The letter touched upon crucial elements in the upcoming proposal:
- Definition of sustainability: To ensure policy coherence and consistency with world- staged ambitions, it is of the utmost importance that the FSFS establishes a clear definition of sustainability and that its implementation takes the three elements of sustainability into consideration in a balanced manner, and aligns with international definitions. Any definition, principle and future legislation should be based on clear, robust, and up-to-date scientific evidence and data.
- Scope of the legislation: The definition of the scope of the regulation will have a crucial impact on EU food production, supply, manufacturing, trade, distribution, and consumption. Currently, the scope of this initiative remains extremely vague. To effectively assess its impact and prepare for its implementation, we call on the Commission to reflect together with food chain actors on a precise scope tailored to agri-food chain ground realities and in accordance with existing sectorial legislation. In addition, the FSFS should provide legal certainty, clarity, and a level playing field for the entire food value chain, ensuring harmonisation at EU level and future-proof legislation.
- Policy coherence and an interdisciplinary approach: The new framework would need to ensure coherence with all relevant EU legislation, across areas of impact to our sector and involve the relevant Commission’s Directorate-Generals (DGs) and their expertise (DG GROW, TRADE, CLIMA, JUST). Such an interdisciplinary approach will help ensure a truly long-term change and avoid incoherence or duplication with already existing legislation.
- Elaboration and implementation of the FSFS: The further elaboration process of the FSFS should be based on a multi-stakeholder cooperation, involving agri-food chain actors, and ensure a high level of EU harmonisation to avoid any fragmentation of the Single Market. In addition, more clarity is needed on the management and implementation of this policy within the Commission, once the FSFS is adopted.
- Interlinkage of food security and sustainable food systems: Any sustainable food system should also ensure food security (including food availability, affordability, and accessibility) and nutrition security.
- Trade and international dimension of sustainability: Sustainable food systems would need to consider the interconnectedness of EU and global agri-food chains and, as such, take the international dimension of trade for food and nutrition security and circularity into account.
- Realistic cost review and support for necessary transitions: Further assessment would be necessary to analyse the potential costs of the envisaged measures under the FSFS. The FSFS should act as an enabling regulatory framework, and thus entail the necessary incentives, financial, and technological support to enable food chain actors to contribute to the transition towards more sustainable food systems.
- Recognition of the diversity of the agri-food realities in their contribution to sustainability: The FSFS should allow for all food chain actors to focus on key areas for their sustainability improvement in ways that are suited to their realities, taking into account the diversity of processes and products.