green Deal (EGD)4
in terms of
reducing waste generation. No formal evaluation was conducted because the transposition
and implementation of the last amendment of the WFD in 2018 are not yet completed (see
Annex 5 for details).
The WFD aims for waste not to harm the environment and human health, and implements
the ‘polluter pays’ principle through extended producer responsibility (EPR) schemes. The
WFD mandates Member States to set up separate collection5
for bio-waste (including food
waste) by 31 December 2023 and for textiles by 1 January 2025. It also mandates the
Commission to assess by the end of 2023 the feasibility of establishing an EU-wide food
waste reduction target to be met by 2030. Even though textiles and food waste have their
own specificities, they share a common legal basis with the WFD and are subject to the
same overarching objectives. Therefore, both waste streams are covered by this IA.
As regards textiles, the IA examines different policy options to improve textile waste
management in line with the ‘waste hierarchy’6
enshrined in the WFD, prioritising waste
prevention, re-use and recycling of textiles over other recovery options and disposal. As
regards food waste, it explores different policy options for setting EU-wide food waste
reduction targets.
The Circular Economy Action Plan (CEAP)7
and the EU Strategy for Sustainable and
Circular Textiles (‘Textiles Strategy’)8
call for reinforced and accelerated EU and Member
State action to prevent textiles waste and to improve the circularity of textiles, as it is
a resource intensive sector alongside food causing significant negative environmental
externalities, where financing and technological gaps impede progress towards the
transition to a circular economy.
The introduction of EU-wide food waste reduction targets, as called for by the Farm to
Fork Strategy9
aims to contribute towards a sustainable food system that is more resource
efficient while minimising impacts on the environment. Reducing food waste also
contributes to food security, currently at the centre of the political agenda. This will in
turn improve food affordability, for instance, by helping consumers avoid purchasing food
that is then disposed of.
Table 1 – Mapping of the main links of policy priorities to the WFD
Policy area WFD contribution and relevance
3
OJ L 150, 14.6.2018, p. 109–140
4
COM/2019/640 final
5
Article 3(11) of the WFD defines ‘separate collection’ as “the collection where a waste stream is
kept separately by type and nature so as to facilitate a specific treatment”.
6
The waste hierarchy is a central concept in the WFD that establishes an order of preference for managing
and disposing of waste: prevention first (including re-use) followed by waste management operations:
preparing for re-use, recycling, recovery and last disposal. It is operationalised through specific rules and
performance targets, such as setting separate collection obligations and targets for prevention, recycling or
diversion from landfill.
7
COM/2020/98 final
8
COM/2022/141 final
9
COM/2020/381 final
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The 8th
Environment
Action Programme (8th
EAP)10
Timeline: 2022-2030
Speed up the transition to a climate-neutral, sustainable, non-toxic, resource-
efficient, renewable energy-based, resilient and competitive circular
economy to attain the EU’s 2050 vision of living within planetary
boundaries.
Circular Economy Action
Plan (CEAP)
Timeline: since 2020
Increase circularity of resource intensive sectors, such as textiles and food11
for people, regions and cities. Prevent or reduce waste generation. Enhance
the implementation of the polluter pays principle. Strengthened markets for
secondary raw materials and more circularity. Reduce environmental
impacts through improved waste management.
Bioeconomy Strategy12
Timeline: Updated
bioeconomy strategy
published in October
2018
Calls for actions to reuse, reduce and recycle bio-waste streams. Principles
such as the circular economy, cascading use of biomass and the waste
hierarchy are at its core.
Ecodesign for Sustainable
Products Regulation
(ESPR)13
Timeline: Commission
proposal published in
March 2022
Make sustainable products the norm in the EU by setting minimum
requirements to improve their circularity, energy performance,
promote/support sustainable production and consumption models and
stimulate re-use, repair and recycling.
EU Strategy for
Sustainable and Circular
Textiles (‘Textiles
Strategy’)
Timeline: Published in
March 2022
Calls for urgent action across the entire lifecycle of textiles to ensure
sustainable textile products and circularity to retain textiles’ value in the
economy for as long as possible and to reduce dependencies on virgin raw
materials.
Farm to Fork Strategy
Timeline: Published in
May 2020
Reduce food waste levels. Establish a baseline for food waste levels,
considering new data measured by MS and propose legally binding targets
to reduce food waste across the EU by 2023.
Commission analysis of
the drivers of food
security14
Timeline: Published in
January 2023
Food waste is one of the main drivers affecting food security from both the
supply and demand sides. Food waste reduces productivity and can reduce
food availability. Additionally, reducing food waste could contribute to food
price decreases, thereby potentially improving economic access to food.
Proposal for a legislative
Framework for a Union
Sustainable Food System
(‘FSFS’)
Timeline: planned for Q3
2023
Food waste reduction will be part and parcel of the future legislative proposal
establishing a framework for a Union Sustainable Food System. There will
be synergies between the two initiatives (e.g., when MS implement national
food waste prevention programmes to meet the set targets, they would need
to take into account the general principles of FSFS, where applicable and
relevant).
Food Information to
Consumers15
– revision of
EU rules on date marking
Clarify wording of ‘use by’ and ‘best before’ dates to prevent food waste
linked to the misunderstanding and/or misuse of these dates.
10
OJ L 114, 12.4.2022, p. 22–36
11
https://single-market-economy.ec.europa.eu/industry/transition-pathways_en.
12
European Commission, Directorate-General for Research and Innovation, A sustainable bioeconomy for
Europe: strengthening the connection between economy, society and the environment: updated bioeconomy
strategy, Publications Office of the European Union, 2018, https://data.europa.eu/doi/10.2777/792130
13
COM/2022/142 final
14
SWD(2023) 4 final, Drivers of food security
15
OJ L 304, 22.11.2011, p. 18–63
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REPowerEU16
Timeline: Published in
March 2022
Increasing production from 3.5 (2021) to 35 (2030) bcm of biomethane from
sustainably sourced feedstock, including food waste, to strengthen security
of energy supply and reduce dependence on Russian fossil fuels. While food
waste reduction is not expected to contribute to this target, indirect effects
(e.g. freeing land for non-food uses) may have limited impact.
Social Economy Action
Plan17
Timeline: Published in
December 2021
Sets waste management rules to provide opportunities for social enterprises
and circular business models.
Chemicals Strategy for
Sustainability18
Timeline: Published in
October 2020
Protect citizens and the environment from harmful chemicals, ensuring all
chemicals are used more safely and sustainably and prioritising innovation
for substituting substances of concern across sectors, such as textiles.
Zero pollution action
plan19
Timeline: Published in
May 2021
Mandate that waste is managed without endangering human health and
harming the environment. Promotes the waste hierarchy to reduce pollution.
Both Council20,21
and Parliament22,23
call for and welcome the Commission’s approach to
improve the sustainability and circularity of textiles. They call on the Commission to
prioritise waste prevention, introduce EPR, promote high-quality recycling, increase
recycling capacity and demand for recycled textiles, and adopt EU end-of-waste criteria
for textiles as well as promote the resilience and social justice of the ecosystem.
Parliament has called for the reduction of food waste and advocated setting specific food
waste prevention targets: at least 30% and 50% reductions by 2025 and 2030,
respectively24, 25, 26, 27
. In 2016, Council28
called on Member States to confirm their
commitment to achieving SDG 12.3 through a range of initiatives, supported by the
Commission in key areas such as food waste monitoring. Subsequent updates on progress
made in Member States were adopted through Council Conclusions in 201829
and 202030
.
16
COM/2022/108 final
17
COM/2021/778 final
18
COM/2020/667 final
19
COM/2021/400 final
20
Council of the EU, More circularity - Transition to a sustainable society – Council conclusions, 4 October
2019.
21
Council of the EU, Draft Council conclusions on Making the Recovery Circular and Green – Approval,
11 December 2020
22
OJ C 298, 23.8.2018, p. 100–111 (Resolution on the EU flagship initiative on the garment sector)
23
OJ C 465, 17.11.2021, p. 11–29 (Resolution on the New Circular Economy Action Plan)
24
OJ C 227E, 6.8.2013, p. 25–32 (Resolution on how to avoid food wastage)
25
OJ C 265, 11.8.2017, p. 65–75 (Resolution on resource efficiency: moving towards a circular economy)
26
OJ C 307, 30.8.2018, p. 25–43 (Resolution on resource efficiency: reducing food waste, improving food
safety).
27
OJ C 270, 7.7.2021, p. 2–20 (Resolution on the European Green Deal)
28
Council of the EU, Food losses and food waste - Council conclusions, 28 June 2016.
29
Council of the EU, Food losses and food waste: assessment of progress made on the implementation of
June 2016 Council conclusions - Information from the Presidency and the Commission - Exchange of views,
28 March 2018
30
Council of the EU, Food losses and food waste: assessment of progress made in implementing the Council
conclusions adopted on 28 June 2016 ‒ Information from the Presidency and the Commission, 9 November
2020
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Support of the EU and Member States for halving global food waste by 2030 was also
confirmed in 2022 at COP15 (Target 16)31
.
As a follow-up to the Conference on the Future of Europe, the Commission announced in
2022, a “new generation” of citizens’ panels to consult randomly selected citizens before
certain key policy proposals, with the first panel of this type organised to support this
initiative on the topic of food waste. This citizens’ panel however provided
recommendations32
that have a broader scope than the current initiative. It will support the
overarching work of the Commission on food waste and serve as a guide to help Member
States in achieving their target.The panel outcome has been annexed to this impact
assessment (see Annex 16).
A European Court of Auditors report recommended to strengthen and better coordinate the
EU Strategy to combat food waste. While noting measures set out in the 2015 Circular
Economy Package, it expressed criticism of the Commission for, in their view, decreasing
its levels of ambition over time, including on setting waste reduction targets and delaying
obligations for Member States’ reporting on food waste33
.
The preparatory work for this assessment, including the studies and the public consultation,
looked into other areas governed by the WFD: waste prevention practices, waste separate
collection systems and waste oils. The preliminary analysis shows that implementation of
the ‘2018 waste package’ is still ongoing and that further information and data are
necessary to comprehensively evaluate the Directive and assess the necessity of additional
EU action (see Annex 8 for details).
2. TEXTILES
2.1. Facts, figures and context
This section summarises the main facts, figures and context related to textiles and the
implementation of the waste hierarchy (see Annex 6 for details).
The textile industry is an essential part of EU manufacturing. The EU textiles, wearing
apparel and leather manufacturing market consists of around 226 600 companies in 2021,
over 99% of which are SMEs34
, and employed around 1.7 million people35
. In 2021, the
EU textile and clothing sector had a gross turnover of €191 billion36
.
Over the last two decades, the EU textile industry has transformed itself from mass
low value-added production to high-quality products, especially in high-end and
31
Where reference is made, in this document, to SDG Target 12.3, this also encompasses the EU’s
commitment to Target 16 of the COP15 Global Biodiversity Framework.
32
European Citizens’ Panel on Food Waste, Final recommendations, February 2023
33
European Court of Auditors, Combating food waste: an opportunity for the EU to improve the resource-
efficiency of the food supply chain. Special report No 34, 2016, Publications Office of the European Union,
2017, https://data.europa.eu/doi/10.2865/272895
34
The European Commission defines SMEs as having less than 250 persons employed. They should also
have an annual turnover of up to EUR 50 million, or a balance sheet total of no more than EUR 43 million
(Commission Recommendation of 6 May 2003).
35
Eurostat data set ‘Enterprise statistics by size class and NACE Rev.2 activity’ (SBS_SC_OVW), combing
NACE codes C13, C14 and C15.
36
Ibidem.
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luxury fashion, technical textiles37
. Italy, Germany, France, Spain, Portugal, Poland,
Romania, Netherlands, Austria and Belgium represent the most important Member States
in terms of textile and apparel production in the EU. Southern Member States tend to focus
on clothing, while technological-intensive textile industries are mainly located in
Germany, Italy and Austria. Generally, textile production is frequently clustered in
concentrated manufacturing hubs.
However, most production of the textiles consumed in the EU takes place in third countries,
mainly in Asia. Consequently, most of the environmental pressures of the EU
consumption of textiles occur in third countries38
. The EEA estimates that to produce
the amount of clothing, textiles and footwear consumed in the EU in 2020, 80% of primary
raw materials, 88% of water and 92% of land used and 73% of greenhouse gas (GHG)
emissions took place outside the EU. Additionally, almost 13 million full-time equivalent
workers were employed worldwide in the supply chain39
.
Textiles are highly globalised, with the EU being a significant importer and exporter. It
has been estimated40
that in 2019 the import of fibres, yarns, fabrics and particularly
finished products in the EU jointly corresponded to 13.5 Mt41
. Women’s clothing and other
knitted and woven garments were the main exported textile products, accounting for 24%
and 23% of total exports that year. Switzerland, the UK, the USA and to a lesser extent
China are the main destinations of EU textile exports accounting for 46% of total EU textile
exports. A significant amount of textile goods is also traded over national borders within
the EU. A total of 6.5 Mt of textile goods moved within the EU in 2019.
The growing trend of online shopping exacerbates so-called ‘fast fashion’42
, which is
characterised by more frequent fashion collections being placed on the market43
with low-
priced products that do not internalise environmental externalities44
, encourage customers
to shop impulsively and incentivises purchasing larger quantities of clothes45
. This
increasing textile consumption leads to increasing volumes of textile waste.
Figure 1 shows the mass flow analysis for textile generation and waste management in the
EU. Data on generation and management of textile waste in EU vary from different
sources, depending on the scope of the textiles covered, reference years and the
methodology of calculation/estimation. This IA mainly rests on the results of an ongoing
JRC study46
for the reference year 2019, which covers all kinds of textiles along the whole
value chain, starting from fibres production to the end-of-life of textile products. The
37
https://single-market-economy.ec.europa.eu/sectors/fashion/textiles-and-clothing-industries/textiles-and-
clothing-eu_en
38
European Environment Agency, 2019
39
EEA. Textiles and the environment: the role of design in Europe’s circular economy (2022). Available at:
https://www.eea.europa.eu/publications/textiles-and-the-environment-the.
40
Flows are represented as tonnes, and refer to annual mass units
41
European Commission, Joint Research Centre. Techno-scientific assessment of the management options
for used and waste textiles. 2023 (under development)
42
What is fast fashion and why is it a problem? | Ethical Consumer
43
Lai, O., What is fast fashion, Earth.org, 2021, https://earth.org/what-is-fast-fashion
44
Stakeholder workshop.
45
European Commission, Joint Research Centre, 2021, https://data.europa.eu/doi/10.2760/858144.
46
European Commission, Joint Research Centre. Techno-scientific assessment of the management options
for used and waste textiles. 2023 (under development)
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apparent consumption47
of textiles in the EU (i.e. domestic retail and textiles placed on the
market for business-to-business applications) was estimated to be around 12 Mt.
Total textile waste generated, covering clothing and footwear, home textiles, technical
textiles, and post-industrial and pre-consumer waste, was estimated at 12.6 Mt,
including fractions that are discarded during textile production (post-industrial waste, 11%
of total waste), at the retail stage (pre-consumer waste, 3%), and by households and
commercial entities waste (post-consumer waste, around 87%). Post-industrial and pre-
consumer waste is likely to consist of fewer fibre types and material blends48
that make it
easier to identify49
and be treated. Such waste is typically collected by waste collectors
based on commercial contracts, whereas municipalities, social and commercial enterprises
are engaged in collection of post-consumer household textiles. Post-consumer textiles
waste50
generated in 2019 amounted to 10.9 Mt. Clothing and footwear waste amounted
to 5.2 Mt, equivalent to 12 kg per person per year in the EU.
There are large variations across national separate collection systems in terms of their
scope. The most common systems cover clothes and household textiles (and often
footwear) for re-use purposes and at times also for recycling. Mattresses, carpets and other
similar bulky materials with textile components are typically collected as bulky waste.
Only about 2.4 Mt textiles are separately collected every year in the EU (around 22%
of total generated post-consumer textile waste and around 39% of textile waste
covered by collection systems). Therefore, about 8.5 Mt (78%) of textile waste is
largely discarded in household mixed waste and end up incinerated or landfilled.
Collected textiles are sent to sorting facilities, to be separated into re-usable51
and
recyclable fractions52
. EU sorting capacity is insufficient to manage the textile waste
generated within the EU and is estimated to stand at 1.8 Mt with the remaining of
separately collected textile waste (>50% of the total exports or 0.5-1.0 Mt) being
exported in an unsorted fashion to third countries. This can be mainly attributed to the
lower cost of the sorting process in these third countries and the capacity gap in the EU.
Re-use within the EU of separately collected waste is estimated at about 8% (0.19 Mt).
It is the so-called ‘cream’ fraction (i.e. the fraction with the highest economic value) within
the collected material and generates an important share of the revenues for the sorters53
.
47
Import of finished textiles + finished textiles produced in the EU – finished textiles produced in the EU
that are exported.
48
Elander, M., Automated feeding equipment for textile waste: experiences from the FITS-project, Mistra
Future Fashion, 2019.
49
European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs,
Duhoux, T., Maes, E., Hirschnitz-Garbers, M., et al., Study on the technical, regulatory, economic and
environmental effectiveness of textile fibres recycling: final report, Publications Office, 2021,
https://data.europa.eu/doi/10.2873/828412
50
Unwanted consumer textiles can be exchanged, sold, donated or discarded as waste either via textile
separate collection or in the mixed waste bin. For ease of reading, this document will use the term textile
waste even if part of the unwanted clothes is provided to be re-used.
51
The European Recycling Industries’ Confederation (EuRIC) is the umbrella organisation for European
Recycling Industries.
52
European Commission, Joint Research Centre, Donatello, S., Danneck, J., Löw, C., et al., Circular
economy perspectives in the EU textile sector: final report, Publications Office, 2021,
https://data.europa.eu/doi/10.2760/858144.
53
Nørup, N., Pihl, K., Damgaard, A., Scheutz, C., 2019a. Evaluation of a European textile sorting centre:
Material flow analysis and life cycle inventory. Resources, Conservation and Recycling 143, 310–319.
doi:https://doi.org/10.1016/j.resconrec.2019.01.010
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Export is the most common fate of separately collected textile waste sorted in the EU (0.85
Mt; 48% of the total sorted). This means that annually a total of 1.83 Mt of used and
waste textiles are exported to third countries, mainly to Asia and Africa (jointly
receiving close to 90% of the EU exports)54
. Although the main purpose of the exports is
re-use, it is likely that a large share of the textiles sent to Africa is ultimately not re-usable
and may contribute to adverse environmental and social impacts in the country of
destination55
.
There are different assessments of the overall reusability of discarded clothing and
household textile waste ranging from 45%56
to 65%57
. The fraction after sorting that does
not meet the quality requirements is mostly recycled (corresponding to 32% of the
separately collected waste or 0.8 Mt), and low amounts of waste-to-energy recovery or
disposal (5-10%) are generated after the sorting process. Together with the recycled share
of post-industrial and pre-consumer waste, the total mass that enters textile recycling
plants, effectively corresponds to the estimated recycling capacity in the EU (0.70-0.85
Mt/year).
Some Member States have established national textile management regulations assigning
responsible to actors for the collection of waste. France and soon also the Netherlands
are the only Member States with a mandatory EPR scheme, which mandates textile
producers to organise collection of re-usable textiles and textiles waste. Sweden, Germany,
Bulgaria, Belgium and Spain are planning to adopt EPR schemes and other Member States
are carrying out feasibility studies. There are differences in the scopes, reporting and
regulation of the producers and other operators across Member States.
The formal re-use sector, dominated by social enterprises, is currently the most active in
separate collection and sorting of textiles, with a business model based on the sale of the
best quality textiles. Most sorting presently takes place manually, which is time-consuming
and costly, but essential to separate out textiles for reuse. Automatic sorting is still in the
initial stages (<1% of post-consumer textiles sorting) and needs considerable investments
to scale up and improve; however, it seems likely that in a near future automated sorting
could become complementary or partially replace the sorting of textiles that are destined
for recycling. Currently two main types of recycling technologies are used for textiles:
mechanical and chemical recycling. Additionally, textile waste can be thermally recycled,
but at present, this process is not implemented at industrial scale in the EU. Most of the
fraction recycled in EU is converted into low value products (e.g. wipers, cleaning cloth,
insulation materials) by means of mechanical recycling, and the share that is actually
54
EEA, 2023. EU exports of used textiles in Europe’s circular economy. Available at:
https://www.eea.europa.eu/publications/eu-exports-of-used-textiles/eu-exports-of-used-textiles.
55
Cobbing, M., Daaji, S., Kopp, M., Wohlgemuth, V., 2022. Poisoned Gifts From donations to the dumpsite:
textiles waste disguised as second-hand clothes exported to East Africa. Available at:
https://www.greenpeace.org/static/planet4-international-stateless/2022/04/9f50d3de-greenpeace-germany-
poisoned-fast-fashi
56
Alcin-Enis I., Kucukali-Ozturk M., Sezgin H. (2019) Risks and Management of Textile Waste. In:
Gothandam K., Ranjan S., Dasgupta N., Lichtfouse E. (eds) Nanoscience and Biotechnology for
Environmental Applications, Environmental Chemistry for a Sustainable World, vol 22. Springer, Cham.
https://doi.org/10.1007/978-3-319-97922-9_2.
57
Tojo, N., Kogg, B., Kiørboe, N., Kjær B. and Aalto K., Prevention of Textile Waste. Material flows of
textiles in three Nordic countries and suggestions on policy instruments, NORDEN,
http://dx.doi.org/10.6027/TN2012-545.
EN 8 E
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recycled for further applications as apparel is low (2% of sorted material, see Annex 6 for
details).
EN 9 EN
Figure 1: Mass flow analysis for textile generation and waste management in the EU (for the status quo reference year 2019). The mass flows in each node
are expressed in Mt/year58
58
European Commission, Joint Research Centre. Techno-scientific assessment of the management options for used and waste textiles. 2023 (under development)
EN 10 E
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2.2. Problem Definition
2.2.1. What are the problems?
Despite waste prevention being a key objective of the WFD and the implementation efforts
at national level including by private actors, waste generation continues to increase and
only a ‘relative decoupling’ of waste generation from economic growth can be observed59
.
Currently, around 78% of the post-consumer textiles waste is not separately collected and
ends in mixed household waste, destined to be incinerated or landfilled. This is not in line
with the waste hierarchy, is resource inefficient and leads to environmental harm in the EU
and in third countries through excessive levels of GHG emissions, water consumption,
pollution and land use.
The separate collection obligation for textiles in the WFD is coming into force on 1 January
2025. According to information from Member States, it is estimated that the separate
collection systems, and the sorting and recycling infrastructures, which are unlikely to be
ready to handle the expected additional amounts to be collected, mainly those diverted
from mixed household waste. Sorting infrastructure is expected to take place in most
Member States close to the waste collection and at a higher scale in those where the market
conditions are favourable (e.g. lower costs, existing upscaleable infrastructure and skills,
proximity to recycling/production hubs and ports). Recycling infrastructure is not expected
to take place in all countries and are likely to be located in regions close to the textile
production centres, existing infrastructure bases.
Key environmental, economic and social consequences
The textile sector is resource intensive. As previously mentioned, in relation to both the
production of raw materials and textile most of the pressures and impacts related to the
consumption of clothing, footwear and household textiles in the EU occur in other regions
of the world. The majority of these negative impacts are borne by Asia, where most fibre
production and textile manufacturing take place. The textile sector is the fifth largest
sector in terms of GHG emissions, thus being a significant contributor to climate
change. According to the EEA, textile purchases in the EU in 2017 generated about 654kg
of CO2 emissions per person60
. It also has high impacts in terms of chemicals and water
pollution. Therefore, preventing, re-using and recycling textile waste can help reducing the
environmental footprint of the sector.
Additionally, the waste management costs of used clothing and household textiles are
not addressed in the price of new products. On average, the costs of collection and
treatment would equate to approximately 12 cents per item. However, these costs vary by
item type, with those involving a mix of textile fibre types and the inclusion of disruptors
(for example buttons and zips) costing more to manage and those that comprise a single
fibre type with no disruptors such as t-shirts costing less. Given the large volumes of textile
wastes currently disposed of in residual waste, the cost of disposal and the environmental
externalities of that disposal including emissions from incineration and landfilling are also
not internalised. Other externalities include notably the environmental and social impacts
59
European Environment Agency, Waste prevention in Europe, 2021, Waste prevention in Europe —
European Environment Agency (europa.eu).
60
European Parliament, The impact of textile production and waste on the environment, 2020,
https://www.europarl.europa.eu/news/en/headlines/society/20201208STO93327/the-impact-of-textile-
production-and-waste-on-the-environment-infographic.
EN 11 E
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of textile waste exported to third countries disguised for re-use purposes, in particular, in
relation to exported non-sorted textiles.
Fragmented definitions lead to administrative burden and pose barriers to cross-
border shipments. Different policy and regulatory signals in each Member State and
information gaps hamper the scaling up of the recycling industry and re-use and disrupt
the level playing field of the single market. This obstructs not only the transition to a
circular economy in textiles, but also prevents jobs and value-added being created in the
EU. The insufficient sorting and recycling infrastructure is likely to lead to textiles not
being treated in line with the waste hierarchy even once the separate collection obligation
comes into force. Low added-value manufacturing mainly occurs in third countries.
