Ambitions to make public sector food more sustainable have been broadly welcomed but there are big gaps in the government’s plan. Nick Hughes reports.
They’ve been a long time coming but the development of new food procurement standards for the public sector suggests the penny has finally dropped within government that it can use its considerable buying power to more sustainable ends.
A key plank of the new policy proposal – announced in the recent food strategy whitepaper and fleshed out in a consultation document – will see a target for 50% of public sector food spend, which totals over £2bn a year, to go on food produced locally or certified to higher environmental production standards.
Caterers will be required for the first time to report on a range of metrics to demonstrate compliance against the new policy, which updates content from the current government buying standards for food (GBSF) and balanced scorecard, streamlining the two documents into one.
The government is also consulting on whether buying standards, which are currently mandatory across all central government departments, their executive agencies and non-departmental public bodies in England, should be a requirement across the wider public sector including in schools, local authorities and residential care settings.
Questions remain unanswered around certain details – notably around enforcement and penalties for non-compliance – however the intent of the new policy has been broadly welcomed by green groups. In a draft consultation response seen by Footprint, the Soil Association says some of the proposed changes represent a high level of ambition, especially in the context of a challenging operating environment.
Sustain’s Ruth Westcott, who co-ordinates the charity’s work on the climate and nature emergency as well as sustainable fishing, agrees: “The proposals are quite ambitious – 50% of spend on more sustainable produce would be a great step.”
Some experts, however, are sanguine about how impactful the new proposals will really be in their current form. Prestige Purchasing chairman David Read points to some “muddled” thinking within the proposals and suggests the document “takes a long time to say two simple things: they are raising standards (but without much real detail), and widening the nature of the tender process away from too much focus on cost.”
So what’s contained within the new procurement proposals and what issues will need addressing if the new regime is to prove a success?
Three-pronged approach
The proposed new policy is split into three sections: fair and transparent procurement guidance principles; the new GBSF; and data reporting requirements. Under the first section, the headline proposal is that tenders should have as a minimum a 10% social value, 40% cost and 50% quality weighting. This is significant given that a report last year by the House of Commons environment, food and rural affairs (EFRA) committee found that under the current regime price is often weighted at 60% or more of the scoring in tenders. The Soil Association says the new weighting is appropriate although it says Defra needs to provide further clarity on how these principles will be enacted and enforced in practice.
Read, however, worries that the approach is naïve, arguing that a keen focus on cost enables buyers to afford better quality products. “Our work in the public sector has proved time and time again that ensuring caterers and suppliers are charging a fair market price creates large amounts of headroom to invest in permanent better standards. Raising standards but reducing the focus on cost is a naïve recipe for even more inflation, and is frankly misguided.”
Local requirement
The meat of the policy is contained in section two which sets out new buying standards. Here, the headline proposal is a minimum requirement that at least 20% of food spend must be on food certified to higher environmental production standards, up from the current 10%, and in total 50% of spend must be on locally produced foods or those certified to higher environmental production standards.
The consultation document currently defines locally produced food as ingredients produced, grown or caught within the same region as it is consumed, or a neighbouring county. Multi-ingredient foods can qualify as locally produced if at least 50% of the quantity of their ingredients are from the local region.
Higher environmental production standards, meanwhile, are defined as production systems demonstrating integrated farm management of natural habitats and biodiversity; soil management and fertility; prevention and control of pollution; energy, water and waste management; and landscape and nature conservation. In practice, the government says this means sourcing LEAF certified produce “or equivalent”, or food from organic production systems.
The Soil Association says the 50% overall target is welcome but is seeking clarity on what equivalent to LEAF means. (There is a similar grey area concerning commodities where sourcing requirements are for products like palm oil, soya and cocoa to be “demonstrably legal and sustainable” through “certification, or equivalent”.)
Read, for his part, suggests the 50% target for local and higher standard food has been deployed in a way that suggests the government believes “they deliver broadly the same outcomes, when they most certainly don’t”.
It’s certainly the case that local doesn’t always equal sustainable. What happens, for example, if your nearest chicken producer has been linked to the ecological demise of local rivers as is reported to be happening in the River Wye? There must be a question too over the practicality of achieving such a high proportion of local sourcing for large multi-site caterers with central buying functions.
“Surely a standards driven approach that raises the bar on local, regional, national and international supply is more desirable?” says Read, who adds that he does understand and support the desire to support local food culture but doesn’t believe the current proposal is the right way to deliver it.
