A significant practical difference that distinguishes the labelling approach recommended in this report for environmental impact (especially GHG emissions) from that recommended for nutritional content is inherent in the nature of these attributes: The ideal content in most food ingredients is often a matter of optimal dose and also varies with the physiology of the consumer. In contrast, the GHG emissions attribute exhibits a clear normative direction of the “less is better” type: it is always good to emit less GHG. It is better to emit none, and it is even best to be most negative in emissions, i.e. to absorb as much GHC as possible (e.g. through carbon offsetting). Furthermore, it is by now scientifically established and overwhelmingly accepted that the simultaneous deterioration of multiple environmental parameters poses a severe threat, with overarching catastrophic effects of human-induced climate change foreseen at all levels (social, economic, and also on the biodiversity and on broader ecosystems). These parameters, namely the clear definition of the problem and the clear normative direction of the change needed mark a stark difference between the two issues analysed in this report. In a sense, when dealing with the environmental issue we have the more fortunate situation that the enemy, so to speak, namely greenhouse gasses – GHG, is clear and what needs to be done is beyond doubt as well: to reduce their concentration in the atmosphere as much as possible. This is particularly important in connection to food production, which amounts to about a quarter of total manmade GHG emissions globally. The problem, however, is not as simple when it comes to how to achieve this reduction in the present political and economic context. Despite decades of warnings, by now we have already missed the opportunity to avoid catastrophic effects of climate change and the time available to mitigate them also runs out.62 In this regard, the prospect of an EU-wide Front-of-Pack (FoP) environmental labelling initiative, even if it applies only to food products, is certainly a move in the right direction.

Product labelling is a tool long used in efforts to remove information asymmetry that prevents ethical consumerism from optimizing the levels of unobservable (credence) product attributes in the market. Such labelling initiatives succeeded to bring some improvement through product certification and also through positive spill over effects to the broader production sector. However, decades of experience shows that the progress achieved is insufficient as compared (a) to the magnitude of the environmental challenges and of the sheer scale of changes needed to address them, and (b) to the potential for ethical consumerism that remains available as indicated by consistent research results showing increased environmental concern among the international public. In this context, the present report begins with a critical assessment of the functionality of established label types that are typically used to facilitate ethical consumerism. This critical assessment advances the view that the established product labelling paradigm suffers from functionality limitations that do not allow ethical consumerism to develop into a mainstream market force of a magnitude sufficient to incentivize the much needed, substantial, and widespread, improvements in the environmental performance of the supply sector, causing the market for environmentally friendly products to fail. These functionality limitations essentially cancel from the outset any hope that a conventional EU-wide nutrition and environmental label will be the much-needed game-changer that will radically transform the environmental impact of food production.