Production and disposal of imported textile waste create significant negative societal
impacts at local, regional and global levels61
.
The visual problem tree is presented as part of the intervention logic in Section 2.4 (see
Figure 3).
2.2.2. What are the problem drivers?
Several regulatory, market and behavioural problem drivers can be identified hampering
the treatment of textile waste in line with the waste hierarchy, namely, prioritising
prevention, re-use followed by preparation for re-use and recycling, and minimising
treatment of textile waste as residual waste (see Annex 7 for details). The visual problem
tree is presented as part of the intervention logic in Section 2.4 (see Figure 3).
Regulatory failures
While specific waste management and reporting obligations are defined in the WFD
in relation to textiles, the underlying definitions of ‘textiles’, ‘used textiles’ and ‘waste
textiles’ that set out the scope of those obligations are either non-existent or subject
to broad and inconsistent interpretation among the operators and Member States.
Therefore, it is uncertain which ‘textiles’ are covered under the separate collection
obligation set out by the WFD, both in terms of textile types and sources of waste. Member
States and regional authorities do not apply in a harmonised way the definition of ‘textile
waste’ and ‘used textiles’ to similar separate collection approaches and materials or
products. The information reported by Member States on re-use of textiles and textile waste
management under the WFD presents significant gaps and robustness concerns due to all
of the above notions being subject to different interpretations nationally.
The industry stakeholders have consistently raised that non-harmonised application of
definitions results in uncertainties to the waste management and re-use operators as to the
legal status of the material they handle. Therefore, the potential to transport those materials
to other regions, Member States or outside the EU for re-use, preparation for re-use or
recycling is hampered to respond to the market needs for demand of used textiles and
recycled fibres and create economies of scale that are needed to scale up re-use and
recycling activities. These uncertainties increase the costs and legal and administrative
risks to the economic operators and hinder the potential for creating economies of scale
which can only be achieved at regional and cross-border level. Non-uniform application
of the textile waste and used textile (i.e. product not waste) concepts complicates the
enforcement of EU rules on waste shipment and undermines re-use operations due to
administrative and legal uncertainties of the concerned shipments. It also generates textile
61
Ellen Mac Arthur Foundation, 2017, https://ellenmacarthurfoundation.org/a-new-textiles-economy.
EN 12 E
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waste data that is not comparable or robust across Member States, which in turn hampers
proper waste management policy, infrastructure and investment planning by the Member
States and used textile and textile waste operators.
The present approaches to separate collection in relation to the assignment of the
responsibility for it (i.e. municipalities, commercial/social enterprises, producers), the
scope of separate collection systems and the state of implementation of the rules
indicate significant inconsistencies and likely delays in full roll-out of the separate
collection systems and infrastructure for subsequent treatment. Textile waste
management actors are also typically small commercial or commercial enterprises. These
inconsistencies and fragmentation hamper the mobilisation of the textile and waste
industry at EU level and commitment of the investments for the necessary collection,
sorting, recycling and research and development activities.
Most Member States do not yet have full separate collection schemes in place and a clear
organisation and attribution of the responsibility for its collection and subsequent
treatment, with textile collection for re-use mainly operating informally through social
enterprises and commercial collectors. These national policy discussions and investment
decisions are also impacted and delayed to varying extent awaiting the outcome of the on-
going EU level policy discussions in the context of this initiative, primarily the possibility
of introducing a harmonised EPR scheme for textiles. Thus, timely implementation in view
of scaling up re-use and recycling is unlikely, in particular, since these regulatory barriers
impede investments.
Several Member States have chosen to implement the separate collection obligation by
establishing an EPR for textiles (i.e. entrusting textile waste management to producers)
and several more are also considering taking this route to ensure treatment of textile waste
in line with the waste hierarchy and the financing for such activities. However, the varied
national approaches to regulating EPR scope, its operational and organisational
features lead to regulatory fragmentation, increased compliance costs for the obliged
industry to abide by heterogeneous levels of regulations in each Member State they
operate in as the same activities, products and economic operators are subject to
different rules in different Member States. This regulatory fragmentation would hamper
their ability for coordination and investment in sorting, re-use and recycling which are
intrinsically cross-border activities. As further schemes will be adopted by Member States
(legislation is in preparation or discussions are at an advanced stage in several countries,
e.g. Sweden, Belgium, Bulgaria, Spain, Slovakia), it is expected that the divergences
identified in the case of French, Dutch and Swedish systems will continue to grow across
the EU, as Member States determine the scope and nature of their own schemes. To prevent
this, the textile and waste industrial stakeholders as well as NGOs are unanimously calling
for mandating and harmonising EPR for textiles at EU level.
National and regional variations in the scope of separate collection systems for textiles and
other materials (e.g., footwear, accessories, leather goods) that are or would be collected
through the same separate collection systems impact the material composition of the
collected material and the cost and therefore the feasibility of subsequent sorting for re-use
or recycling since sorting operations generally have predefined acceptance criteria for the
material composition it may process. It also undermines sorting activities at scale at
regional level serving several countries.
In addition, the current EU sorting capacity will be insufficient to process all
separately collected textiles and would need to be significantly scaled up, primarily
EN 13 E
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through manual sorting and, most likely, in all Member States and particularly in
regions in the vicinity of recycling facilities and markets relevant for the uptake of
used and recycled textiles. Delays in national waste management policy planning and
implementation and regulatory fragmentation that undermine consistency, scale and cross-
border movement of collected, sorted or recycled textile as outlined above are all factors
that hamper the ability of the textile value chain to take coordinated steps towards
circularity. It undermines the scoping of feedstock sources and composition as well as
investment planning and certainty for the sorting, processing and recycling infrastructure.
Despite most of collected textiles being exported outside the EU, there is also a lack
of reliable information on the fate of exported used textiles outside the EU and the
share that is treated as waste in the receiving countries since the classification codes
relevant for the export of used textiles do not distinguish between sorted or unsorted used
textiles and therefore the share of the present waste textiles. In fact, there are conflicting
reports from various sources with several indicating that a considerable share of second-
hand (exported as non-waste) clothing arriving from the EU is treated as waste, namely,
recycled or disposed of62
.
Waste prevention action and monitoring is insufficient as consumption and generation
trends increase and national waste prevention programmes rarely include monitoring
indicators or targets to monitor and assess the effectiveness of the measures and policies.
Market failures
The ‘fast fashion’ which offers low-priced textiles the production of which does not take
into account negative environmental externalities encourages consumers to over-consume.
This leads to an increase in the quantity of textiles consumed and the velocity with which
textiles are being discarded. Textile producers lack incentives designing long-lasting,
re-usable or recyclable products63, which hampers the development of circular
business models64. It also leads to some textiles not being fit for recycling.
There is a significant funding gap for the financing of textile management in line with
the waste hierarchy. Any separate collection and sorting of textile waste that currently
takes place in the EU is financed by the re-use market by selling the ‘crème’ for a profit.
And it relies heavily on the export of the textiles with the declared purpose of re-use.
However, global re-use markets are saturating, and the exported re-usable textiles price per
tonne is decreasing65
. Based on the estimated composition of separately collected textile
waste once the separate collection obligation is fully implemented, this financing model
will no longer be feasible since the cost of managing the sorting and treatment of the non-
re-useable fraction will be greater than the revenues from selling the ‘crème’ or other re-
usable fractions in the EU and global re-use markets. Furthermore, the sorting and
recycling facilities are costly and lengthy to set up, including, in view of training
professional sorting personnel since the vast majority of sorting is carried out manually.
The global reuse markets are saturating, contributing to increased waste generation as
products of low quality have a shorter longevity. Also, the informal resale by consumer-
to-consumer (C2C) of ‘crème’ clothes is subject to a considerable growth impacting the
62
EEA, 2023. EU exports of used textiles in Europe’s circular economy. Available at:
https://www.eea.europa.eu/publications/eu-exports-of-used-textiles/eu-exports-of-used-textiles
63
Stakeholder workshop, call for evidence.
64
Stakeholder workshop, call for evidence (Policy Hub, Circularity for Apparel and Footwear).
65
See footnote 41.
EN 14 E
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profitability of the waste management operators resale operations. The C2C used textile
market has also shown to encourage customers to buy more reused products because
they are cheaper.
Certain information and technological barriers are also hampering recycling of
textiles. The composition of textiles waste is largely unknown, constituting an information
constraint, resulting in increased sorting and monitoring costs, hindering recycling of many
fibres/compositions. In addition, uncertainties in relation to the quality of recycled textiles
may reduce their demand. This is partially due to the disparate way in which Member
States collect and treat textiles and partially due to information on textiles not reaching or
reaching in unreadable way (due to lack of automatic sorting) the waste operators. While
mechanical recycling is currently well developed as is the predominant recycling process
applied, it also generates lower quality secondary raw materials. The upscale of uptake of
this material is hampered by the low primary material costs which don’t take into account
the environmental externalities and the demand for recycled materials. For recycling of a
broader variety of fibre compositions and technologies that deliver high quality secondary
raw materials suitable for textile product applications, the technology readiness levels for
scaling up at industrial level are not yet attained, but close. Considerable investments are
needed in the research and development for developing automatic sorting and recycling
technologies to address the growing amounts of recyclable textiles post 2025.
Behavioural drivers
Despite increasing awareness, the ‘use-and-dispose’ culture or ‘take-make-use-throw’
mindset is still largely fostered across the whole supply chain and adopted by consumers
increasing the volumes of textile waste are generated. Consumers are mostly unaware
of the negative environmental externalities of production and end-of-life management
of textiles, impeding a change in consumption habits.
2.2.3. How likely is the problem to persist?
Since waste generation continues to be positively correlated with economic growth
(‘relative decoupling’), it is likely that waste generation is expected to increase in line with
the economic recovery following the COVID-19 pandemic. Despite EU initiatives, such
as the ‘2018 waste package’ and efforts at Member States level to prevent textile waste
and manage it according to the waste hierarchy, consumption and production patterns are
still expected to lead to growing amounts of textiles being placed on the EU market,
being consumed and eventually given for re-use or discarded (see Figure 2).
The Textiles Strategy proposes actions for the full lifecycle of textile products, by targeting
the way textiles are designed and consumed. As part of the implementation of the ESPR,
eco-design requirements for textiles will aim at increased product durability,
reparability, recyclability and the use of recycled materials. Such measures would
contribute to reducing textile waste generation and facilitating increased recycling rates
but not before the end of the decade.
The future review of the Textile Labelling Regulation will also have an impact on the
baseline. It is expected to potentially increase the demand for higher quality textiles
products, ease sorting and recovery of materials and fibre-to-fibre recycling, play a role in
reducing energy consumption in washing and in extending the durability and maintaining
the quality, and facilitate the second-hand market across Member States via the ‘uniform
size labelling’.
EN 15 E
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The Commission proposal for the Waste Shipments Regulation (WSR)66
aims to restrict
the export of waste to non-OECD countries unless the country can demonstrate its ability
to manage waste in an environmentally sound manner. It also looks to establish in the
future clear criteria to differentiate between used goods and waste to prevent waste from
being falsely exported as used goods and therefore limit illegal shipments. The
development of such criteria could complement the measures taken in the context of the
Textile Strategy, including for textiles under the WFD as lex specialis.
The JRC has commenced assessments underpinning the development of end-of-waste
(EoW) criteria for textile waste in early 2023. Where further adoption of such criteria at
EU level by the Commission takes place, such harmonised EoW criteria are expected to
bring legal certainty and contribute to smoother shipment of materials derived from treated
textile waste for re-use and recycling within the EU and to third countries.
Determining the impact of the separate collection obligation under Article 11 of the WFD
that requires separate collection for textiles from 1 January 2025 is challenging (see details
in Annex 7). Currently, separate collection sits at around 39% of textile waste covered by
collection systems. By relying on JRC67
and McKinsey68
studies, it can be shown that
under very optimistic and stylised assumptions, the estimated separate collection rate in
the EU would reach between 60-80% by 2035 (according to McKinsey), under more
realistic assumptions between 50-55% by 2035 and under more conservative
considerations at around 40-44% (according to the JRC). Benchmarking the experience
with glass further corroborates that the JRC estimates seem plausible. This means that after
10 years of the binding separate collection obligation unfolding its effect, roughly 50% of
the generate post-consumer textile waste that would be covered by separate collection
systems is likely to be separately collected. A preliminary JRC estimate for 2030 would
suggest post-industrial waste generation of 13.3 Mt yr-1 and separate collection of 3.15 Mt
yr-1. This would result in an EU-level average estimate for separate collection of roughly
41-45% in 2030.
Member States are setting up collection systems, but they are not encouraged to accelerate
the implementation given that the re-use market growth is likely to be limited and
automated recycling is still being developed from a technological perspective. A timely
implementation of the separate collection obligation is also likely to be challenging
according to the surveys of the Member States implementation progress. An increased
collection capacity would require a CAPEX of €500 million, equivalent to an annual
average of €63 million69
(see Annex 6 for details).
Figure 2 below shows the mass flow analysis for textiles and textile waste in the EU in
2035 (the underlying assumptions are detailed in Annex 7). The share of separately
collected textile waste that is re-used is estimated to fall from 45% in 2019 to 41% in 2035.
This will challenge the re-use actors’ business model because of limited increase in their
revenues from re-use and additional costs of collection, sorting, recycling and disposal of
the non-re-useable textiles. The re-use sector is expected to double in five years, but this
is driven by resale platforms where consumers sell their ‘crème’ directly at the detriment
66
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021PC0709
67
See JRC, 2021. Circular economy perspectives in the EU Textile sector
68
McKinsey & Company, 2022. Scaling textile recycling in Europe–turning waste into value
69
European Commission, Joint Research Centre. Techno-scientific assessment of the management options
for used and waste textiles. 2023 (under development).
EN 16 E
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of professional re-use actors, putting further strain on the municipal, commercial and social
enterprises managing separately collected waste70
.
The increasing amount of post-consumer textile waste generated in 2035 (15.5 Mt
compared to 11 Mt in 2019) is estimated to result in higher levels of separate collection,
reaching 3.6 Mt by 2035. This will lead to equivalent sorting needs. Manual sorting will
keep playing an essential role, especially for reuse purposes. Sorting efficiency can be
improved thanks to automatic technologies71
but they are still in development and currently
are not widely applied to support subsequent pre-processing and the recycling processes.
Significant R&D investments are therefore needed to raise the technology readiness levels
for a variety of sorting and recycling technologies to increase the fibre and material
diversity that can be treated by them.
As implicitly shown in Figure 2 in 2035, recycling is estimated to reach 53% of
separate collection of post-consumer waste (36% within the EU and 17% outside the
EU). The recycling share within the EU is thus expected to increase by four percentage
points, up from 32% in 2019. Energy recovery from textile waste through incineration will
remain the dominant treatment for textile wastes that are not separately collected and those
that cannot be re-used or recycled. The share of post-consumer, and post-industrial and
pre-consumer waste that is incinerated for energy recovery is expected to increase
from 45% in 2019 to 60% in 2035, mainly by diverting waste landfilling to incineration.
Landfilling is expected to account for 18% of post-consumer, and post-industrial and
pre-consumer waste.
70
Ibidem.
71
European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs,
Duhoux, T., Maes, E., Hirschnitz-Garbers, M., et al., Study on the technical, regulatory, economic and
environmental effectiveness of textile fibres recycling: final report, Publications Office, 2021,
https://data.europa.eu/doi/10.2873/828412
EN 17 EN
72
72
European Commission, Joint Research Centre. Techno-scientific assessment of the management options for used and waste textiles. 2023 (under development)
Figure 2 - Mass flow analysis for textile generation and waste management in the EU (for the baseline scenario for 2035). The mass flows in each node are expressed
in Mt/year71
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2.3. Why should the EU act?
2.3.1. Legal basis and nature of the legal instrument
Article 192 of the Treaty on the Functioning of the European Union (TFEU)73
empowers
the EU to act in the field of environmental policy to preserve, protect and improve the
quality of the environment, and protect human health and contribute to the prudent and
rational utilisation of natural resources; and promote measures at the international level to
deal with regional or worldwide environmental problems.
The initiative would be realised through a targeted amendment of the Directive
2008/98/EC on waste (WFD) which is the only legal vehicle to regulate textile waste
prevention and management in the EU and is based on Article 192(1) TFEU. While
there are several legal acts regulating textiles products (e.g. REACH, Textiles Labelling
Regulation, ESPR), the WFD is the only legal instrument regulating all aspects of textile
waste management, including the specific obligations to ensure separate collection,
treatment and reporting requirements.
The targeted amendment of the WFD would build on these existing requirements to
remove identified regulatory barriers and address market failures by making those
provisions clearer, more specific and harmonised to reduce the scope of potential national
divergences and create the conditions for the scaling up re-use and recycling of textiles
infrastructure. In addition, the creation of the EPR for textiles obligations would follow the
minimum requirements established in EU law and aim for harmonisation. This objective
would be further pursued by mandating the Commission to adopt more detailed rules
through implementing acts, such as on sorting and reporting requirements, calculation rules
for the collection target and fee modulation. Clear application dates for the individual
measures would be defined in line with the feasibility of implementing them and the
necessary adaptation time needed for the obliged stakeholders.
2.3.2. Subsidiarity: Necessity of EU action
Given the transboundary nature of textiles value chain from an economic, environmental
and social perspective (see Section 2.1), the sale, consumption and end-of-life
management of textiles is intrinsically linked to the functioning of the single market
and global value chains. The high dependency on raw materials highlights the importance
of boosting circular business models to lower the use of primary raw materials and help
mitigate the associated with its negative environmental externalities.
The collection, sorting and recycling systems need to be scaled up to be prepared for the
upcoming separate collection obligation and its full implementation since several
regulatory and market failures that impact all Member States and actors across the textile
value chain currently obstruct sufficient provision of collection, sorting and recycling
capacity. The absence of a common EU approach to textiles management risks
creating or further entrenching a regulatory fragmentation and disrupted waste and
material flows, thereby hampering cross-border movements of textiles (products,
used and waste textiles) and coordinated action and swift investments across the EU.
There are high risks for further increase in the regulatory fragmentation and administrative
burdens on the industry stakeholders, mainly SMEs, resulting from diverse application of
the polluter pays principle through national extended producer responsibility schemes for
73
OJ C 326, 26.10.2012, p.47, https://eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=OJ:C:2012:326:FULL
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textiles. Addressing transboundary environmental externalities, including GHG emissions
and the export of textiles (and waste disguised as non-waste) to third countries is more
effectively addressed by EU action, in particular, as the key problem drivers relate to
regulatory failures resulting from lack of harmonised definitions and regulatory
fragmentation and a funding gap common to all Member States.
The WFD regulatory approach of harmonising certain elements of waste management
(definitions, quantitative or qualitative objectives operationalising the waste hierarchy,
polluter pays principle, reporting requirements) and leaving room for national and local-
specific implementing measures (waste management planning and permitting of waste) is
consistent with EU level action limited to only the extent strictly necessary.
2.3.3. Subsidiarity: Added value of EU action
An increased harmonisation of the approaches to textile waste management in terms of
scope of textiles targeted, clear definitions, minimum shipment and treatment requirements
to operationalise the waste hierarchy, organisational features of textile collection systems
and burden sharing would provide legal certainty for the needed concerted action by the
concerned stakeholders across the textile value chain (Member States, social enterprises,
waste managers, producers, other economic players, citizens) to invest in the development
of infrastructure across the EU to maximise re-use and recycling. These operators achieve
economic efficiencies due to economies of scale and lower compliance costs by only
having to adhere to one EU-wide uniform regulatory approach, for which EU level action
is required. A harmonised approach to closing the financing gap through common
rules on EPR while reducing other regulatory barriers hampering greater uniformity
of textile waste for sorting inputs and outputs and shipments across country borders
for sorting, re-use and recycling would considerably reduce economic burdens on the
industry and SMEs, maintaining their competitiveness. The combined improvement of
environmental quality can be considered an important co-benefit.
2.4. Objectives: What is to be achieved?
2.4.1. General objective
The overall objective of the WFD revision is to reduce environmental and climate
impacts, increase environment quality and improve public health associated with
textiles waste management in line with the waste hierarchy (see Figure 3).
2.4.2. Specific objectives
The specific objectives address two distinct problems: volume of textiles waste is not
decreasing in line with the European Green Deal ambitions and textiles waste is not
being treated in line with the waste hierarchy. The first step of the waste hierarchy is
about preventing waste generation. Prolonging the useful lifetime of textiles through
increased re-use and increased durability of the products brings the highest environmental
savings and is therefore a priority. Once textile waste is generated, it should be treated as
high up in the waste hierarchy as possible, prioritising re-use, preparation for re-use and
recycling, to alleviate the impact of the textiles sector on the environment in terms of
reducing primary resources use by encouraging the use of secondary materials.
This is consistent with the Textiles Strategy’s objective to “create a greener, more
competitive sector that is more resistant to global shocks”. Textile products placed on the
EN 20 E
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market should be durable, re-pairable and recyclable, to a great extent made of recycled
fibres, free of hazardous substances, produced in respect of social rights and limit
environment harm to the extent possible.
EN 21 EN
Figure 3 - Problem tree and intervention logic for textiles
EN 22 EN
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2.5. What are the available policy measures and options?
2.5.1. What is the baseline from which options are assessed?
The baseline scenario constitutes the benchmark against which other options will be
compared. It includes all relevant EU and national policies in force and all relevant
Commission legislative proposals even if not yet adopted by co-legislators as well as
specific policy options set by the EU Circular Economy Action Plan and, more generally,
by the European Green Deal. The baseline considers the following aspects as summarised
in Sections 1.1 and 1.2, which are further detailed in Annexes 5 and 6:
 the expected and relevant socio-economic developments
 the implementation of the ‘2018 waste package’, including the separate collection
obligation as of 1 January 2025
 efforts at Member State level to prevent textile waste
 relevant Commission proposals impacting the textile value chain
The baseline assumes that no further legislative action will be taken to target the textile
value chain. The baseline is described in Section 2.2.3. The forward-looking trends for
textiles waste up to 2035 are predicted in terms of waste generation, collection, sorting,
and treatment flows (see Figure 2).
2.5.2. Description of the policy options and measures
There are three policy options in addition to the baseline, addressing the specific problem
drivers set out above. These were discussed in several targeted stakeholder consultations
and an expert group meeting with Member States. Each option addresses all the problem
drivers and objectives to reduce waste generation and ensure treatment of textile
waste in line with the waste hierarchy. The summary below provides an overview of the
considered options and measures, and their main characteristics, including a specification
of the drivers that each measure aims to address (see Annex 10 for details).
Baseline – Implementation of the current provisions
The baseline or reference scenario takes into account the ongoing implementation of the
current legislation as well as a realistic expectation of impacts of policy instruments
currently subject to ordinary legislative procedure and relevant to the textile value chain
(see Annex 7 for details).
Option 1 – Supports Member States in implementing and enforcing current
provisions through more harmonised application of definitions, approaches to separate
collection and attribution of responsibility for waste management by adopting non-binding
guidance, recommendations and exercise of existing Commission mandates for secondary
legislation, improving current stakeholder platforms for guidance and exchange of best
practices. This option addresses all problem drivers and both specific objectives albeit with
a likely reduced impact due to the nature of the measures being limited to non-binding
instruments. Option 1 entails the following measures:
1.1 Clarifying definitions in relation to textiles and textile waste through a non-
binding Commission guidance document:
 Defining textiles: Clarification of the scope of separate collection obligation by
reference to CN codes from the Combined Nomenclature Regulation targeted
at customs codes.
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 Defining textile waste: All separately collected textiles are waste until they
undergo a sorting for re-use and/or other processing for recycling.
1.2 Adopting an implementing act under Article 9(7) of the WFD laying down EU-
wide waste prevention indicators: Set measurable textile waste prevention
indicators for more consistent use by Member States to guide waste prevention
measure setting and monitor the performance and effectiveness of national waste
prevention programmes and measures on textiles.
1.3 Providing guidance and support to Member States on textile waste
management: Issuing Commission non-binding guidance on best practices in
textile waste management addressing identified problems due to non-harmonised
application of definitions, reporting rules; issue a Commission Recommendation
inviting Member States to apply EPR for textiles to ensure funding for the
management of textile waste and its infrastructure and define its key features (as
proposed in measure 2.9) to facilitate harmonised application and reduce regulatory
fragmentation, administrative burden on the industry; provide sustainable product
design signals to the producers; and further develop existing platforms for
exchange of practices, policies and projects on circular textile value chain.
Option 2 – Sets additional binding regulatory requirements to improve the waste
management performance in line with the waste hierarchy through a targeted
amendment of the WFD. The purpose of the amendments is to create new operational
obligations on Member States, producers of textiles and waste management operators.
