The UK Food Security Report 2024 reads like an intriguing story, full of plot twists highlighting the incoherence of the UK food system. And there is one bad guy in this story who is associated with every key risk to our food security named in the report:  geopolitical shocks, food price hikes, soil degradation, river pollution and climate change. This character is hidden in plain sight – the most dangerous type. The villain’s name? Fertiliser.

It’s there lurking in the shadows when the report outlines the three key risks for domestic food production, it’s there propping up our reliance on unreliable global supply chains and it’s there entrenching our damaging relationship with fossil fuels.

What are the risks?

Fertiliser features in the story of risks to food security through negative impact on soil health and our reliance on inputs sourced from global supply chains. The intensification of agriculture and the corresponding overuse of fertiliser can lead to nutrient imbalances in soil, with wider implications for soil degradation and productivity.

The UK is totally dependent on imports for nitrogen fertiliser. Fertiliser prices follow energy prices closely, as natural gas is the key ingredient in producing ammonia. In the past few years, with geopolitical tensions including Russia’s invasion of Ukraine, fertiliser prices have fluctuated dramatically. Fertiliser costs for UK farms rose from £1.5 billion in 2021 to £2.0 billion in 2022 and were £1.4 billion in 2023 – and higher fertiliser costs means higher food costs.

And what food do we produce with this fertiliser?

The UK’s ‘food production to supply ratio’ (which in non-technical terms means what food is available in the UK) is a fine example of policy incoherence. What we produce in the UK does not align with dietary guidelines. We overproduce meat and dairy and underproduce vegetables and fruit.

In 2023, the UK produced most of the meat, dairy and eggs that it consumed, as well as cereals, which were predominantly used for animal feed. In the same year it produced a significantly lower proportion of vegetables (53% were produced domestically) and fruits (a mere16%).

We know that availability of fresh produce in the UK is an important part of food security and supports human health. The Eatwell Guide indicates that just over a third of all food consumed every day should be a variety of fruits and vegetables, a minimum of five portions. These are good sources of micronutrients, but we are currently highly dependent on imports to meet demand and many of the countries the UK imports from are also subject to their own climate and sustainability risks.

The science is clear: the food we grow is an important lever in addressing the climate emergency, biodiversity destruction, the public health crisis and animal suffering.

If we move away from industrialised meat and dairy, and shift towards plant-based diets, we could afford to reduce nitrogen-based fertilisers and produce food more efficiently. In other words, we could grow more food in the UK which is good for us, good for the planet and good for animals, while using less fertiliser. Why? Because plant-based foods have higher nitrogen use efficiency than animal agriculture. Diets that are predominantly plant-based also correlate with lower nitrogen footprints, reduced greenhouse gas emissions and positive health outcomes. They would also reduce energy dependency and increase resilience in the food system.

One of the fascinating plot lines in the UK food system story is that, although fertiliser is a complex villain, by shining a light on the role it plays we can set about resolving these urgent challenges. We can write a new chapter about a sustainable food and energy transition. With a shift in diets, and coherent choices around how we produce food, we have the potential to see gains across a range of environmental, health and climate outcomes.

In 2025, Foodrise will be rewriting the story of fertiliser and food.

Watch this space.

Following our research and campaigning highlighting the supply of fish oil sourced from FAO 34 — the Major Fishing Area located off the coast of Northwest Africa — to the European feed industry, Foodrise is issuing this statement in response to the industry’s response, including:   

• Salmon Scotland statement that it does not use marine ingredients sourced from West African fisheries; 

• MOWI’s statement that it has not sourced any raw materials from Mauritania since 2023; 

• Skretting statement that Skretting Norway did not purchase fish oil from Africa in 2023 or 2024 (although we note that according to a media report in November 2024, Skretting stated that it continued to source from the region). 

We are pleased that the industry has responded to the overwhelming evidence on the damaging impact of sourcing from this region. 

We remain extremely concerned about the ‘food-feed competition’ which is being driven by the global aquaculture industry in regions around the world as high-impact activities such as salmon and seabass farming continue to expand to serve high-income consumers in Europe, North America and Asia. 

We therefore reiterate our call to companies throughout the supply chain (feed ingredient and compound feed producers, farmed salmon companies, retailers and food service companies) to provide full transparency on their sourcing practices and to comply with the following set of demands: 

• Fish meal and fish oil (or products dependent on FMFO) should not be sourced from locations where its production is driving food-feed competition and exacerbating food insecurity and/ or exacerbating the risk of collapse of the marine ecosystem  

• Salmon producers must have clear policies on responsible feed sourcing, which exclude the sourcing of feed produced with ingredients that are driving food-feed competition and exacerbating food insecurity and/ or exacerbating the risk of collapse of the marine ecosystem 

• Producers must be fully transparent, consistent and granular on their aquafeed sourcing, including volumes, locations, species

On World Fisheries Day, call for Wagamama to take farmed salmon off its menu to help relieve the pressure on wild fish populations around the world.

Join our call by commenting ‘Hey @wagamama_uk, #DropFarmedSalmon’ on @wagamama_uk Instagram to make some social media noise they can’t ignore!

Around the world, fisheries are in a deep crisis.

A recent FAO report reveals a startling reality: only 62% of fish are being caught at ‘biologically sustainable levels’ —a sharp decline from 90% in 1974. This means a number of fish populations are being depleted, threatening the fragile web of ocean ecosystems. This increasing plunder of our oceans should sound alarm bells across the world. Overfishing degrades delicate ocean ecosystems, endangers wildlife, threatens global food security and the health of our planet.

Many communities rely on fish as their primary source of protein and vital micronutrients – but industrialised fish extraction means that this is under threat.

How does overfishing link to industrial fish farming?

You may have heard that industrial aquaculture is supposed to relieve the pressure on our overfished oceans. However, many of the most economically valuable farmed species such as salmon, sea bass and prawns are carnivores with a rapacious appetite for wild fish. So, what we are seeing is wild fish – including anchovies, herring and sardines – which could be eaten by people, are instead being ground down into feed for corporate-owned carnivorous fish production around the world.

Highlighting the absurdity of this practice, shocking new research has shown that it takes up to 6 kilograms of wild fish to produce just 1 kilogram of farmed salmon. Far from easing the burden on ocean ecosystems, the aquaculture industry’s inefficient and wasteful business model is intensifying it. This is placing even more pressure on global fish populations and damaging the very oceans they say they want to protect.

That’s why on World Fisheries Day, we are ramping up our calls for Wagamama to take farmed salmon off its menu, to help relieve the pressure on wild fish populations around the world, and to finally live up to their claim to ‘tread softly’ on the earth.

We are making waves at Wagamama!

Thanks to the incredible support so far, our petition calling on Wagamama to remove farmed salmon has received over a staggering 100,000 signatures. We’ve received public support from Chris Packham and even made national headlines.

The pressure is paying off: Wagamama has now publicly stated that they will stop serving Norwegian salmon and only serve Scottish salmon in 2025, ensuring that they do not serve salmon that is fed wild fish from West Africa.

