Accepted Manuscript

Ensuring food safety in food donations: Case study of the Belgian

donation/acceptation chain

E. De Boeck, L. Jacxsens, H. Goubert, M. Uyttendaele

PII: S0963-9969(17)30485-4
DOI: doi: 10.1016/j.foodres.2017.08.046
Reference: FRIN 6925
To appear in: Food Research International
Received date: 4 May 2017
Revised date: 16 August 2017
Accepted date: 18 August 2017

Please cite this article as: E. De Boeck, L. Jacxsens, H. Goubert, M. Uyttendaele , Ensuring
food safety in food donations: Case study of the Belgian donation/acceptation chain, Food
Research International (2017), doi: 10.1016/j.foodres.2017.08.046

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 ACCEPTED MANUSCRIPT

Ensuring food safety in food donations: case study of the Belgian donation
/acceptation chain
De Boeck E.*, Jacxsens L., Goubert H., Uyttendaele M.

Laboratory of Food Microbiology and Food Preservation (LFMFP), Department of Food Safety and Food
Quality, Faculty of Bio-Science Engineering, Ghent University, Belgium

*: corresponding author, +32-(0)9 264 99 02, Elien.Deboeck@ugent.be

Abstract

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The food donation process in Belgium is mapped and analyzed to identify bottlenecks in compliance
with the legal framework and implementation of food safety management, based on literature

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search and interviews with stakeholders (donors, acceptors, regulators and facilitators) in Belgium
and at EU level. The study revealed that the food donation/acceptation chain is far less structured

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and organized than the conventional food supply chain. The fragmented landscape of many small
food banks and charity organizations (acceptors), often directed by and working with volunteers
without training in food safety and lack of knowledge of legal food hygiene requirements is a
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bottleneck to generate trust among food donors and restricts the provision of perishable products in
food donations. Lack of refrigerated transport and insufficient cold/freezing capacity in food banks
and charity organizations was identified as a barrier to distribute perishable products. Furthermore,
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in two cities in Flanders (Belgium), at some food donation centers, donated perishable food samples
(n= 72) were taken and subjected to microbiological analysis to determine their overall food quality,
hygiene and food safety status. Twenty-two of 72 analyzed samples showed marginal microbiological
quality based on numbers of yeast, lactic acid bacteria or total viable count. In three samples Listeria
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monocytogenes was detected per 25 g amongst which one ready-to-eat cooked meat product which
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showed increased numbers of L. monocytogenes (3.5 log CFU/g) and Enterobacteriaceae (6.7 log
CFU/g). Overall, in Belgium, most of the donated foods considers nonperishable foods, with more or
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less half of the food collected by the food banks being purchased with funds from FEAD (Fund for
European Aid to the Most Deprived) and thus not derived from food losses. Efforts are being made
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by facilitators to provide a platform for better coordination of donors and acceptors to make more
efficient use of food losses. Regulators at the national level are taking action to clarify and provide
some flexibility in food hygiene regulation and initiatives on EU level to facilitate food donation in the
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combat of food losses are pending. As from the side of the acceptors, it is recommended to
professionalize the acceptation chain in Belgium and seek for a more harmonized approach and
concerted action.

Key words: Food donation; food banks; food waste; food loss; food safety

1.Introduction
Ninety million tons of food was wasted in Europe in 2010, globally it is estimated to be about 1.3
billion tons (FAO, 2013). For Belgium the annual food loss is estimated to be 3.6 million tons (DGENV,
2010; Roels & Van Gijseghem, 2011). These food losses have many causes, both within the agro-food

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chain and with the consumer. Food waste in Europe and North America is estimated at 95-115 kg per
capita per year, while for Sub-Saharan Africa and South/Southeast Asia this is about 6-11 kg per
capita per year (Priefer, Jorissen, & Brautigam, 2016).