They would clarify and harmonise definitions at EU level, clarify the scope of the existing
reporting obligations to improve the robustness of data, clarify the scope of the separate
collection obligations, and introduce new operational obligations for waste operators to
ensure sorting for re-use and recycling. The flagship measure of this option is introducing
a mandate for Member States to set up national EPR schemes for textiles and harmonise
its scope, objectives and key organisational and operational features. This option addresses
all problem drivers and both specific objectives. Option 2 entails the following measures:
2.5 Setting sorting obligations for separately collected textiles: Ensure that all
separately collected textiles are subject to a sorting operation with the objective of
identifying fractions suitable for re-use and preparation for re-use, as a priority, as
well as fractions suitable for recycling. This measure also clarifies that separately
collected used textiles are considered waste until a sorting operation is completed
(this entails Measure 1.1. in a legally binding form).
2.6 Adopting end-of-waste criteria: This measure comprises the adoption by the
Commission of an implementing act setting harmonised EU end-of-waste criteria
that determine the recovery operation input material requirements, recovery
operation requirements and output quality criteria for re-useable textiles and
secondary raw materials from recycled textile waste. The criteria, once adopted,
are binding to Member States and the economic operators and form the basis for
developing an EU secondary raw material market for recycled textiles and high-
quality harmonised sorting outputs of re-useable textiles for global and EU re-use
markets. This measure builds on the obligation for a sorting stage to follow separate
collection set out in Measure 2.5. The mandate for the Commission to adopt this
measure is already established in Article 6(2) of the WFD.
2.8 Setting requirements for shipments of textiles for re-use: This measure sets
minimum requirements for distinguishing shipments of re-useable textiles from
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shipments of waste textiles. It facilitates the enforcement of the EU waste shipment
rules and complements the Waste Shipments Regulation which does not regulate
shipments of non-waste.
2.9 Mandating the use of national EPR schemes for textiles: This measure
implements the polluter pays principle by transferring the obligation to secure the
necessary funding for and the management of used and waste textiles according to
the waste hierarchy from competent authorities to producers. It would assign the
responsibility for the financing and or also operational management of used and
waste textiles to the producers of textiles and their representatives, i.e. producer
responsibility organisations which would carry out or procure the fulfilment of the
specific waste management activities based on the fees collected from producers
based on the amount of textiles each producer places on the market.
The measure would require Member States to establish an EPR scheme for textiles
by mandating producers of textiles, i.e. those who place textile products for the first
time on the market of the Member States, to finance and or organise specific textile
waste management operations. The measure would harmonise all the key features
of the EPR scheme, namely, the scope, objectives and organisational and
operational features of the EPR scheme setting obligations on the competent
authorities, producers and economic operators engaged in waste management. This
is attained by introducing legally binding requirements in the WFD for Member
States and economic operators. Detailed description of all the EPR features to be
regulated is provided in Annex 10 and follows the general minimum requirements
for all EPR schemes as set out in Article 8a of the WFD.
More specifically, the WFD would set a common scope for the EPR (which textiles
and therefore producers are covered), objectives of the EPR (prioritisation of
prevention and recycling and the obligation to meet the quantitative objective set
out in Measure 3.6), operational obligations of the producers (which waste
management and other activities they need to finance, including separate collection
and the minimum requirements for the separate collection network, sorting for re-
use and recycling, recycling and disposal), organisational features of the EPR
scheme to run the EPR scheme and facilitate monitoring of its performance and
enforcement (mandate to use producer responsibility organisations for the
collective implementation of EPR obligations, harmonise EPR fee modulation
criteria and align it with the detailed sustainability criteria for textiles to be set out
in the framework of the ESPR and reporting frequency). The measure also requires
Member States to establish a producer register for the purposes of ensuring
enforcement and monitoring of EPR obligations (it will register all producers
placing products on the Member State markets and subject to the EPR) with the
WFD setting out harmonised requirements on the information to be submitted to
the register.
As is the case for other EU mandated EPR schemes (e.g. legislation on electric and
electronic equipment, packaging and batteries), the WFD will envisage a mandate
to the Commission to adopt implementing acts to further harmonise fee modulation
criteria to reinforce harmonised sustainable product design signals to the producers
and reduce regulatory fragmentation and administrative burden on the industry.
2.14 Improving reporting obligations for textiles: This measure clarifies the scope of
existing requirements on textile waste that the Member States have to report to the
Commission under the WFD to improve the knowledge base at EU level on textile
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and textile waste data flows and enable proper monitoring of the economic and
environmental impacts of textiles. It introduces additional reporting requirements
(currently indicated as voluntary under the WFD) that are strictly required for the
enforcement of measures 2.9 and 3.6 and future proofing of the data flows in view
of possible future performance target setting, where assessed as feasible and
necessary. The realisation of this measure would also entail the adoption of an
implementing act to revise the existing Commission Implementing Decision (EU)
2019/1004 setting out the reporting format on the reporting of municipal textile
waste.
Option 3 – Prescribing waste management performance targets at EU level. This
option entails an amendment to the WFD establishing binding waste management
performance targets operationalising the waste hierarchy for the Member States and
economic operators. Harmonisation of scopes and definitions would be integral to the
definition of the target in the WFD and subsequent implementing acts defining more
detailed rules on the calculation methodology for each of the target. This option addresses
both specific objectives and all problem drivers, albeit it would not bring about a level of
harmonisation as provided by Option 2 since it leaves the decisions on the means to attain
the performance levels to the Member States.
Since the current data on textile waste generation is not sufficiently robust, which is partly
due to the fragmented understanding of whether collected textiles are waste and the scope
of the textiles covered by Member State implementation, Annex 11 explains the feasibility
of the mechanism by which targets could be set in the future and the impacts of that process
(and not the actual levels of targets). In relation to setting a target for collection (Measure
3.6.), a more detailed assessment based on an interim medium-ambition target is presented.
Option 3 entails the following measures:
3.1 Setting an EU textile waste reduction target: The attainment of the target would
reduce the amount of textile waste generated, facilitate coherence in measures and
policies between the different Member States and to harmonise industry effort
towards reaching the target.
3.4 Setting a preparation for reuse target for textiles: The attainment of the target
would improve the reuse of textiles for Member States and reduce the generation
of waste. This covers operations like checking, cleaning, or repairing, recovery
operations, by which textile products that have become waste are prepared so that
they can be reused without any other pre-processing.
3.5 Setting a re-use target for textiles: The attainment of the target would increase
the amount of textiles re-used therefore reducing waste generation. It would
mobilise competent authorities and economic operators activities, including
planning and investment in sorting infrastructure.
3.6 Setting a 50% collection target for textiles: The attainment of the target might
improve separate collection rate for textiles thereby increasing re-use rates,
recycling rates and decreasing disposal rates.
3.7 Setting a target for textiles found in residual waste: The attainment of the target
would improve separate collection system for textiles if the Member States found
excessive textiles contained in the mixed household waste.
3.8 Setting a recycling target for textiles: The attainment of the target would improve
the recycling capacity of Member States by setting a realistic recycling target that
takes into account likely changes in recycling capacity and technologies. It would
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mobilise competent authorities and economic operators activities, including
planning and investment in sorting and recycling infrastructure.
2.5.3. Discarded measures
Other measures considered were discarded mainly because they are not proportional or
coherent with other EU policies. More specifically, some of the measures, such as labelling
requirements for textiles or taxation related economic instruments were considered
incoherent with other EU policies which specifically regulate the matters. Other measures
such as the establishment of minimum requirements on separate collection for textile reuse
were identified as disproportionally limiting the scope for national decision-making.
2.6. What are the impacts of the considered policy measures and options?
Table 2 depicts the impacts of the considered measures that are included in each option.
For each measure, the description of the impacts is provided as well as the overall
balance/direction of impact is indicated as +, - and +/- to indicate these impacts (see Annex
11 for details)74
. This initiative has been flagged as ‘relevant for SMEs’ in the SME Filter
and the ISSG agreed with this assessment.
The impacts on competitiveness have been assessed quantitatively, where possible,
considering impacts on different types of competitiveness75
. Price competitiveness aims to
reflect the relative impacts of prices companies or company groups are able to set within a
market. Dynamic competitiveness refers to the impacts on research and innovation that
would enable to maintain or improve the firms’ competitiveness stance over time. Strategic
competitiveness refers to the firms’ ability to partially meet their raw material or product
demand through re-used or recycled textiles within the EU. As shown in Table 2, the
impacts on competitiveness are either positive or neutral.
2.7. How do the options compare?
Table 3 sets out the overall assessment of each option and then draws conclusion in terms
of how the policy options compare based on the likely impacts of the measures they
contained. This comparison is based on how the options contribute to the two main
objectives, on the balance between economic, environmental and social impacts, and on
the total costs and benefits where these could be calculated.
Option 1 measures would effectively contribute to both intended objectives and the
economic, social and environmental impacts would generally be positive. However, all
measures under Option 1 except for clarifying definitions (measure 1.1) are likely to
address the objectives to a limited extent. Option 1 is also coherent with existing and
planned EU policy initiatives. The costs of measures under Option 1 are generally limited
to administrative costs for public authorities.
74
Please note that a + for the ‘costs’ column indicates a reduction in costs, while a – for the ‘costs’ column
indicates a increase in costs.
75
For an overview of the channels through which the circular economy impacts competitiveness, please see
Flachenecker, F. (2018) The causal impact of material productivity on macroeconomic competitiveness in
the EU. Environmental Economics and Policy Studies 20, 17–46. https://doi.org/10.1007/s10018-016-0180-
3 and Flachenecker, F., Kornejew, M. (2019) The causal impact of material productivity on microeconomic
competitiveness and environmental performance in the EU. Environmental Economics and Policy Studies
21, 87–122. https://doi.org/10.1007/s10018-018-0223-z
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Option 2 measures would be more effective that Option 1 measures in achieving both
intended objectives. Option 2 measures carry higher economic costs than Option 1, while
they generate far higher economic, social and environmental benefits. Option 2 is coherent
with existing and planned EU policy initiatives, while measure 2.9 specifically ensures
coherence with the EU Strategy for Sustainable and Circular Textiles that calls for the
introduction of harmonised measures for EPR for textiles.
The effectiveness of Option 3 measures would depend on their implementation and
enforcement across Member States. The flexibility for Member States to decide which
measures to implement in order to achieve the target would ensure cost-efficiency. Option
3 would be consistent with existing waste targets across the EU environmental legislation.
EN 29 EN
Table 2 – Impacts of considered policy measures
Policy option and measure Costs Benefits Competitiveness impacts Net impacts
Option 1 - Supporting Member States to implement and enforce current WFD provisions
Measure 1.1 – Clarifying definitions in relation to textiles and textile waste + +
Price: +/- depending on current performance
Dynamic: +/- depending on R&I being targeted
Strategic: + higher re-use/recycling
Net positive
Measure 1.2 - Adopting EU wide waste prevention indicators for textiles + +
Price: NA
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Net positive but
limited
Measure 1.3 – Providing Member States with guidance and support in dialogue on the
management of textile waste between actors involved
+ +
Price: +/- depending on current performance
Dynamic: + sharing best practice
Strategic: + higher re-use/recycling
Net positive but
limited
Option 2 – Proposing additional measures to align waste management to the waste hierarchy
Measure 2.5 – Setting sorting obligations for separately collected textiles/textiles waste
- +
Price: +/- depending on current performance
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Net positive
Measure 2.6 – Adopting end of waste criteria
- +
Price: NA
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Net positive
Measure 2.8 – Setting requirements for the shipments of textiles
- +
Price: +/- depending on current performance
Dynamic: NA
Strategic: NA
Net positive
Measure 2.9 – Mandating the use of EPR
+/- +
Price: +/- depending on current performance
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Net positive
Measure 2.14 – Setting reporting obligations for textiles
- +
Price: NA
Dynamic: NA
Strategic: NA
Net positive
Option 3 – Prescribing targets and restrictions
Measure 3.1 – Setting an EU textile reduction target
+/- +
Price: +/- depending on implementation
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Likely net positive
Measure 3.4 – Setting a preparation for reuse target for textiles +/- + Price: +/- depending on implementation Likely net positive
EN 30 EN
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Measure 3.5 - Setting a reuse target for textiles
+/- +
Price: +/- depending on implementation
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Likely net positive
Measure 3.6 - Setting a separate collection target for textiles waste
+/- +
Price: +/- depending on implementation
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Likely net positive
Measure 3.8 – Setting a recycling target for textiles
+/- +
Price: +/- depending on implementation
Dynamic: + incentivise R&I in re-use/recycling
Strategic: + higher re-use/recycling
Likely net positive
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Table 3 – Comparison of options
Policy option and measure Description of impact Overall balance with best alternative
Option 1 – Supporting MS
in implementing and
enforcing current
provisions
Economic costs (for public authorities): €135 000 per guidance developed + EC staff. Measure 1.1
sub-option 1 alternative 2 adds collection costs of €660 million per year
Economic benefits (for public authorities): Reduced administrative burden of €250 000 per year for
measure 1.1, measure 1.1 sub-option 2 alternative 2 offers an administrative cost reduction of €200
per year as waste permits are no longer needed
Environmental benefits (for waste management enterprises): Reducing waste as a result of
improved data on and support for waste prevention, as well as greater reuse and recycling lead to
reduced environmental externalities
Social benefits (for waste management enterprises): Potential increases in employment in the reuse
and recycling sector as a result of the measures foreseen
Costs: €135 000 per guidance + EC staff
Benefits: €250 000 per year
Overall effectiveness, efficiency and
coherence: positive but limited except for
measure 1.1
Option 2 - Additional
regulatory requirements
(assessed for considered
measures)
Economic costs (for producers and consumers): €913 million per year for sorting obligations, €7.79
million per year for producers to report for the purpose of EPR, €750 000 per year for EU
enterprises to comply with EU reporting obligations
Economic costs (for public authorities): register development costs of €2-12.3 million across
Member States and maintenance costs of €11 200 and 69 000 per Member State per year, €4.04
million costs of operating PRO registers and inspections, €208 per competent authority and €78 per
exporter annualised per inspection, €26.5 million landfill tax loss for Member States due to textiles
diverted from landfills
Economic benefits (for producers, consumers and waste management enterprises): EPR of €3.5-4.5
billion annual overall returns on recycling investment (including the benefits of other measures of
Option 2)
Economic benefits (for waste management enterprises): €534 million per year of re-use value and
€117 million per year of recycling value from additional sorting
Environmental benefits: €16 million from GHG emission reduction (assuming a social cost of
carbon of €100 per tCO2e) as well as reduction in release of pollutants to air, water and land that
would otherwise result from inadequate waste management
Social benefits (for consumers and waste management enterprises): 8 740 jobs created and social
impacts of EU waste in third countries mitigated (no net impact assessment; see Annex 4 for details
and underlying assumptions)
Costs: €963 million per year
Benefits: €651 million per year of re-usable
and recyclable materials, and €3.5-4.5 billion
annual overall returns from EPR investments,
environmental benefits (including €16
million or 160 000 tCO2e in GHG savings),
and 8 740 jobs created
Overall effectiveness, efficiency and
coherence: positive and higher compared to
Option 1 and Option 3, depending on the
effectiveness of target implementation
EN 32 EN
Option 3 – Targets
(assessed for considered
measures)
Economic costs (for public authorities and waste management enterprises): €39.2 million per year
for additional textile collection, sorting and treatment to meet a 50% collection target. Lack of
robust data makes target setting for textile waste management premature for most targets
Economic benefits (for producers and waste management enterprises): €28 million per year of
combined reuse and recycling.
Environmental benefits: Additional GHG emission reduction
Costs: €39 million per year (covered by the
EPR measure 2.9)
Benefits: €28 million per year of reusable
and recyclable textiles for the EU re-use and
recycling market, and additional GHG
emission reduction
Overall effectiveness, efficiency and
coherence: effectiveness depends on targets
being met, ensures flexibility for Member
States to find cost efficient instruments to
achieve target, coherence with existing waste
targets
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2.8. Preferred option
2.8.1. Preferred option for textiles
Based on Table 2 and the assessments of how the options contribute to the two main
objectives, on the balance between economic, environmental and social impacts, and on
the total costs and benefits where these could be calculated, the preferred option is Option
2. However, the setting of a textiles waste collection target (measure 3.6) might be
additionally considered to potentially complement the measures in Option 2. Measure 3.6
could therefore also be considered part of the preferred option, but it has administrative
implications, the detailed analysis indicates data challenges in setting a target and the
established 2025 separate collection obligation is likely to have a similar effect. Other
textile waste management targets cannot be set at this stage due to the lack of complete
and robust data. The expected impacts of the preferred option (option 2 and possibly
measure 3.6) are described below.
 The EPR would claim fees from producers/importers putting textiles on the EU
market (but the fees might partially be passed on consumers). The EPR fees are
expected to account for approximately 0.6% of the total cost of the product (or
roughly €0.12 per t-shirt, under conservative assumptions). At the same time, it
would ensure a better recovery of the value of generated waste in terms of re-use
and recycling, including support to the development of closed loop recycling in the
EU (measures 2.5, 2.6, 2.8, 2.9 and 3.6). The recovery of value is estimated to
recover 58% of the costs concerned (measure 2.5).
 Environmental externalities are expected to decrease with greater re-use and
recycling in the EU (measures 2.5, 2.6, 2.9 and 3.6), and in particular in third
countries (measures 2.5, 2.6 and 2.8). This includes savings of €16 million through
reduced GHG emission.
 The social impacts of inadequate textile waste management in the EU (measures
2.5, 2.6, 2.8, 2.9 and 3.6) and in third countries (measures 2.5, 2.6 and 2.8) are
expected to be mitigated. 8 740 jobs would be created in the waste management
sector, including textile recycling (measures 2.5, 2.6, 2.9 and 3.6), and provide
support to social enterprises in managing used textiles (measure 2.9).
 The textiles sector is dominated by SMEs. Microenterprises cover around 88% of
the sector. The preferred option is specifically tailored to minimise the financial
and administrative impacts on microenterprises, most notably by excluding all
microenterprises from the EPR. All remaining SMEs (i.e. SMEs that are not
microenterprises) would still be covered by the EPR. At the same time, the support
to re-use and recycling would support also those SMEs covered by the EPR (i.e.
those that are not microenterprises) compared to the status quo by ensuring more
funding is available, and a more stable feedstock of re-usable and recyclable
textiles are available in the market.
 Greater clarity in relation to the scope of textiles subject to the provisions of the
WFD (measure 1.1 taken up in legally binding form in the measures in option 2) as
well as broader and better information on the flows of those textiles and on the
results of efforts by Member States to address used textiles and textile wastes
(measure 2.14) would reduce administrative costs, facilitate investments in
strategic national and regional hubs for textiles, and limit additional burdens only
to where they are most relevant (measures 2.9 and 2.14).
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2.8.2. REFIT (simplification and improved efficiency)
The initiative aims to address the regulatory barriers identified by stakeholders, namely,
the non-harmonised application of definition of textile waste, the scope of application of
separate collection obligations and the linked diversity in the obligations to the industry
that hamper the scaling up of the reuse and recycling sector. The measures and options
considered aim to harmonise the application of the definition of waste and thus facilitate
the re-use of textiles within the EU single market as well as at global re-use markets
through providing greater legal certainty to the economic operators on the non-waste status
of their shipments and to the competent authorities for the purposes of enforcement.
A harmonised approach to sorting obligations and the application of the EPR aim to reduce
greatly the compliance costs of operators operating across several Member States, in view
of several Member States planning the introduction of such schemes and engaging in
export therefore also offering efficiency gains through economies of scale. It is also
proposed to harmonise certain organisational features for the EPR schemes to improve the
efficiencies in the operation of the schemes, compliance costs of the producers as well as
facilitating enforcement processes, including through mandating membership to a
producer responsibility organisation, harmonising reporting frequency and fee modulation
requirements which are to be fully aligned with the harmonised product requirement
measurement methodologies developed under ESPR.
2.8.3. Application of the one in one out approach
The administrative costs linked to the implementation, reporting and monitoring under the
preferred option mainly Member States and are as follows76
:
 EPR register development costs of €2-12.3 million across Member States and
maintenance costs of €11 200 and 69 000 per Member State per year
 €4.04 million costs of operating PRO registers and inspections
 €208 per competent authority and €78 per exporter annualised per inspection
The preferred option would address the drivers linked to administrative costs for the
enforcement authorities, and operators active in the shipment and treatment of textiles.
Non-harmonised application of textile waste and non-waste status hamper activities
leading to waste reduction as well as economies of scale required to scale-up the EU
recycling sector. The preferred option also aims to reduce the administrative costs incurred
by producers, consumers and waste management operators by increasing the
environmental regulatory approaches, pre-empting the setting up of diverse EPR schemes
or less efficient approaches. Therefore, overall positive net benefits can be expected.
2.9. How will actual impacts of the preferred option be monitored and
evaluated?
Annex 14 details monitoring and evaluation tools for this initiative. The impact of the
preferred policy option in the attainment of the objectives to reduce textile waste and
residual textile waste generation would be monitored through the indicators and targets set
out in measure 3.6. and based on the improved data flows on textiles as a result of measure
76
Acknowledging that not all costs could be quantified, including those textiles that are currently not
separately collected due to a lack of data available, the cost of licensing textile waste collectors given the
large heterogeneity across Member States, the total costs (and benefits) from the application of end-of-waste
criteria for textiles since this depends on the scope of the measure.
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2.14. The latter would also enable further performance targets to be set that is currently
assessed as not feasible under option 3. Monitoring is based on annual data on textiles
reported (measure 2.14 and see Annex 10 for details).
Implementation of the national textile waste prevention measures as part of the national
waste prevention programmes is subject to periodic reviews by the European Environment
Agency (as required by Article 30(2) of the WFD). The Agency publishes a report every
two years containing a review of the progress made in the completing and implementing
waste prevention programmes, including an assessment of the evolution of the prevention
of waste generation for each Member States and for the EU as a whole77
.
77
See footnote 59, p. 10.
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3. FOOD WASTE
3.1. Facts, figures and context
3.1.1. What is food waste and what is the scope of the initiative?
The WFD defines ‘food waste’ as all food, as defined in the General Food Law78
, that has
become waste. This definition, also used in this IA, considers food as a whole and applies
across the food supply chain, from production up to and including consumption. Food
includes inedible parts, where those are not separated from the edible parts when the food
is produced. Further information on the definition and quantification of food waste are in
Annex 6.
Considering this definition, it is not technically feasible to completely prevent food waste.
First, consumers usually cannot consume or re-use inedible parts of food (e.g., bones) for
other purposes. Secondly, certain food (or by-products of food production) must be
discarded due to safety concerns. Thirdly, food waste prevention – whilst a key priority in
the transition to sustainable food systems – cannot compromise food safety, animal or
human health.
The EU’s food waste definition does not include elements which were not food at the time
these are discarded or removed from the food supply chain (e.g., losses occurring before
harvest or slaughter). Neither does food waste include material which is not waste, such as
surplus food that is donated or by-products from food production used for other purposes
(e.g., animal feed or cosmetics).
Food waste arises at all stages of the food supply chain: (a) primary production; (b)
processing and manufacturing; (c) retail and other distribution of food; (d) restaurants and
food services; (e) households. Food waste arising at consumption includes waste generated
both in- and out-of-home. Therefore, stages (d) and (e) are jointly addressed as
“consumption” stage in this IA. Figure 4 shows the scope of the initiative.
Figure 4 – Boundaries of food waste as defined in the WFD (2018). Adapted from Sanchez
Lopez et al. (2020) 79
78
Article 2 of Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January
2002 laying down the general principles and requirements of food law, establishing the European Food
Safety Authority and laying down procedures in matters of food safety, (OJ L 31, 1.2.2002, p.1).
79
Sanchez Lopez, J., Caldeira, C., De Laurentiis, V., Sala, S., Brief on food waste in the European Union,
Avraamides, M., European Commission, JRC121196, 2020
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This initiative focusses on preventing the generation of food waste, in line with the waste
hierarchy in order to ensure the highest value use of food. Moreover, far greater
environmental and cost savings are gained by avoiding its generation80
. Unlike other waste
streams, food waste cannot be recycled into new food and recycling it into compost and/or
biogas ensures only limited recovery of the resources spent on food production. Finally,
the collection and treatment of food waste is already well regulated at EU level81
.
3.1.2. Overview of EU action to prevent food waste
Whilst the WFD was first adopted in 1975 and subsequently subject to several reviews -
the most recent being in 2018- food waste prevention became a specific political priority
at EU level, in 2015, reflecting EU commitments made in the context of the 2030
Sustainable Development Agenda. In this context, the EU and its Member States
committed to achieving Sustainable Development Goal (SDG) Target 12.3 to halve per
capita global food waste at the retail and consumer levels and reduce food losses along
production and supply chains, including post-harvest losses, by 2030.
The EU has implemented a dedicated action plan to reduce food loss and waste, including
both regulatory and non-regulatory actions, initially as part of the 2015 Circular Economy
Action Plan and, since 2020, under the EU’s Farm to Fork Strategy. In doing so, the
Commission aims not only to lay down clear obligations for Member States as regards
reduction of food waste but also to create an enabling policy environment that supports
Member States in taking effective action. Since 2015, the Commission has taken initiatives
to clarify and harmonise relevant legislation (e.g., amendments to food hygiene rules to
facilitate safe food donation practices) as well as to support the development and sharing
of best practice and solutions to reduce food waste across the EU as set out below.
