A methodological review of UK food ecolabels: Final report

Introduction
The environmental impacts of agriculture have been the focus of considerable public concern for several decades, with the climate and biodiversity crises being at the forefront. Hence there has been an increasing demand for food production systems to transition to an approach based on agroecology and demonstrate that multiple environmental and socio-economic objectives are being met. The pressures and drivers of change within food systems are multiple, complex and connected, and includes the personal values and preferences of food producers, government policies and initiatives, and market demands from retailers and consumers. With respect to the latter, environmental labelling (ecolabelling) has a potential role in influencing the evolution towards sustainable food production. They include simple green claims on packaging with no verification; assurance labels where production standards are required; and those which attempt to quantify environmental impacts and outcomes. Therefore, labelling schemes potentially impact production practices directly (through required production standards) or indirectly via increased retailer and/or consumer demand for products with green credentials. A common methodology for ecolabelling of food is yet to emerge, so the methods, techniques and sources of data that underpin different ecolabels are variable. Hence, there is a need to investigate the approaches and data being used to understand their relative strengths and weaknesses within the context of a transition to sustainable production.
This report is a methodological review of food ecolabels that are currently operating or are expected to operate in the UK. It does not aim to explore the effectiveness of ecolabels as tool for changing consumer or business purchasing behaviour, but rather that if ecolabels have the potential to have any impact in this respect, to what extent do their methodologies provide a true and fair view of environmental impacts and the implications for a transition to agroecology; food sovereignty; and meeting national environmental targets. This could help identify any potential synergies and conflicts between different approaches to ecolabelling and other initiatives, such as policies, agri-environment schemes, etc., that also aim to facilitate a transition to sustainable food production.
Ten ecolabelling schemes that are relevant to the UK were selected and placed into two groups: (1) product-based; and (2) farm assurance-based. Each scheme was systematically reviewed, characterised and evaluated using a framework that encompassed true and fair principles including avoidance of bias; consistency; pragmatism; recognition of subjective elements; faithful representation of environmental impacts; and transparency. Information and data were collated for each scheme from publicly available sources and included a general description; environmental impact coverage; data sources, data quality and verification (incl. the use of primary and secondary data); impact communication; and transparency. With respect to environmental impact coverage, a bespoke classification was developed and applied that encompasses Life Cycle Assessment (LCA) impact categories, ecosystem services and planetary boundaries, to provide a classification that is both holistic and independent from any particular scheme.
The findings of the review, within the context of providing a true and fair view of environmental impacts; the transition to agroecology; food sovereignty; and meeting national environmental targets, are summarised below across five topics: (i) aims and objectives of the schemes; (ii) environmental impact coverage; (iii) impact communication; (iv) fit for purpose; and (v) further research and development, with associated key messages and conclusions shown on the right.

Aims and objectives of the schemes
It is important to acknowledge that the schemes differ in their aims and objectives, both between and within the two groups of schemes examined. Product-based schemes are consumer-focused with the aim of helping them make more sustainable choices, and three of the schemes also focus on food businesses as part of their drive is to impact the wider food industry. The product-based schemes also differ slightly in their environmental focus reflecting a sector where climate change is often the single focus, but increasingly additional environmental impacts are being utilised. Farm assurance-based schemes are largely farmer-focused. The driver is that the schemes will enable and support changes in farming practice to those which have more positive environmental impacts. There are differences in focus amongst the farm assurance-based schemes including integrated, regenerative and organic production; and biodiversity.
There is a clear difference between the product-based and farm assurance-based schemes with respect to governance (incl. accountability and transparency) in that they are 'top-down' and 'bottom-up' respectively. Product-based schemes have largely been driven by the priorities and motivations of those developing food products. Whereas farm assurance-based schemes have largely been driven by the priorities and motivations of primary producers, which has resonance with respect to the principles of food sovereignty, i.e. greater empowerment of farmers within the food system.
Taking a wider perspective, it is important to understand how ecolabelling could contribute to the development of sustainable food production systems, i.e. those that are viable in the long-term with respect to the environmental and socio-economic outcomes that society desires. For example, do ecolabel methodologies only report potential impacts of food or do they also support the adoption of agroecological practices. This is an inherently complex topic, much of which is beyond the scope of this review, however some elements are explored below with respect to the coverage of environmental impacts by the schemes, their interpretation and communication, and whether the schemes are 'fit for purpose'.

