American Frozen Food Institute
EPANonrulemakingEPA-HQ-OLEM-2022-0415

Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics

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Jun 22, 2024
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American Frozen Food Institute filings
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American Frozen Food Institute filed 1 comment on this docket between Feb 7, 2024 and Feb 7, 2024. 63 other organizations filed here. The comment window closed 906d ago.

What American Frozen Food Institute filed (1)

Feb 7, 2024· Comment submitted by American Frozen Food Institute (AFFI) et al.· EPA-HQ-OLEM-2022-0415-0157

Our organizations appreciate the opportunity to comment on the EPA, USDA, and FDA Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics ("draft Strategy"). These organizations represent businesses that produce frozen foods and utilize frozen warehouses and transportation to safely distribute frozen foods. Freezing and frozen foods play a vital role in any national strategy aimed at prevention and reduction of food loss and waste. In these comments, we delineate key steps such a strategy should immediately undertake to build needed infrastructure to galvanize food waste reduction efforts across the frozen food supply chain. Executive Summary We appreciate the work EPA, USDA, and FDA (the "agencies") have done to date and are supportive of the draft Strategy. The national goals to reduce food loss and waste by 50% and achieve a 50% recycling rate by 2030 are ambitious, complex, very challenging, and will require coordination and effort across many stakeholders. The frozen food industry is ready and eager to collaborate with the administration to work toward achieving these goals. To that end, it is critical to consider the role of frozen foods in a national strategy. Indeed, "freezing" is among the most ancient and natural methods of food preservation, designed to maintain nutritional value, taste, and texture. Freezing uses temperature to preserve foods; preservatives are not added to aid the freezing process or increase the shelf life of frozen foods. A framework inclusive of frozen foods is appropriate, necessary, and supported by the following points: 1.Frozen foods extend the shelf life of foods to allow for the reduction of waste at food service, retail, and particularly at the consumer level. 2.More and enhanced cold-chain infrastructure is needed both to ensure frozen foods are available for all consumers and to extend the shelf life of otherwise perishable products that may otherwise contribute to food loss at the farm production level. 3.Frozen foods provide affordable access to easy-to-prepare, nutrient-dense foods and play an essential role in promoting health equity. 4.The agencies should continue to consider how to reduce food loss and waste associated with food recalls. We address each of these points, as well as recommendations for future research, in more detail in the attached comments.

Abstract

The Environmental Protection Agency (EPA), U.S. Department of Agriculture (USDA) and Food and Drug Administration (FDA) have developed the Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics (“draft Strategy”) to help prevent the loss and waste of food, where possible, and increase recycling of food and other organic materials. The draft Strategy identifies concrete steps, and complementary EPA, USDA, and FDA actions, that will help accelerate the prevention of food loss and waste, where possible, and recycling of the remainder with other organic waste, across the entire supply chain. The actions detailed in this draft Strategy will help the U.S. meet its National Food Loss and Waste Reduction Goal to halve food loss and waste; contribute to reaching the National Recycling Goal to achieve a 50 percent recycling rate by 2030; and contribute to global achievement of the United Nations Sustainable Development Goal Target 12.3. Preventing food loss and waste and recycling food and other organic waste will also reduce landfill methane emissions, in support of the U.S. Methane Emissions Reduction Action Plan, which identified food waste prevention and organic waste diversion as the top two methane emissions reduction strategies for municipal solid waste.

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