The WFD requires Member States to prepare specific food waste prevention
programmes in line with the waste hierarchy. As part of the waste prevention
programme, Article 9 of the WFD (as revised in 2018) obliges Member States to take
measures to reduce food waste at each stage of the food supply chain and encourage food
donation and other redistribution for human consumption, prioritising human use over
animal feed and the reprocessing into non-food products. Member States are also called
upon to provide incentives for the application of the waste hierarchy, such as facilitation
of food donation (Article 4 and Annex IVa). Guidance on the application of the waste
80
Slorach, Peter C., Jeswani Harish K., Cuéllar-Franca, Rosa, Azapagacic, Adisa, Environmental and
economic implications of recovering resources from food waste in a circular economy, Science of The Total
Environment, Volume 693, 25 November 2019, 1333516.
81
See Annex 5 – Food Waste – section: Downstream management of food waste
EN 38 E
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hierarchy to food waste prevention82 is already in place and laid down, not only at EU
level, but through that of international organisations83
.
The WFD requires Member States to reduce food waste at each stage of the food supply
chain, monitor food waste levels and report progress made. The Commission adopted, in
2019, a common food waste measurement methodology84
, to be utilised as a basis for EU-
wide food waste monitoring.
Food waste prevention requires an integrated approach, involving multiple players
from the public and private sectors. Established in 2016, the EU Platform on Food Losses
and Food Waste (FLW) supports all actors in defining measures needed to prevent food
waste, sharing best practice and evaluating progress made over time. The Platform has
supported the development of EU guidelines to clarify relevant provisions in EU
legislation and lift barriers to food donation85
and the feed use of food86
no longer intended
for human consumption. It has also adopted its own deliverables (e.g., recommendations
for action in food waste prevention) and has supported work undertaken at EU level to
improve date marking87
practices. The Commission is currently considering the most
efficient ways to facilitate the understanding and use of date marking (i.e., ‘best before’
and ‘use by’ dates) aiming to prevent food waste without jeopardising food safety. The
revision of marketing standards for fruit and vegetables, for which a Delegated Act is
expected to be adopted in Q3 2023, aims to introduce certain derogations which may also
contribute to the reduction of food waste.
The Commission is also undertaking work to strengthen the evidence base for food waste
prevention interventions88
in order to guide effective action, including those addressing the
hotspot of food waste generation at consumption89
. In collaboration with the European
Health and Digital Executive Agency (HaDEA), the Commission provides grants to
support Member States and stakeholders90
in improving food waste measurement and
implementation of actions to reduce food waste.
The Commission has supported research and innovation to address food waste
prevention, including development of blueprints for the establishment of national
public-private partnerships (e.g. Voluntary Agreements) to reduce food waste across the
82
Guidelines on the preparation of food waste prevention programmes (2008), Bio-waste prevention
guidelines (2011); Brief on food waste in the European Union (see footnote 79, page 32); EU Platform on
Food Losses and Food Waste, Recommendations for action in food waste prevention (2019)
83
FAO, Voluntary Code of Conduct for Food Loss and Waste Reduction (2022). The Code presents the
actions and measures that countries, national and sub-national authorities, food supply chain actors, the
private sector, producer organizations, civil society organizations, academic and research institutions, and
other relevant stakeholders should take or put in place in order to contribute to FLW reduction. It also
presents guiding principles that should be followed in implementing these actions and measures.
84
OJ L 248, 27.9.2019, p.77-85
85
OJ C 361, 25.10.2017, p. 1–29
86
OJ C 133, 16.4.2018, p. 2–18
87
https://ec.europa.eu/food/safety/food_waste/eu_actions/date_marking_en
88
European Commission, Joint Research Centre, Caldeira, C., Sala, S., De Laurentiis, V., Assessment of food
waste prevention actions. Development of an evaluation framework to assess the performance of food waste
prevention actions, Publications Office, 2019, https://data.europa.eu/doi/10.2760/9773
89
The EU pilot project, European Consumer Food Waste Forum, will deliver a compendium of best practice
in consumer food waste prevention by July 2023.
90
Example: HaDEA 2022 call for proposals to help stakeholders take action on fighting food waste
EN 39 E
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food supply chain.91
Calls for proposals under the EU Research and Innovation Framework
Programme Horizon202092
and Horizon Europe93
are offering new opportunities for
research and innovation to address food loss and waste.
In order to support ongoing sharing of resources, latest developments and good
practices, the Commission has established a digital platform, the EU Food Loss and
Waste Prevention Hub, to provide a “one-stop-shop” for all stakeholders active in the area
of food waste prevention. The RESTwithEU pilot project94
showcases best practice digital
tools to mitigate food waste in the restaurant industry.
3.1.3. Amounts of food waste at EU level
In Q3 2022, Eurostat published the first results of the EU-wide monitoring of food waste
levels, measured according to a common methodology95
. In 2020, total food waste reached
nearly 59 Mt (131 kg per person per year). Roughly 10% of food supplied to retail, food
services and households is estimated to be wasted.96
Over half of food waste (53%) is
generated by households (more than 31 Mt). The second biggest share (20%) is the
processing and manufacturing sector (around 10 Mt). The remaining shares – representing
altogether a quarter of the total food waste – originate from the primary production sector
(11%; 6 Mt), restaurants and food services (9%; more than 5 Mt) and retail and other
distribution of food sectors (7%; more than 4 Mt).
Figure 5 - Estimated food waste generation in the EU in 2020, Eurostat97
Figure 6 - Food waste by sector of activities by Member State, 2020, Eurostat 98
91
REFRESH, WRAP GLOBAL, Building partnerships, driving change. A voluntary approach to cutting
food waste, 2019
92
See projects CHORIZO and ToNoWaste
93
See projects FOLOU and WASTELESS
94
https://restwith.eu/
95
See note 84, page 34
96
Eurostat, Food waste and food waste prevention estimates, March 2023. Note that earlier estimations
(October 2022) were 57 Mt, i.e., 127 kg/capita.
97
See note 96
98
Eurostat, Food waste and food waste prevention by NACE Rev. 2 activity - tonnes of fresh mass, March
2023 – the data for Romania are not yet available.
EN 40 E
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There is significant variation in the levels of food waste per capita. Figure 5 provides an
overview of food waste levels by Member State (expressed as kg/inhabitant), presented in
aggregated form: primary production and processing and manufacturing; households, retail
and other distribution of food and restaurants and food services.
Several factors explain the differences in food waste amounts reported by Member States.
These include, amongst others: the size of the manufacturing base; whether the country is
a net food exporter or importer 99
; share of disposable income allocated to food; population
flux (e.g., due to tourism, migration); cultural differences and food habits. In addition, as
2022 was the first reporting year, some differences may decrease as Member States gain
experience in food waste monitoring over time.
General waste statistics, such as data on municipal waste (which include a large fraction
of food waste) do not show any reduction between 2012 and 2020. Similarly, Eurostat
estimates of food waste amounts, showed that the amounts had remained stable between
2012 and 2018 (i.e., between 66 and 69 Mt)100
. Finally, the first results of the EU-wide
monitoring of food waste, while not directly comparable to previous estimates101
, show
slightly lower levels of food waste generation which however remain insufficient in the
light of the ambition of halving food waste by 2030, as called for by SDG Target 12.3.
More details can be found in Annex 6.
3.2. Problem Definition
3.2.1. What are the problems?
Despite the growing awareness of the negative impacts and consequences of food waste,
political commitments made at EU and Member State levels and EU measures
implemented since the 2015 CEAP, food waste generation is not decreasing as required
to make significant progress towards SDG Target 12.3. In the EU, despite the existing legal
obligations in the WFD and the supporting activities of the Commission described in
section 3.1.2, action taken to date in Member States is disparate and has not allowed
a significant reduction of food waste levels, as demonstrated by the relative stability of
municipal waste levels since 2012 and Eurostat estimations. More specifically, the full
potential for reducing food waste is not realised as underlying behavioural and market
99
Food waste arising in processing and manufacturing is quantified where it originates i.e. exporting country.
100
Eurostat, Monitoring framework - Circular economy indicators. Estimates are based on the relevant
Waste Statistics categories that are expected to included food waste.
101
FUSIONS EU Project, Estimates of European food waste levels, 2016
EN 41 E
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drivers of food waste generation are not adequately addressed in national strategies
and roadmaps.
Key environmental, economic and social consequences
Food waste is one of the largest sources of inefficiency in the agri-food chain. In particular,
it results in negative environmental and climate impacts, as reaffirmed in the biodiversity
agreement under COP15 (Target 16), which hinder achieving ambitions laid down in the
EGD.
Food has embedded environmental consequences102
because of the energy, natural
resources use and associated emissions generated throughout its life cycle. Food
consumption is the main contributor to the environmental impacts103
and biodiversity
footprint104
of EU consumption.
When food is discarded, all the embedded energy and resources and their environmental
consequences, such as GHG emissions – that accumulate along the food chain – still
materialise with no benefit for human nutrition. Food processed, transported and cooked
that is then wasted at consumption – has a higher environmental impact than unprocessed
food products lost at the farm. The 58.5 Mt of food waste generated in the EU in 2020105
caused emissions of 252 Mt of CO2 equivalents106,107
. This corresponds to 16% of the total
GHG impact resulting from the EU food system, calculated with a consumption-based
approach108
. Food waste also puts unnecessary pressure on limited natural resources. For
example, the amount of water consumed to produce food that is ultimately wasted can be
quantified as 342 bn m3
water eq.109
, corresponding to 12% of the total impact of EU food
production and consumption. Food waste is also responsible for 16% of impacts on soil as
caused by land use activities110
, while the consequences on marine eutrophication are 15%
of the total.111,112
102
Over 90% of respondents to the public consultation agreed or strongly agreed that reducing food waste
will help reduce environmental impacts and mitigate climate change (Annex 2 – public consultation).
103
Sanye Mengual, E. and Sala, S., 2023 Consumption Footprint and Domestic Footprint: Assessing the
environmental impacts of EU consumption and production.
104
Sanyé-Mengual, E., Biganzoli, F., Valente, A., Pfister, S., & Sala, S. (2023). What are the main
environmental impacts and products contributing to the biodiversity footprint of EU consumption? A
comparison of life cycle impact assessment methods and models.
105
https://ec.europa.eu/eurostat/databrowser/view/env_wasfw/default/table?lang=en
106
Calculated using the Consumption Footprint methodology, as presented in: European Commission, Joint
Research Centre, Sanyé Mengual, E., Sala, S., Consumption footprint and domestic footprint: assessing the
environmental impacts of EU consumption and production: life cycle assessment to support the European
Green Deal, Publications Office of the European Union, 2023, https://data.europa.eu/doi/10.2760/218540.
107
Sala, S., De Laurentiis, V., and Sanye Mengual, E., EU Food consumption and waste: environmental
impacts from a supply chain perspective, European Commission, 2023, JRC129245.
108
The methodology used for this estimation is presented in Section 2.2.1 of Annex 4.
109
A m3
-world eq. represents a cubic meter consumed on average in the world. The average refers to a
consumption-weighted average, and hence represents the locations where water is currently consumed.
110
Assessed considering impacts on four soil properties: biotic production, erosion resistance, groundwater
regeneration and mechanical filtration, as presented in: De Laurentiis, V., Secchi, M., Bos, U., Horn, R.,
Laurent, A. and Sala, S., Soil quality index: Exploring options for a comprehensive assessment of land use
impacts in LCA, Journal of Cleaner Production, 215, pp.63-74, 2019.
111
The Consumption Footprint covers the 16 impact categories of the Environmental Footprint (European
Commission, 2021) including freshwater eutrophication which is caused mainly by phosphorous emissions.
112
OJ L 471, 30.12.2021, p. 1–396.
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As regards economic consequences, the 58.5 Mt of food waste have an associated market
value estimated at 132 bn euros.113
These costs include lost resources by food business
operators at each stage of the food supply chain, but also unnecessary spending by
households. In addition, the cost of collection and treatment of food waste is estimated at
an additional 9.3 bn euros114
.
Wasting food has important social consequences. It leads to unnecessary spending of
resources that could be otherwise allocated. The average share of food expenditure (agri-
food and food services) in total household expenditure in the EU is around 19%115
.
Discarding food that is fit for human consumption – rather than redistributing that food to
those in need, including through food donation – also represents a missed opportunity in
the light of growing challenges to food security. Although, in Europe, food availability is
ensured, food affordability is a concern for a growing number of EU citizens: 32.6 million
people cannot afford a meal with meat, fish, chicken or vegetarian equivalent every second
day.116
Finally, for many consumers, wasting food has an important ethical dimension117
.
3.2.2. What are the problem drivers?
The main drivers and situations that generate food waste in the food value and consumption
chain are widely documented118
and relate to: insufficient consumer food management;
inefficiencies and trade-offs in the food supply chain; and lack of understanding and
certainty regarding food safety standards. Moreover, in the EU – except for a few front
runners – the lack of evidence-based, coordinated approaches in Member States leads
to food waste generation going largely unchecked. The failure of governments to
effectively address the behavioural and market drivers of food waste through evidence-
based food waste prevention strategies and programmes, involving multiple players, means
that food waste is not decreasing in line with commitments agreed to as part of the global
Sustainable Development Agenda.
The abovementioned drivers are reflected in the responses to the public consultation as
regards challenges to achieving food waste reduction and who needs to act (see Annex 2,
113
Estimated using the JRC food waste prevention calculator -
https://eplca.jrc.ec.europa.eu/permalink/valeria/prevention_action_calculator.xlsm
114
Manfredi, S., & Cristobal, J., Towards more sustainable management of European food waste:
Methodological approach and numerical application. Waste Management and Research, 34(9), 957–968,
2016, https://doi.org/10.1177/0734242X16652965.
115
European Commission, Directorate-General for Agriculture and Rural Development, EU agricultural
outlook for markets, income and environment 2022-2032, Publications Office of the European Union, 2023,
p. 43. https://data.europa.eu/doi/10.2762/29222. Note: very small variation (less than 1%), because of
slightly different MAGNET baseline used.
116
Eurostat, October 2022. Living conditions in Europe - material deprivation and economic strain -
Statistics Explained
117
The need to ensure access to food and solidarity in the food supply chain is also highlighted in the
recommendations of the European citizens’ panel on food waste.
118
FAO, The State of Food and Agriculture. Moving forward on food loss and waste reduction, 2019; UNEP,
Food Waste Index Report 2021; Champions 12.3, Changing behaviour to help more people waste less food
– a guide, 2022; Combating food waste: an opportunity for the EU to improve the resource-efficiency of the
food supply chain (see note 33, page 4)
EN 43 E
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synopsis report – public consultation) as well as in the recommendations made by EU
citizens119
to step up action to reduce food waste in the EU.
The EU food safety regulatory framework in general cannot be considered as a driver of
food waste as its implementation seeks to ensure a safe, sustainable food system and
protect human and animal health. On the contrary, by reducing the occurrence of food
safety hazards in foods, EU food safety policy helps to prevent food waste. When food
safety incidents arise (e.g., presence of Salmonella, dioxins…), quick action in accordance
with Commission Decision (EU) 2019/300 will limit recalls and reduce food waste.
1. Insufficient consumer food management. At the consumer level, the drivers120
and
behaviours that lead to food waste are complex and often inter-related. These can occur
during planning, shopping, storing, preparing and/or consuming stages.
Food waste reduction depends on consumers’ motivation, opportunity and ability to act121
.
There may be insufficient motivation to take action due to a number of factors including
lack of awareness about food waste; attitudes and/or level of concern about food waste and
its related impacts; lack of self-awareness on the amount of food generated; food prices in
relation to household incomes; lack of role models and other examples pointing to food
waste prevention as a social norm122
. Lack of opportunity such as time constraints
affecting meal planning and preparation, not having access to technologies supporting food
management (e.g., freezing) or to advice on how to store and re-use food safely can lead
to food being wasted. Lack of ability (knowledge and skills) can also contribute to
insufficient food management, leading to food waste.
One of the main reasons leading to avoidable food waste in households is food not being
used in time including due to the misunderstanding of the meaning of date marking123
.
Moreover, the consumer trend towards healthier diets124
and increased demand for
fresher, chilled and convenience foods will result in a greater share of grocery products
within the food categories where date marking issues are more likely to drive food waste125
.
Consumer expectations regarding the appearance of food (such as the size and shape of
fruit and vegetables) can contribute to food waste upstream in the food supply chain just
119
European Citizens’ Panel on Food waste, Final recommendations, February 2023.
https://citizens.ec.europa.eu/food-waste-panel_en
120
Attiq, S., Danish Habib, M., Kaur, P., Junaid Shahid Hasni, M., & Dhir, A., Drivers of food waste
reduction behaviour in the household context, Food Quality and Preference, 94, 2021,
doi:10.1016/j.foodqual.2021.104300; Canali et al. Drivers of current food waste generation, threats of future
increase and opportunities for reduction, FUSIONS Project. ISBN: 978-94-6257-354-3, 2014.
121
van Geffen, L., van Herpen, E., Sijtsema, S., van Trijp, H., 2020. Food waste as the consequence of
competing motivations, lack of opportunities, and insufficient abilities. Resour. Conserv. Recycl. X 5,
100026. https://doi.org/10.1016/j.rcrx.2019.100026.
122
Hebrok, M., Boks, C., 2017. Household food waste: Drivers and potential intervention points for design
– An extensive review. J. Clean. Prod. 151, 380–392. https://doi.org/10.1016/j.jclepro.2017.03.069;
123
Flash Eurobarometer 425 (2015): while 58% of Europeans state that they always check ‘use by’ and ‘best
before’ labels when shopping and preparing meals, less than half understand the meaning of ‘best before’
(47%) or ‘use by’ (40%).
124
Moz-Christofoletti, M.A.; Wollgast, J., Sugars, Salt, Saturated Fat and Fibre Purchased through
Packaged Food and Soft Drinks in Europe 2015–2018: Are We Making Progress?, Nutrients 2021, 13, 2416.
125
Bumbac, R., The European food market – increased consumer preference towards convenience and
healthy food. Junior Scientific Researcher, Vol V, No. 2, pp. 53-61
EN 44 E
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as the food environment can also influence consumer food purchases and habits (e.g.,
availability of ‘doggy bags’ in restaurants to take home surplus food from meals)126
.
At the consumer level, the drivers and behaviours that lead to food waste are also impacted
by market causes, for instance, the price of food. As increased food productivity has, over
the years driven down the price of food, it may be perceived as having a relatively low
value The challenge however lies in how to ensure higher perceived value of food,
without actually increasing its price, notably in the context of recent inflation; hence this
driver is not addressed. The growing interest in short supply chains (as reflected in the
recommendations of the Citizens’ panel) may also help combat food waste by better
linking consumers with producers and building greater appreciation for food.
2. Inefficiencies and trade-offs in the food supply chain. In pursuing an economically
efficient approach, actors in the food supply chain may not always prioritise efficient use
of natural resources and the reduction of environmental impacts. For example, products of
lower market value may not warrant investment in prevention measures, and operators may
decide to compensate for waste by producing or buying in more127
.
Moreover, failures in food business operations (e.g., spillage, spoilage, break in the cold
chain) as well as lack of cooperation between supply chain actors can lead to food waste128
.
Other drivers also include inefficiencies in the production, handling, storage, processing,
packaging, distribution and marketing of food; the lack of measurement, diagnosis and
corrective action to address food waste in business operations; buffers in food production
systems in order to ensure meeting contractual agreements and/or food security; poor stock
management; inaccurate forecasting of supply and demand as well as unfair trading
practices (e.g., last minute order cancellations)129
.
Supply chain management systems can also affect food waste. The length of remaining
shelf-life on a product delivered to the retailer is a key factor driven by the stock control
function of date marks (‘use by’ and ‘best before’). While ensuring sufficient available
shelf-life at retail and consumption is important, the setting by retailers of strict Minimum
Life On Receipt (MLOR) criteria may result in product returns and food waste130
.
3. Lack of understanding and certainty as regards the implementation of food safety
standards may lead to situations where food that is still safe for human consumption is
removed from the food supply chain.
One such example concerns the possible misinterpretation of date marking set out in EU
food labelling rules131
– requiring that most pre-packed foods display a date mark and
126
REFRESH, Policies against consumer food waste, Background report contributing to “REFRESH Policy
brief: reducing consumer food waste” (D3.4), 2019.
127
The State of Food and Agriculture. (see note 118, page 38)
128
The State of Food and Agriculture. (see note 118, page 38); Food Waste Index Report 2021 (see note 114,
page 38); Changing behaviour to help more people waste less food – a guide (see note 118, page 38);
Combating food waste: an opportunity for the EU to improve the resource-efficiency of the food supply chain
(see note 33, page 4)
129
Ghosh, R., & Eriksson, M., Food waste due to retail power in supply chains: Evidence from Sweden.
Global food security, Global Food Security, Volume 20, March 2019, pp. 1-8.
130
European Commission, Directorate-General for Health and Food Safety, Market study on date marking
and other information provided on food labels and food waste prevention: final report, Publications Office,
2018, https://data.europa.eu/doi/10.2875/808514.
131
Regulation (EU) No 1169/2011 on Food Information to Consumers
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accompanying wording that explains whether the date signals a threshold in the product’s
safety (“use by”) or its quality (“best before”). It is estimated that up to 10% of food waste
generated annually in the EU is linked to date marking132
.
With the exception of table eggs and poultry meat, EU legislation does not prescribe how
date marking should be established. The choice of date mark and length of shelf-life – both
of which can impact on food waste – are determined by food business operators. In doing
so, food business operators are required to ensure food safety, and tend to act cautiously to
take account of differences in storage conditions within the food supply chain and
households. Concern about consumer perceptions of products (e.g., freshness, quality) can
also prevent firms from exploiting the potential for extension of shelf-life provided by
improved storage technology.
The marketing of foods beyond their date of minimum durability (i.e., ‘best before’) is
allowed under EU rules, provided that the foods concerned are still safe and their
presentation is not misleading. In practice, both misunderstanding of the meaning of ‘best
before’ and, in some Member States, measures taken to restrict placing on the market of
food past the ‘best before’ date can also result in barriers to food donation133
.
Traceability requirements for food safety purposes have also been raised as a potential
cause of food waste, mainly by food business operators at retail level which consider these
as an additional administrative burden and thereby an obstacle for donation of surplus
food134
. However, food safety has to be ensured throughout the food supply chain,
including food donation. It is therefore crucial to ensure full traceability to prevent and/or
contain a possible food safety incident.
4. The lack of evidence-based, coordinated approaches in Member States – despite the
existing obligations in the WFD – means that the systemic causes of food waste are not
adequately addressed and that food waste is not decreasing at the pace and scale required
to meet SDG Target 12.3.
Reducing food waste, and in particular that arising at consumption, requires an integrated,
systemic approach, involving multiple partners from the public and private sectors, with
coordinated actions tailored to address specific hotspots as well as attitudes and behaviours
that lead to food waste.
The Voluntary Code of Conduct for Food Loss and Waste (FLW) Reduction135
, developed
by Food and Agriculture Organization (FAO), calls for setting up an adequate
institutional, policy and regulatory framework in order to facilitate the coordination of
actors, enable investments and support and incentivise both improvement of practices and
adoption of good practices. In the EU, national authorities in Member States are best
placed to design effective national food waste prevention strategies and programmes
132
Market study on date marking and other information provided on food labels and food waste prevention:
final report (see note 130)
133
European Commission, Directorate-General for Health and Food Safety, Food redistribution in the EU :
mapping and analysis of existing regulatory and policy measures impacting food redistribution from EU
Member States, Publications Office, 2020, https://data.europa.eu/doi/10.2875/406299
134
The issue of traceability has been raised by the EU Fit For Future Platform in an opinion adopted in 2022.
The Platform suggests that the Commission explores the possible benefits of updating the EU Guidelines on
Food Donation.
135
See note 83, page 33.
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that address relevant behavioural and market drivers, supported by an appropriate
evidence base.
In addition, the United Nations Environment Programme (UNEP) calls on governments to
follow the “Target-Measure-Act” evidence-based approach136
to achieve rapid and
concrete results regarding food waste prevention. Targets set the level of ambition and can
help guide effective action based on food waste diagnostics (that is, carrying out a baseline
assessment of food waste levels and “hotspots” in order to identify causes of food waste
generation, underlying drivers and define corresponding solutions to address these).
In particular, countries which have achieved significant reduction of consumer food waste
associate both public-private partnerships and collaboration between government and
actors in the food supply chain, committed to a common roadmap for food waste
reduction at national level, with a consumer behaviour change campaign.
