Food waste reduction is rising up the policy agenda across the UK and the EU. Yet most strategies still focus on managing waste rather than preventing it. In this guest insight piece, Noëlle Smits van Waesberghe from the Ellen MacArthur Foundation draws on insights from their Big Food Redesign Challenge, to explore how building upcycling into policy can help design waste out of the food system.
Momentum to reduce food loss and waste has never been stronger. Binding food waste reduction targets are set in the EU, while national strategies and voluntary frameworks are encouraging businesses in the UK to measure and reduce waste.
Yet the dominant policy response still focuses on managing food waste after it has already been generated. Efforts typically centre on improving collection infrastructure, monitoring waste levels, or diverting surplus to lower-value uses such as animal feed. These interventions are important, but they address only one end of the chain.
The upstream product design choices that determine how much waste is created in the first place remain almost entirely off the policy radar.
This is a significant missed opportunity, with substantial untapped potential earlier on: in the decisions about what gets made, from which ingredients, and how. Upcycling reframes food surplus and by-products not as waste to be managed, but as an opportunity to extend the value of the product through better design.
Designing food products with upcycled ingredients can unlock a range of benefits. By keeping nutrients at their highest value for human consumption, upcycling supports food security while reducing dependence on virgin agricultural inputs and the environmental pressures they create. It also unlocks new business opportunities: one firm’s by-product becomes another’s ingredient, generating new revenue streams while reducing waste management costs. Reflecting this potential, the global upcycled foods market is projected to reach an estimated $97 billion by 2031.
Evidence from industry
The technology and business models needed to transform by-products and surplus streams into valuable ingredients already exist. Breweries are supplying spent grain to ingredient manufacturers. Apple pulp and oat residues from plant-milk production are being transformed into cereals and snacks. Cocoa pod husks, once discarded, are finding their way into new food products. The products that were successful in the Ellen MacArthur Foundation’s Big Food Redesign Challenge demonstrated that incorporating upcycled ingredients is both feasible and beneficial for business, climate and nature.
What remains missing is a policy environment that recognises, incentivises and measures upcycling as a prevention strategy within national food waste frameworks in the UK and the EU. In the absence of such signals, the system continues to default to disposal or downgrading surplus to lower-value uses, rather than keeping nutrients at their highest value for human consumption.
If prevention sits at the top of the waste hierarchy, policy must measure, incentivise and reward it accordingly.
The policy shifts that would unlock upcycling at scale
1. Recognise upstream product design as a food waste prevention strategy
The upcoming transposition of the revised EU Waste Framework Directive presents a timely opportunity to strengthen the role of product and ingredient design in food waste prevention. Member States should explicitly recognise the use of upcycled ingredients as a formal prevention measure within national food waste programmes, alongside downstream waste management interventions.
Policy frameworks should clearly distinguish between upcycling by-products into food for human consumption and other recovery pathways such as animal feed or anaerobic digestion. Monitoring frameworks could also include measurable upcycling indicators, such as the volume of by-products redirected into food manufacturing and the number of upcycled products entering the market. Doing so would better align food waste policy with food resilience and security, resource efficiency, and circular economy objectives.
A similar policy window is emerging in the UK. The forthcoming Circular Economy Growth Plan, expected soon, represents the most significant near-term opportunity to embed upcycling within national strategy. The government has highlighted that an estimated £22 billion worth of edible food is wasted annually in the UK, a substantial loss of economic value across the supply chain. Upcycling directly addresses this: by designing edible by-products back into the food system, it simultaneously advances circular economy, climate, and economic resilience objectives. With agri-food already identified as one of the Growth Plan’s five priority sectors, the sector roadmap must look upstream to product design, and create the conditions for upcycling to scale across the food system.
2. Provide regulatory clarity so side-streams can be treated as food, not waste
Even where the business case for upcycling is clear, companies face significant practical barriers. Upcycled ingredients frequently straddle multiple regulatory domains: food safety and hygiene rules, waste management law, animal feed regulations, and in some cases novel food approval processes. In practice, it is often easier and less burdensome to cascade side-streams down the value chain than to retain them at human food grade. For smaller companies, the cost of navigating novel food approval can trap innovations in R&D indefinitely.
Regulatory guidance is needed to clarify when and how food side-streams can legitimately be treated as food resources – provided safety is ensured – rather than defaulting to a waste classification. Clearer definitions and streamlined pathways would reduce friction for businesses, create a level playing field, unlock investment for early-stage development, and send a clear market signal that this is a priority area.
Furthermore, unlike in the United States, where a third-party Upcycled CertifiedTM standard has emerged, the UK and EU lack a recognised definition or label for “upcycled food”. Certification can play a complementary role in supporting market uptake by creating additional value and trust with consumers, strengthening incentives for businesses to overcome the hurdles above.
Conclusion
The upcoming Circular Economy Growth Plan in the UK and the transposition of the revised EU Waste Framework Directive provide a timely opportunity to change this. Explicitly recognising upcycling as a prevention strategy and clarifying regulatory pathways would help unlock solutions that businesses are already beginning to demonstrate.
To be effective, this will need clarity on who is responsible for developing the guidance, targets and, where needed, regulation. Despite taking slightly different approaches to the circular economy, with the desire between the EU and UK to cooperate in this area, particularly for traded products, there is an opportunity at this nascent stage in policy development to explore the potential for a common approach for upcycled food products.
Design choices made at the start of the food chain determine how much waste is generated later. If policymakers are serious about meeting 2030 food waste reduction targets, those choices cannot remain outside the policy conversation.
Photo by Arno Senoner on Unsplash