Whilst this is a step in the right direction, there is still more to do.

Scottish farmed salmon remains highly problematic and unsustainable. Whilst succeeding in marketing itself as a heathy, responsible protein source, this couldn’t be further from the truth. Beneath the surface, the reality of this industry is a much more troubling tale.

Scottish salmon production remains dependent on wild fish caught all over the world to feed it – every year, the industry uses around 460,000 tonnes of wild fish to produce 179,000 tonnes of farmed salmon. Worse, in the process, millions of farmed salmon die every year before harvest, often because of disease. This means not only the pointless and callous waste of farmed salmon, but also of the wild fish which were caught to feed them.

Recent news coverage exposed a mass mortality event at a Mowi Scotland salmon farm where more than 1 million salmon died. This distressing level of mortality demonstrates appalling negligence from the industry. However, unfortunately, the true scale of this mortality extends beyond the pens as the lives of wild-caught fish, in the form of feed, are wasted too.

Putting the reality of Scottish farmed salmon on Wagamama’s menu

To mark World Fisheries day, we interviewed Don Staniford, an activist who’s seen the realities of fish farming first hand. You can watch our video here.

Once again, Wagamama’s reluctance to take meaningful action has proven that we need to keep raising our voices. Until they commit to removing farmed salmon, industrial aquaculture will continue putting intense pressure on world fisheries by consuming vast amounts of wild fish, further depleting already struggling fish populations.

What can you do?

Join us and take action! Comment ‘Hey @wagamama_uk, #DropFarmedSalmon’ on Wagamama’s Instagram posts to get involved in some social media activism.

Nearly 15,000 people object to ‘outrageous’ plans for Norfolk ‘mega-farm’ housing 870,000 chickens and 14,000 pigs

Campaigners urge council to reject Cranswick’s ‘US-style megafarm’ – FarmingUK News

Campaigners call on King’s Lynn and West Norfolk Council to reject plans for US-style industrial megafarm, say Council breaking the law by not considering climate impacts

Campaigners have today issued an urgent call to the Borough Council of King’s Lynn and West Norfolk to reject plans to build a US-style ‘megafarm’ in Liz Truss’s former constituency in rural Norfolk on the grounds that it would jeopardise local and national climate change commitments.

Campaigning group Feedback and Sustain, the UK’s alliance for better food and farming, have also warned the Council that it is breaking the law by inexplicably leaving greenhouse gas emissions out of scope in the planning application produced by the developer of the site, industrial meat producer Cranswick Plc.

Greenhouse gas emissions from the proposed facility – which could produce up to 6 million chickens and 56,000 pigs a year in Methwold, Norfolk – are expected to be substantial. Legal challenges may be forthcoming if this application were to be approved, in light of significant deficiencies in the application.

In the wake of a Supreme Court’s judgment earlier this year – the Finch ruling – Feedback and Sustain’s legal advisers have indicated that the direct and indirect climate impacts of industrial livestock units must be considered by Councils when deciding on factory farm planning applications. Methwold is widely seen as a test case for similar planning applications by industrial livestock producers in other parts of the UK.

Cranswick Plc is one of the UK’s largest producers of pigs and chickens and has been the subject of complaints and enforcement action regarding extreme ammonia emissions and river pollution. It reported revenues of £2.3 billion for the year ending in March 2024 and supplies both the UK and export markets, including China.

There is significant local resistance to the extension of the Methwold factory farm: to date, the Council has received an unprecedented 10,000 letters objecting to the proposal.

If King’s Lynn and West Norfolk Borough Council decides to grant planning permission, it would be in contravention of its climate strategy: the Council declared a climate emergency in 2021, and its climate strategy contains targets to reduce the Council’s own emissions as well as the wider emissions from local industry, transport, and domestic homes ‘as and when opportunities arise’.

The UK Government’s net zero commitment is enshrined in law, and national planning policy for England includes an objective to move to a low-carbon economy. The Methwold application would threaten the delivery of both policies. To meet national climate change targets, the Committee on Climate Change recommends a 20-50% reduction in meat consumption by 2050.

Natasha Hurley, Director of Campaigns at Feedback said, “Expanding emissions-intensive factory farming as the climate crisis intensifies is madness. This megafarm must be stopped, and we believe the law is on our side. We urge West Norfolk Borough Council in the strongest possible terms to reject this planning application.”

Ruth Westcott, Campaign Manager at Sustain said, “Industrial megafarms like this are completely unnecessary. As well as the unacceptable impact on the climate, family farmers say these kind of supply chains impose prices, trading terms, and insecurity that they can’t survive. Sustainable farming is the real path to creating good jobs, local food security and decent returns for farmers.”

King’s Lynn and West Norfolk Borough Council is currently conducting a 30-day public consultation following the publication of an environmental statement by Cranswick on 31^st October. This will be followed by a review, with the Council expected to issue a decision on the planning application in early 2025.

The government is currently undertaking a review of the National Planning Policy Framework. Sustain and Feedback have both called for climate change to be made a material planning consideration for industrial livestock units in submissions to the government. They are also calling for a national presumption against new and expanded intensive livestock units in polluted catchments.

Notes to editors:

• Kings Lynn and West Norfolk Borough Council’s latest Local Carbon Audit report and district emissions report shows that total gross emissions from council activities are 3,574 tonnes and transport emissions are 389,000 tonnes. The proposed development was estimated by Sustain to be capable of producing up to 120,000 tonnes CO₂ equivalent per year.
• Under the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, environmental impact assessments must include greenhouse gas emissions and the project’s vulnerability to climate change. Despite this, planning applications for industrial livestock units do not currently include a detailed GHG assessment as the norm.
• Factory farming is on the rise across the UK. Norfolk is one of several British counties targeted by developers of US-style megafarms. According to Compassion in World Farming, the number of the largest intensive livestock units in the UK has increased by 20% since 2016.
• Cranswick supplies most of the UK’s grocery retailers and has a strong presence in the wholesale and food service sectors as well as a “substantial export business.”

Contacts:

• Natasha Hurley, Director of Campaigns – Feedback natasha@foodrise.org.uk
• Ruth Westcott, Campaign Manager – Sustain ruth@sustainweb.org

We’re delighted to share a guest blog from Roz at Still Good Food, diving into the world of gleaning in East Anglia – just in time to kick off this year’s harvest season!

This is our fourth year Gleaning at SGF! We are based in Bury St Edmunds, Suffolk and we set our project up in 2017.

We are an environmental project and work with supermarkets via FareShare, redistributing food that is approaching or past its ‘Best Before’ date (not ‘Use By’).

We are based in the heart of an agricultural region. The area is largely arable growing sugar beet, cereals, potatoes, onions, leeks, brassica and fruits.

We work with five commercial farms, three fruit farms (apples and pears), and two arable where we have gleaned onions, potatoes, cabbage, kale and leeks.