In order to assess the situation in the EU, an analysis137
was carried out of the measures
taken in the Member States, based on Member States’ contributions to various EU-level
data collection initiatives and web sites138
. While Member States have committed to
reaching SDG Target 12.3, overall, action taken so far at national level is insufficient
and not at the scale required139. All Member States have some actions in place to prevent
food waste; however, most Member States have not yet adopted a specific target on food
waste reduction nor a roadmap to drive concrete action at national level - relying instead
on their overall commitment to SDG Target 12.3. Thus, the level of ambition, the degree
to which measures have been implemented, and results obtained vary considerably (see
further details in Annex 7):
 Lack of overall approach to guide effective action (food waste diagnosis, targeted
activities to key hotspots, evaluation): Only 3 Member States140
have demonstrated
this approach.
 Lack of overarching strategy and roadmap for achieving agreed targets: Only 12
Member States141
have strategies in place, with wider scope than measures in the
specific food waste prevention programmes foreseen in the WFD; however, with
limited or partial evidence of monitoring and evaluation. Another 11 Member
States142
report on actions undertaken at national level; however, these appear to be
still at an early stage in their development and/or are limited in duration, scale or scope
(e.g., voluntary agreements, redistribution and awareness campaigns). Monitoring and
136
Food Waste Index Report 2021 (see note 118, page 38)
137
The assessment was based on: Member States’ contributions to the EU Food Loss and Waste Prevention
Hub; targeted surveys to members of the EU Platform on FLW; Member States’ contributions to a 2020
progress assessment on the implementation of 2016 Council Conclusions on Food Losses and Food Waste;
findings from a review of Member States’ Country Profiles by the European Environment Agency (EEA).
138
This assessment is based on: De Laurentiis, V, Mancini, L, Casonato, C, Boysen-Urban, K, De Jong, B,
M’Barek, R, Sanyé Mengual, E, Sala, S. Setting the scene for an EU initiative on food waste reduction
targets. Publication Office of the European Union, Luxembourg, 2023, doi: 10.2760/13859, JRC133967
139
The Champions 12.3 high-level coalition also reported that global progress by governments and
companies on achieving SDG Target 12.3 is slower than needed. See: SDG Target 12.3 on Food Loss and
Waste: 2022 Progress Report | Champions 12.3 (champions123.org)
140
The Netherlands, France and Germany.
141
The Netherlands, France, Germany, Austria, Belgium (particularly Flanders and Brussels capital),
Croatia, Finland, Ireland, Italy, Portugal, Spain and Sweden.
142
Member States with low-to-mid level actions: Bulgaria, Czechia, Denmark, Estonia, Greece, Hungary,
Latvia, Lithuania, Luxembourg, Slovakia and Slovenia.
EN 47 E
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evaluation are either not defined, not implemented or not reported. The remaining four
Member States143
appear not to have strategies in place.
 Lack of clear accountability and governance, engaging all players (from both
public and private sectors) to ensure effective coordination of action: Generally,
government sponsor is not clearly identified due to shared agenda
(agri/food/environment). The majority of Member States (23)144
have public-private
partnerships or collaborative fora with commitments or actions in place, however,
coordination of efforts appears to be not well documented nor visible. There is also
limited evidence of reporting on progress, suggesting low priority of the food waste
agenda in national policymaking.
 Efforts do not adequately target both improving supply chain efficiency and
supporting consumer behavioural change: 11 Member States145
follow a dual
approach with actions to improve supply chain efficiency (e.g., voluntary agreements
or stakeholder dialogue fora) and measures fostering behavioural change. Although
all Member States have some actions targeting consumers, these mainly focus on
awareness raising rather than behavioural change.
A few Member States can be considered front runners in their efforts to set up evidence-
based approaches:
The Food Waste Agenda in The Netherlands (non-regulatory approach)
 Overall strategy and roadmap: Target in line with SDG 12.3 (2015 to 2030). 30% reduction in
household food waste (2010-2022). A slight decrease has been reported in total quantities of food
waste generated, but data for supply chain level food waste is highly uncertain.
 Food waste diagnosis and evidence-based approach: annual monitoring and publication of food
waste levels since 2012.
 Governance: Food Waste Free United Foundation (2018) established to shape the Dutch food waste
prevention agenda. The Government facilitates and supports food waste actions and regularly
reports to the parliament on the implementation of the FW agenda.
 Supply Chain Engagement:
o Voluntary agreement (2018), coordinated by independent body (Foundation) consisting of a
multi-stakeholder platform catalysing food waste prevention initiatives across the supply chain,
in collaboration with government and education institutions, as well as food business operators
and financial organizations (cost of 208.000 EUR/year).
o online food redistribution platform
o Support for food business operators for food waste prevention solutions (200.000 EUR/year).
 Consumer behaviour:
o Annual consumer campaigns “United Against Food Waste” to reduce household food waste
(2019-2022), supported by government (7 million euros).
o Other consumer awareness and behaviour interventions (week against food waste, date
marking campaign (2020) and actions in schools).
The French Food Waste Pacts (regulatory approach coupled with stakeholder engagement)
143
Cyprus, Malta, Poland and Romania.
144
All Member States excluding Cyprus, Estonia, Lithuania, Malta.
145
Belgium, Denmark, Finland, France, Germany, Hungary, Ireland, Italy, Luxembourg, The Netherlands,
Sweden
EN 48 E
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 Overall strategy and roadmaps/routes towards impact: Target set by the French government
and adopted by law aims for 50% reduction before 2025 for retail and collective catering sectors,
and by 2030 for other sectors (baseline 2015). Two pacts (2013, 2017).
 Governance: Involving five ministries and 58 stakeholders (6 working groups). Regional
networks with annual calls for proposals to support territorial food/food waste reduction projects.
 Food waste diagnosis and evidence-based approach addressing supply chain engagement:
o Food redistribution: obligation for retailers (>400m2 surface area) to establish partnerships
with charities to ensure redistribution of surplus food as practices to destroy edible foods became
prohibited (Garot Law, 2016).
o Mandatory measures extended to collective catering and the food and drink industry (2019)
and wholesalers (2020).
o Action plans against food waste are mandatory for the abovementioned sectors (including
diagnosis supported by French environment Agency, ADEME).
o Pilot project on fruit and vegetables to support producers in the diagnosis and implementation
of tools to reduce food losses and waste (ADEME, 2021).
o Evaluation of the second pact, included an overview of actions reached so far (2021).
 Consumer behaviour:
o Education on food waste reduction for consumers in the school curricula (Egalim law,
2018). Teacher trainings and educational materials.
o National pact on date marking, co-signed by Agriculture and Environment ministries, initiated
by Too Good To Go.
o National campaign to raise awareness on the difference between ‘best before’ and ‘use by’
dates and creation of ‘anti-food waste’ aisles in retail stores.
Overall, the situation in the EU – based on the nature and level of activity – shows that
only three Member States are well positioned to make significant progress in achieving
SDG Target 12.3. The insufficient and uneven response of Member States in taking action,
in line with EU and global commitments, is therefore a key regulatory issue which this
initiative seeks to directly address.
The visual problem tree is presented as part of the intervention logic in Section 3.4.2.
3.2.3. How likely is the problem to persist?
Without further EU intervention, Member States will continue to adopt food waste
prevention programmes that do not include a national target, that will lack monitoring and
that will not be supported by adequate governance, with ineffective coordination of action.
In addition, the initiatives taken by most Member States to date remain at an early stage of
development or are on such a small scale that delivery of results at the level required to
significantly reduce food waste generation in the EU by 2030 is unlikely. The few
initiatives taken to date that show any quantifiable results at national level will not be
sufficient to achieve EU and global commitments by 2030. It can be expected that the
measures will generally remain insufficient to ensure progress at the pace required to
achieve SDG Target 12.3, and that the underlying behavioural and market drivers of food
waste generation will remain inadequately addressed in national strategies. As a result, it
can be expected that action will remain disparate and that the potential for reducing food
waste will not be realised.
A few individual cases, including experience gained outside the EU146
do show, however,
significant food waste reduction potential. Therefore, it could be argued that the current
146
E.g., United Kingdom or The Netherlands – see Annex 7 for further information
EN 49 E
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activities – if they were to grow over time – would have some impact, even without any
additional future intervention at EU level. However, taking into account the very short time
horizon up to 2030, as well as the lack of robust data on the progress made over the last
period (see section on Problem Definition above), it can be assumed that there will be no
significant change in food waste reduction. Based on the analysis of the existing prevention
policies, it is expected that general trend will be stable. Further details are provided in
section 3.5.1 describing the baseline.
Since waste generation is linked to economic growth, it is likely that waste generation will
increase along with the economic growth expected in the medium term.
It can therefore be concluded that food waste generation will not be decreasing as required
to meet the global and EU commitments, with resulting environmental, economic and
social consequences (including the contribution to food security).
3.3. Why should the EU act?
3.3.1. Legal basis and nature of the legal instrument
Article 192 of the Treaty on the Functioning of the European Union (TFEU) empowers the
EU to act in the field of environmental policy to preserve, protect, and improve the quality
of the environment and protect human health and contribute to the prudent and rational
utilisation of natural resources; and promote measures at the international level to deal with
regional or worldwide environmental problems. empowers the EU to act in the field of
environmental policy to preserve, protect, and improve the quality of the environment and
protect human health and contribute to the prudent and rational utilisation of natural
resources; and promote measures at the international level to deal with regional or
worldwide environmental problems.
The initiative would be realised through targeted amendments to the WFD which is based
on Article 192 (1) TFEU and already regulates major aspects of food waste prevention
(definition, obligations for Member States, planning, reporting) and management (e.g.,
separate collection). The amendment of the Directive would build on these existing
requirements and waste prevention measures and will introduce binding objectives to be
achieved by Member States and the timeframe for their achievement.
3.3.2. Subsidiarity: Necessity of EU action
Given the cross-border nature of the problems (e.g., environmental pressures and impacts
related to food waste) and supply chains that underpin the Union food system, a
harmonised transformational change as regards reduction of food waste can only be
effectively achieved at EU level.
The decrease of food waste generation is insufficient across all EU Member States and the
underlying drivers that generate food waste are the same across the EU.
Food waste generation has significant trans-boundary environmental and pollution effects
including the production of significant GHG emissions within the EU. Food is traded
widely within the EU internal market147
and the Member State of food production is often
147
In 2021, more than two thirds (68.8 %) of the EU’s total trade in agricultural, fisheries and food and
beverage products was between EU MS – Key figures in the European food chain - 2022 edition, (Statistical
Office of the EU (2022))
EN 50 E
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different from the Member State of consumption. Food businesses that operate cross-
border, for example larger food producers or major retail chains with activities in several
Member States, need coherence and clarity on the level of ambition expected in order to
plan investments and actions on food waste prevention.
A coordinated approach at EU level can bring reliability and continuity and thus support
adoption of new business models by food business operators in order to accelerate food
waste reduction across the food value chain. For example, a group of the world’s largest
food retailers and providers, including companies operating throughout the EU, have
committed to working with their suppliers to halve food waste by 2030148
. An assessment
of the world’s progress towards achieving SDG Target 12.3149
shows that companies are
taking action to address food loss and waste at a greater rate than countries. The setting of
binding targets on Member States to further drive action by governments is expected to
help accelerate reduction of food waste in the food supply chain.
Food has embedded environmental and climate consequences, because of the energy and
resources used and associated emissions throughout its life cycle. Most of these
environmental externalities are not internalised into food prices, thus obstructing the
market mechanisms to provide the necessary incentives to minimise them. Therefore,
reduction of food waste across the EU in a consistent manner is needed to ensure, in each
Member State, prudent and rational utilisation of natural resources, reduction of negative
impacts on climate, biodiversity and use of natural resources, with benefits extending
beyond national borders. Importantly, by making the food system more efficient, food
waste reduction also contributes to food security across the EU.
Despite political commitments made at international, EU and national levels, existing legal
requirements in the WFD and supporting activities by the Commission, Member States’
responses to food waste have been uneven and are, overall, not sufficient to address the
problems identified and the environmental, economic and social consequences for
consumers, enterprises and society as a whole. The variation in efforts across Member
States as regards reduction of food waste generation and different levels of expectations as
to the contribution of food business operators indicates a need for reinforced and uniform
legal measures at EU level to drive the progress at the pace required to achieve SDG Target
12.3.
While the EU legislator can define a common target for reduction of food waste for
different stages of the food supply chain to ensure the EU achieves these objectives, each
Member State will retain the same level of flexibility to develop the most effective policies
and measures to reach the objectives, taking into account its national context and
specificities, while being able to draw on the supportive actions led by the Commission as
described in section 3.1.2. This is particularly the case for reducing food waste at
consumption level: while EU-wide actions can help, they cannot easily take into account
the complex, market- and culture-specific drivers of food waste generated by consumers
in different Member States, nor the behavioural change levers. Such initiatives need to be
tailored to address the specific situations in Member States, informed by food waste
diagnostics and developed with local partners, such as local governments, education
148
Champions 12.3 release: World’s leading food retailers and providers engage nearly 200 suppliers in
cutting food loss and waste in half (24 September, 2020)
149
Champions 12.3, SDG Target 12.3 on Food Loss and Waste: 2022 Progress Report (September 2022)
EN 51 E
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institutions, retailers, NGOs and food producers. Member States themselves are best
placed to take forward such targeted efforts including information and behavioural change
campaigns tailored to their citizens’ needs and taking into account policy frameworks and
governance models. Furthermore, initiatives targeting supply chain efficiency also need to
be addressed at national levels150
where governments may define the specific objectives
and actions required, in cooperation with food business associations, as part of national
food waste prevention strategies and roadmaps established to reach national targets.
The intended amendment of the WFD therefore seeks to directly address the regulatory
drivers identified in this impact assessment and to incentivise Member States to take action
addressing the behavioural and market drivers of food waste generation.
3.3.3. Subsidiarity: Added value of EU action
EU action on food waste reduction brings added value as it is more effective and efficient
than individual actions by Member States taken in isolation. An EU regulatory framework
ensures coherence notably through the setting of common objectives as regards the
reduction and monitoring of food waste, avoiding a fragmented approach by addressing
the drivers of food waste in a coordinated manner and giving certainty to operators.
Setting food waste reduction targets is expected to confer clear accountability to Member
States for driving more ambitious action at national level, in line with their and the EU’s
commitment to achieve global targets. In order to achieve results in the short term, and to
give food business operators, consumers and public authorities the necessary perspective
for the longer term, quantified targets for reduction of food waste generation, to be
achieved by Member States by 2030, should be set. Such targets are expected to reinforce
efforts to identify and scale-up effective strategies/initiatives both within and across
Member States, in particular by:
o streamlining the contribution of food business operators, notably in the context of
cross-border supply chains, avoiding shifting waste from one stage of the food supply
chain to another and ensuring systemic reduction across the food value chain;
o helping to ensure that drivers (market and behavioural) are addressed
consistently/simultaneously by all Member States, in line with actions taken by the –
so far few – front-runners as less advanced Member States can benefit from the
experience of others;
o accelerating the development of effective national food waste prevention strategies by
spreading good practices and synergies from similar approaches being developed in
different Member States and by further leveraging the EU knowledge base regarding
environmental impact of food waste generation, prevention and management.
Member States’ achievement of food waste reduction targets will be facilitated by EU level
supporting measures that can both supplement and reinforce action at national level (see
section 3.5.2 for further details). Such EU-level action will support Member States through
the provision of relevant guidance and tools to reduce food waste while allowing flexibility
150
For instance, in Germany, a Voluntary Agreement on the reduction of food waste in the away-from-home
catering sector has been established between the Federal Ministry of Food and Agriculture (BMEL) and
business associations of the catering and hotel sector. As part of the Voluntary Agreement (VA), business
associations have agreed on reduction targets and measures to reduce food waste. The VA was developed in
a dialogue forum for the sector, supported by the BMEL.
EN 52 E
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in the approach to be taken. Nonetheless, the obligations already laid down in the WFD
(see section 3.1.2) will ensure coherent implementation of food waste prevention initiatives
by Member States, in line with the waste hierarchy. Moreover, the proposed setting of
targets for specific stages of the food supply chain provides Member States with a common
approach in reducing food waste and priorities for action.
By acting at EU level, in combination with actions taken at Member State level, barriers
to the implementation of food waste prevention can be identified and assessed as they arise,
including the possible need for further intervention. For example, amendments to food
hygiene legislation, adopted in 2021 in order to lay down certain requirements to promote
and facilitate food donation whilst guaranteeing its safety for consumers, reflected issues
raised by Member States and food business operators in context of the prior elaboration of
EU food donation guidelines (adopted in 2017).
3.4. Objectives: What is to be achieved?
3.4.1. General objective
The general objective of this revision is to reduce the environmental and climate impacts
of food systems associated with food waste generation. Preventing food waste would also
contribute to food security. More specifically, by increasing the efficiency of food systems
and supporting consumer behavioural change to avoid unnecessary discarding of food, it
would be possible to feed a greater number of people with the same food production.
Reducing food loss and waste can therefore contribute to meet the expected growing
demand for food whilst ensuring that our food system operates within planetary
boundaries.
The links between the problems, general objectives and specific objectives are presented
in the intervention logic in Annex 7.
3.4.2. Specific objectives
The first specific objective of the initiative is to assign clear responsibility to Member
States for accelerating reduction of food waste along the food supply chain and in
households, in their respective territories, and thus make a solid contribution towards
achieving SDG Target 12.3.
As second specific objective, the initiative also seeks to ensure sufficient and consistent
response by all Member States to reduce food waste, in line with that of front-runners.
This should lead each Member State to take ambitious action – deploying the most
effective measures, tailored to its specific national situation – and aiming to support
consumer behavioural change as well as strengthen coordination of actions between actors
across the whole food value chain as well as with other relevant actors (e.g., academia,
NGOs, financial institutions…).
In order to facilitate systemic action, Member States will need to ensure an enabling
institutional, policy and regulatory framework that can adapt to evolving needs of key
players. Findings from the public consultation showed strong agreement of respondents
with the effectiveness of taking such food waste prevention measures, with the vast
EN 53 E
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majority agreeing with the setting of EU-level legally binding food waste reduction targets
(74% - 488 replies)151
.
Figure 7: Problem tree and intervention logic for food waste
151
Further details are presented in Annex 2 – public consultation.
EN 54 E
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3.5. What are the available policy measures and options?
3.5.1. What is the baseline from which options are assessed?
The baseline is a “no policy change” scenario, with the current WFD remaining in force.
Although Member States will continue to define and implement food waste prevention
measures and the Commission will continue to lead supporting activities as described in
section 3.1.2, it is expected that action across the EU will remain uneven and disparate and
will not sufficiently leverage the full potential of food waste reduction, as the behavioural
and market drivers will likely not be adequately addressed under this scenario. Thus, food
waste levels are not expected to decrease in line with the EU and global commitments.
The baseline assumes that no further legislative action will be taken at EU level to target
directly the reduction of food waste. While it reflects relevant EU and national policies in
force (such as related climate or agriculture policies), it does not include Commission
proposals (i.e., policies not yet adopted by co-legislators) foreseen by the relevant EU
strategies and, more generally by the EGD (see Annex 10, section 2.1 Baseline - for further
details).
The baseline considers a series of variables which influence the evolution of food waste
projections up to 2030, including the GDP and population growth, which are the main
factors152
, as well as developments in agri-food production and services. On this basis,
food waste levels are expected to remain constant between 2020 and 2030, with only 0.1%
change (from 56.98 Mt in 2020 to 57.04 Mt in 2030, see also Figure 8)153
. However, the
expected changes in food waste generation vary between Member States. While countries
with increasing population and a well-performing economy and agrifood sectors are
expected to show an increase in food waste generation, some Central and Eastern European
countries are expected to experience a strong demographic decline resulting in a reduction
of food waste, in spite of comparatively high economic growth rates. Baseline (and further
assessment of impacts) is based on the estimates of October 2022154
.
The detailed description of the baseline as well as the situation of different Member States
(including key drivers) is presented in Annex 10, section 2.1 Baseline.
Some of the assumptions regarding factors such as economic growth, demography, or
energy are based on 2021 data. Therefore, they already include impacts from the COVID
pandemic. However, food-price inflation, energy crisis and other recent developments
exacerbated by the Russian invasion of Ukraine, are not taken into account. Inflationary
pressures are expected to fall in the short- term; however, uncertainty remains as to their
influence and evolution over the ten-year span.
Separate collection of bio-waste is already considered in the projection on food waste
amounts. On its own, separate collection does not impact the amounts of food waste
generated. However, separate collection obligations for bio-waste have already been
152
European Commission, Joint Research Center, Global Energy and Climate Outlook: Advancing towards
climate neutrality, Dataset, 2021, https://data.jrc.ec.europa.eu/dataset/067e2ab2-d086-4f19-972e-
5c46473f5efb
153
The projection is based on projected growth of municipal waste amounts - 8.3% at the EU level (calculated
using a regression on GDP and population) and then implemented to the MAGNET model using a top-down
approach.
154
The updated estimations from March 2023 are slightly higher (58.5 Mt vs previous 57 Mt) became
available only after completion of the modelling exercise; however, as all options are compared to the same
baseline, impact on the results would be minimal.
EN 55 E
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gradually implemented by Member States over several years, and no significant changes
in the amounts of food waste have been observed as a consequence. Therefore, entry into
force of the legal obligation from 2024 is not expected to have any significant impact on
generation of food waste.
Regarding technological change, production technology development in terms of
agricultural and forestry technology development, and feed efficiency are considered in
the baseline. However, technological developments that are aimed at reducing food waste
are not considered as little data are available about the concrete impacts of new digital and
smart technologies (such as food-sharing smart phone applications) on food waste
reduction.
3.5.2. Description of the food waste policy options
Pre-selection of options
While the legal obligation in the WFD specifically calls for the setting of food waste
reduction target155
, in the preparation of this impact assessment other measures at EU level
that could help address the problem drivers have also been considered.
Public authorities such as Member States or the European Commission cannot themselves
directly reduce food loss and waste, but they are indispensable in providing overall
strategic direction as well as supporting and coordinating action from multiple players in
the public and private sectors to reduce food waste.
As presented in section 3.1.2 (Overview of EU action to prevent food waste), the European
Commission has already implemented measures (regulatory and non-regulatory) to support
Member States in taking action in many of these areas and monitor the EU’s progress. In
order to facilitate synergies between EU- and Member State-level action, the Commission
intends to require Member States to formally designate a competent authority for food
waste prevention within existing government services. As this entails no additional costs,
it has not been assessed in the IA.
The potential further actions which could be considered by the Commission include items
listed hereunder.
a) Supporting consumer behavioural change
Evidence suggests that changing consumer behaviour as regards food waste cannot rely on
simple awareness raising but requires a mix of different interventions targeted to address
specific behaviours and population groups156
. In order to curb consumer food waste,
joined-up action involving multiple players is needed, drawing on consumer insights
derived from research carried out in Member States. Findings and learning related to
155
Article 9.6 of the WFD: “By 31 December 2023, the Commission shall examine the data on food waste
provided by Member States in accordance with Article 37(3) with a view to considering the feasibility of
establishing a Union-wide food waste reduction target to be met by 2030 on the basis of the data reported
by Member States in accordance with the common methodology established pursuant to paragraph 8 of this
Article. To that end, the Commission shall submit a report to the European Parliament and to the Council,
accompanied, if appropriate, by a legislative proposal.”
156
Champions 12.3, Changing behaviour to help more people waste less food – a guide, 2022; Cristobal
Garcia, J., Pierri, E., Antonopoulos, I., Bruns, H., Foster, G. and Gaudillat, P., Separate collection of
municipal waste: citizens’ involvement and behavioural aspects, EUR 31310 EN, Publications Office of the
European Union, Luxembourg, 2022, ISBN 978-92-76-59008-8, doi:10.2760/665482, JRC131042.
EN 56 E
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consumers’ own motivation and intentions to reduce food waste, opportunity factors (e.g.,
available time and financial resources), and consumers’ abilities (knowledge and skills
related to food management) are important elements to help inform behavioural change
interventions and information campaigns.
To make behavioural interventions aiming to reduce consumer food waste more effective
(and efficient), it is important to understand the contexts in which food waste occurs, and
the people and groups that create food waste. Some groups waste more than others and
some will be more influenced to change their behaviour than others. Obtaining such
knowledge is an essential foundation for the design of both interventions and messaging,
ensuring that these are as effective as possible.
In designing such interventions, a top-down, “one size fits all” approach will not address
the underlying behavioural drivers of food waste157
. As regards nudges, the best choice
depends on the specific situation at hand and requires in-depth knowledge of the target
group and context. For instance, nudges that make food waste avoidance easier and more
convenient will primarily work for those who consider reducing food waste as effortful or
nudges to avoid food waste during meal preparation will not address decisions made when
food shopping (e.g., overbuying) which may later lead to food waste.
Whether or not nudges (or other behavioural interventions) are effective in reducing food
waste depends to a large degree on the target group, the context in which they are
implemented (e.g., city, region, country), the engagement of other players (e.g., food
business operators), and the overall policy context. Importantly, their effectiveness relies
on empirical evidence, which usually stems from rigorous experimental testing, often done
in laboratories. Scaling up from the laboratory to a local, regional or country-wide
initiative, although challenging158
, can be accomplished best by actors with sufficiently
detailed knowledge. Moreover, the design of experiments may need to be adapted based
on results and learning gleaned, requiring ongoing monitoring and updating.
