Data story: Key signals in food waste reduction — emerging standards
New food waste disclosure requirements are reshaping buyer expectations — CSRD, SEC, and voluntary frameworks create a patchwork of emerging standards for 2025 and beyond.
Data story: Key signals in food waste reduction — emerging standards
Food waste disclosure is transitioning from voluntary initiative to regulatory requirement. CSRD mandates waste reporting for EU operations. California's SB 1383 requires organic waste diversion tracking. Major buyers increasingly demand supplier waste metrics. Five signals reveal the emerging standards shaping buyer requirements.
Quick Answer
Food waste disclosure standards are converging around the Food Loss and Waste Protocol methodology, with regulatory mandates accelerating adoption. CSRD requires waste disclosure for large EU companies starting 2024. US federal contractors face new sustainability reporting. Major retailers are embedding food waste metrics in supplier scorecards. Companies should prepare for standardized measurement, third-party verification, and public target-setting.
Signal 1: CSRD Waste Disclosure Requirements
The Data:
- Companies affected: 50,000+ under CSRD (EU operations)
- Waste disclosure: ESRS E5 requires comprehensive waste metrics
- Food sector specificity: ESRS agriculture and food sector standards in development
- Timeline: First reports due 2025 (for 2024 data)
What It Means:
The EU Corporate Sustainability Reporting Directive creates mandatory waste disclosure requirements with standardized metrics and assurance.
ESRS E5 Requirements:
- Total waste generated by category
- Waste diverted from disposal (recycling, composting, recovery)
- Waste directed to disposal (landfill, incineration)
- Hazardous vs. non-hazardous classification
- Circular economy practices and material reuse
Food-Specific Considerations:
- Food waste as percentage of total waste
- Destination hierarchy tracking (human consumption, animal feed, compost, landfill)
- Upstream and downstream waste (Scope 3 equivalent for materials)
- Reduction targets and progress
Verification Requirements:
Limited assurance required initially, moving to reasonable assurance. Third-party auditors must verify waste data accuracy and methodology compliance.
Signal 2: US Regulatory Landscape Fragmenting
The Data:
- State mandates: 8 states with organic waste diversion requirements
- California SB 1383: 75% organic waste reduction target by 2025
- SEC climate rules: Scope 3 emissions (including waste) for large filers
- Federal contractors: New sustainability disclosure requirements
What It Means:
Unlike the EU's harmonized approach, US food waste regulation is emerging through state-level mandates and sector-specific requirements.
California SB 1383 Requirements:
- 50% reduction in organic waste disposal by 2020 (achieved)
- 75% reduction by 2025 (in progress)
- 20% edible food recovery for human consumption
- Mandatory organics collection for all residents and businesses
- Penalties for non-compliance starting 2024
Other State Requirements:
- Vermont: Universal recycling law includes food scraps
- New York: Food waste recycling for large generators
- Massachusetts: Commercial organic waste ban
- Connecticut: Large generator food waste requirements
Federal Trajectory:
SEC climate disclosure includes Scope 3 emissions for large accelerated filers. Food waste in supply chains contributes to Scope 3. Federal contractor sustainability requirements expanding.
Signal 3: Voluntary Frameworks Gaining Traction
The Data:
- 10x20x30 participants: 35 retailers engaging 700+ suppliers
- FLW Protocol adoption: 60+ major food companies
- Science Based Targets (FLAG): Forest, land, and agriculture targets including waste
- CDP reporting: Food waste module launched 2023
What It Means:
Before regulation mandates disclosure, voluntary frameworks are establishing best practices and creating pressure for transparency.
Food Loss and Waste Protocol:
The FLW Protocol (developed by WRI, WBCSD, and others) provides standardized:
- Definitions distinguishing loss vs. waste
- Quantification methodology (weight-based)
- Boundary-setting for scope
- Destination categorization
- Reporting templates
CDP Food Security Questionnaire:
CDP launched food-specific disclosure covering:
- Food waste generation and disposal
- Reduction targets and strategies
- Supply chain engagement
- Water and biodiversity linkages
Champions 12.3:
This CEO-led coalition commits to SDG 12.3 (halving food waste by 2030). Member companies report progress annually using FLW Protocol methodology. Progress: 15% average reduction among active participants.