To date, we have gleaned just over 30 tonnes of farm fresh produce that would never have left the farm, mainly due to the “Cosmetic Criteria” set by supermarkets.

All gleaned produce goes through our two shops for a small “donation”. It also goes to local schools, food banks, projects that support hostels/homeless people and church projects. We are also now sending a tonne of beautiful “Cox le Vera” apples to City Harvest in London.

We have a team of over 35 volunteers who are passionate and dedicated and it would be impossible to do this work without them. We also work have great volunteers from the Lions club at Felixstowe and the New Century Lions, Cambridgeshire. We get free van hire here.

And, of course, the farmers who support us are very happy to see the fruits of their labour (and money) used for such a good cause. Farmers are now contacting us – which is a great indication of the success of our work.

Gleaning is also great fun, social and a really worthwhile way to spend couple of hours or so!

Fancy joining a glean? Email roz@stillgoodfood.org

After maintaining a stony silence in response to our campaigning for almost a year, Wagamama have finally revealed that they will be removing Norwegian farmed salmon from their menu, but the battle isn’t over yet. 

Last month, Wildlife TV Presenter & Conservationist Chris Packham joined the public call for Wagamama to drop farmed salmon from its menu because of its outsize environmental and social footprint. His support provided a welcome boost to our campaign and associated petition, which a staggering 100,000 people have now signed. 

This gained widespread media attention from  The National, Seafood Source, IntraFish, The Fish Site and others. As a result, Wagamama finally responded to our concerns after almost a year of silence, revealing to The National that they will be removing Norwegian salmon from their menu and replacing it with Scottish farmed salmon. 

We are glad to hear that Wagamama is distancing itself from the Norwegian salmon farming industry, which is known to be contributing to a food crisis in West Africa by sourcing fish oil —a key ingredient used to make aquafeed— from the region. However, Wagamama’s move to Scottish salmon does nothing to address the huge and systemic problems within the toxic salmon farming industry as a whole. That’s why we’re not letting them off the hook.

What’s the issue with farmed salmon? 

For decades the salmon industry has succeeded in marketing itself as a clean, environmentally friendly protein. However, this is far from the reality.  

From hazardous pesticides and fish faeces flowing from salmon farms into the surrounding marine ecosystems, to mass fish die offs due to overcrowding and disease, and threats to wild fish populations from sea lice parasites, the toxic farmed salmon industry has huge environmental and welfare issues.  

But it doesn’t end there.  

The industry’s appetite for millions of tonnes of wild fish to feed farmed salmon, in the form of fish meal and fish oil (FMFO), is harming communities around the world. Much of this wild fish comes from the Global South, in places like Mauritania, Southeast Asia and Peru. This extractive business model creates a problem: fish that are a vital source of food and income for coastal communities are instead being used to feed salmon consumed by the Global North. It’s a hugely inefficient and unjust use of nutritious fish, which could be eaten directly by people. 

How did Wagamama respond and what do we make of it?  

With Wagamama in the spotlight following widespread news coverage last month, a company spokesperson finally responded to our concerns in The National in July. This followed months of attempts to elicit a reaction from Wagamama through letters and a visit to its HQ in Central London.  

The main take-home from Wagamama’s response was: 

• Their Norwegian and Scottish salmon suppliers do not use feed from West Africa. 

• By the end of 2024, they will only use Scottish salmon from RSPCA-approved sites. 

• The FMFO fisheries that are used by salmon farming companies Wagamama buys from are accredited by GlobalGAP, the world’s leading standard for seafood farmed with care 

However, these responses leave a lot of questions unanswered. In light of this, we have sent them a letter outlining our ongoing concerns and a continued invitation to engage with us on this issue. You can find a copy of that letter here. 

When it comes to Wagamama’s claim that none of their suppliers use feed from West Africa, we have asked for evidence of the companies they have been sourcing from.  In our Blue Empire Report we found that the four big feed producers, MOWI, Skretting, Cargill and BioMar supply close to 100% of the feed used in Norwegian salmon farming. All of them source fish oil from West Africa. A recent investigation from the Financial Times even shows satellite footage of an oil tanker leaving West Africa and docking in Norway at a MOWI feed factory.1 So, it seems unlikely that Wagamama have separated themselves entirely from this complicated supply chain 

Turning our attention to Scottish sites, according to industry body Salmon Scotland, they do not use feed sourced from West African fisheries. We questions whether this is in fact the case as feed supply chains are so complex, and there is very little transparency for consumers and independent observers such as Feedback to interrogate these kinds of claims. However, putting this aside, using wild fish to feed farmed fish remains deeply inefficient and damaging.  Annually one-fifth of total marine catch is used to create FMFO, the bulk of which goes towards creating feed for the aquaculture industry. These fish, over 90% of which are overfished or at their maximum sustainable limit, are otherwise edible or could remain in the ocean to perform an important role in the marine ecosystem. So, regardless of whether Wagamama is using FMFO from West Africa, it is still contributing to this extractive and wasteful supply chain. For example, in some instances wild fish is being caught in Norway to feed farmed salmon, which is still contributing to extinction and loss of livelihoods in local communities in Scandinavia.  

Wagamama’s promise to move to RSPCA-approved Scottish salmon by the end of 2024, is hardly an achievement. The vast majority of Scottish salmon farming is RSPCA-approved, yet there are many welfare and wider issues still endemic to Scottish salmon farming. As set out by WildFish in its report, Responsibly Farmed?,  the RSPCA Assured standard, which claims to be welfare-led, sets no maximum mortality threshold limit; despite mortality being a recognised indicator for welfare performance. Consequently, Scottish farms reporting as many as 74% of its fish dying in a single month are still covered by the RSPCA Assured scheme.  Very high disease and mortality rates are raising wide concerns that certification schemes are failing to ensure salmon farms meet minimum standards that the public would expect from these schemes.  

Back in October last year we brought Wagamama’s attention to the issues with using GlobalGAP in their sourcing standards. It is therefore ironic that Wagamama are now pointing to it to demonstrate Wagamama is adhering to high standards is problematic. Like many other voluntary standards, GlobalGAP fails to address the ‘food-feed’ competition. This standard currently only requires 60% of soy and FMFO contained within certified feed to be from approved ‘sustainable’ sources, opening the door to outright harmful supply chains. Recording the origin of FMFO is only required ‘where possible’, allowing for untraceable and damaging sourcing. Further, any contribution to overall demand for FMFO (regardless of certification) where total demand already outstrips what can be sustainably supplied, contributes to overfishing and food insecurity. 

So, are they off the hook? 

In a word, no.  

On the one hand, it sounds like they’ve listened by moving away from Norwegian farmed salmon. But sadly, Scottish companies (some of which, like MOWI, are Norwegian-owned anyway) appear to be no better than their Norwegian counterparts when it comes to mass mortalities, wasteful feeding practices and the over-reliance on flawed certifications. 

There is still a long way to go before Wagamama are ‘off the hook’. 

Haven’t signed the petition yet? You can sign here.