Environmental impact coverage
With respect to product-based schemes, the omission of biosphere related impacts, such as biodiversity; and poor accounting of site-specific impacts, including air, soil and water quality, soil provision and water flow regulation, which are all critical for agroecology (and more so with climate change), are notable omissions. Some schemes acknowledge these omissions, while others only focus on the impacts they do cover. There is also a tendency for reliance on secondary and/or modelled data rather than primary data from farmers and food producers. Advances are being made in developing databases, but concerns remain with respect to how well they reflect variability within different production systems and practices; transparency; and whether a product-oriented perspective creates issues for data governance and control within the context of food sovereignty. With respect to the farm assurance-based schemes, these potentially cover a wider range of environmental impacts, especially those relating to the biosphere. They are based on primary farm data and account for local conditions and circumstances that can greatly influence environmental effects and impacts. However, certification is based on practices adopted and not achieved environmental outcomes. Thus, the delivery of environmental benefits is unverified and their contribution to national environmental targets uncertain.
The use of primary data is desirable with respect to providing a true, fair and reliable picture where at the very least primary data for food production activities should be used to feed into models to derive secondary data on environmental impacts. However, taking a product-based perspective often demands data for thousands of activities and processes which leads to many activities and processes in the food system being considered part of the background system, for which databases of secondary data are considered adequate. However, such data should not be used for problem- and case-specific foreground data. Thus, the use of secondary and/or modelled data for key life cycle stages in food production, such as pre-farmgate, is a significant issue with respect to providing a true, fair and reliable picture, especially with respect to accounting for the impact of different methods of production, including many agroecological practices designed to address problem- and case-specific issues. It is beyond the scope of this review to determine all the uncertainties this introduces into the picture, but there is potential for them to be significant.
Some of the product-based schemes are seeking to utilise more primary data and some have attempted to extend the scope of the impacts covered with novel metrics. Similarly, there is a desire amongst the farm assurance-based schemes to gather evidence to verify environmental outcomes. In both instances, progress has been limited, however further development and innovation should be encouraged. Technologies and scientific understanding are rapidly evolving, for example in direct measurement of emissions and remote sensing, alongside methods for handling data to develop advances to facilitate a true and fair view of environmental impacts. Additionally, the collection of more primary data can feed into improvements to secondary data sources. Taking a wider perspective, environmental data is often collected for more than one purpose. There are many other uses, such as demonstrating the delivery of ecosystem services, or trading schemes for carbon, nutrients and biodiversity. A consistent picture of environmental impacts needs to be presented across all these use cases, including ecolabels. Any inconsistences or contradictions due to different perspectives, metrics or data could damage the credibility of all the schemes concerned and thus the perception of their reliability, which could be counterproductive with respect to achieving progress towards environmental targets.

Impact communication
A common challenge for all ecolabels is communication; how to convey environmental benefits and burdens within the confines of a label. As outlined above, it was beyond the scope of this review to explore the psychology of behaviour change amongst different businesses and consumers. Thus, communication has not been explored from this perspective, but more from a factual perspective, i.e. what should be communicated to consumers to present a fact-based picture of the environmental impacts arising or relating to how the food was produced. The two key challenges for product-based schemes are placing impacts in context (normalisation) and how to communicate multiple impacts.
With respect to normalisation, some schemes attempt to utilise the planetary boundaries concept, which has the most resonance for agroecology, but this is problematic as boundaries have not been defined for all impacts. Other schemes benchmark the impact of a product against others, but this only places it within the context of the population of products, thus has little bearing on sustainability.
With respect to handling multiple impacts, the product-based schemes tend to adopt an approach of aggregating the outputs from all the impact metrics in a single score or rating. This is problematic in terms of potentially hiding detail, which is exacerbated by the omissions outlined above, and conveying impacts relative to benchmarks such as planetary boundaries. Additionally, when LCA is applied in other contexts, aggregation is not usually undertaken due to its problematic nature. Aggregating the data to aid communication to consumers can result in something that is meaningless, which does not align with a true and fair picture.
With respect to the farm assurance-based schemes, communication centres around the adoption of good practices and their associated environmental benefits. In some instances, monitoring of environmental effects and outcomes is encouraged as part of good practice, but it does not form the basis of certification, thus there is no verification of any outcomes that are delivered.