Many definitions for food loss, food waste, etc. are being used in literature and all types of reports,
which leads to confusion and impedes uniform measurement and as such, straightforward
comparison between studies in this field (FUSIONS, 2016; Lebersorger & Schneider, 2014). FUSIONS
(Food Use for Social Innovation by Optimizing Waste Prevention Strategies) was an EU FP7 project

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(2012-2016) initiated to harmonize food waste monitoring, to link social innovation to reduction of
food waste and the development of guidelines for a common Food Waste Policy for EU-27 (FUSIONS,

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2014, 2016). Based on this FUSIONS framework, studies of Tarasuk and Eakin (2005) and the Public
Waste Agency of Flanders (OVAM (2012)) a definitional framework was set, which is illustrated in

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Figure 1. In this paper food waste is defining those losses not suitable anymore for human
consumption while food loss are considered to be those losses which are still applicable for human
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consumption, including surplus food being structurally over production along the agro-food chain
and food wastage being overproduction during food preparation in domestic kitchens, restaurants
or catering.
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In primary production food waste/losses are mainly caused by plant diseases or molds damaging
plants or by sorting out of products due to rigorous qualitative standards etc. (Priefer et al., 2016). A
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second source of food waste/losses is created during processing due to overproduction, technical
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shortcomings, damage of products or packaging, etc. (Richter & Bokelmann, 2016). In distribution
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and retail short shelf life dates, miscorrelation between customer demand and offer, damaged
packages for instance will result in food waste/losses (Lebersorger & Schneider, 2014; Roels & Van
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Gijseghem, 2011). Also in food services (e.g. restaurants and catering) food losses can occur. Wrong
portion sizes and difficulty to predict customer demands are important causes(Engstrom & Carlsson-
Kanyama, 2004; Silvennoinen, Heikkila, Katajajuuri, & Reinikainen, 2015). The last shackle in the
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chain is the consumer/household itself. Wrong portion sizes, insufficient knowledge of appropriate
food storage and food preparation practices, poor experience in planning meals, etc. can lead to food
losses (Edjabou, Petersen, Scheutz, & Astrup, 2016; Priefer et al., 2016). A major cause here is wrong
interpretation of shelf life dates, which remains an important issue for consumers. Indeed, the study
of Van Boxstael, Devlieghere, Berkvens, Vermeulen, and Uyttendaele (2014) provided evidence that
30% of Belgian consumers dont know the difference between use by and best before dates.

The first measure to reduce food waste/loss is prevention (Papargyropoulou, Lozano, Steinberger,
Wright, & bin Ujang, 2014). Ways to prevent food waste/loss are already widely discussed in

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literature, for example changing aesthetic criteria and cultural expectations of size and shape of fruit
and vegetables could significantly reduce food losses at primary production (Mourad, 2016),
optimizing food packaging design to extend the shelf life of products (Gronman et al., 2013), a close
collaboration between food manufacturer and retailer could lead to more accurate prediction of
orders and stock management (Richter & Bokelmann, 2016). At retail level, Lebersorger and
Schneider (2014) mention education and awareness raising of employees and they propose that
food service providers could adapt portion sizes to customers real needs, by offering choice of
portion sizes to graded prices (Priefer et al., 2016). Potential prevention strategies in households

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could be to streamline food date labelling and intelligent packaging, for example by use of time
temperature indicators (Pennanen et al., 2015; Priefer et al., 2016).

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A second possibility is to consider to what extent food losses are still appropriate for human

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consumption and to provide the surplus food fraction of food losses for donation to economically
deprived people. In 2014 24.4% Europeans were at risk to end up in poverty and 9.6% was not able
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to pay for a full meal (FEBA, 2014). Specifically for Belgium, Vandevoort (2013) reports that 1 in 10
Flemish people are living in poverty. Better coordination between food losses and the demand for
food aid would be beneficial for both issues: minimizing food still applicable for human consumption
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to be discarded and providing access to wholesome and nutritious food to economically deprived
persons. Several authors already stated that reducing food waste could significantly impact an
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increase in food security (Ingram et al., 2013; Priefer et al., 2016). Optimization of the
donation/acceptation process can only be achieved, if all stakeholders, such as donating retail or
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processing companies, regulatory bodies, food banks, charity organizations, etc. are willing to
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cooperate (Priefer et al., 2016).