In the wake of the publication of our Blue Empire report, this week we sent an open letter to the Norwegian government, calling on it to ban the salmon farming industry from sourcing fish oil from West Africa in light of the threat this practice poses to regional food security and livelihoods.  

The 39 signatories comprise organisations and academic experts from around the world.  Several of the African groups such as the Collectif Taxawou Cayar, WADAF, RAMPAO and CFFA represent the region’s small-scale fishing sector and communities which are suffering from the impact of overfishing, in part driven by the production of fishmeal and fish oil for the global aquaculture industry. Norwegian and international NGOs including Naturvernforbundet (Friends of the Earth Norway), the Environmental Protection Association of Norway (NMF) and Oceana have also joined the call to action.  

Humble beginnings… 

From the humble beginnings in the 1970s, Norway is now the world’s biggest farmed salmon producer, with Norwegian companies occupying eleven out of the top 20 slots in the list of global producers of farmed salmon.  The industry is dominated by a handful of powerful multinational corporations, including MOWI, the world’s largest salmon farming company, which had a turnover of nearly €5 billion in 2022, and supplies supermarkets all across Europe.  

However, what some in Norway view as a corporate success story, has come at the expense of communities and fish populations in the Global South.  

Norway’s ‘Blue Empire’ 

Our ‘Blue Empire’ report published earlier this year, shows that, as the world’s largest salmon producer, Norway’s salmon farming industry has an enormous ‘feed footprint’, driving the extraction of around 2 million tonnes of wild-caught fish each year to produce fish oil, which is fed to Norwegian farmed salmon. A significant share of this fish comes from food insecure regions, such as West Africa where food insecurity has hit a 10 year high. Our research calculates that the production of West African fish oil for the Norwegian aquaculture industry is depriving up to 4 million people in the region of fish.  

With this in mind, we argue that what Norway sees as a ‘blue opportunity’ is in fact a ‘blue empire’. The movement of wild fish from the Global South to feed salmon in the Global North which is then sold at a premium is creating a new type of food colonialism, further entrenching global inequity.  

‘The fishmeal industry is a serious threat to food security and the future of fisheries in West Africa. This industry plunders our marine resources to feed intensive aquaculture in Asia and Europe, when local populations need it for their own food. It is time that “the fish of the poor stopped feeding the fish of the rich”. Our oceans and our people deserve better!’  

Dr. Aliou Ba, Senior Ocean Campaign Manager, Greenpeace Africa

Adding to the absurdity, the Norwegian government’s uncritical embrace of industrial aquaculture stands in stark contrast to Norwegian development policy. In 2022, Norway’s Strategy promoting food security in development policy  stated that their overall objective was to “fight hunger and increase global food security”. In the foreword to the strategy, Anne Beathe Tvinnereim, Minister of International Development emphasized that while in sub-Saharan Africa, 70–80% of the population works in agriculture and fishing, “Paradoxically, these very farmers and fishers represent the majority of chronically hungry families.” Whilst the government is setting out admirable goals to fight hunger globally and highlighting the macrotrends driving food insecurity in Africa, they remain silent on Norway’s role, with the extractive business model of its salmon farming industry creating the very conditions they say they want to improve. .  

What we are calling for 

In light of these findings, we are calling on Norwegian policy makers to:  

1. Ensure that Norwegian companies’ activities and feed sourcing practices do not contradict its own development policy by mandating an immediate ban on the sourcing of fish oil from food insecure regions including Northwest Africa; 

1. Stop further growth in Norway’s salmon farming sector so that it remains within planetary boundaries; 

1. Mandate genuine transparency throughout aquaculture supply chains, including full disclosure of suppliers – from source fisheries upwards 

You can read our letter here:

Download the letter here.

Key points:

• Over 100 organisations and academics have called on the FAO to retract a key report over serious methodological errors downplaying the emissions reduction potential of a shift to lower-meat and dairy diets, a joint-letter released today.
• The FAO’s claims were mainly based on two papers. Scientists who co-authored these papers recently accused the FAO of distorting their work and called for the report to be retracted.
• Last year, the FAO faced allegations from former staff that it had ostracised them and censored their work for highlighting the climate emissions impact of livestock and potential benefits of dietary change to reduce meat and dairy consumption.

Over 100 organisations and academic experts have called on the FAO to retract a report over serious methodological errors, which downplay the emissions saving potential of shifts to lower-meat and dairy diets.

In the report Pathways towards Lower Emissions, published at COP28 in December 2023, the FAO made claims that lower meat and dairy diets had limited potential to reduce emissions from global livestock, promoting instead other methods such as intensification of livestock production. The main evidence the FAO report cited for this claim were papers co-authored by academics Dr Paul Behrens and Dr Matthew Hayek.

In April 2024, Behrens and Hayek wrote to the FAO to express “dismay” that the FAO’s paper “seriously distorts” their scientific papers, calling for a retraction and re-issuing of the report with “more appropriate sources selected and methodological errors rectified” [1]. Behrens and Hayek concluded that as a result of the serious errors it contains, the FAO report “systematically underestimates” the opportunity of sustainable lower-meat and dairy diets for reducing greenhouse gas (GHG) emissions [2] compared to a business-as-usual 2050 scenario by a factor of between 6 and 40 [3].

Now, over 100 organisations and experts have signed a joint-letter to the FAO’s Director-General, Dr. Qu Dongyu, calling for the report to be retracted. The letter, coordinated by Foodrise, is signed by 78 civil society organisations including Greenpeace, Changing Markets Foundation, Friends of the Earth US, Rainforest Action Network, ActionAid US and Seeding Sovereignty. It is also signed by 22 academic experts, Connecticut State Representative David Michel and investor Adasina Social Capital.

The organisations support Behrens and Hayek’s call for the Pathways report to be retracted and call for “a comprehensive investigation of how these serious errors and systemic biases were allowed”, raising concern over a media report from 2023, in which ex-FAO officials said they had been sidelined and censored by the FAO following lobbying from high livestock-producing companies and countries [4].

Echoing the call by Behrens and Hayek, the organisations call for the Pathways report to be retracted and reissued only once the methodological errors it contains have been rectified, drawing on more appropriate and up-to-date studies and following engagement in serious dialogue with independent academics and experts from civil society. The letter also recommends that the release of the FAO’s 2050 Roadmap should “be delayed until it has adopted “more robust, inclusive and transparent processes”.

The significant methodological errors in the FAO’s Pathways report include double counting meat emissions to 2050, mixing different baseline years in its analysis, and including emissions from increases in vegetable, fruit and nut consumption which are unrelated to substituting meat and dairy in diets [5]. In addition, the FAO makes several inappropriate modelling choices, such as ignoring the potential carbon sequestration from land spared by dietary change and conflating sustainable healthy diets with nationally recommended diets (NRDs) – most of which do not factor sustainability into their design – rather than using models like the EAT-Lancet diet. It also uses NRDs which have since become obsolete as many countries have since updated theirs to recommend lower meat consumption [6]. For instance, Spanish Guidelines from 2022 now recommend 0-3 meat portions/week [7] and German guidelines from 2024 now recommend no more than 300g meat per week [8].