Whilst such efforts may be supported and enhanced through actions undertaken at EU level
– through EU-funded research159
and sharing of best practice and learning from actions
undertaken on-the-ground – interventions to support consumer behavioural change can
only be undertaken in and by Member States. The integration of consumer behavioural
change initiatives in the context of national food waste prevention programmes ensures
their alignment with objectives defined at national level, supported by an appropriate
evidence base and engaging multiple players in a joined-up approach, in particular: policy
makers, food businesses, non-food businesses (e.g., technology providers), non-
governmental organisations (consumer, environmental…) and educators/other influencers
(including social media).
157
Bruns, H. and Nohlen, H., Segmenting consumers and tailoring behavioural interventions to reduce
consumer food waste, EUR 31547 EN, Publications Office of the European Union, Luxembourg, 2023, ISBN
978-92-68-04228-1, doi:10.2760/541400, JRC134011.
158
Al-Ubaydli, O., List, J. A., & Suskind, D. L. (2017). What Can We Learn from Experiments? American
Economic Review: Papers & Proceedings, 107(5), 282–286. https://doi.org/10.1257/aer.p20171115
159
For instance, EU-funded project CHORIZO aims to improve the understanding of how social norms
influence behaviour and food waste generation and use this knowledge to improve the effectiveness of
decision-making and engagement of food chain actors towards zero food waste.
EN 57 E
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b) Consumer education
In its recommendations160
on actions needed to step up food waste prevention, the EU
citizens’ panel highlighted the importance of education. Education is a competence of
Member States which are also best placed to take forward both the integration of food and
food waste prevention in school curricula as well as carrying out targeted campaigns
addressing relevant behavioural drivers and tailored to their citizens’ information needs.
The Commission supports such actions by facilitating sharing of best practice and learning
in consumer education through a variety of tools161
(see section c).
c) Clarification and/or amendment of EU legislation in order to facilitate
prevention of food waste, in line with the waste hierarchy
As regards clarification and/or amendment of EU legislation to support food waste
prevention, a major effort has already been delivered in particular in the area of food
donation and the use of food for feed purposes but also in the area of measurement and
reporting of food waste levels by Member States162
. As further needs arise, it is expected
that these will be addressed, on an ongoing basis, notably through the work of the EU
Platform on FLW and Member States’ cooperation with Eurostat. For example, the EU
Platform on FLW is currently carrying out a new assessment of barriers and opportunities
to further facilitate redistribution of surplus food. Based on findings, the Commission may
update the EU food donation guidelines to integrate possible new issues identified. For
these reasons, this action can be considered as already implemented, with tools in place for
its delivery, and potential for its further strengthening will be considered based on findings
of the EU FLW Platform’s assessment.
d) Reinforcing dissemination and transfer of learning and best practices
Dissemination and encouraging transfer of learning and best practices, including
assessment of the effectiveness of food waste prevention initiatives, are already carried out
on an ongoing basis by means of the EU Platform on FLW and the digital EU Food Loss
and Waste Prevention Hub. In the digital pathway tool, that the RESTwithEU pilot
project163
will provide in Q3 2023 restaurants are guided to digital tools that help to
mitigate food waste along the supply chain. The new EU pilot project ‘European Consumer
Food Waste Forum’164
, will also deliver in June 2023 solutions and tools to help all actors
(including regulatory authorities) in implementing effective actions to reduce consumer
food waste.
According to the assessment of progress made in implementing the Council conclusions
on food losses and food waste, under the German Presidency of the Council of the
European Union165
, Member States have benefited from the exchange of information and
160
European Citizens’ Panel on Food waste, Final recommendations, February 2023. Recommendation n°18.
161
See for example: European Commission, Leaflet: How to reduce food waste in your daily life, 2020
available in all official languages of the EU.
162
See note 96, page 35
163
https://restwith.eu/
164
European Commission, EU Project: European Consumer Food Waste Forum, October 2021 - July 2023.
165
Food losses and food waste: assessment of progress made in implementing the Council conclusions
adopted on 28 June 2016, November 2020. (see note 30, page
3)https://data.consilium.europa.eu/doc/document/ST-11665-2020-INIT/en/pdf
EN 58 E
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experience made possible by the Platform, which have often inspired further action at
national level.
While increasing resources applied to ‘best practice’ sharing could further support
effective food waste prevention, dissemination of best practices cannot – in and of itself –
mobilise Member States and build capacity at national level to implement ambitious food
waste prevention strategies and actions. Based on the experience with uptake of identified
best practices today, this would not be sufficient to accelerate progress in all Member
States to take decisive actions for achieving SDG Target 12.3.
e) Legislative measures requiring specific actions of food business operators in
particular at retail– such as obligations related to food donation or banning
the destruction of edible food.
As part of their waste prevention programmes, Article 9 of the WFD (as revised in 2018)
obliges Member States to take measures to reduce food waste at each stage of the food
supply chain and encourage food donation and other redistribution for human
consumption, prioritising human use over animal feed and the reprocessing into non-food
products. Member States are also called upon to provide incentives for the application of
the waste hierarchy, such as facilitation of food donation (Article 4 and Annex IVa).
While most Member States promote food donation through voluntary measures (e.g., food
redistribution guidelines, stakeholder fora, digital tools and platforms) often coupled with
fiscal incentives, others have laid down specific measures laying down obligations related
to food donation (e.g., France, Czech Republic, Hungary, Poland). However, such
measures need to be precisely adapted to national conditions due to differences in the
structure and functioning of the markets, cooperation amongst actors in the food supply
chain, national legislative frameworks, policy culture (e.g., regulatory vs non-regulatory
approach) etc. The current measures laid down in the WFD provide the appropriate
framework for implementation of national measures tailored to the specific situation in
Member States.
f) Setting targets on Member States
While EU policy and supportive measures already seek to mobilise action by Member
States to prevent food waste in their territories, existing waste prevention measures cannot
ensure sufficient results within the fixed timeframe set by the SDG Target 12.3. Achieving
significant reduction of food waste in the EU by 2030 would require all Member States to
establish comprehensive and ambitious national food waste prevention strategies and
ensure their effective implementation as for far done only be a few countries.
In order to achieve this, more compelling action, set out in legislation and laying down
clear objectives for Member States, seems required at EU level. Such EU targets could
either be defined as national objectives or binding targets to be achieved by Member States.
In line with the subsidiarity principle, targets would allow Member States to develop their
own mix of policy measures including voluntary or legally binding measures or a
combination of both, depending on their national specificities.
Therefore, following this pre-screening, the abovementioned legislative and non-
legislative options (a-e) have not been analysed further in the IA. The analysis of policy
EN 59 E
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options to reduce food waste have focused on different approaches and levels for the setting
of food waste reduction targets (f).
EU measures to support Member States in reaching targets
 Operations of the EU Platform on FLW and its five dedicated sub-groups (action and
implementation; consumer food waste prevention; date marking and food waste prevention; food
donation; and food loss and waste monitoring). This multi-stakeholder forum brings together
international organisations, Member States and actors in the food value chain including consumer
and other NGOs to support all players in defining measures to prevent food waste, sharing best
practice and evaluating progress made over time. The Platform is currently preparing a case study
report on the implementation of Voluntary Agreements (public-private partnerships) to share
results and learning of Member States and other actors. Furthermore, the Platform is carrying out
new data collection on barriers and opportunities on food redistribution practises across the
EU.
 Supporting consumer behavioural change efforts, notably through the dedicated Platform
subgroup on consumer food waste prevention and the deliverables of the European Consumer
Food Waste Forum, and further dissemination of its solutions and tools tailored to meet the needs
of specific target groups (e.g., policymakers, food business operators).
 Facilitating consumer understanding and use of date marking: the Commission is currently
exploring the most efficient ways of doing so, without jeopardising food safety.
 Sharing best practice, resources and learning from food waste prevention to accelerate
progress through the EU Platform on FLW and the EU Food Loss and Waste Prevention Hub.
 Clarify and/or amend EU legislation as needed to facilitate food waste prevention in line
with the EU waste hierarchy. Ongoing assessment of the policy environment at Member State
and EU levels and consideration of any additional EU-level actions needed (e.g., possible
updating of EU food donation guidelines).
 Strengthen the evidence base for food waste prevention interventions through ongoing
assessment and continued development of the evaluation framework for food waste prevention
initiatives, in cooperation with the Joint Research Centre. Research and innovation support for
food waste prevention will continue both through ongoing EU-funded research projects and
further calls for proposals under Horizon Europe1
and other funding instruments (LIFE, InterReg
Europe).
 Grants to support Member States and stakeholders in improving food waste measurement
and implementation of actions to reduce food waste, in collaboration with HaDEA. Such grants
are awarded, on an annual basis, under the Single Market Programme.
 Biennial assessment of the progress of food waste prevention in Member States by the
European Environment Agency taking into consideration, amongst others, data reported to
Eurostat, and Member States’ food waste prevention programmes.
3.5.3. Setting a food waste reduction target
Taking into account the existing legal requirements in the WFD, the supportive measures
at EU-level implemented and the results achieved so far, the setting of EU-wide food waste
reduction targets is a necessary next step. By setting targets, the Commission aims to
catalyse the development and implementation of national food waste prevention
strategies of sufficient breadth and scale to adequately address the behavioural and market
drivers of food waste at national and local levels.
Setting targets in EU waste legislation is a policy instrument which requires Member States
to take action whilst however giving full flexibility as to the selection of measures required.
Member States may choose the policy instruments that would be the most effective and
efficient according to the specific situation in their respective territories.
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Introducing targets for food waste sets a clear objective and ensures that food waste
prevention becomes a long-term political priority. They provide legal certainty as well as
a common direction for all players and a coherent vision for society overall.
Such a policy approach is necessary given the multi-faceted nature of food waste caused
by different drivers and requiring multiple players to take action simultaneously166
as set
out in Section 3.2.2. (See specific examples of Member States actions in Annexes 7 and
10).
Research indicates that targets can be very effective motivators and can drive action when
they are set at the right level (i.e., that the required strategic levers are available and that
policymakers can achieve the right balance between motivating action and what is actually
possible to achieve).167,168
In particular, this instrument has been used in waste legislation
since the mid-1990s. Examples include the target for waste recycling169
, targets on limiting
on landfilling of biodegradable municipal waste and targets on recovery and recycling
of packaging waste170
.
These targets have been an effective policy tool in the area of waste management. While
several infringement procedures were initiated by the Commission due to the targets’ not
being achieved by the deadlines foreseen, no Member State has ultimately been fined as
all of them eventually achieved the prescribed target. Finally, food waste reduction targets
are a policy tool advocated by the European Parliament since 2012171
. The proposal to
revise the WFD in 2014172
set aspirational targets for Member States to reduce food waste
by 30% by 2025. The Commission later withdrew the proposal173
and adopted a new one,
in 2015, without targets. During negotiation of the new proposal174
, the Parliament
requested again to set targets. As a result, due to lack of data at that time, when the co-
legislators amended the Directive in 2018, the Commission was mandated to assess, by the
end of 2023, the feasibility of setting EU-wide targets accompanied, if appropriate, by a
legislative proposal.175
166
Stakeholders expressed strong support for the setting of EU-level food waste reduction targets in IAA,
public consultation and meetings of the EU Platform on FLW as well as the measures which need to be
implemented by multiple players in order to achieve food waste reduction (see Annex 2 – synopsis report).
167
Targets for a circular economy - Piero Morseletto
https://www.sciencedirect.com/science/article/pii/S0921344919304598
168
https://www.eea.europa.eu/publications/diverting-waste-from-landfill-effectiveness-of-waste-
management-policies-in-the-european-union
169
Article 11 of the WFD
170
OJ L 365, 31.12.1994, p. 10–23 – Art 6
171
OJ C 227E, 6.8.2013, p. 25–32 (European Parliament resolution of 19 January 2012 on avoiding food
wastage)
172
COM/2014/0397 final - 2014/0201 (COD)
173
This was part of a broader withdrawal of pending legislative proposals carried out on adoption of the 2015
Work Programme. Withdrawal of Commission proposals: OJ C 80, 7.3.2015, p. 17–23
174
COM/2015/0595 final - 2015/0275 (COD)
175
Article 9.6 of the WFD: “By 31 December 2023, the Commission shall examine the data on food waste
provided by Member States in accordance with Article 37(3) with a view to considering the feasibility of
establishing a Union-wide food waste reduction target to be met by 2030 on the basis of the data reported
by Member States in accordance with the common methodology established pursuant to paragraph 8 of this
Article. To that end, the Commission shall submit a report to the European Parliament and to the Council,
accompanied, if appropriate, by a legislative proposal.”176
Inception Impact Assessment, Proposal for a
revision of Directive 2008/98/EC on waste – part on food waste reduction target. See Annex 2 for details on
EN 61 E
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The policy options described below have been included in the Inception Impact
Assessment176
(IIA) and stakeholders were consulted on these including the EU Platform
on Food Losses and Food Waste. Stakeholder feedback showed broad support for the
setting of EU-level food waste reduction targets, with even higher endorsement expressed
in the public consultation by public authorities (see Annex 2- synopsis report).
3.5.4. Development of the policy options
Setting the format of the targets
Following input received from stakeholders177
, the Commission has further analysed
modalities for setting the binding targets. The analysis covered the following choices:
 Scope – i.e., which stages of the food supply chain should be addressed
 Expression – i.e., the way targets are to be expressed and measured
 The way the targets are set for Member States.
Concerning the scope, the question considered was whether targets should be limited to
the hotspot for food waste generation (i.e., consumption, including retail due to its impact
on the former) or rather address the whole food supply chain (post-farm gate to the final
consumer). While SDG Target 12.3, calls for “halving per capita global food waste at the
retail and consumer levels,” it also requires “reducing food losses along the production and
supply chains, including post-harvest losses”.
There was consensus among stakeholders that retail and consumption (food services and
households) represent important food waste generation hotspots and need to be targeted.
178
However, there were differing views as to whether the targets should also cover two
earlier stages (i.e., primary production and processing and manufacturing) in order to drive
food waste reduction upstream, in line with the global target. Food waste in primary
production is often considered a “side effect” of inefficiencies in the overall functioning
of the food supply chain or other factors beyond the control of producers (e.g., weather,
international trade restrictions). The potential for further reduction of food waste in food
processing and manufacturing was regarded by some as more limited given the inherent
economic incentive for operators to reduce food waste. Notwithstanding, most
stakeholders providing feedback to the IIA affirmed that food waste reduction targets
should cover the whole food supply chain.
In the light of these considerations, it was decided to test options covering the whole food
supply chain. However, since reducing food waste at production and consumption
requires different approaches and measures and targets different stakeholder groups,
differentiated targets would need to be proposed to address these stages separately.
It is important to note that, for setting the targets, the retail (food distribution) and
consumption (food services and households) stages are considered together. Despite
retail’s more limited contribution to food waste generation in the EU, setting a common
stakeholder responses to the setting of EU-level targets during IAA, public consultation and by the EU
Platform on FLW.
176
Inception Impact Assessment, Proposal for a revision of Directive 2008/98/EC on waste – part on food
waste reduction target. See Annex 2 for details on stakeholder responses to the setting of EU-level targets
during IAA, public consultation and by the EU Platform on FLW.
177
see in particular Annex 2, section 1, Inception Impact Assessment
178
see Annex 2, section 1, Inception Impact Assessment
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target reflects the influence of retail practices on consumption (e.g., portion sizes,
consumer information on shelf-life and storage, offers and promotions) and possible
related impact on food waste. Moreover, setting a joint target for these sectors (combining
retail, food services and households) will allow Member States flexibility to reduce waste
more in one sector than another, depending on their specific circumstances. Setting
separate targets for each of these stages would add unnecessary complexity and make
measurement less robust179
.
Concerning how food waste reduction targets should be formulated, the inception IA
proposed that targets could be expressed either as:
 the percentage reduction of food waste from the baseline year (2020) amount to
that in the target year (2030), or
 absolute amounts, i.e., in kilograms per capita per year to be achieved by 2030 (per
country).
In the feedback, stakeholders gave roughly equal support to both variants, with a slight
preference for targets expressed as a percentage. Expressing targets as percentage
reduction has the following advantages: consistency with the formulation of other waste
targets; for food processing and manufacturing, targets should refer to volume of
production and cannot be effectively expressed in absolute amounts; ensures a
differentiated approach by Member States (countries with high amounts of food waste need
to make proportionally higher efforts, but no one is exempted from taking any action at
all). Finally, targets expressed as a percentage reduction are less likely to be affected by
reporting errors/inaccuracies and modification of the measurement methodology.
Targets should therefore be expressed as a percentage reduction from the baseline year
(2020, or earlier if credible data are available) to the target year (2030).
Three possibilities were examined for the way in which targets should be set:
 the same target level for all Member States;
 target level differentiated by Member State;
 a collective target set at EU level – based on contributions from individual Member
States.
Stakeholders providing feedback to the IIA most often chose the collective EU target as a
preferred approach followed by the same target for all Member States, with targets
differentiated by Member State receiving the least support. Interestingly from the few
Member State authorities that provided feedback, all selected setting the same target
level.180
Although setting a collective EU target could help incentivise action across the EU to reach
a common target whilst taking account of Member States’ different national situations, it
carries significant risks. Unlike the targets established in the context of the climate effort-
179
One of the challenges with measurement and reporting of food waste is the between waste arising from
households and that generated by the food services and retail sectors – as waste from these sources are often
collected together as municipal waste.
180
See Annex 2, section Inception impact assessment and call for evidence for an impact assessment
EN 63 E
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sharing mechanism181
, the lack of a robust data series on food waste levels (in fact, so far
Member States have only reported once according to a common methodology) would not
allow an evidence-based differentiation of targets by Member States. Finally, the process
of agreeing contributions to a shared, collective target is rather long, which would
challenge the possibility of achieving any agreed target by 2030.
While such an approach can possibly be implemented in the future on the basis of time
series data, it was considered unfeasible for this exercise. However, expressing the
reduction target as a percentage already addresses, to some extent, differences between
Member States. Further analysis therefore focused on assessing impacts from setting the
same target levels for all Member States. Moreover, this approach is also consistent with
commitments made by all Member States individually to achieve SDG Target 12.3 in 2015.
In order to take into account the different status as regards Member States’ implementation
of food waste prevention, a derogation from the 2020 baseline year (i.e. an earlier baseline)
could however be envisaged for those which can provide evidence of action taken prior to
that date, with monitoring confirming the progress made.182
Due to lack of clear national
monitoring and limited published data available, any earlier progress achieved by Member
States (see Annex 7) could not be considered as part of the baseline for this IA.
Moreover, intermediate targets are not proposed given the short timeframe between the
expected adoption of the Directive and 2030; progress of Member States will be monitored
through the Early warning report183
(Article 11b, WFD).
The detailed analysis that led to this approach is presented in Annex 10.
Voluntary vs legally binding targets
As the Inception IA focussed on the Commission’s commitment to propose legally binding
targets, voluntary targets were not part of stakeholders’ consultations.
Voluntary targets might be more easily accepted by Member States as they are more
flexible, while helping to some extent to raise awareness regarding the need to take action.
They are therefore likely to fulfil the first specific objective of the initiative, that is, to
assign clear responsibility for reduction of food waste to Member States. However, their
disadvantage is that they cannot be enforced and therefore their effects are weaker and less
predictable.
This impact assessment considers both scenarios of setting legally binding and voluntary
targets.
Selecting policy options for setting food waste reduction targets
181
https://climate.ec.europa.eu/eu-action/effort-sharing-member-states-emission-targets/effort-sharing-
2021-2030-targets-and-flexibilities_en
182
The derogation requested by Member States could be granted in accordance with a procedure similar to
Art 10.3 of WFD. The Member State in question will need to notify the Commission and other Member
States and provide required data.
183
At least three years before the target’s deadline, the Commission and EEA draw up, for each Member
State, a report on progress towards the targets. For Member States at risk of not attaining the targets, it should
include appropriate recommendations and examples of relevant best practices.
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The levels selected for the mandatory targets for this IA cover the full spectrum of targets
outlined in the IIA (15-50% reduction) with the voluntary target based on SDG Target
12.3. The rationale for proposing these levels is explained in Annex 10.
Option 1 is based on the minimum targets examined in 2014.
 Target for primary production – not applicable,
 Target for processing and manufacturing – 10%,
 Target for retail and consumption stages – 15%
Option 2 is a more ambitious variant with the maximum target examined in 2014 for retail
and consumption.
 Target for primary production – not applicable,
 Target for processing and manufacturing – 10%,
 Target for retail and consumption stages – 30%
Option 3 reflects the targets set referred to in SDG Target 12.3 and additional commitment
made by the “Food is never waste” Coalition184
.
 Target for primary production – 10%,
 Target for processing and manufacturing – 25%,
 Target for retail and consumption stages – 50%
Option 4 reflects setting a voluntary target at the level of the SDG 12.3 commitment
regarding the retail and consumption stages (i.e., 50% reduction) with no numerical
commitment assumed for earlier stages. This option would not be subject to enforcement
mechanisms other than annual reporting of food waste levels.
The targets are expressed as a percentage change between 2020 (baseline) and 2030. For
processing and manufacturing, these refer to the reduction in absolute amounts of food
waste, whilst for retail and consumption, targets should refer to a percentage change in
food waste levels per capita, to take into account population changes.
3.5.5. Discarded measures
During the stakeholders’ consultations (IIA and public consultations185
, EU Platform on
Food Losses and Food Waste), stakeholders suggested that additional measures on food
waste prevention be considered. These were however discarded on the grounds that they
were not proportional nor coherent with other EU legislation. A more detailed overview of
the discarded measures (e.g., extending the scope of the WFD to cover on-farm food losses
or relaxing feed safety rules) is provided in Annex 10.
184
The ‘Food is Never Waste’ Coalition was launched by a group of partners at the UN Food Systems
Summit, in 2021, to accelerate reduction of food loss and waste, toward achieving SDG 12.3. The Coalition
seeks to halve food waste by 2030 and reduce food losses by at least 25%.
185
In particular through position papers.
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3.6. What are the impacts of policy options
3.6.1. Approach to analysis of the impacts186
As explained in sections 3.2.1 and 3.2.2, the reduction of food waste cannot be achieved
by a few individual measures but rather results from the coordination of many actions
carried out by multiple players. In the light of this complexity, and given lack of data on
the environmental, economic and social impacts of specific food waste prevention
measures, economic modelling was used to compare the options, that is, the Modular
Applied GeNeral Equilibrium Tool (MAGNET)187
. This global economy-wide
equilibrium model belongs to the European Commission’s Modelling Inventory
(MIDAS188
). As it depicts the interlinkages and rebound effects of all sectors, it is suitable
for economy-wide simulation of the impacts of policy scenarios and has already been used
for several food loss and waste-related assessments in high-level reports (EC189
; FAO190
;
IFAD191
) and supports the EU’s Common Agricultural Policy, trade and other policy
assessments.
The MAGNET model simulates the impact of achieving the food waste reduction targets
in Member States but does not provide an analysis of concrete instruments by which
Member States can implement waste reduction policies. In the model, for each policy
option, it is assumed that target levels have been reached and food waste is reduced by a
certain amount (Option 1, 2 or 3). Subsequently, the reduction of food waste, for instance
at the consumer level, is expected to have the following market effects: first, consumers
throw away less food, so they can buy less. As a result, overall food demand falls;
consequently, market prices decline and, in return, provide incentives (households savings)
which can be spent on different food or non-food goods and services.
The equilibrium model describes the situation after the targets are achieved (i.e., a new
equilibrium is reached). If the given target is not met, the expected impacts (both positive
and negative) should be proportionally reduced.
To reduce that uncertainty, the selection of food waste reduction levels to be achieved, has
been done based on previous experiences from countries as well as political commitments.
The uncertainty is therefore highest in areas of little or no previous experiences – in
particular in the area of primary production. However, as this sector has very small impact
compared to other sectors, the impact from this uncertainty on the results of the analysis is
186
This assessment is based on: De Jong B, Boysen-Urban K, De Laurentiis V, Philippidis G, Bartelings H,
Mancini L, Biganzoli F, Sanyé Mengual E, Sala S, Lasarte-López J, Rokicki B, M’barek R. Assessing the
economic, social and environmental impacts of food waste reduction targets. A model-based analysis.
Publications Office of the European Union, Luxembourg, 2023, doi:10.2760/77251, JRC133971.
187
Woltjer, G.B., Kuiper, M., 2014. The Magnet Model: Module Description. LEI Wageningen UR, The
Hague, The Netherlands. https://edepot.wur.nl/310764.
188
https://web.jrc.ec.europa.eu/policy-model-inventory/explore/models/model-magnet
189
European Commission, Directorate-General for Agriculture and Rural Development, EU agricultural
outlook for markets and income 2018-2030; European Commission, Joint Research Centre, Boysen-Urban,
K., M’barek, R., Philippidis, G., et al., Exploring changing food attitudes to respect planetary boundaries:
a global, model-based analysis, Publications Office of the European Union, 2022,
https://data.europa.eu/doi/10.2760/744504
190
FAO, The State of Food and Agriculture 2019. Moving forward on food loss and waste reduction, Rome,
2019
191
IFAD, Transforming food systems for rural prosperity. Rural Development Report 2021.