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Among the EU Member States and also outside EU, roles and organization of food banks and charity
organizations can vary a lot. In some countries they merely serve as intermediate agents receiving
donations, store them and then redistribute them (Garrone, Melacini, & Perego, 2014). In contrast,
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the North-American/Australian food bank model is deemed to be going further and actually
providing assistance to economically deprived persons by focusing on healthy food, providing
nutritional information and combing food literacy programs with initiatives to stimulate physical
activity (Butcher et al., 2014; Garrone et al., 2014; Lindberg, Lawrence, Gold, & Friel, 2014). McIntyre,
Tougas, Rondau, and Mah (2015) describe the existence of food banks and other charity
organizations as signaling government failure in providing suitable social welfare and utters several
critiques on food banks, based on the seven deadly ins as cited by Poppendieck (1998). These are:
inaccessibility (food is difficult to obtain because of poor location, hours of operation or transit
options); inappropriateness (food provided does not meet dietary needs, or personal/cultural

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preference of clients); inadequacy (food provided is not nutritious); indignity using the food bank is a
stigmatizing experience in which people may be treated with suspicion, depersonalized or lose some
of their independence); inefficiency (emergency food systems are not efficient and give the illusion of
efficiency because they do not count donations as inputs); instability supply depends on donations of
money, food and labor that may be variable or unreliable); insufficiency (the inability to provide
sufficient food to meet clients needs) (Poppendieck, 1998).

In this study, the food donation/acceptation chain in Belgium was investigated. Based on literature

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search, national and regional reports and interviews with different stakeholders in Belgium (donors,
acceptors, regulators and facilitators) and some at EU level, the food donation process in Belgium is

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mapped in a flow chart. The information provided was analyzed to identify bottlenecks and
difficulties to overcome concerning legal framework and food safety management issues in this food

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donation process. If food donation occurs within the framework of combat of food losses, food is
often donated near to the end of shelf life and thus the legitimate question arises whether food
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offered to economically deprived people is indeed still wholesome, of sufficient sanitary quality and
food safety is ensured. No actual information on the microbiological contamination of food at the
time of food donation was found in the current literature. Therefore a small survey was executed in
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two main cities in Flanders (Belgium), where samples of perishable food products (n= 72) were taken
at some food charity centers and subjected to microbiological analysis to determine the overall food
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quality, hygiene and food safety status of this donated food. Although this manuscript focuses on the
issue of food safety in the food donation/acceptation process, also relevant political and economical
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aspects will be briefly discussed, as these elements are shaping the context of the
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donation/acceptation process and could have a significant impact on food safety of the donated
products.
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2.Material and methods

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2.1 Literature search to map the flow of food donation in Belgium

In a first step information was acquired from different sources. Information on the European
legislation or guidelines of relevance to the food donation/acceptation process was investigated
through the EURLEX (2016) website offering access to EU-law and the European Commission Food
Safety portal (EC., 2016c). The website of the Belgian Federal Agency for Safety in the Food Chain
(FASFC, 2016) was consulted for relevant national regulations or guidelines. Relevant peer reviewed
scientific literature was searched but the most of the information was gained through grey literature
via general internet search engines, consulting national or regional reports, flyers or stakeholders,

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etc. Moreover, regional information sessions dealing with food loss and food donation were
attended (Inagro (2015), Flanders Food (2015) and Foodlabs (2016)). Based on the information
gained in this step, a preliminary flow chart was developed, illustrating the process flow of the
donation/acceptation chain in Belgium and relevant stakeholders identified.

2.2 Interviews with stakeholders to identify bottlenecks in food

donation/acceptation chain
Based on the literature and information search four types of stakeholders could be distinguished

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which all have interests related to the donation/acceptation chain. Interviews were mostly taken
through face to face meetings by the same two interviewers and took approximately one hour of

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time. At request, some interviews were taken by telephone or mail. Surveys were structured with
restricted open questions. Due to the knowledge gained in the first step (information search)