Signal 4: Buyer Requirements Cascading to Suppliers
The Data:
- Retailer requirements: 70% of major retailers now ask suppliers about food waste
- Supplier scorecards: Waste metrics appearing in 40% of assessments
- Contract provisions: Food waste reduction clauses in 25% of new contracts
- Preferred supplier status: Waste performance influencing sourcing decisions
What It Means:
Major buyers are embedding food waste requirements in procurement, creating market-based incentives independent of regulation.
Walmart Project Gigaton:
Walmart's supplier sustainability initiative includes:
- Food waste reporting for food suppliers
- Reduction targets aligned with SDG 12.3
- Recognition for top performers
- Technical assistance for improvement
Tesco Supplier Requirements:
Tesco mandates food waste disclosure from all food suppliers:
- Annual waste reporting using standardized template
- Reduction plans for suppliers above threshold
- Third-party verification for large suppliers
- Preferred terms for leaders
Foodservice Operators:
Sodexo, Compass Group, and Aramark all require supplier waste metrics and include performance in sourcing decisions.
Signal 5: Investor Expectations Increasing
The Data:
- ESG integration: 80% of major investors consider food waste material
- Engagement campaigns: FAIRR investor network engaging 30+ food companies on waste
- Risk framing: Food waste as operational risk, regulatory risk, and stranded asset risk
- Valuation impact: Studies showing 2-5% valuation premium for waste leaders
What It Means:
Investors increasingly view food waste as material financial issue, creating pressure for disclosure and improvement.
Investor Concerns:
- Operational efficiency: Waste represents lost margin
- Regulatory risk: Compliance costs and penalties
- Supply chain resilience: Waste signals inefficiency
- Brand and reputation: Consumer sentiment on sustainability
- Climate exposure: Food waste as emissions source
FAIRR Waste Index:
The FAIRR Initiative ranks major food companies on waste management:
- Disclosure quality and completeness
- Target ambition and progress
- Strategy and governance
- Supply chain engagement
Companies with poor scores face engagement letters and potential divestment.
Preparing for Compliance
Immediate Actions (2025)
- Implement FLW Protocol measurement across operations
- Establish baseline by product category and facility
- Set reduction targets aligned with SDG 12.3 (50% by 2030)
- Begin supplier engagement on waste disclosure
Medium-Term (2026-2027)
- Extend measurement to Scope 3 (supplier and customer waste)
- Prepare for third-party verification requirements
- Integrate waste metrics into financial planning
- Develop public reporting in line with CSRD/ISSB
Long-Term (2028+)
- Achieve reasonable assurance level verification
- Embed waste in product design and supply chain decisions
- Link executive compensation to waste targets
- Report alongside financial statements
Action Checklist
- Assess which disclosure frameworks apply (CSRD, SEC, state mandates)
- Implement FLW Protocol measurement methodology
- Establish multi-year baseline for year-over-year comparison
- Set public reduction targets aligned with SDG 12.3
- Develop supplier engagement program on waste disclosure
- Prepare for third-party verification requirements
- Integrate waste metrics into investor communications
- Build internal capacity for ongoing measurement and reporting
FAQ
Which disclosure framework should we prioritize? If operating in the EU, CSRD is mandatory and should drive primary methodology. Align with FLW Protocol (referenced by CSRD) for interoperability with other frameworks (CDP, voluntary initiatives).
How do we measure supplier food waste? Request standardized disclosure using FLW Protocol template. Provide training and support for smaller suppliers. Use industry averages for suppliers unable to report, while building capacity for primary data.
What targets are considered ambitious? SDG 12.3 calls for 50% reduction by 2030 from 2015 baseline. Science Based Targets FLAG guidance provides sector-specific pathways. Targets below 30% reduction may face investor scrutiny.
How much does compliance cost? Implementation costs vary by complexity: $50,000-200,000 for initial measurement systems, $20,000-50,000 annually for third-party verification. Many companies find savings from waste reduction exceed compliance costs.
Sources
- European Commission. "ESRS E5 Resource Use and Circular Economy." EC, 2024.
- California Air Resources Board. "SB 1383 Implementation Status." CARB, 2024.
- World Resources Institute. "Food Loss and Waste Protocol." WRI, 2024.
- FAIRR Initiative. "Appetite for Disruption: Food Waste Report." FAIRR, 2024.
- Champions 12.3. "2024 Progress Report." WRI, 2024.
- CDP. "Food Security Questionnaire Guidance." CDP, 2024.
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