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Improvement Areas in the Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics

Late last year, the U.S. Environmental Protection Agency (EPA), the U.S. Department of Agriculture (USDA), and the U.S. Food and Drug Administration (FDA) released a Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics. The draft strategy identifies policy and coordination steps that the agencies may take to address food loss and waste. The overall aims of the strategy are commendable, and the strategy builds on interagency collaboration started during the Trump Administration and includes some of the commitments made in the Biden Administration’s White House Strategy on Hunger, Nutrition, and Health.

The draft strategy is grounded in a philosophy focused on promoting a circular economy, an economic model encouraging resource efficiency in part by using products that would otherwise be seen as waste to produce different products. The draft strategy appropriately looks to manage food based on the wasted food scale, which prioritizes different pathways to manage food. The wasted food scale’s most preferred pathway is completely preventing food waste. At a step down from complete prevention, the scale encourages donating food for others’ consumption and then using food for animal feed. The least preferred pathway on the scale is throwing out food without recovering any energy from it (i.e., sending food to landfill or incineration).

As an overarching matter, there are a few areas in which the draft strategy should be strengthened. These include extending beyond three agencies, committing to data reporting, and creating a cross-agency research plan among other areas.

The draft strategy should go beyond being a three agency collaboration to become a true whole of government effort, perhaps by building on the existing Federal Interagency Collaboration to Reduce Food Loss and Waste. When extended, the strategy should influence Department of Defense compost procurement and Agency for International Development funding to improve food storage infrastructure in developing countries, among other potential initiatives from a broader set of departments.

Additionally, as data can be used to measure progress and shape future policy efforts the agencies should commit to extensive reporting on progress. This should include updating the Waste Reduction Model, which estimates emissions and energy costs associated with different materials, with new data. It should also include partnering with the creators of new tools such as the Global Farm Loss Tool, meant to measure on-farm loss, to draw on private sector data expertise. As a base level, it should include making data the agencies collect publicly available so new policy innovation can be suggested and efforts can be calibrated as needed.

Creating a cross-agency strategic research plan can go a long way to filling the gap the agencies identified on dedicated funding for food loss and waste research. To start, the agencies should identify the key food loss and waste research gaps. They should then consider existing agency research authorities that might be used to fill the gap, including looking beyond the primary agencies involved to reach authority granted to agencies such as the National Science Foundation. Even within the primary agencies involved there is room for further work, for example, the USDA should use the Agriculture Food and Research Initiative to work to extend the food shelf life to reduce food waste.

The draft strategy lays out four objectives:

1. Prevent food loss (a term used when food is lost in the production process before it is sold to the consumer) where possible.

2. Prevent food waste (a term used when food is wasted in retail settings or by consumers themselves) where possible.

3. Increase the recycling rate for all organic waste.

4. Support policies that incentivize and encourage food loss and waste prevention and organics recycling.

Objective 1: Prevent Food Loss

In this objective, the EPA, the USDA, and the FDA committed to supporting The Emergency Food Assistance Program (TEFAP) Farm to Food Bank Projects, using Local Agriculture Market Program (LAMP) funding to address on-farm food loss, and investing in innovative food packaging and processing technologies.

Building on these steps, the agencies should expand the draft strategy to further prevent food loss in two ways. First, they should collaborate with the Department of Education to educate students about food waste and support schools that implement innovative food waste strategies, such as by recognizing such schools as Green Ribbon Schools. Second, they should fund projects focused on preventing and reducing food waste through the Composting and Food Waste Reduction Cooperative Agreements. These agreements offer federal funding to help local governments undertake compost projects and other plans to reduce food waste.

Objective 2: Prevent Food Waste

As part of this objective, the agencies committed to a national consumer education campaign to increase consumer awareness about food waste. Significantly, the effort includes date label education and looks to use existing distribution channels such as school systems to maximize reach. This is important as ReFED estimates 33% of all food in the United States goes to landfills, is burned, is washed down the drain, or is left unharvested.

To go beyond these awareness steps, the agencies should standardize date label requirements across the USDA and FDA to prevent consumer confusion. Date label confusion causes 7% of consumer waste according to ReFED. It is therefore not surprising voluntarily industry efforts to standardize labels have been introduced by leading private entities and industry associations. Additionally, the agencies should examine if food donation tax deductions should be restructured to align incentives.

Objective 3: Increase the Recycling Rate for All Organic Waste

With this objective, the agencies turn to increasing organic recycling. To do so, the agencies committed to building educational materials to support community composting, expanding end markets for recycled organic waste, and confronting organic waste contamination issues.

To make further progress here, the agencies should build demand by facilitating the formation of an exchange to match compost generators and buyers and increasing supply by giving farmers incentives to compost. The Pandemic Cover Crop Program (PCCP) offers a model for the latter, with a $5 per acre premium under crop insurance for planting cover crops. The agencies should also adopt a similar per acre incentive for compost application.

Objective 4: Support Policies that Incentivize and Encourage Food Loss and Waste Prevention and Organics Recycling

In this objective, the agencies identify two overarching strategic actions they intend to take. They intend to support international actors and state, local and tribal policy makers. In both strategic actions, the agencies display a commendable commitment to collaboration. Collaborative efforts are more likely to produce synchronous approaches that are simpler for regulated entities to comply with consistently. They are therefore more likely to gain broad support and be easily implemented.

To help the agencies reach their goals, they should create a database of successful state and local food waste reduction policies, providing guidance to FDA-regulated entities on donating safe food that is not marketable, and increase state flexibility to permit food donation that does not comply with non-safety food laws and regulations.

The draft strategy is an important development for addressing food waste. Going forward, advocates and industry stakeholders should play close attention to the final strategy released. They should also look for action from both Congress and the agencies. On the Congressional front, advocates should look to see if the upcoming farm bill authorizes elements of the strategy that require legislative approval. On the agency front, advocates should look for regulatory action to implement the strategy.

While federal policy to prevent food waste has been relatively slow and incremental to date, the draft strategy may signal increasing activity in this space.

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