Fit for purpose
A fundamental issue is whether the ecolabelling schemes, and their associated methods and processes, are 'fit for purpose' with respect to facilitating a transition to agroecology; ensuring food sovereignty; and meeting national environmental targets. Different approaches are giving rise to a 'perspective disparity' driven by different data demands and purposes, due to different stakeholders and motivations, which conflict with respect to understanding what is fit for purpose for food ecolabelling and food sovereignty. This is clearly manifested when considering system boundaries and where primary and secondary data are utilised. In a product-oriented perspective, pre-farmgate emissions and impacts, which are usually the largest for food products, are categorised as part of the background system and/or as Scope 3 emissions, i.e. they are outside the direct control of the assessed entity for which secondary data is often assessed to be adequate. However, from a farm-oriented perspective, pre-farmgate emissions and impacts are considered part of the foreground system, and/or as Scope 1 emissions, for which primary data should be sought and used. In the context of the transition to agroecology, changes in practices on farms are required that deliver environmental outcomes. If ecolabelling is to be used as a tool to support this transition, alongside other initiatives and schemes, then it must respond to changes at the farm level and farmers should have the power and tools to govern and control this data to enhance food sovereignty. Thus, a product-oriented approach is potentially flawed with respect to providing an ecolabelling scheme fit for this purpose, unless the approach can be adapted to utilise more primary data from farms, and in so doing enable more equitable governance.
Agricultural production systems need to adopt practices that have a lower environmental footprint and transition to a system based on agroecological principles. The drivers for this transition are complex and include scientific understanding, social, cultural and personal values, government regulation, environmental pressures, and market forces. Ecolabelling as a tool overlaps with many of these as a mechanism to communicate impacts. The picture that is communicated must be a true and fair view of the environmental impact of food. If it is not, then it risks skewing the picture, creating perverse incentives or trade-offs with other issues, and driving the system in the wrong direction. Businesses demand efficient and economic solutions, and hence why standardised methods and databases of impacts are appealing, but this must not be pursued at the expense of creating a true and fair picture of the environmental impacts of food production. There is a risk of externalising important impacts, such as biodiversity, in pursuit of a standardised and/or simplified approach to ecolabelling, which could be counterproductive with respect to its aims. The complexity needs to be embraced to truly resolve the challenges society faces.
The scope of the environmental impacts needs to be extended for all schemes, but especially for the product-based schemes. Issues such as wildlife species populations and biodiversity cannot be overlooked simply because they are difficult to measure in a standardised way. The need for more outcome-based metrics, to demonstrate progress towards environmental targets desired by society was a finding over a decade ago and this need remains. The practices adopted on farms to improve environmental performance must deliver that performance, and this can only be determined by measuring the outcomes. Additionally, many impacts are site-specific, so the demand for metrics that capture this detail persists. Product-based and farm assurance-based schemes can have a positive role despite the weaknesses outlined in this study. In many respects, they have opposite attributes. Product-based schemes use more outcome metrics, but with significant omissions; a lack of accounting for site-specific factors; and largely using secondary and/or modelled data. Whereas farm assurance-based schemes have greater coverage of environmental impacts; account for site-specific factors; and use primary data, but rely on practice-based metrics. Thus, neither approach is currently providing a comprehensive ecolabelling solution that provides a true and fair view of environmental impacts, supports the transition to agroecology, and supports meeting national targets.
There is a push by many organisations to develop a more unified approach to ecolabelling, but this is largely from product-based perspectives and motivations. There appears to be an assumption that a product-based approach is the only solution which is possibly driven by the EU Unfair Commercial Practices Directive and the Product Environmental Footprint (PEF) approach. This could be interpreted as accepted practice, rather than establishing what is acceptable to provide a true and fair view of the environmental impact of a food product. There is also a risk that a product-based approach becomes interpreted as synonymous with outcome-based metrics, which is potentially misleading, more so if farm assurance-based schemes continue to encourage the measurement of environmental outcomes on farms. Many product-based schemes also utilise LCA as a methodological framework for environmental impact assessment, but as outlined above, key environmental impacts are omitted from LCA due to a lack of standardised metrics. Metrics for other environmental outcomes do exist, and the technology for measuring and handling the data are evolving at a rapid pace, so the opportunity to gather primary data on environmental outcomes in the future should be exploited, rather than relying on secondary and/or modelled data. The transition to sustainable production and consumption systems will rely on having the most accurate and reliable picture of the environmental impacts of food, which in turn will facilitate the adoption of agroecological practices that deliver the outcomes desired. This needs to be coupled with appropriate governance to ensure primary producers are empowered and incentivised to engage with this transition, ranging from those just embarking on this journey to those regarded as advocates. Food production systems are socio-ecological; hence this must be an integral part in any ecolabelling scheme.

Further research and development
There is scope for further research and development on ecolabelling with respect to providing a true and fair view of the environmental impacts and more effectively supporting the transition to agroecology, food sovereignty and meeting national environmental targets. This includes identifying novel environmental impact metrics to plug gaps in coverage; seeking practical options for measuring environmental outcomes on farms; exploring new technologies to generate data; exploring the utilisation of data collected within assurance schemes to improve data in other supply chain initiatives; enhanced systems for data governance and control to improve food sovereignty; exploring benchmarks or targets for all metrics within the context of what needs to be achieved for the transition to agroecology; exploring alternative approaches to aggregation that do not hide important detail and/or avoid the issue of burden shift; and explore the viability of multi-component (environmental profile) labels. This work needs to be undertaken by ecolabel developers and practitioners, be that industry; government, regulators, academic institutions, or third sector organisations, in a collaborative fashion to ensure a harmonised solution emerges.
Drawing upon the ideas above, there is an opportunity to explore hybrid approaches across the schemes. This could be a combination of a farm assurance-based approach to encourage the adoption of best practices and utilisation of its primary farmgate data to feed into a product-based approach to support the quantification of outcome-based metrics; thus providing an improved basis to confirm whether the practices are delivering the environmental outcomes society demands. This could result in a picture of the environmental impacts of food that is true and fair, which supports the transition to agroecology and meeting national environmental targets, and, if coupled with enhanced systems for data governance and control, has the potential to improve food sovereignty by improving the connections between producers and consumers.