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considered to be insignificant. For more information on how the results of the MAGNET
modelling should be interpreted in the light of feasibility, see section 3.7.
For Option 4, due to the voluntary nature of the target, no specific food waste reduction
level could be assumed with certainty, and requires making assumptions about the level of
uptake by Member States. It is expected that, on average, reduction level achieved will be
higher than in the baseline scenario, but lower than in option 1 with mandatory food waste
targets. This assumption is based on the fact that actions taken by Member States following
their political commitments, since 2015, to the voluntary SDG Target 12.3, have not
allowed the EU to make significant progress towards the global target of halving food
waste by 2030. There is no reason to believe that including an obligation for Member States
to set voluntary targets, in the WFD, would lead to significant improvement in this
regard192
.
As regards Option 4, it is not possible to assign specific reduction level (but only a range
of reduction), therefore the MAGNET model was not run for this option. As the impacts
for Option 4 are expected to be in the range between the baseline and Option 1, Option 4
will be described by reference to impacts from these options.
Limitations of economic simulation models result from these being a conceptual
framework representing the economy in a structured but schematic and simplified manner.
By definition, they cannot reproduce reality in its full complexity and thus have
shortcomings and limitations in their use, with underlying data and parameter choices
affecting the uncertainties. In particular, food waste data published by Eurostat, while of
good quality, so far are limited to 2020. This results in some uncertainty due to the lack of
time series data, which would help assess the evolution of food waste amounts in Member
States.
The empirical evidence as regards the response of food chain actors to food waste reduction
is too limited to be implemented in the models (such as consumer decisions on whether to
spend savings from avoided food waste on food or non-food products and services which
have important impact, e.g., on farm income or jobs in the agri-food sector).
Regarding economic parameters, this impact assessment includes the same choices as
those made in other policy assessment studies (previously cited) to ensure consistency. As
part of the quality checks, elasticities in waste generation were subject to sensitivity
analysis (see Annex 4, section 2.1 for details). Finally, since all options are compared to
the same baseline, most of the baseline-related uncertainties are reduced in their impact
and multiple result checks proved a plausible model outcome.
In addition to results of the MAGNET model, environmental benefits linked to food waste
reduction have been assessed with tools developed for the Consumption Footprint
indicator193
, also referred as “bottom-up” analysis, which provides support to EU policy
192
It is assumed that some progress beyond the baseline will be achieved in particular in 12 countries with
established strategies and in some of the 11 countries which have started to develop actions – see section
3.2.2.4 for analysis of the situation in Member States.
193
Sala, S., De Laurentiis, V., and Sanye Mengual, E., EU Food consumption and waste: environmental
impacts from a supply chain perspective, European Commission, 2023, JRC129245.
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development in monitoring194
and impact assessments,195
enabling a highly granular
analysis of the environmental impacts of consumption. The approach relies on the
application of Life Cycle Assessment (LCA) method, which allows assessing the
environmental impacts of food and food waste by modelling individual food products in
their entire life cycle (from agriculture production to food waste management). The
resulting environmental impacts that are avoided in the three policy options can be
translated in monetary terms by applying conversion factors compiled by Amadei et al.,
(2021)196
. See Annex 4 for details on models used.
3.6.2. Overview of impacts considered
Food waste reduction is expected to have a series of significant positive environmental
impacts. The environmental benefits linked to production, consumption and waste
treatment of food, which were considered as most significant are: greenhouse gas
emissions, land use, water use and marine eutrophication. Other environmental benefits
assessed with the Consumption Footprint indicator (e.g., ozone depletion, acidification)
are considered less relevant in the context of food systems and therefore not part of this
IA. Nevertheless, they are expected to show the same pattern – environmental benefits
increase proportionally with the reduction of food waste.
In terms of economic impacts, the reduction of food waste and resulting decrease in
demand of food in the EU affects the entire agri-food system and economy as a whole. In
addition to the overall macroeconomic impact, the analysis presents a few indicators for
the areas, where the distributional effects of food waste reduction are most visible. These
are change in the value of agri-food production; change in market prices; trade balance;
and farm income. The analysis also includes the presentation of estimated adjustment costs
per stage of the food supply chain and per Member State. A detailed overview of economic
impacts is presented in Annex 11.
The social dimension considered for this analysis relates to the impact of food waste
reduction on prices and therefore on food affordability and potential savings for
households. As the agri-food production and consumption system will be affected as a
whole, the impact on jobs in the agri-food sector is also assessed.
Where impacts could not be quantified (e.g., in part of territorial impacts and the
contribution to the ‘digital by default principle’), a qualitative analysis has been
performed.
3.6.3. Impact on food waste: amount of food waste prevented
Option 1 leads to an estimated reduction of food waste of around 7 000 ktons, Option 2 of
around 13 000 ktons and Option 3 of around 23 500 ktons. The deciding factor for these
different estimated outcomes is the food waste target set at the consumption level. An
194
The Consumption Footprint is a headline indicator of the new monitoring framework of the Circular
Economy and of the monitoring framework for the 8th Environment Action Programme. Consumption
Footprint – Food is being proposed for the monitoring framework of the Farm to Fork Strategy.
195
The Consumption Footprint has been used in the IA of the 2030 climate targets or the IA of the Ecodesign
for Sustainable Products.
196
Amadei, A.M., De Laurentiis, V. and Sala, S., 2021. A review of monetary valuation in life cycle
assessment: State of the art and future needs. Journal of Cleaner Production, 329, p.129668.
EN 68 E
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increased reduction of food waste in the upstream stages (i.e., ‘primary production’ and
‘processing and manufacturing’), under all 3 options, has more limited impacts. This is due
to the smaller share of total food waste attributed to upstream stages of the food supply
chain.
Figure 8 – Food waste quantities in the baselines 2020 and 2030, and in scenarios 2030
Source: MAGNET simulation results (2020 baseline based on ESTAT 2022)
Details on reduction of food waste per stage of the food supply chain as well as reduction
per food commodity group are presented in Annex 11. All quantified impacts directly
depend on the amount of food waste prevented. As mentioned earlier, reduction of food
waste from Option 4 would be between Baseline 2030 and Option 1 (i.e., less than 7 mln
tonnes).
3.6.4. Environmental impacts
Estimations with the MAGNET model take into account rebound effects of reduced
household food expenditures that could result in rising non-food expenditures, which could
lead to increases in emissions from other economic activities. As Table 4 shows, while
there is a reduction in total GHG emissions in the agrifood, landfill and other waste
treatments in the EU, in the rest of the economy there is a slight increase in GHG emissions
(+0.3% in Option 3). Still, Option 2 and Option 3 lead to reductions in emissions as a
whole. In addition, reduction in emissions in non-EU countries are observed due to a
decreasing trend in their exports to the EU (linked to reduced demand for food). The
modelling does not take into account other policy constraints, such as the national
greenhouse gas emissions reduction targets established in the EU. In reality the rebound
effect may actually translate in the need to take less measures in other sectors to achieve
the agreed GHG reduction targets, reducing overall mitigation costs in the economy with
the same environmental effect.
Table 4 – Savings of GHG emission, MAGNET model results, scenarios vs the baseline
Emission reductions per sector
of economy,
changes vs. baseline
Option 1 Option 2 Option 3 Option 4
Absolute change, million tCO2eq (% change)
EU Agri-Food -3.5 (-0.6%) -6.9 (-1.3%) -11.3 (-2.1%) -3.5 - 0
Landfill -1.1 (-2.3%) -2.5 (-5.0%) -4.5 (-9.1%) -1.1 – 0
Other waste
treatment
-0.3 (-2.6%) -0.5 (-5.0%) -0.9 (-8.6%)
-0.3 – 0
-
10.000
20.000
30.000
40.000
50.000
60.000
Baseline_2020 Baseline_2030 Option 1_2030 Option 2_2030 Option 3_2030
-13 118 kton
-23 541 kton
-6 948 kton
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Rest of the
economy
2.9 (0.1%) 6.0 (0.2%) 10.2 (0.3%)
0 – 2.9
TOTAL -2.0 (0.0%) -3.9 (-0.1%) -6.5 (-0.2%) -2 – 0
Non-EU TOTAL
-6.2 (-
0.01%)
-12.6 (-
0.03%)
-21.3 (-0.05%)
-6.2 - 0
Source: MAGNET simulation results
Avoided emissions calculated with the bottom-up analysis are significantly higher in
quantity, but the pattern remains the same. Both methodologies show that savings in
amounts of food waste, at any stage of the food supply chain, have a direct positive impact
on reduction of GHG emissions, both within the EU and globally. According to the bottom-
up analysis, which considers emissions embedded in food during its full life cycle (e.g.,
emissions from production of fertilisers, transport of food or electricity for freezers, waste
treatment at end of life), the consumption phase has a major role in the overall avoided
emissions as, in a life cycle perspective, products wasted at consumption accumulate all
the impacts created in the previous steps of the supply chain. Food waste generated at this
stage contributes to 65% of the GHG emissions associated with food waste generation in
the 2030 baseline, while the primary production stage accounts for 2%. For this very
reason, a target for primary production has only a small impact on avoided emissions
overall.
Other environmental impacts considered for this IA – land use, marine eutrophication
and water use – show a similar pattern for the impacts. An overview of the results obtained
with the bottom-up analysis is provided in Table 5 and a comparative analysis with
MAGNET in Annex 11.
Table 5 – Environmental savings linked to food waste reduction according to the bottom-
up analysis (the values in brackets are the % savings compared to the impact of food waste
in the baseline)
Environmental impact category Option 1 Option 2 Option 3 Option 4
GHG emissions [Million tCO2eq] -33 (-14%) -62 (-25%) -108 (-44%) -33 - 0
Land use [Trillion Pt]197
-1.2 (-14%) -2.2 (-26%) -3.8 (-44%) -1.2 - 0
Marine eutrophication [Million kg
N eq.]
-283 (-14%) -532 (-26%) -922 (-45%)
- 283 - 0
Water scarcity [Bn m3 water eq.] -43 (-13%) -80 (-24%) -141 (-42%) -43 - 0
Summary of environmental impacts: All options deliver significant environmental
benefits. The magnitude of benefits increases with the scope and level of targets, from
Option 1 to Option 3. The benefits would be lowest for Option 4.
3.6.5. Economic impacts
Reducing food waste leads to a reduction in the overall demand for food198 compared to
the baseline in 2030 for all options (option1: -2.1%; option 2: -4.2%; option 3: -7%) and,
in consequence, to increased availability of agricultural commodities in the short to
medium term.
197
Dimensionless (point) unit representing soil quality index (LANCA model) - taking into account erosion
resistance, physicochemical filtration, groundwater regeneration, mechanical filtration and biotic production.
198
The MAGNET model already includes increased purchases due to improved affordability of food.
EN 70 E
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Reduction in consumer demand increases from Option 1 to Option 3 as more food waste
is avoided and food remains available for human consumption or for other uses. This
reduction in demand does not fully translate into a reduction of production and is instead
likely to be partly counterbalanced through a decrease in imports of certain products and a
slight increase in exports, which results in an improved agrifood trade balance. The
reduction in consumer demand is highest for vegetables, cereals and fruits as these are the
commodities with the highest waste shares. Detailed impacts on the consumer demand for
selected commodities, including per individual country, are available in Annex 11.
The economy in the EU27 as a whole is in all three options only marginally affected.
Calculating a standard measure for macroeconomic impacts, i.e., the value added at basic
prices (output minus intermediate consumption), hereafter called “income”, the EU27
shows a slight increase of net income of more than EUR 2 bn (0.022%) in option 3. Also,
for options 1 (EUR 0.8 bn, 0.008%) and 2 (EUR 1.6 bn, 0.016%), the overall economic
impact is positive.
Dividing the effects into representative sectors of the economy, the options show
incremental income reductions in the food chain, which in absolute terms are
overcompensated by gains in non-food sectors. While the effects in primary agricultural
production and secondary food processing are following established supply-demand
patterns, the impacts in the tertiary food sector (food service) are considered at the higher
end (i.e., most conservative/pessimistic), as the exact behaviour of actors could not (yet)
be empirically proven. The model depicts that most of the positive income change comes
from tertiary non-food – i.e., non-food services. The net income changes on Member States
level depict some heterogeneity, with most countries showing no or small positive changes.
Generally, the absolute income change is higher for large countries with strong economy
(see Annex 11, section 2.3.5. GDP and income).
Figure 9 – Income changes in the EU27, Options compared to baseline (2030) for different
actors
Note: Rest of the economy includes a broad number of sectors with either positive or negative income changes. Again,
Option 4 would be placed between 0 and Option 1.
Source: MAGNET simulation results
EN 71 E
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Production of agricultural sector and market prices of food
As a result of reduced demand for food, production and prices are expected to decrease
and achieve a new market equilibrium at which less agricultural commodities are sold, at
lower market prices (with a reduction respectively between 0.03% up to 1.35% under
Option 1, between 0.10% to 2.59% under Option 2, between 0.16% and 4.02% under
Option 3) on the domestic market. See Annex 11, sections 2.3.2. and 2.3.3. for more details.
Trade impacts
Reduced demand for food means that consumers purchase less of domestically produced
as well as imported food commodities. For some products which become more competitive
because of lower prices on the world market, exports from EU to non-EU countries may
therefore slightly increase.
The generally decreasing trend in extra-EU imports and increasing trend in extra-EU
exports leads to an improvement of EU’s agrifood trade balance across all scenarios versus
the baseline in 2030. The maximum expected increase is observed in Option 3, which
amounts nearly to EUR 7 900 million. The highest increases in the agri-food trade balance
are seen in the fruits sector (Option 1: EUR 340 m; Option 2: more than EUR 600 m;
Option 3: EUR 1 bn) and the vegetable sector (Option 1: EUR 200; Option 2: EUR 390;
Option 3: over EUR 600 m).
The model shows the maximum change, based on the assumption that non-EU countries
will not reduce their food waste generation. If they do reduce food waste – in line with the
SDG Target 12.3 – the EU’s advantage will decrease proportionally to their progress.199
Due to lack of solid data from non-EU countries, it is not possible to quantify the potential
change in the trade balance.
Farm income
Farm income is expected to decrease due to lower food demand and lower prices as
explained above. Income losses in the crop sector are higher than in the livestock sector
(reflecting the higher share of fruit, vegetables and cereals in total food waste200
). Option
1 leads to a decrease of around EUR 2.2 bn in farmers’ income from crops (EUR 1.4 bn)
and livestock farming (EUR 0.8 bn), whereas in Option 2 this decrease reaches EUR 4.2
bn and in Option 3 – EUR 7 bn. This corresponds to a decrease of a total of 3.5% for
primary agriculture in Option 3. The income in the total agri-food sector (including food
processing but not food services) could experience, in the EU, a similar decrease of about
3.6% in Option 3. The model does not take into account possible developments in
production systems and consumption habits201
, such as increased consumption of fruit and
vegetables, linked to the transition to sustainable food systems, and which could trigger
needs for new products and/or services (e.g., shift to organic farming or increased demand
for local products and shorter supply chains). Moreover, these possible negative impacts
199
On condition that other variables (e.g., population size) will not change.
200
Promoting the shift to healthier and sustainable diets, as called for by the Farm to Fork Strategy could,
however, increase demand for fruit and vegetables.
201
FAO’s SOFA report (2019) indicates that whilst reducing food waste at retail and consumption may lead
to reduced farm income, lower prices may also encourage consumers to trade-up their food purchases to
more expensive, higher quality food.
EN 72 E
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may be further mitigated by an increased demand for food globally, linked to the expected
growth of the world population and evolving food consumption habits202
. For this reason,
the numbers above should be treated rather as a worst-case scenario.
Costs of implementation – distribution per stage of food supply chain
The reduction of food waste requires both producers and consumers to modify their
behaviour. This may entail costs (e.g., additional time required for planning purchases, loss
of convenience etc.), not all of which relate directly to financial impacts and cannot easily
be quantified. The survey203
and literature review show a non-conclusive picture for
financial costs with values ranging from 8 up to more than 6000 EUR per tonne of avoided
food waste204
.
For this assessment, the financial and non-financial costs associated with the
implementation of food waste reduction actions along the stages of the food supply chain
up to end users are estimated by imposing adjustment costs (simulated for the purpose of
the model by inserting taxes) on those agents that generate food waste from the farmgate
to the end user (for details see Annex 4, section 2.1.3). As shown in the table below, such
costs increase more than proportionally when moving towards more ambitious options as
food waste prevention actions usually first target the areas where savings are easiest to
achieve.
It should be noted that the adjustment costs (for all groups in the food supply chain)
assessed here are not determined as a function of the impact of food waste reduction on
the income of farmers or the food sector, trade or other elements. They are calculated
independently and then used as a variable for quantifying the economic impacts associated
with reaching the assumed food waste reduction levels. The total adjustment costs for food
waste reduction are calculated in the following way: in the model it is determined, for each
group of actors in the supply chain (i.e., primary producers, food processors, retailers,
households), the costs of achieving a specific food waste reduction target, i.e., linked to
the change of behaviour of the supply chain actors. These adjustment costs are estimated
to be around EUR 0.9 bn for Option 1, EUR 2 bn for Option 2, and EUR 3.8 bn for Option
3 and are much smaller than the economic impacts on the food supply chain caused by
market (including trade) and income effects due to the reduced food demand.
Adjustment costs for food waste reduction along the stages of the food supply chain to the
end users are shown in the table below, while further information and graphs are in Annex
11, section 2.3.6. Since the largest portion of food waste is generated at the consumption
stage, the costs associated with food waste reduction at this stage are the highest (exceeding
EUR 3 bn in Option 3). Costs for the industry are estimated to be lower.
202
SWD(2023) 4 final Drivers of food security (section 8.24. Food choices and 8.25. Demographic trends)
203
Targeted consultations on food waste prevention initiatives aimed at collecting quantitative data on costs
of the waste prevention initiatives and amounts of food waste prevented. See Annex 2 for more details.
204
It is worth to compare these costs with the value of avoided food waste at consumption level, which is
on average 2860 EUR/t (source: JRC food waste prevention calculator -
https://eplca.jrc.ec.europa.eu/permalink/valeria/prevention_action_calculator.xlsm )
EN 73 E
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Table 6 – Adjustment costs per sector of the food supply chain
EU27 - total costs, EUR millions
PRIM PROC RETAIL HH TOTAL
Option 1 1 166 108 670 945
Option 2 2 157 183 1,651 1,993
Option 3 46 286 306 3,147 3,786
Option 4 0-1 0-166 0-108 0-670 0-945
Source: MAGNET simulation results
Regarding adjustment costs of food waste reduction per ton of food waste reduced, the
highest costs occur for households – reaching up to EUR 160 per ton (Option 3) on average
of food and agricultural products (see Table 7 below). However, costs for the retail and
distribution sector are also estimated to be over EUR 100 per ton (Option 3) if food waste
reduction targets are high (50% for Option 3).
The distribution of costs between the Member States shows that for countries smaller in
size and/or with relatively lower food waste quantities than the EU average in the baseline
the total costs are negligible with higher costs for bigger/richer countries (see Annex 11,
section 2.3.6).
Table 7 – Main economic impacts
Impacts Option 1 Option 2 Option 3 Option 4
Change in overall
income in economy
[EUR]
0.8 bn 1.6 bn 2.3 bn 0 to 0.8 bn
Change in demand
for food
-2.1% -4.2% -7% -2.1% to 0
Change in the value
of agri-food
production
-0.9% -1.8% -3.0% -0.9% to 0
Change in market
prices of food
-0.0% to -1.4% -0.1% to -2.6% -0.2% to -4.0% -0.0% to -1.4%
Trade Balance (TB)
per sector205
[EUR]
AGRI TB:
1.4 bn
FOOD TB:
1.1 bn
AGRI TB:
2.7 bn
FOOD TB:
2.2 bn
AGRI TB:
4.3bn
FOOD TB:
3.6 bn
AGRI TB:
0 to 1.4 bn
FOOD TB:
0 to 1.1 bn
Farm income [EUR] -2.2 bn -4.2 bn -7 bn -2.2bm to 0
Estimated
adjustment costs per
stage of the food
supply chain per ton
PROC:14
RETAIL: 25
HH: 20
PROC: 13
RETAIL: 51
HH: 59
PRIM: 6
PROC: 29
RETAIL: 123
HH: 158
PROC: 0-14
RETAIL: 0-25
HH: 0-20
205
AGRI includes all primary agricultural commodities (crops and livestock), FOOD includes all processed
food commodities, including food services.
EN 74 E
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of food waste
reduction206
[EUR/to
n]
Aggregated
adjustment costs per
ton of food waste
reduction [EUR/ton]
17 41 102 0-17
Total adjustment
costs for food waste
reduction for actors
in the food chain
[EUR]
0.9 bn 2.0 bn 3.8 bn 0 to 0.9 bn
Source: MAGNET simulation results
Summary of economic impacts:
Food waste reduction by 2030 will have impacts on the economy of the whole food system.
The magnitude of such changes increases from Option 1 to Option 3. However, the
MAGNET model shows that negative economic impacts on the food production sector are
compensated by positive effects in other economic sectors. Even for the most ambitious
reduction targets for food waste (Option 3), the associated negative economic impacts for
the most affected actors (i.e., primary producers and processing and manufacturing) are
not significant (not more than 3.6%207
) and impacts on the economy as a whole are
marginally positive. Reaching the targets set in Option 1 comes at a comparably low cost
per ton, while costs tend to increase more than proportionally when moving to medium
(Option 2) and high (Option 3) targets. It may be expected that cost of reduction of food
waste (per tonne of food waste avoided) would be the lowest for Option 4.
3.6.6. Social impacts
Food affordability
The average share of food expenditure (agri-food and food services) in total household
expenditure in the EU for 2020 was around 19%, which, in the baseline scenario, is
projected to decrease by 1.5 percentage points in 2030208
. However, this share differs
across Member States.
In all policy options examined, the share of food expenditure is expected to fall further,
mostly because of decreased demand for food and food price reductions. The model shows
that consumer prices may also change; however, these are small (generally around 1%)209
and of a mixed pattern for different countries and different types of food (see Annex 11).
Due to an expected decrease in food prices, and the reduced amount of food (and food
services) purchased, households could save, on average, from EUR 220 to over EUR 720
per year (depending on target levels) and spend these amounts on better food or other goods
206
PRIM – primary production. PROC – processing and manufacturing. HH - households (including out-of-
home consumption (food services)).
207
With most pessimistic assumption that all savings on avoided food waste will be spent for non-food
products and services.
208
EU agricultural outlook for markets, income and environment 2022-2032, p. 43. See note 115, page 37.
209
The price effect on the consumer side compared to the farm gate is normally reduced because of the
varying and smaller share of farm income, in the final product price.
EN 75 E
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and services. Such savings are particularly relevant in the current context of rising food
prices. See Annex 11 for presentation of country-specific data.
Figure 10 – Food expenditure shares and percentage change deviations in food
expenditure share scenarios vs baseline 2030
For Option 4 share would be between 17.4 and 17.7%, while change would be below 2% - i.e., between Baseline
2030 and Option 1.
Source: MAGNET simulation results
Jobs in the agri-food sector
According to the simulations carried out with the MAGNET model, all options generally
seem to lead to a decrease in employment in the agri-food sector, compensated by
increased employment in non-food sectors. However, the results as regards the reduction
of jobs need to be interpreted with caution due to methodological limitations as well as
scarcity of relevant data. For instance, as mentioned in the section on farm income, the
model does not take into account the possible need for new products and/or services (e.g.,
shift to organic farming which is more labour intensive). For this reason, also here, the
numbers below should be considered as a worst-case scenario. Moreover, Member States
which have already made progress in reducing food waste have not reported any decrease
in jobs in the food supply chain as a consequence of food waste reduction.
Keeping in mind the abovementioned limitations, the model finds that the decrease in
employment in the agri-food sector depends on the level of the food waste reduction target
and amounts to 70, 135 and 220 thousand jobs, respectively, for Options 1, 2 or 3 compared
to the baseline scenario. In percentage change, this means a reduction for the primary
production and food processing/manufacturing sectors of 0.7, 1.3, 2.1% jobs, respectively.
However, job reduction in primary production and processing/manufacturing sectors, as a
consequence of food waste prevention, is expected to be compensated by job increases
related to new service requirements and/or food valorisation in the agri-food sector210
as
well as opportunities in non-agri-food sectors due to increased demand. For instance, based
210
Other elements of the Farm to Fork Strategy – such as seeking to convert a greater share of land used for
food production to organic, which tends to be more labour-intensive than conventional farming – will create
additional jobs. Hence reducing food waste could also be seen as an opportunity to free up qualified labour
in the agri-food sector to enable implementation of other initiatives linked to sustainable food systems.
EN 76 E
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on data from surveys to stakeholders, the number of new jobs created is estimated for
options 1, 2 and 3, at: 6,700, 12,500 and 22,300 respectively, for roles such as: logistics
operators in food banks, coaching supermarkets’ staff as part of food redistribution
initiatives, collection/transport of products deriving from the valorisation of surplus food
and by-products.
