Energy and Climate Change CommitteeMemorandum submitted by the Food Ethics Council

1. The Food Ethics Council (FEC) is a charity that provides independent advice on the ethics of food and farming. The 15 members of the FEC are leaders in their relevant fields, and appointed as individuals. They bring a range of expertise to our work, from academic research through to practical knowledge of farming, business and policy.

2. With WWF-UK, the FEC has produced three papers exploring policy opportunities to enable sustainable food consumption.1 In particular, the papers have contributed to debate over the role of changes in meat consumption in mitigating climate change. This work has facilitated a constructive conversation about this emotive issue among farming organisations, environmental groups and policy makers, underpinned by analysis of the potential environmental, animal welfare, economic and social impact of a wide range of possible policy interventions. This response draws on that work.

How do assessments of the UK’s greenhouse gas emissions differ when measured on a consumption rather than a production basis?

3. Defra reports that, across the economy as a whole, a 20% rise in UK consumption-related emissions since 1990 has outstripped reductions in emissions from domestic production.2

4. Globally, emissions associated with production have been falling in rich countries committed to reporting and to making reductions under the UN Framework Convention on Climate Change (UNFCCC; these countries are known as Annex B countries). However, increases in consumption within those countries, met mainly by imports from China, India and Brazil, have contributed to an overall increase in global emissions.3

5. Agriculture is estimated to account directly for around 10-12% of global greenhouse gas emissions, rising significantly, by some models up to 32%, if the effects of agriculture-related land use change and food supply chains are also included.4 In the UK, agriculture and food chain emissions are estimated to account for between 20% and 30% of total emissions by consumption, with the larger figures including emissions associated with land-use change overseas.5 Agricultural and food chain emissions do not appear to account for a large share of the overall transfer from Annex B to non-Annex B countries.6

6. Nevertheless, “off-shoring” appears to be an issue in the UK food chain, where a quarter of emissions currently derive from net imports.7 Since methods of accounting for soil carbon loss and emissions from land use change remain in development, estimates of food chain emissions should be treated with caution. However, a growing UK agricultural trade deficit since 1990,8 and high overseas rates of land use change for food and feed production point in the towards significant off-shoring.

What are the benefits and disadvantages associated with taking a consumption-based rather than a production-based approach to greenhouse gas emissions accounting?

7. We consider that there are considerable advantages to taking a consumption-based approach to greenhouse gas emissions accounting, but would see this as an adjunct to production-based approaches, rather than as an alternative.

8. A consumption-based approach provides a basis for addressing the massive net transfer of emissions from Annex B to non-Annex B countries, which has so far frustrated efforts to reduce overall global emissions. In seeking to close this loophole, it will be crucial to respect the UNFCCC principle that countries should mitigate emissions based on “equity and in accordance with their common but differentiated responsibilities and respective capabilities”.9 Combining production- and consumption-based approaches appears to provide a fairer and more realistic basis for doing so than the alternative, which is to impose strict production-based emissions reduction targets on non-Annex B countries.

9. Within the food chain, models of the potential for technical abatement of greenhouse gas emissions, for example through improvement in production efficiency, will not be sufficient to ensure that agriculture plays a proportionate part in meeting the UK’s target to reduce emissions 80% by 2050. Looking beyond the 2020 target, changes in diet towards less greenhouse gas-intensive foods are also likely to be necessary, implying changes in consumer behaviour. So there is a case for consumer behaviour change from production-based analytical perspective. However, consumption-based accounting provides a stronger and more direct rationale for consumer behaviour change. Consuming less greenhouse gas-intensive diets evidently provides a mechanism for the UK to lower its overall contribution to global emissions, yet the incentives for UK policy to achieve these reductions is diminished if the sole accounting system is production-based and a significant share of the benefits accrue “off book”, in other countries.

10. The farming sector has been wary of consumption-based approaches greenhouse gas accounting and mitigation, as these have often taken the form of public campaigns for consumers to eat less meat – a product that many farmers rely on selling for a livelihood. However, our analysis suggests that the farming sector has an economic interest in supporting a greater policy focus on consumption-based accounting, and our experience shows that farming industry bodies are willing to recognise that.

