12 July 2019
Primary Food Processors (PFP) welcomed European initiatives aimed at improving sustainability and reducing food waste across the food supply chain while expressing concerns regarding the inclusion of several primary food processing sectors within the European Commission’s proposed methodology for measuring food waste.
The organisation supports the objective of developing a harmonised European framework for food waste reporting but argues that the methodology should accurately reflect the realities of primary food processing operations and the legal definition of food waste.
According to PFP, products can only be considered food waste if they first meet the legal definition of food. Materials that are not edible, are not intended for human consumption or were never designed to become food products should therefore not be classified as food waste.
The association emphasised that primary food processing industries have long operated highly efficient production systems that maximise the use of agricultural raw materials. Through integrated processing models, co products and by products are redirected into animal feed, pharmaceuticals, bio based materials, cosmetics, fuels and numerous industrial applications.
PFP argues that this approach significantly reduces waste generation while supporting circular economy objectives and resource efficiency throughout the value chain.
The organisation called on the European Commission to reconsider the inclusion of cereals, cocoa, sugar and vegetable oil processing sectors within mandatory food waste measurement requirements. According to PFP, such reporting obligations would measure waste streams that do not represent food waste and would create unnecessary administrative burdens without generating meaningful environmental benefits.
PFP also warned against the misclassification of industrial co products and secondary outputs as food waste. Many materials generated during processing are intentionally directed towards feed, bioeconomy and industrial markets and therefore remain valuable resources rather than waste.
The association provided examples from several sectors. Cocoa processing generates products used in food, feed, pharmaceuticals and packaging applications. Sugar processing fully valorises sugar beet components through food, feed and industrial uses. Vegetable oil processors utilise all components of oilseeds, while starch and flour industries direct raw material fractions into multiple food and non food markets.
According to the organisation, introducing reporting obligations where no meaningful food waste exists risks increasing compliance costs while providing limited environmental value. PFP therefore advocates for a more targeted and proportionate approach that reflects the operational realities of primary food processing industries.
The association concluded that food waste policies should support sustainability objectives while recognising the substantial contribution primary food processors already make to resource efficiency, circular economy principles and full raw material utilisation.
PFP members process approximately 220 million tonnes of raw materials and employ more than 120,000 people across the European Union.