Moreover, the MAGNET model calculation for the food services sector, which estimates
a rather strong reduction, does not differentiate between the impact of food waste reduction
on consumption in- and out-of-home. If food service operators reduce food waste in their
businesses, such action does not reduce consumer demand for the services as such; hence
the possible impact on jobs is expected to be much more limited, if any.
Table 8 – Social impacts
Impacts Baseline Option 1 Option 2 Option 3 Option 4
Change in jobs in agri-food
sectors211
10.6 m - 70 000,
-0.7%
- 135 000,
-1.3%
- 220 000,
-2.1%
-70 000 to 0
-0.7-0%
Average share of food
expenditure (agri-food and food
services) [total household
expenditure]
17.7% 17.4% 17.0% 16.6% 17.4-17.7%
Savings in food expenditure per
household (of four persons)
[EUR per year]
- 221 439 724 0 - 221
Source: MAGNET simulation results
Summary of social impacts:
Quantifiable social impacts are strongly linked to economic impacts and show a similar
pattern. The greater the reduction of food waste, the better the options perform in terms of
food affordability and household savings. On the other hand, the magnitude of negative
impacts on employment in the agri-food sector rise from Option 1 to Option 3, which are,
however, expected to be compensated through new job profiles in the sector and gains in
other economic sectors.
From the responses to the IIA (see Annex 2 – synopsis report), it emerged that the
contribution to food security related to the saving of food that might otherwise be wasted
and its redistribution to those in need is seen as the main social benefits deriving from food
waste prevention initiatives. Moreover, additional benefits related to awareness raising on
the value of food, training provided to employees and volunteers, education and social
cohesion were also reported. There are also negative social impacts such as
“inconvenience” or the so-called ‘labour-leisure’ trade-off (i.e., “lost” leisure time linked
to more attention to food preparation, more trips to the supermarket etc.).
These impacts are not specifically addressed as they are regarded as minor, however these
factors are integrated in the estimation of the costs linked to reduction of food waste at
consumption level.
211
i.e., primary production and processing and manufacturing and not including retail and food services.
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3.6.7. Impact on SMEs
The scope of the initiative in the area of food waste is limited to setting food waste
reduction targets for Member States and will not apply to individual businesses directly.
While Member State authorities will likely engage with all actors in the food supply chain,
the actions observed so far in countries which have undertaken coordinated actions to
reduce food waste focus on larger businesses and on voluntary measures encouraging
engagement in food waste prevention supported by government financing. For more
examples on how Member States implement such policies see Annex 7 and Annex 15
(SME Test). It is to be noted that SMEs can be indirectly impacted as part of the supply
chains of large companies and changes in strategic decisions by big retail chains. In
addition, a change in the business environment due to a reduction in demand for food is
estimated to affect SMEs in the same way as for other businesses, with most impacted
industries being the food manufacturing, waste collection and treatment and food
services.212
Yet, the impact may be proportionally higher on SMEs due to limited
resources, the lower ability to absorb shocks and access to finance. See Annex 11, section
2.5.2 for more details.
3.6.8. Territorial distribution of economic and social impacts
Those regions whose production structure is more orientated towards the sectors most
affected by food waste reduction (agriculture, food manufacturing and waste) will also be
the most exposed to its overall economic and social impact (see Annex 11, section 2.5.3
for more details). A greater differential impact is expected in the less developed regions
(per capita GDP below 75% of the EU average) due to the higher importance of the
agricultural and waste collection sectors in their economic activity structure. However, the
impact is expected to be marginal as even in Option 3, the economic and social impacts do
not exceed 0.5% of both total value added and employment by region.
3.6.9. Impact on fundamental rights
There is no impact on fundamental rights.
3.6.10. ‘Digital by default’ principle and digitalisation
New digital and smart technologies can play a role in food waste prevention, such as in
the areas of diagnosis and planning (e.g., linked to waste measurement) or food sharing
(e.g., use of applications). Any binding target is expected to create incentives for new
digital solutions or increase their use; however, the impact of targets on uptake of digital
technologies cannot be assessed due to little data on the use and contribution of these
technologies on food waste to date.
3.7. Feasibility analysis
The feasibility of reaching the food waste reduction targets set out in the options is
understood as the expected ability of Member States to reach the proposed targets. It was
assessed taking into account two main criteria:
212
Farms are not considered as SMEs in Eurostat’s Structural Business Statistics data, but it can be expected
they will be impacted in similar way.
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 the fraction of food waste which can be avoided (i.e., edible);
 the experiences from countries and the results obtained in the last decade.
Concerning the first criterion, the data reported so far do not provide a solid EU overview
of how much food waste could be avoided. The rough estimation made by JRC suggest
that the maximum theoretically achievable level of reduction would be about 70% for retail
and consumption stages (see Annex 11, section 2.6 Feasibility Analysis). Of course, higher
targets are more difficult to achieve.
Concerning the country experiences, an analysis was conducted on national food waste
strategies and policies on food waste reduction, including their implementation,
monitoring and reporting. Moreover, a search for quantitative data on food waste reduction
reported by Member States and the United Kingdom was performed213
. The data search
used various sources: information shared in the EU Platform on Food Losses and Food
Waste and on the EU Food Loss and Waste Prevention Hub; information gathered by the
survey for Member States launched as part of the stakeholder consultation (see Annex 2);
national websites; reports from other organisations (e.g., Waste and Resources Action
Programme (WRAP), etc.
The results of the analysis show that monitoring and evaluation of food waste prevention
initiatives is not a widespread practice and where it exists, there is a lack of quantitative
indicators (see Annex 11, section 2.6). Moreover, no Member State has reported food
waste reduction achieved in primary production, and it is therefore not possible to assess
the feasibility of reaching food waste reduction targets for this stage of the supply chain.
As regards the governance and enforcement capacity of Member States related to food
waste prevention, the experience of leading countries (discussed in section 3.2.2) does not
identify any specific technical barriers, suggesting that these should be relatively easy to
establish under all options. The WFD already lays down obligations for Member States to
establish national food waste prevention programmes, which Member States can make full
use of in order to achieve the future targets. The progress of Member States depends more
on the level of prioritisation of food waste reduction (including allocation of human and
financial resources) and the breadth of the approach taken at national level.
However, the time remaining to reach the target also plays a role when considering the
feasibility of food waste reduction, with sufficient level of prioritisation being essential in
order to achieve higher target levels. It is important to consider that Member States are at
different stages in their implementation of such initiatives and, therefore, it cannot be
assumed that all could replicate results similar to those achieved by leading countries in
the given timeframe. While levels of food waste differ between EU Member States, the
targets expressing food waste reduction as a percentage means that countries with lower
food waste generation will need to make proportionally less efforts to meet the targets.
In order to make progress in reducing food waste, Member States must adopt an evidence-
based systemic approach including: 1) carrying out a food waste diagnosis (where food
waste occurs, who wastes food, how much and why); 2) identifying actions to address
hotspots aiming to improve supply chain efficiency and support consumer behavioural
change; 3) establishing clear accountability for food waste reduction within government
(e.g., designation of a national competent authority); 4) ensuring an appropriate
213
The UK was considered in the analysis due to the fact that this country is a pioneer in food waste reduction,
implementing evidence-based interventions with regular measurement of progress since 2007.
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governance mechanism, led by an authoritative, credible body, to effectively coordinate a
national action plan or strategy, involving both public and private sectors; 5) monitoring,
reporting and sharing learning on progress made. (Country case studies and further
information on national policy initiatives are presented in section 3.2.2 and Annex 7,
section 2, section on ‘national policies & monitoring’).
Member States may also find opportunities to streamline both their allocation and use of
resources by integrating food waste reduction under other policy strands relevant to
the establishment of sustainable food systems, for example in initiatives related to
bioeconomy (e.g., Denmark), circular economy (e.g., Denmark, France, Greece, Spain,
Sweden) and in particular climate action. For example, Finland has, in 2017, highlighted
the reduction of food waste as a climate policy measure in its report on Medium-term
Climate Chance Policy Plan for 2030, Germany in its 2015 Climate Action plan, France in
its National Low-Carbon Strategy and, outside the EU, Norway has integrated food waste
reduction actions in the public and private sectors as part of their Climate Plan 2021-2030.
Still, although Member States committed, as of 2015, to meeting SDG Target 12.3 – which
calls for reducing food waste at levels in line with Option 3 – actual progress achieved to
date shows that achieving this target level by 2030 would be extremely challenging for the
Member States, even with full prioritisation of food waste reduction and allocation of
related resources.
However, efforts taken by individual countries and organisations, if replicated by others
and when combined with binding food waste reduction targets, are expected to deliver
more significant results. Experience gained by front-runners show the potential – such
as reductions in household food waste reported by the Netherlands (30% reduction over
12 years) and the United Kingdom (17.8% reduction over 11 years). Results and
knowledge gained regarding the efficiency of food waste prevention initiatives, better tools
and continued sharing of best practice through the EU Platform on FLW and the wide
range of existing, ongoing and planned initiatives at EU level (which are detailed in section
3.2.2, 3.5.2, Annex 7 and Annex 10) will support Member States in reaching the targets.
The continued integration of food waste prevention in other EU policy areas (e.g., date
marking or marketing standards) and voluntary industry measures such as the Code of
Conduct on Responsible Food Business and Marketing Practices214
are also expected to
contribute to food waste reduction in the EU and facilitate compliance with the targets.
Based on the performance of leading countries, table 9 assesses the likelihood that EU
Member States as a whole, would be able to implement national policies allowing them to
reach the targets included in the selected options, by 2030.
Table 9 – Overview assessment of the feasibility of different policy options (target levels
to be achieved by 2030)
Primary
production
Processing &
manufacturing
retail and
consumption*
Option 1 Not applicable + +
Option 2 Not applicable 0/+ 0/+
Option 3 ? - -
214
European Commission, Food Safety, EU Code of Conduct on Responsible Food Business and Marketing
Practices, 2021
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Option 4 Not applicable Not applicable ++
* considering only results achieved at household level
++ easily achievable; + achievable ;; – very difficult to achieve; 0 difficult to achieve; ? uncertain;
The table above shows that the second option would already require significant efforts
from Member States while reaching the third option by 2030 would be more challenging,
in particular given the need to more effectively address behavioural drivers in order to
reduce consumer food waste. This analysis also shows that uncertainty exists as to the
feasibility of achieving food waste reduction at primary production level, although the
impacts from this stage of the food supply chain is insignificant (see Section 3.6). As
regards Option 4, since voluntary targets are expected to be easy to achieve, it scores
highest on feasibility.
3.8. How do the options compare?
This section compares the expected impacts of the options in terms of their overall
effectiveness, efficiency, feasibility, coherence, and proportionality.
Table 10 – Comparison of food waste reduction policy options
Criteria Baseline Option
1
Option 2 Option 3 Option 4
Effectiveness
SO1: assign clear responsibility to Member
States for accelerating reduction of food waste
in the EU, in line with EU and global
commitments.
0 + ++ +++ +
SO2: ensure sufficient and consistent response
by all Member States, in line with that of front-
runners.
0 + ++ +++ 0/+
Efficiency + ++ +++ +
Coherence
Internal coherence 0 + + + +
External coherence 0 + ++ +++ +
Technical feasibility (based on feasibility
analysis – section 3.7)
0 + 0 - ++
Proportionality 0 + ++ ++ +
The scores are given on the expected magnitude of impact as explained above: + + + being strongly positive,
+ + positive, + moderately positive, –/+ neutral, – moderately negative, – – negative and – – strongly
negative. For technical feasibility: + means that the assessment is positive, 0 means neutral and – means
that it is negative.
EFFECTIVENESS. In terms of assigning clear responsibility to Member States for
accelerating reduction of food waste in the EU by 2030 (specific objective 1), all options
make a contribution towards achieving EU and global commitments and perform better
than under the baseline. All targets are clearly time bound, built on an existing monitoring
mechanism of the WFD and measured through an established common methodology.
Moreover, the compliance check by the Commission is based on the existing mechanism
of the early warning report in the WFD215
. If targets are not met, they can be enforced by
infringement procedures. For these reasons, all options score positively.
215
WFD – Art. 11b – see also footnote 178, page 58
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The different scores assigned to the different options reflect the extent to which they
allow to reach EU and global commitments. Options 1 and 4, which allow for the lowest
level of food waste reduction, is assigned the lowest score. Given that most of food waste
is generated at the household level, introducing higher targets at the consumption level
(Option 2: 30% and Option 3: 50%), leads to larger decreases in total food waste
generation. For this reason, Option 2 scores higher than Option 1. Option 3 scores the
highest due to the reduction foreseen at consumption level in line with SDG Target 12.3
and as it is the only option that also requires to address food waste at primary production.
In terms of the ensuring sufficient and consistent response by all Member States to
reduce food waste, in line with that of front-runners (specific objective 2) all options
score positively, as it is expected that the targets proposed will lead Member States to take
more effective action than under the baseline. However, due to lower levels of targets,
Option 1 requires less significant prioritisation of food waste prevention at national level
and thus focuses on results that could be achieved with more limited efforts and resources
from national authorities. For instance, it cannot be guaranteed that an evidence-based
approach coordinated at national level and involving all players (see drivers 4, section
3.2.2.) will be taken up as a key principle to achieve results under this option. Similarly,
there is a risk that in a situation with lower levels of targets, business operators would not
be inclined to invest in new processes or use emerging technologies. As Option 4 is
voluntary, by definition, and considering the experience to date in the light of the
longstanding voluntary SDG Target 12.3, this option cannot ensure that Member States
take sufficient and effective action, and therefore it is assigned with the lowest score, just
above the baseline.
Options 2 and 3 require Member States to take an active role and strongly engage in food
waste reduction and therefore score higher than Option 1. In particular, such higher targets
are expected to encourage Member States to carry out clear diagnosis, define actions to
address the hotspots identified, define a clear governance, and engage all players, including
food business operators and consumers. They are also expected to better and more
systematically leverage existing guidelines and best practices and provide the necessary
incentives.
Finally, the stronger responses required under Option 3 fort the consumption level require
very far-reaching measures. As Option 3 seeks to reduce food waste at primary production,
a consistent response will also be required in this area. For these reasons, Option 3 scores
the highest.
EFFICIENCY. The analysis carried out in this IA bases its economic assessment mainly
on a general equilibrium model (MAGNET). The key measure for cost and benefits is the
change of value added/income, which reflects the net impacts on the actors in the whole
economy and its different value chains in a coherent manner. This would result in net
income increases of about EUR 0.8 bn (Option 1), EUR 1.6 bn (Option 2) and EUR 2.3 bn
(Option 3). While the costs of reduction of food waste increase with the ambition level (see
point on adjustment costs in section 3.6.5), these costs are compensated in terms of impact
on the economy as a whole.
It should be noted that most of the environmental and social impacts are not fully
quantifiable in monetary terms and additional quantification for the purpose of efficiency
requires combining outcomes from different methodological approaches. Therefore, the
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environmental benefits are calculated from the bottom-up approach and based on the
assumptions presented in Annex 4, section 2.2.1. Overall, the options could lead to
monetised environmental savings of EUR 5-12 bn (Option 1), EUR 9-23 bn (Option 2) and
EUR 15-40 bn (Option 3). It should be noted that benefits from avoided GHGs emissions
are global, while costs are borne within the EU. As Option 4 is expected to perform in a
range between baseline and option 1, it is expected to deliver some economic and
environmental benefits, but at lower scale than Option 1.
Table 11 – Overview of net benefits in monetary terms (and cost-benefit ratio)
Benefits and cost Option 1 Option 2 Option 3 Option 4
Economic:
Sectors of the economy
Primary agriculture -2.2 bn EUR -4.3 bn EUR -7.0 bn EUR -2.2 - 0
Secondary food (processing and
manufacturing)
-3.1 bn EUR -6.0 bn EUR -10.0 bn EUR -3.1 - 0
Tertiary food (food services) -5.5 bn EUR -11.1 bn EUR -18.4 bn EUR -5.5 - 0
Tertiary non-food (non-food
services)
9.6 bn EUR 18.9 bn EUR 30.6 bn EUR 0 – 9.6 bn
EUR
Rest of the economy 2.0 bn EUR 4.2 bn EUR 7.1 bn EUR 0 – 2 bn
EUR
Total change of value added/income
in economy*
0.8 bn EUR 1.6 bn EUR 2.3 bn EUR 0 - 0.8
bn EUR
Environmental:
Overall environmental savings
monetised
5-12 bn EUR 9-23 bn EUR 15-40 bn EUR 0 - 12 bn
EUR
Social + + + +
Benefits to cost ratio + ++ +++ +
* The economic net benefits include all benefits/gains and costs/losses throughout the
whole economy.
Source: MAGNET model simulation; environmental results: bottom-up approach
Concerning social impacts, while there are negative impacts on jobs in agri-food industries,
which increase from Option 1 to Option 3 (see Table 8), the model results depict them to
be balanced by increases in jobs in the non-food sectors. In addition, all options result in
savings on food spending at household level, with savings also increasing from Option 1
to Option 3. Therefore, the balance of social impacts is regarded as equally positive for all
options, with a higher focus on benefits at household level in the most ambitious options
and a new equilibrium in the job distribution along the food supply chain and the whole
economy.
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In terms of overall efficiency, all options provide a good balance between costs and savings
and benefits for society at large, with Option 3 scoring clearly highest. While all options
have a marginal (but positive) impact on economy they offer significant environmental
benefits in the EU and at global level.
COHERENCE. As all options are about the setting of reduction targets – either legally
binding (Options 1, 2 and 3) or voluntary (Option 4)- without imposing any additional
measures, internal coherence with EU food waste policies is ensured. The coherence
between the policy options on textiles and food waste is also ensured: related measures
address specific problems and do not overlap, and they contribute to the common objective
of increasing the level of protection of the environment and public health.
All options are coherent with other relevant EU policy objectives. Legally binding targets
will lead to GHG emissions reduction, thus contributing to the EU climate neutrality
objective by 2050 and to the objective of at least 55% net reduction in greenhouse gas
emissions by 2030. Achieving the target would also lead to more sustainable use of land,
reduced marine eutrophication and less water scarcity, in line with the upcoming
Framework for Sustainable Food Systems, the Bioeconomy Strategy and nature
protection policies. Finally, reducing food waste contributes to increased resilience of
food systems and contributes to food security by improving supply chain efficiency and
productivity as well as food affordability. By delivering higher environmental gains,
Options 2 and 3 offer higher contributions to these policies.
FEASIBILITY. Technical feasibility was scored based on the extent to which efforts
would be required at national level (see section 3.7.).
PROPORTIONALITY. While none of the options exceeds what is necessary to achieve
the objectives, lower targets are less suitable to contribute to the achievement of SDG
Target 12.3. The options do not set new measures at EU level, as implementation of the
targets will build on the already- required national food waste prevention programmes and
future monitoring will build on the EU-wide methodology established as part of the
monitoring and reporting obligations included in the WFD in 2018. For this reason, the
less ambitious options (including voluntary targets) score worse.
3.9. Preferred option
Option 1 and Option 4, while being easier to achieve and contributing to strengthening
Member States actions, fall short of the EU’s ambition to meet the SDG Target 12.3.
Options 2 and 3 are both considered as strongly engaging Member States in implementing
actions to reduce food waste. Option 2 will be effective in providing a strong policy
impulse for Member States to take action to reduce food waste at national level while being
proportionate and feasible.
This option has therefore been selected to present the joint expected impact of the initiative
in the next section.
The achievement of Option 3 offers the most significant environmental benefits and
therefore scores highest in terms of effectiveness. This option also best reflects the political
commitment of the EU and its MS to contribute to the achievement of the aspirational and
non-binding SDG Target 12.3. However, given the state-of-play showing limited progress
across the EU and therefore doubtful technical feasibility of this option, Member States
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would likely consider such a target as challenging to achieve in the required timeframe,
making it more difficult to impose.
3.9.1. REFIT (simplification and improved efficiency)
This initiative aims to complement that work already undertaken and planned to address
possible barriers to the implementation of the waste hierarchy (see section 3.5.2.(c)).
Targets will provide further impetus for the sharing of learning and best practice and
coordinating action through existing EU-level support mechanisms, which can help
improve the efficiency of food waste reduction actions.
3.9.2. Application of the one in one out approach
In the case of food waste, and as presented in Section 3.6.1, the IA assesses the impacts of
setting-up targets giving the overarching indications of range of costs resulting from the
measures expected to be enacted by Member States to achieve these targets. Therefore, it
does not introduce any new specific measures to be adopted by Member States or direct
obligations on food business operators.
3.9.3. How will actual impacts of the preferred option be monitored and
evaluated?
Monitoring and evaluation of progress towards food waste reduction target will be done
on the basis of existing legal obligation i.e., annual reports from Member States on food
waste amounts and reporting rules of the WFD (art 37.3). The data are reported to and
published by Eurostat (Annex 6 details food waste monitoring). In addition, the
compliance check will be based on the existing mechanism of the early warning report of
the WFD, at the latest three years before the target’s deadline (i.e., by 2027); the
Commission will also take stock of progress made in 2030.
The current monitoring of food waste reduction allows to address the operational
objectives identified in this IA – see Annex 14.
Implementation of the national food waste prevention programmes as part of the national
waste prevention programmes is subject to periodic reviews by the European Environment
Agency (as required by Article 30(2) of the WFD). The Agency publishes every two years
a report containing a review of the progress made in the completion and implementation
of waste prevention programmes, including an assessment of the evolution as regards the
prevention of waste generation for each Member State and for the Union as a whole.
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4. CUMULATIVE IMPACTS
The table below summarises the cumulative impacts expected by the preferred options for both
textiles and food waste.
Table 12 - Cumulative impacts of the preferred options for both textiles and food waste
Preferred
combined
option
Description of impact Net impacts
Option 2 -
Additional
regulatory
requirements
+ target for
textiles
(measure 3.6)
AND
Option 2 for
food waste
reduction
targets
Economic costs
 €913 million per year for sorting obligations
 Register development costs of €2-12.3 million across Member
States and maintenance costs of €11 200 and 69 000 per
Member State per year
 €7.79 million per year for producers to report for the purpose
of EPR
 €4.04 million costs of operating PRO registers and inspections
 €39.2 million euro per year for additional textile collection,
sorting and treatment to meet a 50% collection target
 €208 euro per competent authority and €78 per exporter
annualised per inspection
 €750 000 per year for EU enterprises to comply with EU
reporting obligations
 €26.5 million landfill tax loss for Member States due to
textiles diverted from landfills
 Reduction in demand for food of 4.2% and a change in value
of agri-food production of -1.8% alongside a fall in market
prices of between 0.1 and 2.6%
 A fall in farm income of €4.2 billion per annum
Total adjustment costs for food waste reduction for actors in the food
chain - €2 bln [€41/ton of food waste avoided] Economic benefits
for textile sector
 EPR: €3.5-4.5 billion annual overall returns on recycling
investment (including the benefits indicated for the other
measures)
 Additional sorting: €534 million per year of reuse value and €94
million per year of recycling value
 Additional collection: €28 million per year of combined reuse
and recycling value
Economic benefits for food waste reduction
 overall value added for EU economy €1.6 bn (including
abovementioned costs)
 savings in household food expenditure of €439 per year per
household (4 pers.)
Environmental benefits
 €16 million from GHG emission reduction from textile waste as
well as reduction in release of pollutants to air, water and land
that would otherwise result from poor waste management.
 3.9 (in EU) and 12.6 (out of EU) million tonnes GHG emission
reduction (including rebound effect) OR 62 million tonnes of
GHG avoided (without counting the rebound effect)
Costs:
€975 million (these
costs may fall on
consumers, producers or
a mix of both).
Overall value added for
EU economy form the
reduction of food waste
1.6 bn EUR (0.016%)
Benefits:
Direct benefits of €656
million of reusable and
recyclable textiles for
the EU reuse and
recycling market as well
as support to €3.5-4.5
billion annual overall
returns from EPR
investments.
Savings in household
food expenditure of
€439 per year per
household (4 pers.)
Additional GHG
emission reduction
equal to €16 million per
year from textiles and
additional GHG
emission reduction
equal to 62 million
tonnes per year (overall
environmental savings
monetised - €9-23 bn),
8 740 jobs created in
waste management but
up to 135 000 lost in
agri-food sectors
(expected to be
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 reduction in release of pollutants to air, water and land that
would otherwise result from poor waste management
 Reduced impact on land use of 2.2 Trillion Pt,
 reduction in marine eutrophication of 532 million kg of Neq
 reduction in water scarcity of 80 billion m3 per annum.
 Overall environmental savings monetised - €9-23 bn
Social benefits
 8 740 jobs created in relation to textiles and social impacts of
EU waste in third countries mitigated (no net impact
assessment; see Annex 4 for details and underlying
assumptions)
 Up to 135 000 jobs lost in agri-food sectors (expected to be
compensated in other sectors)
compensated in other
sectors)
Overall effectiveness,
efficiency and
coherence: positive