11. The farming sector’s economic interest in supporting consumption-based approaches to greenhouse gas emissions accounting relates to their long-standing concern that the UK’s leadership across areas of policy including climate change and animal welfare burdens UK producers with additional costs, drives UK retailers to source from overseas, and simply off-shores the problems UK policies were intended to address. This problem is invisible within a production-based approach to greenhouse gas accounting, which would register progress against the UK’s emissions targets if consumption remain unchanged and UK farmers were simply reducing production and losing business to overseas competitors. The UK farming industry has also been keen to point to the UK’s potential environmental comparative advantage in certain forms of agricultural production, and farming organisations have recognised that these advantages can only be recognised and incentivised through consumption-based approaches to accounting.

12. It has proved easier for farming organisations to endorse a consumption-based approach to greenhouse gas accounting than a consumption approach to mitigation (ie consumer behaviour change). Farmers have shown a preference for mitigation measures that are within their control as producers, especially where they are likely to yield cost savings. However, we have found producer organisations will to recognise that:

(a)some production-based mitigation measures will save farmers money while others will carry a net cost, as illustrated by marginal abatement cost curves for agriculture;10

(b)likewise, it is possible to envisage consumption-based mitigation strategies that either benefit or harm the sector’s profitability; and

(c)that it therefore makes sense for producers to engage in efforts to develop consumption-based greenhouse gas mitigation strategies that contribute to the overall environmental, social and economic sustainability of their sector, rather than assuming initiatives to promote more sustainable consumer behaviour are necessarily a threat to their industry.

Would it be (a) desirable and (b) practicable for the UK to adopt emissions reduction targets on a consumption rather than production basis?

13. For the reasons outlined above, we consider that it is very desirable for the UK to adopt emissions accounting, and reduction targets on a consumption basis. This should be as well as, not instead of, production-based targets.

14. We are not well-placed to comment on the practicality of such an approach. However, we suggest that the benefits are sufficiently significant that it would have to be immensely impractical for there to be any justification not to proceed in this way.

October 2011


1 MacMillan, T & Durrant, R (2009) Livestock consumption and climate change: a framework for dialogue. Food Ethics Council and WWF-UK. MacMillan, T and Middleton, J (2010) Livestock consumption and climate change: progress and priorities. Food Ethics Council and WWF-UK. WWF-UK and Food Ethics Council (2011) A square meal: how encouraging greener eating fits the UK government’s ambitions for the environment, farming and the Big Society. WWF-UK and FEC.

2 Defra (2011) Greenhouse gas emissions relating to UK consumption.

3 Peters. G, Minx, J, Weber, C & Edenhofer, O (2011) Growth in emission transfers via international trade from 1990 to 2008. PNAS,

4 Garnett, T (2008) Cooking up a storm: food, greenhouse gas emissions, and our changing climate. Food Climate Research Network, Guildford.

5 Audsley, E, Brander, M, Chatterton, J, Murphy-Bokern, D, Webster, C, and Williams, A (2009) How low can we go? An assessment of greenhouse gas emissions from the UK food system and the scope to reduce them by 2050. WWF-UK.

6 Peters G, Minx, J, Weber, C & Edenhofer, O (2011) Growth in emission transfers via international trade from 1990 to 2008. PNAS, figure 5.

7 Defra (2010) Food statistics pocketbook. Defra, London.

8 Defra (2010) Food statistics pocketbook. Defra, London.

9 UNFCCC (1997) The Kyoto protocol to the United Nations Convention on Climate Change. Cited in Peters. G, Minx, J, Weber, C & Edenhofer, O (2011) Growth in emission transfers via international trade from 1990 to 2008. PNAS,

10 Committee on Climate Change (2010) The fourth carbon budget: reducing emissions through the 2020s. Committee on Climate Change, London.

Prepared 17th April 2012