by | December 22, 2020 | Opinion

Does the Farm to Fork strategy ‘walk the talk’ on food environments?

To facilitate a shift towards healthier, more sustainable diets, the EU Farm to Fork strategy points to the creation of a “favourable food environment”.

A ‘food environment approach’ recognises that a wide range of contextual factors, which are mostly beyond individual control, shape what foods we buy and eat. For EU food policy, this marks an important move away from the ‘consumer choice’ model, which simplistically assumes that people will make the ‘right’ food choices when provided with enough information and when prompted to adopt a ‘healthy lifestyle’.

Food environments not only help to frame the problem, but also present a systematic, evidence-informed approach to policy solutions. This article analyses whether the Farm to Fork strategy is consistent with a food environment approach in terms of the policy actions it pursues. It does so by mapping the strategy’s actions against seven food environment policy dimensions and a recommended policy mix.

Food environments: a quick evolution

The food environment concept emerged from the public health discipline, conceived in the context of tackling obesity and preventing non-communicable diseases (NCDs). Throughout the 2010s it made its way into international academic literature and a range of health policy documents, including by the World Health Organization (WHO). Subsequently, the concept was taken-up in the wider food systems debate. In the EU, food environments emerged on the scene only in 2020 as part of recommendations by EU chief scientists and, most prominently, the Farm to Fork strategy itself.

There are two main current definitions of food environments, which are similar, but offer slightly different emphases. The original definition by INFORMAS [1] focuses on the conditions that influence choices:

The collective physical, economic, policy and sociocultural surroundings, opportunities and conditions that influence people’s food and beverage choices and nutritional status.”

The definition by the High Level Panel of Experts on Food Security and Nutrition (HLPE) takes a more consumer-centric starting point:

Food environment refers to the physical, economic, political and socio-cultural context in which consumers engage with the food system to make their decisions about acquiring, preparing and consuming food.” 

Food environments: what policy domains?

Based on such comprehensive framing, the food environment approach may appear difficult to manage. This is, however, far from true.

Tools are available to unpack the concept in a practical way and to benchmark the quality of food environments by means of the Food Environment Policy Index (Food‐EPI). This index identifies seven dimensions to categorise food environment policies:

    1. Food composition
    2. Food labelling
    3. Food promotion
    4. Food provision
    5. Food retail and outlets
    6. Food prices
    7. Food in trade and investment agreements

Food environments: what policy types?

The food environment approach not only points to the dimensions in which food policies should be conceived, but also helps to reflect on the types of policy actions required. The choice of measures is important for the equity, effectiveness and cost-effectiveness of policy responses.

One clear finding from the public health discipline is that there are no ‘silver bullet’ solutions and that a comprehensive and multi-layered approach is needed to tackle today’s unhealthy food environments. At the same time, an ‘effectiveness hierarchy‘ of policies can be identified, in which regulatory options implemented at a society-wide level deliver the highest returns on investment. Another observed feature is that policies that require lower agency from individuals tend to be more equitable and effective. Likewise, a recurring observation is that policy approaches that rely on industry self-regulation and voluntary commitments lack efficacy, especially in the area of curbing the marketing of unhealthy foods.

These findings are confirmed and further reinforced by the EU’s chief scientists in their opinion on sustainable food systems. Neatly summarised, they recommend to:

    1. “Use the complete policy mix”
    2. “Focus on regulatory and fiscal measures as the main drivers of change”
    3. “Consider voluntary means only as supplementary drivers”

Does Farm to Fork ‘walk the talk’ on food environments?

To assess whether the Farm to Fork strategy is ‘walking the talk’ on food environments, the relevant actions under the strategy have been mapped according to the seven policy dimensions presented above, and according to policy type – voluntary or regulatory.