The organisations call on the FAO to align its research with other peer-reviewed science, such as EAT-Lancet and the IPCC’s Special Report on Climate Change and Land, which estimate much higher emissions savings. For instance, the IPCC cites a study which estimates that a flexitarian diet (75% of meat and dairy replaced by cereals and pulses, with only one portion of red meat a week) would reduce global emissions by approximately 5 GtCO₂-eq per year [9] – over 9 times higher than the FAO’s estimate.

QUOTES

Martin Bowman, Senior Policy and Campaigns Manager at Feedback, said:

“The FAO has made serious and embarrassing errors in its Pathways report – these mistakes are a stain on the FAO’s reputation, unless rectified. All these errors systematically underestimate the emissions reduction potential of lower-meat and dairy diets. People will rightly ask whether FAO staff have simply been incompetent, or whether this indicates systematic bias against dietary change – particularly in light of recent allegations from ex-FAO staffers that they have been ostracised and censored for their work on dietary change, following lobbying from livestock companies and high-meat producing countries. The FAO must restore its integrity by immediately retracting the flawed Pathways report, and reissuing it with mistakes rectified, following engagement with academic experts and civil society.”

Nusa Urbancic, CEO of Changing Markets Foundation, said:

“The debate around the climate impact of food and farming is extremely polarised and riddled with industry-funded disinformation. For this reason, it’s of paramount importance that international organisations, such as the FAO, present impartial and scientifically robust reports that can serve governments as a guide for climate action in the sector. We are concerned about the lack of rigour in the Pathways report and we are convinced that the FAO can and must do better.”

Merel van der Mark, Senior campaigner at Rainforest Action Network, said:

“It was shocking to hear JBS, the world’s largest meat packer, proclaim at an event during the COP in Dubai, that the report just released by the FAO showed that meat was ‘not the problem, but the solution to the climate crisis’. Now that we know that the FAO distorted scientific papers, it makes one wonder what role JBS and other meat companies had in shaping the FAO’s report.”

Pete Smith, Professor of Soils & Global Change at the University of Aberdeen, said:

“While it is reasonable to involve stakeholders in such a report, it is very disappointing to see the pathways and recommendation in the report being so heavily skewed by vested interests. The science is clear that a reduction in consumption of livestock products is overconsuming countries is an essential lever for climate change mitigation, so it is unfathomable to see this option practically ignored and the science misused. The FAO has long been a trusted voice in the space, which makes this report even more disappointing.”

Shefali Sharma, Global Agriculture Campaigner with Greenpeace [16], said:

“The FAO continues to have major problems with conflict of interest, particularly in its partnership with Big Dairy corporations. The influence of the Global Dairy Platform, the dairy industry’s biggest corporate lobby is evident in its joint publication with the industry. The FAO’s Pathways report once again downsizes the estimation of livestock’s contribution to climate change, though the previous estimate was already challenged by academics. We would like to see the FAO hold up stringent standards for peer review that are truly independent, transparent and rigorous so that it can remain trusted and influential in food and climate agriculture policy amidst other UN bodies.”

NOTES TO EDITORS

Joint-letter is available here – please if possible link to report in coverage

Further quotes available on request

CONTACT: Martin Bowman, martin@foodrise.org.uk

FURTHER INFORMATION

Comments by Behrens and Hayek on the FAO report:

In April 2024, Matthew Hayek, Assistant Professor at New York University, commented to the Guardian newspaper that “The FAO’s errors were multiple, egregious, conceptual and all had the consequence of reducing the emissions mitigation possibilities from dietary change far below what they should be. None of the mistakes had the opposite effect.” [10]

Other responses to Behrens and Hayek’s letter:

FAIRR, a global investor network with a membership of $70 trillion in collective assets of support, has also said that since the FAO is responsible for both the Pathways and upcoming 2050 Roadmap, the “concerns raised by the authors [Behrens and Hayek]” extend to the 2050 Roadmap report – saying “It is FAIRR’s expectation that the UN-FAO will provide a substantive response to the issues raised by Professors Behrens and Hayek and will make adjustments to their analyses if and as needed” and emphasising that “the highest level of academic integrity and impartiality must be maintained by the UN-FAO” for the result to be scientifically sound [11].

The emissions mitigation potential of dietary change:

The FAO Pathways report misleadingly estimated that the emissions mitigation potential of dietary change is only 0.19-0.53 Gt CO₂-equivalent per year.

Behrens and Hayek estimate that this is between 6 to 40 times lower than the actual potential. Based on Clark et al.’s (2020) modelling, the direct emissions mitigation potential from dietary change in line with the EAT-Lancet diet is closer to 3.10 Gt CO₂ equivalent per year, rising to 6.22 Gt CO₂eq per year if the carbon sequestration potential from ecosystem restoration on spared land is factored in, compared with a 2050 BAU baseline [12].

The International Panel on Climate Change (IPCC) found, with high confidence, that a shift to more plant-based diets could mitigate GHG emissions by between 0.7 – 8 GtCO₂-eq per year, with higher reductions in meat and dairy leading to higher emission reductions [13]. For instance, the IPCC cites a study which estimates that a flexitarian diet (75% of meat and dairy replaced by cereals and pulses, with only one portion of red meat a week) would reduce global emissions by approximately 5 GtCO₂-eq per year [14] – over 9 times higher than the FAO’s estimate.

A recent survey [15] of over two hundred climate scientists and food and agriculture experts, over half of whom have authored IPCC reports, found that:

• Global livestock emissions need to be reduced by 50% by 2030 and 61% by 2036, with faster and deeper reductions in higher-income countries, in order to limit global warming in line with the Paris agreement;
• 78% of the experts surveyed said that absolute global livestock numbers need to peak by 2025;
• Reducing human consumption of livestock products and reducing the number of livestock animals were ranked as having the biggest potential for reducing livestock emissions, whilst intensification of livestock was rated as the measure with lowest potential.

The emissions mitigation of shifting to vegan diets would be even higher. Poore and Namecek (2018), a peer-reviewed meta-analysis in the journal Science based on around 38,000 farms producing 40 different agricultural goods around the world, estimated that the total emissions mitigation potential of dietary change towards vegan diets was 14.7 billion tonnes of CO2eq reduction per year – 6.6 billion tonnes of direct CO2eq reduction, plus an additional 8.1 bn tonnes of CO2eq of carbon removals per year for 100 years if nature is restored on the land spared.

More info on Feedback:

Feedback is a UK- and Netherlands-based environmental campaign group working for food that is food for the planet and its people. For more info, see: https://foodrise.org.uk/

References:

[1]  Paul Behrens and Matthew Hayek, “Letter to Dr Tiensin: Retraction Request – FAO’s Pathways toward Lower Emissions Report,” April 9, 2024, https://www.universiteitleiden.nl/binaries/content/assets/science/cml/essays/retraction-request-pathways-to-lower-emissions.pdf.

