Celebrating the EU Code of Conduct: what voluntary commitments has UNESDA made?
by Helen Benson, Scientific and Regulatory Affairs Director, UNESDA

The European Commission’s EU Farm to Fork conference today marks a timely point for all of us who are actively inputting to this groundbreaking strategy to pause and to reflect on what we have achieved so far. After all, it was only about a year and half ago in May 2020, just a few weeks into the initial outbreak of the COVID-19 pandemic in Europe, that the European Commission launched its Farm to Fork Strategy with the lofty aim of building more sustainable food systems.
The Farm to Fork Strategy was accompanied by a lengthy list of ambitious legislative and non-legislative measures. On the non-legislative side, an integral part of the Farm to Fork action plan and the first major flagship deliverable is the EU Code of Conduct for Responsible Food Business and Marketing Practices.
Food chain united around the EU Code of Conduct
It was truly impressive to see how the EU Code of Conduct succeeded in so rapidly bringing all sectors of the food chain together around a common vision. Intensive work started on drafting the Code in December 2020, after which there followed six months of rapid and productive collaboration between the European Commission, the food industry, retailers, NGOs and other key stakeholders. UNESDA was proud to be part of this inclusive process from the very start.
Defying all normal timelines for such an ambitious project, the Code was finalised only six months after conception and formally launched at a celebratory event on 5 July 2021. It was then that UNESDA, along with some of its members and over 50 stakeholders, signed the Code and announced concrete commitments to help accelerate the EU shift towards more sustainable food systems.
Why is the Code so relevant? First and foremost, it sets out the actions that the actors ‘between the farm and the fork’ can voluntarily commit to undertake to tangibly improve and communicate their sustainability performance. It contains a set of aspirational objectives, each with specific targets. But importantly the Code also ‘walks the talk’ as it also includes indicative, tangible and measurable actions to make healthy and sustainable food choices easier for all EU citizens.
UNESDA’s ground-breaking commitments to the EU Code of Conduct
UNESDA has a long history of self-regulatory action, being the first food industry association anywhere in the world to set out its pioneering ‘no marketing ANY products to kids’ policy, way back in 2006. This policy is not product-based and does not contain a ‘nutrient profile’. Why? Simply because UNESDA’s ethos is that children under 13 should not be directly targeted by any advertising or marketing for any product.
When we look back at the last 15 years, we can state with pride that UNESDA has created an efficient, effective and fast-track self-regulatory production line. With this, the EU soft drink sector has proven that voluntary initiatives are a nimble and effective tool to complement appropriate legislation.
On the occasion of the launch of the EU Code of Conduct on Responsible Food Business and Marketing Practices in July this year, UNESDA showed its proactive and responsible role once again. It submitted its commitments to the Code, and also underlined the need for the European Commission to create an enabling framework that helps achieve the goals of UNESDA’s commitments.
UNESDA’s commitments to the Code include our new and enhanced health and nutrition commitments and Circular Packaging Vision 2030 – thereby covering the two main aspirational objectives around healthy, balanced and sustainable diets and creating an optimised circular and resource-efficient food chain.
Our flagship commitment on health and nutrition is around sugar reduction – this time we commit to reducing the average added sugars in our beverages by another 10% from 2019-2025 across Europe. This will represent an impressive overall industry-wide commitment to a reduction of 33% in average added sugars over the past two decades, following up on our 14.6% reduction between 2015-2019.
When it comes to circularity of our packaging – this time we commit to achieve fully circular packaging by 2030, which means our packaging will be 100% recyclable, over 90% collected and using 100% recycled and/or renewable material. In our view, this is the definition itself of circularity in a closed loop bottle-to-bottle recycling process.
The UNESDA commitments follow the principles of “going further” and “materially relevant” to the European soft drinks sector, as requested by the European Commission. They are a mix of commitments going well beyond existing EU requirements, addressing areas not covered by EU legislation and enhancing and expanding on previous commitments made.
Creation of an ‘enabling framework’ will be key
As such, we are confident that they will significantly contribute to the European Commission’s objective of accelerating the transition to sustainable food systems. However, co-creating an enabling framework is of key importance to ensure targets are reached. We therefore continue to call on the European Commission and national authorities to work with industry to establish enabling, coordinated, coherent and complementary measures to help us achieve the goals of our commitments.
Code of Conduct the trampoline for a pan-stakeholder approach to future food sustainability
It is clear that the EU’s Farm to Fork Strategy has had an impressive start defying the odds, not least a pandemic. Even more valuable than creating tangible commitments across the whole food chain, it has fostered a truly collaborative and globally ambitious approach spanning the whole length of the food chain. It has made us all realise that it’s only by working together that we can truly achieve more sustainable food systems for our children and for our children’s children.
UNESDA looks forward to continuing to setting itself ever more ambitious goals and commitments and thereby keeping the Code of Conduct and its ethos very much ‘alive’ and relevant for many more years to come.