Mapping: Farm to Fork actions according to policy dimension and type

Farm to Fork Action Food EPI Dimension(s) Policy type
Ensure sustainable food production
Adopt recommendations to each Member State addressing the nine specific objectives of the Common Agricultural Policy (CAP), before the draft CAP Strategic Plans are formally submitted Food provision Voluntary
Stimulate sustainable food processing, wholesale, retail, hospitality and food services’ practices
Develop an EU code and monitoring framework for responsible business and marketing conduct in the food supply chain

Food composition

Food labelling

Food promotion

Food provision

Food retail

Launch initiatives to stimulate reformulation of processed food, including the setting of maximum levels for certain nutrients

Food composition


Voluntary, some regulatory?
Set nutrient profiles to restrict promotion of food high in salt, sugars and/or fat

Food promotion


Proposal for a revision of EU legislation on Food Contact Materials to improve food safety, ensure citizens’ health and reduce the environmental footprint of the sector

Food composition (if incl. food contact materials)


Proposal for a revision of EU marketing standards for agricultural, fishery and aquaculture products to ensure the uptake and supply of sustainable products

Food provision


Promote sustainable food consumption, facilitating the shift towards healthy, sustainable diets
Proposal for a harmonised mandatory front-of-pack nutrition labelling to enable consumers to make health conscious food choices

Food labelling


Determine the best modalities for setting minimum mandatory criteria for sustainable food procurement to promote healthy and sustainable diets, including organic products, in schools and public institutions Food provision Regulatory
Proposal for a sustainable food labelling framework to empower consumers to make sustainable food choices Food labelling Voluntary/Regulatory (?)
Review of the EU promotion programme for agricultural and food products with a view to enhancing its contribution to sustainable production and consumption

Food promotion


Review of the EU school scheme legal framework with a view to refocus the scheme on healthy and sustainable food Food provision Voluntary
Reduce food loss and waste
Proposal for a revision of EU rules on date marking (‘use by’ and ‘best before’ dates) Food labelling Regulatory

The mapping shows that:

    • Of the 27 actions in the annex to the strategy, 12 have been identified as especially relevant to shaping food environments, or around 40% of the actions.
    • The actions cover most food environment dimensions, with the exclusion of “Food prices” and “Food in trade”.
    • The “Food retail” dimension, referring both to in-store environments and food outlets in communities, and “Food promotion” dimension, referring to actions to tackle unhealthy food marketing are only weakly covered.
    • Around 50% of the actions are voluntary, and 2/3 of the actions are either voluntary or involve action on consumer information (labelling).

Conclusions and next steps

Several conclusions can be drawn from this quick analysis.

First of all, the strategy not only refers to the food environment concept, which is a great step forward in policy framing, but also ensures that a significant proportion of the actions – around 40% – are directly relevant for reshaping food environments, while addressing multiple food environment policy dimensions.

Secondly, despite the former, there is a clear overreliance on consumer information (labelling) policies and voluntary initiatives. This betrays that the ‘old way’ of thinking about demand-side food policy is still prevalent in the strategy and that a ‘real’ food environment approach has not yet taken root.

Thirdly, the choice of actions provides no indication that a prior systematic analysis has been performed about the needs and gaps in food policies and regulations, including with a view on the EU’s competence to address them. Lacking such analysis, it remains unclear whether the actions proposed are actually the most relevant and strategic ones to improve food environments. The lack of attention to pricing, advertising and trade policies, all critical for a sustainable food systems transition, compounds this worry.

As a next step, it will be important for the Commission to acknowledge some of the analytical and policy gaps in the strategy and focus on the opportunities to mend those. For instance, it should consider to study the outcomes of the Healthy Food Environment Policy Index study for the EU conducted under the Joint Programming Initiative (JPI) on a Healthy Diet for a Healthy Life. Based on its outcomes, the Commission should consider presenting new policy initiatives for areas insufficiently addressed by the strategy and take the proposal for a Legislative framework for sustainable food systems as an important next opportunity to overcome current deficiencies.


[1] International Network for Food and Obesity/non-communicable diseases Research, Monitoring and Action Support

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