[2] Paul Behrens and Matthew Hayek, “Letter to Dr Tiensin: Retraction Request – FAO’s Pathways toward Lower Emissions Report,” April 9, 2024, https://www.universiteitleiden.nl/binaries/content/assets/science/cml/essays/retraction-request-pathways-to-lower-emissions.pdf.

[3] NOTE: These are estimated savings if the EAT-Lancet diet was adopted globally. The EAT-Lancet Planetary Health Diet was a diet modelled by the EAT–Lancet Commission of scientists and experts aiming to achieve healthy diets for all, within planetary boundaries. For more info, see: https://eatforum.org/eat-lancet-commission/the-planetary-health-diet-and-you/  Behrens and Hayek mention the “6 to 40” estimate in: Arthur Neslen, “UN Livestock Emissions Report Seriously Distorted Our Work, Say Experts,” The Guardian, April 19, 2024, sec. Environment, https://www.theguardian.com/environment/2024/apr/19/un-livestock-emissions-report-seriously-distorted-our-work-say-experts.

[4] Arthur Neslen, “‘The Anti-Livestock People Are a Pest’: How UN Food Body Played down Role of Farming in Climate Change,” The Guardian, October 20, 2023, sec. Environment, https://www.theguardian.com/environment/2023/oct/20/the-anti-livestock-people-are-a-pest-how-un-fao-played-down-role-of-farming-in-climate-change.

[5] Paul Behrens and Matthew Hayek, “Letter to Dr Tiensin: Retraction Request – FAO’s Pathways toward Lower Emissions Report,” April 9, 2024, https://www.universiteitleiden.nl/binaries/content/assets/science/cml/essays/retraction-request-pathways-to-lower-emissions.pdf.

[6] Paul Behrens and Matthew Hayek, “Letter to Dr Tiensin: Retraction Request – FAO’s Pathways toward Lower Emissions Report,” April 9, 2024, https://www.universiteitleiden.nl/binaries/content/assets/science/cml/essays/retraction-request-pathways-to-lower-emissions.pdf.

[7] ASEAN, “Food-based dietary guidelines – Spain,” Food and Agriculture Organization of the United Nations, 2022, http://www.fao.org/nutrition/educacion-nutricional/food-dietary-guidelines/regions/spain/es/.

[8] Deutsche Gesellschaft für Ernährung e. V., “DGE-Ernährungskreis,” Deutsche Gesellschaft für Ernährung e. V., 2024, http://www.dge.de/gesunde-ernaehrung/gut-essen-und-trinken/dge-ernaehrungskreis/.

[9] C. Mbow et al., “Food Security. In: Climate Change and Land: An IPCC Special Report on Climate Change, Desertification, Land Degradation, Sustainable Land Management, Food Security, and Greenhouse Gas Fluxes in Terrestrial Ecosystems” (IPCC, 2019), https://www.ipcc.ch/site/assets/uploads/sites/4/2021/02/08_Chapter-5_3.pdf Chapter 5 p488.

[10] Arthur Neslen, “UN Livestock Emissions Report Seriously Distorted Our Work, Say Experts,” The Guardian, April 19, 2024, sec. Environment, https://www.theguardian.com/environment/2024/apr/19/un-livestock-emissions-report-seriously-distorted-our-work-say-experts.

[11] FAIRR, “FAIRR Comments on Request by Academics for Retraction of FAO Report | FAIRR,” FAIRR, April 30, 2024, https://www.fairr.org/news-events/press-releases/fairr-comments-on-request-by-academics-for-retraction-of-fao-report.

[12] Michael A. Clark et al., “Global Food System Emissions Could Preclude Achieving the 1.5° and 2°C Climate Change Targets,” Science 370, no. 6517 (November 6, 2020): 705–8, https://doi.org/10.1126/science.aba7357; Behrens and Hayek, “Letter to Dr Tiensin: Retraction Request – FAO’s Pathways toward Lower Emissions Report,” April 9, 2024 https://www.universiteitleiden.nl/binaries/content/assets/science/cml/essays/retraction-request-pathways-to-lower-emissions.pdf.

[13] P.R. Shukla et al., “Climate Change and Land: An IPCC Special Report on Climate Change, Desertification, Land Degradation, Sustainable Land Management, Food Security, and Greenhouse Gas Fluxes in Terrestrial Ecosystems – Technical Summary” (IPCC, 2019), 49, https://www.ipcc.ch/site/assets/uploads/sites/4/2020/07/03_Technical-Summary-TS_V2.pdf.

[14] C. Mbow et al., “Food Security. In: Climate Change and Land: An IPCC Special Report on Climate Change, Desertification, Land Degradation, Sustainable Land Management, Food Security, and Greenhouse Gas Fluxes in Terrestrial Ecosystems” (IPCC, 2019), https://www.ipcc.ch/site/assets/uploads/sites/4/2021/02/08_Chapter-5_3.pdf Chapter 5 p488.

[15] Helen Harwatt et al., “Options for a Paris-Compliant Livestock Sector: Timeframes, Targets and Trajectories for Livestock Sector Emissions from a Survey of Climate Scientists” (Harvard Law School Animal Law and Policy Program, March 2024), https://animal.law.harvard.edu/wp-content/uploads/Paris-compliant-livestock-report.pdf.

[16] Shefali Sharma, is a Global Agriculture Campaigner with Greenpeace Germany

A UN report launched at COP28 contained major errors downplaying the huge emissions saving potential of lower-meat diets – an embarrassing error, or bowing to the livestock industry?

Feedback has coordinated a joint-letter signed by over 100 organisations and leading experts from around the world, calling on the United Nations Food and Agriculture Organization (FAO) to urgently retract a report because it contains serious errors, which significantly understate the emissions saving potential of shifts to lower-meat diets – playing into the livestock industry.

The FAO made its misleading claims based mainly on two scientific papers. But here’s the problem: earlier this year, two of the academics who co-authored those papers called on the FAO to retract the report for seriously distorting their work. The academic experts Paul Behrens and Matthew Hayek identified serious errors in the FAO report, saying to the Guardian “The FAO’s errors were multiple, egregious, conceptual and all had the consequence of reducing the emissions mitigation possibilities from dietary change far below what they should be. None of the mistakes had the opposite effect.”

The scale of this distortion is staggering – Behrens and Hayek estimate that the emissions mitigation from dietary change in line with the EAT-Lancet diet is between 6 and 40 times higher than the FAO’s estimates!

How did the FAO get it so wrong? Some of the mistakes committed by the FAO are embarrassingly basic and objectively wrong – like double-counting meat emissions, mixing different baseline years in its analysis, and including fruit and vegetable emissions unrelated to replacing meat – which all have a big effect on the results. Commenting on this, Hayek said “It wasn’t just like comparing apples to oranges. It was like comparing really small apples to really big oranges.” The rest are inappropriate and biased modelling choices, such as ignoring the potential carbon sequestration from restoring nature on land spared by dietary change, and choosing to only model very unambitious levels of meat reduction in diets.

