EU food-waste targets: turn a national obligation into an operational plan

Targets are measured against a reference period rather than against a single year, and the Commission's explanation sets out the reference period and the alternatives permitted in certain circumstances. [H] The alternative provisions matter because they mean the basis on which a member state measures progress may not be the basis assumed.

For a business, the practical implication is to avoid repeating a reference period or a measurement basis from secondary commentary without checking it against the current official position. The details are the kind that get simplified in reporting and that determine what a measure actually requires.

It is also worth noting that a reduction target expressed per capita, as the retail and consumption target is, is a different kind of measure from one expressed on the total tonnage in a sector. They respond to different things, and a business trying to understand its own position needs to know which basis applies.

Regardless of the precise legal position, four components make up a defensible operational plan, and each is useful on its own terms.

A baseline comes first, built from the business's own material flows rather than from a national figure. That means measurement by process step and reason, with a stated boundary, as set out in our companion analysis on factory baselines. Without it, progress cannot be demonstrated and interventions cannot be prioritised.

A prevention portfolio comes second. Prevention is a set of measures — process changes, specification reviews, planning improvements, storage and handling adjustments, surplus routing — rather than a single initiative. Building the portfolio means identifying candidate measures, costing them and sequencing them by expected effect and effort.

Reporting evidence comes third. Whatever a business reports should be supportable: measured where possible, estimated only where necessary, with the method recorded. The distinction between measured and estimated data is what makes a figure defensible.

Monitoring comes fourth. National measures, guidance and requirements develop, and what applies to a business depends on those developments. Assigning someone to watch the position is a small commitment that prevents a large surprise.

A business could reasonably ask whether any of this is worth doing before it is directly required. Three arguments suggest it is.

The financial argument is that material lost is material paid for and not sold, and disposal costs money on top. Reducing loss improves margin irrespective of any target. Where a business has not measured its loss by process step, the first baseline frequently identifies savings that were invisible in aggregate reporting.

The commercial argument is that customers ask. Retailers and large buyers increasingly request waste and loss data from suppliers, and a business that can answer from a maintained dataset is in a better position than one that assembles an answer under time pressure for each request.

The readiness argument is the simplest. A business with an established baseline and a prevention portfolio can respond to a new requirement by reporting what it already measures. A business without one faces the whole exercise from the beginning, at whatever point the requirement arrives.

The order matters because each step depends on the previous one. Baseline before prevention, because measures cannot be prioritised without knowing where loss arises. Prevention before reporting, because a report on measures with no evidence of effect is not informative.

The baseline is the step most often skipped under time pressure, and it is the one that everything else rests on. A business that begins with a prevention initiative has no way to demonstrate what changed, and no basis for deciding whether the initiative was the right one.

Starting with measurement is slower at the outset and considerably faster thereafter, because every subsequent question is answered from data the business already holds.