Elsewhere, there is a requirement that all animal source food must be procured from production systems which comply with UK animal welfare standards “or equivalent” (another potential grey area). In addition, all shell and liquid eggs must be sourced from cage-free systems, for example, barn, free-range or organic (there is a specific question over the feasibility of this requirement in the consultation questionnaire).
Seafood with a rating of 4 or 5 (worst choice) in the Marine Conservation Society’s (MCS) good fish guide must not be procured while tuna and prawns – including where used as ingredients in a processed product – must not be procured wherever possible. Some tuna and prawn species are rated as 1 or 2 (best choice) under the MCS’s guide, however Footprint understands that although the government’s intention is not to ban tuna or prawns outright it does want caterers to avoid them in favour of locally caught or farmed options (which prawns and tuna tend not to be). Again, it’s a case of local being used as a proxy for sustainable when this doesn’t always reflect the reality.
Menus the missing link
Looking beyond sourcing, menus will have to vary throughout the year to reflect the natural growing or production period for the UK, such as cauliflower, butternut squash and venison in the winter, and new potatoes, berries and lamb in the summer. Caterers must also make at least one menu cycle change every three months.
Sustain’s Westcott says what is missing from the policy is any specific measure to bring menus into line with the government’s Eatwell guide and therefore reflect a healthy and sustainable diet. “The plans reference net-zero as one of the aims, but offer no proposal for how to do so,” she says. Westcott believes there should be a requirement to include two portions of veg and/or pulses in every meal, plus a portion of fruit if a dessert is offered. She also wants to see more meat-free options being made available with Sustain having previously called for government buying standards to include a requirement for less but better meat and dairy.
Meat reduction, perhaps unsurprisingly given government intransigence on the issue, does not feature at all within the new policy – an omission Read describes as “bizarre in the light of the overarching ambitions set out”.
The Soil Association says that managing cost will be a major challenge, noting how meeting its own Food for Life standard does tend to cost caterers more in relation to pre-existing procurement practices. But it believes the challenge is not insurmountable if, for example, caterers can offset price increases by using less meat as well as through changes such as writing requirements into contract tenders, looking closely at reducing waste and changing practices in the kitchen.
On the subject of waste, the policy requires prevention of food waste to be prioritised, with any surplus food fit for consumption to be re-distributed. Caterers must provide evidence of a ‘target, measure, act’ approach to managing and minimising the impacts of waste, in line with Wrap’s food waste reduction toolkit. They will also be required to provide evidence of a yearly reduction in food waste as a percentage of total food handled and share data for onsite and offsite volumes of food waste, both separately and combined, with procurers. This aligns with new proposals for mandatory reporting of food waste in England.
Re-usable packaging items must be used wherever possible, such as washable plates and cutlery, while equipment that has reached its end of use must be made available for re-use, repair or refurbishment wherever possible.
Complex compliance
Arguably the biggest culture shift for caterers – and there may be practical challenges too – will be around how they demonstrate compliance with the new policy. For the first time, businesses will need to report to Defra on a range of metrics including the percentage of total food and catering budget spent on local staff; percentage of spend on food produced locally or to certified higher environmental production standards; food waste as a percentage of food handled; and the destination of food waste. They will also have to report on the quantity of food purchased per sub-category including meat; dairy and eggs; vegetables; beans and pulses; and seafood. The document says this will enable Defra to estimate the associated greenhouse gas emissions and better understand how these can be cost-effectively reduced, to help meet the government’s ambition to reach net-zero. The first year of measurement will be the end of March 2023 to the end of March 2024 meaning the first full year of reporting will be required by the end of July 2024.
The concerns of both Sustain and the Soil Association centre on what action will be taken on the back of the data being submitted and how the standards will be enforced. “Simply requiring businesses to report isn’t enough,” says Westcott, who notes that businesses and government departments are required to report in quite a basic way on compliance with the current standards as part of their greener government commitments, and a number have been found not to meet them.
The Soil Association says the proposed approach “leaves obvious gaps and falls short of a robust approach”. It says as a matter of urgency, Defra should, as stated in the government’s food strategy, explore using an assurance scheme as a means of verifying compliance with the standards.
Nor is there any detail yet on what the penalties will be for caterers not complying with the rules. Defra is understood to be exploring future approaches for ensuring compliance with the policy but as a first step is prioritising the establishment of standards and a clear understanding of the current baseline.
Leaving aside for a moment concerns around some of the detail and questions around compliance, the consensus is broadly that the new policy is a step in the right direction towards a better, more sustainable set of standards for public sector food.
Amid widespread dismay over recent trade deals and a food strategy for England deemed thin and toothless, might it be that public food procurement stands alone as an example of how the government can use food policy as a force for good?