This leads to the question: Did the United Nations Food and Agriculture Organization (FAO) just make some extremely embarrassing errors? Or did it intentionally distort evidence under pressure from the livestock industry? Either way, the FAO has questions to answer. Unless rectified, these mistakes are a stain on the FAO’s reputation.

Our joint-letter to the FAO’s Director-General backs up Behrens and Hayek’s call for the damaging FAO report to be retracted. It has been supported by 78 organisations and 23 academics and experts from around the world, including Greenpeace, Changing Markets, Friends of the Earth US, ActionAid US, Seeding Sovereignty, investor Adasina Social Capital, Connecticut State Representative David Michel, and over 20 academics and experts.

We raise concern over a media report from 2023 where former FAO staff spoke out, saying they had been sidelined and censored by the FAO for highlighting the high emissions of livestock and more plant-based diets as an effective solution. This reportedly followed lobbying from high livestock-producing companies and countries in backlash to FAO publications like Livestock’s Long Shadow. As a result, we call for “a comprehensive investigation of how these serious errors and systemic biases were allowed”.

The FAO’s new report, by accident or design, seems to play into the hands of big livestock companies – whilst downplaying dietary change as a solution, it enthusiastically advocates for the intensification of livestock. The livestock industry were quick to leap on this – Merel van der Mark, Senior campaigner at Rainforest Action Network, reports that “It was shocking to hear JBS, the world’s largest meat packer, proclaim at an event during the COP in Dubai, that the report just released by the FAO showed that meat was ‘not the problem, but the solution to the climate crisis’”.

That’s why our joint-letter calls for the FAO to urgently retract and reissue its report only once the methodological errors it contains have been rectified, drawing on more appropriate and up-to-date studies and following engagement in serious dialogue with independent academics and experts from civil society. We also recommend that the release of the FAO’s 2050 Roadmap should be delayed until it has adopted “more robust, inclusive and transparent processes”.

There is a strong scientific consensus that one of the most effective ways to reduce emissions from the food system is a shift towards lower-meat, more plant-based diets. A recent survey of over two hundred climate scientists and food and agriculture experts, over half of whom have authored IPCC reports, found that global livestock emissions need to be reduced by 50% by 2030 and 61% by 2036, and that reducing human consumption of livestock products and reducing the number of livestock animals have the highest potential for reducing livestock emissions, whilst intensification of livestock was rated as the measure with lowest potential.

The International Panel on Climate Change (IPCC) found, with “high confidence”, that a shift to more plant-based diets could mitigate GHG emissions by between 0.7 – 8 GtCO₂-eq per year, with higher reductions in meat and dairy leading to higher emission reductions. For instance, the IPCC cites a study which estimates that a flexitarian diet (75% of meat and dairy replaced by cereals and pulses, with only one portion of red meat a week) would reduce global emissions by approximately 5 GtCO₂-eq per year. That is over 9 times higher than the FAO’s estimate.

It is shocking that a United Nations institution like the FAO, which has so much global influence and is looked to as a reliable scientific authority, should distort evidence so flagrantly in favour of the livestock industry. The FAO must act now to restore its reputation and stop spreading misinformation.

Two locations, five days and an unquantifiable number of meaningful conversations — the Feedback team has just returned from Greece where we attended the Our Oceans conference in Athens and the Seas of Change Summit on Industrial Fish Farming in Poros, a small island in the Saronic Gulf fighting plans to install sea bass farms along a quarter of its stunning coastline.

On the surface of it both events set out with the same objectives: to bring together the global community to discuss and address the challenges that face our oceans, ranging from climate change to overfishing and environmental degradation. However, after diving into both events, we’ve resurfaced with very contrasting impressions.

Our Oceans

The Our Ocean Conference (OOC) was first launched under the initiative of the U.S. Department of State and the Secretary of State John Kerry in 2014. This year was the 9th Our Ocean conference hosted in Athens, Greece. The theme for this year’s conference was ‘An Ocean of Potential’, claiming the conference ‘presents an opportunity for all stakeholders to join forces in delivering accelerated, transformative action.’

Governments and international bodies uncritically back the expansion of (industrial) aquaculture 

We were shocked by the uncritical embrace of aquaculture on display at the Our Ocean conference, despite the sector’s many well-documented social and environmental impacts.  

Our recent Blue Empire report details how Norwegian salmon farms are depleting our seas as a result of farmed salmon’s voracious appetite for wild fish, depriving millions in the Global South of vital nutrients. But when we attended a side event on food security and blue foods (the only event specifically addressing fish farming), all we heard from the panellists was a headlong enthusiasm for the growth of aquaculture worldwide, without offering any critical perspectives.  

From the UN Food and Agriculture Organisation (FAO) representative to the Norwegian Deputy Minister of Foreign Affairs, there was a complete lack of nuance or consideration of the damage intensive fish farming is wreaking to wild fish populations, the environment and people’s livelihoods in some of our most vulnerable communities. 

Climate justice needs to be central

Despite various events centring voices from those most affected by the climate crisis, we found that climate justice was deprived of the centre stage it deserves. 

Events that offered climate justice perspectives tended to be hosted at either lunch time or at the end of the day with the result that they attracted smaller audiences than others. For example, a plenary of the with Heads of State and Government of small island states, which are facing a truly existential threat as a result of climate change, was scheduled as the last event of the day, meaning it was poorly attended. The audience for the most important event of the day dwindled to a handful of people by the end of the session. Climate justice needs to be at the heart of every discussion on climate.  

Seas of Change

The Seas of Change summit in Poros, Greece was the highlight of our trip, bringing together communities, political representatives, scientists and NGOs from across the world, ranging from Greece and Spain to far-flung Argentina and Tasmania. The aim of the event was to discuss the growing threat of industrial carnivorous fish farming on our shores, in particular in the EU.

Industrial fish farming is increasingly dominated by multi-billion-dollar corporations 

Globally, large multinational corporations are aggressively driving the charge on the expansion of fish farming. From Avramar in Europe; MOWI in Norway, Scotland and Chile; JBS in Tasmania, the expansion of destructive fish farming shows no signs of slowing down. Across the world, corporations are taking advantage of the ocean, which is supposed to be a global public good, demonstrating their ruthless pursuit of profit at the expense of communities and the environment.  

Despite challenges from communities on the negative local environmental and economic impacts, the companies, backed by huge financing from banks and in the form of public subsidies, continue to push for rapid growth, whilst presenting their industry as the solution to feeding the world.  

The movement against destructive fish farming is global and growing

As the industry has expanded worldwide, affecting people at every stage of the supply chain, destructive fish farming has become a global issue. Given how destructive the industry is, it is no surprise that campaigning against intensive fish farming is also going global, uniting communities worldwide around a common cause.  

We were lucky enough to meet people actively resisting destructive fish farming around the world, from Argentina, Tasmania, Norway, US, Spain and the UK. The diversity of the movement was reflected in the diversity of tactics used in campaigns. We saw examples of documentaries, art installations, demonstrations, petitions, academic research, legal action, surveys and lobbying. As corporates are growing, the resistance movement is growing in strength too. 

We were particularly inspired by the local organisations in Argentina, now known as the Global Salmon Farming Resistance (GSFR), who successfully campaigned for industrial salmon farming to be banned. Their story demonstrated the power of persistent campaigning.  

With public awareness rising on the negative impacts of fish farming and the growing global momentum, we can remain ‘stubbornly optimistic’ that we will continue to see even more examples of successful campaigns. 

This was the first time the summit had taken place, but participants collectively brought decades of expertise and experience to the table, leaving us feeling energised and ready to embark on the next stage of our work together as a movement.  

On 21 December 2023, the tribunal of the Court of Appeal, presided over by Sir Keith Lindblom, recent resignee of the Garrick Club, dismissed Foodrise’s claim for judicial review of the government’s Food Strategy. Aside from putting a significant damper on my year end festivities, the tribunal’s judgment has far reaching and alarming implications for the UK’s plans to cut carbon to net zero.

When the Climate Change Act 2008 was passed, it seemed the government finally had a response to the threat of climate deregulation. Reassuringly, Section 13 of the act states that “The Secretary of State must prepare such proposals and policies as (they) consider will enable the carbon budgets (…) to be met”. Of further comfort was the establishment of the government’s climate change advisory body, the Climate Change Committee (CCC). Fast forward to the 2020s, however, and hope that this once pioneering framework legislation could lead to meaningful emissions reduction has all but been dashed.

In the food, land use and farming sector, Foodrise’s areas of interest, government initiatives to tackle climate change have been scant. This is despite agriculture generating some 12 per cent of national greenhouse gas emissions, and repeated calls from the CCC to curb them, most notably through lower production and consumption of meat and dairy. This is a political hot potato neither the current government, nor seemingly the next, wish to countenance.

The Food Strategy was supposed to support net zero

In October 2021, the government duly published its periodic Net Zero Strategy, as required under the Climate Change Act. Predictably, there was no mention of meat and dairy reduction – or food and agriculture more generally – but the government instead pointed to the upcoming Food Strategy, which was to “support the delivery of net zero, nature recovery and biodiversity commitments”. This statement suggested to us that the Food Strategy would ‘cover’ emissions reduction in the food and farming sector, that it would be the place where the government would finally unveil a suite of measures to, as it said, “incentivise farmers to produce (…) food in the most sustainable way”.

When it was eventually published, in June 2022, after much delay, Lord Deben, then the CCC’s chair, said that the Food Strategy did “precious little to tackle emissions from agriculture which is now one of the most serious contributors to climate change”. The rest of us, not bound by position, just said it was “total rubbish”. Dismayed that a crucial opportunity to tackle climate change had been squandered, we decided to apply for a judicial review of the Food Strategy, enlisting the services of solicitors Leigh Day.

Several refusals, appeals and permissions later, and after several changes to our grounds, the questions put before the Court of Appeal were, as follows:

• Was the duty under Section 13 of the Climate Change Act engaged in the development and adoption of the Food Strategy? That is to say, should the secretary of state have put in place the proposals and policies to meet carbon budgets in the strategy?
• And, if so, when adopting the strategy, did the secretary of state need to give significant weight to, and give cogent reasons from the advice of the CCC on emission reducing measures in food and farming, especially on meat and dairy?

It turns out, the answer to both these questions is a unanimous ‘no’. And now for those alarming implications for the UK’s ability to meet its climate goals.

In answering the first question, the court ruled that the secretary of state referred to in Section 13 of the Climate Change Act was the secretary of state for the Department for Business, Energy and Industrial Strategy (BEIS), now the Department for Energy Security and Net Zero (DESNZ).  It ruled that only the secretary of state for DESNZ has responsibility under the act to put in place proposals and policies to meet carbon budgets, under Section 13.

The secretary of state for the Department for Environment, Food and Rural Affairs (Defra), who signed off the Food Strategy, has no such legal obligation, neither does the secretary of state for transport, or any other department for that matter. The secretary of state for DESNZ, however, has the task of ensuring that proposals and policies “taken as a whole”, across ministries, enable carbon budgets to be met. In doing so, they, as the ruling put it, “may take into account the proposals and policies that other Secretaries of State may prepare”, but the preparation of such policies is tentative and discretionary.

The DESNZ secretary of state’s job to ensure carbon budgets are met is made difficult – perhaps even impossible – by the fact that their counterparts in other ministries do not need to lift a finger to reduce carbon emissions, if they don’t want to. They can instead continue to churn out strategies that ignore this imperative.

And so, the ruling established that secretaries of states – other than DESNZ – are not compelled under the Climate Change Act to develop proposals and policies to reduce emissions. They are not bound by the Section 13 obligation. The act fails to make emissions reduction a core project of all ministries. And, since we know emissions must be reduced across the board, in food, farming, aviation, everywhere, it’s hard to see how the government can plan and make this happen. It seems it can’t.

CCC advice can be ignored

In answering the first question, the second became purely academic and did not need to be addressed. Alas, it was, and the ruling on the second question was startling to my legally untrained eyes and ears: “…we do not doubt that the CCC have the power to give such advice (…) [ie on measures to meet carbon budgets]. It does not follow, however, that the Secretary of State is under a duty to take it into account.”

In other words, the CCC can advise away all it pleases, but the government need not engage with its advice at all. Despite the ruling, it seems unlikely to me that parliamentarians who voted for the act in 2008 envisaged the CCC as a provider of ignorable expert advice, wasting both its time and our money. Not only that, from whom is the government supposed to get advice on proposals to meet its carbon budgets, if not from its own climate advisers, the body with a statutory mandate to provide it? The government’s track record, in food and farming at least, suggest the answer is from no one.

At the time of writing, we have filed for permission to appeal in the Supreme Court. If that is not granted, it will be the end of the road for this case. If it is granted, Foodrise will face an uphill battle to raise the legal fees to proceed. Should we succeed in this, our legal team will make the case to the Supreme Court that the Court of Appeal’s ruling was a terrible mistake. Let’s hope it can be corrected because, as things stand, while the targets set out in the Climate Change Act have the right level of ambition, the implementation framework is such that net zero can’t and won’t be met.

Addendum: Unfortunately, the permission to appeal in the Supreme Court was refused on 8^th May, because ‘the application does not raise an arguable point of law’. Naturally, our lawyers would dispute this reason, but it is nonetheless the end of this legal challenge. The implications for the scope and effectiveness of the Climate Change Act as described in this blog stand and the need for climate legislation that is both ambitious and implementable is more pressing than ever.

This blog was originally published by Green Alliance.

Billion-dollar financing is driving unsustainable increases in global meat and dairy production, a report has found.