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targeted questions could be developed for each of the interviewees. Surveys were therefore tailored
to the type of stakeholder. The objective of the interviews was to refine and validate the preliminary
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flow chart which was developed based on initial literature search. As such, this flow chart was
discussed with the interviewee in the first phase of the interview. Suggestions related to the flow
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chart and other information concerning the organization of the donation/acceptation process (e.g.
transport, type of products donated/accepted, liability, quality control) were registered by the
interviewers. In a second phase of the interview the interviewee was asked to list the barriers and
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bottlenecks which he/she already experienced in this donation/acceptation process. When all
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interviews were completed, the initial flow chart was updated based on the suggestions of the
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interviewees. Additionally, all survey results were assembled in tables arranged per stakeholder type
in order to have an overview of all information which was gathered. From these tables, the main
findings, as presented in the results section of the present manuscript could be extracted. All
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interviewees were informed about the objective of the interview and consented with publication of
the results. The information provided during the interviews is not reflecting an official viewpoint of
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their organizations.

First, the regulators were considered as the course and organization of this donation/acceptation
process is hugely influenced by European and national legislation. Knowledge of Belgian national
legislation was deepened based on an interview with three experts from the Belgian Federal Agency
for Safety in the Food Chain (FASFC). On an European level, two experts from the European
Commission DG SANTE were interviewed (1 responsible for coordination concerning food waste
prevention and 1 expert in food hygiene). Also a staff member of the Flemish Ministry Department of

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Welfare, Public Health and Family was consulted to clarify the situation for the Flemish region, as in
Belgium the regional competent authority is dealing with this issue of food losses.

Secondly, facilitators were defined as organizations in the donation/acceptation chain with the
objective of facilitating the entire donation/acceptation process. As such, roles and responsibilities of
different existing facilitating bodies could be clarified. KOMOSIE npo, the network of non-profit
organizations involved in recovery and energy-cutting activities in Flanders often popped up during
literature search and was therefore also consulted in an interview (1 expert). Also 1 member from

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the board of the European Federation of Food Banks (FEBA), as, according to literature, the lion share
of donations in Belgium go through this channel. To get a more practical idea of the working and

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organization of food banks, 1 member of the board of one of the 9 local food banks was interviewed
(province of West-Flanders). The interviews shed light on the importance of Belgian Federal Public

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Service Social Integration (FPS SI) in the food donation/acceptation process, an organization which
role was not derived from the literature search and thus showing the need of refining the preliminary
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flowchart. Consequently, the role of this Federal Service was further investigated through an
interview with a staff member.
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A third party of interest are the donors. These include overarching organizations, such as the Belgian
association of Food Industry and Food Trade (COMEOS), representing the majority of large retailers
active in Belgium. Another interview was conducted with representatives from FEVIA (Belgian
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Association of the Food Industry), this association represents most of the larger companies and
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sector associations involved in food processing in Belgium. But interviews were also taken with a
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number of individual retailers and with some individual fruit and vegetable auctioneers. Overall, as
for the donors 2 experts from COMEOS (head product policy and sustainability and advisor) were
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interviewed, 3 interviews were taken with individual (large) retailers in Belgium, two experts from
FEVIA were interviewed (food policy director and advisor), and 3 interviews were taken with
individual fruit and vegetable auctioneers in Belgium.
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A fourth party which could be distinguished are the acceptors. .Of all
contacted organizations, only 1 social restaurant (Ghent), 2 social groceries
(Bruges, Ghent) and 1 food distribution organization (Ghent) were relevant
(working with donations or self-made/grown products) and open for
collaboration. Besides an interview with each of these acceptors (4 contacts
in total) also product samples were taken (vide infra).2.3 Case study:
microbiological quality and food safety of donated products

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Food products are often used in social restaurants or distributed at social groceries or food bank
distribution centers at or near to their end of shelf life date. As a case study to acquire information

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on the overall status of microbiological quality and safety of food products offered for donation was
elaborated. A small survey was executed in two cities in Flanders (Belgium), where samples of

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perishable food products were taken. The four acceptors of food donations that were also included
in the interview round (vide supra) were therefore visited an additional three times within a period
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of seven weeks (February-May 2016). At each visit 2 to 10 food samples were taken. The type and
number of samples taken, was determined to a large extent as per the nature of the type of food
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being available at the time of visiting the food distribution center. Per definition only perishable food
products were analyzed, as microbiological analysis of shelf stable products (mainly dry pre-packed
or canned products) would not be relevant. Moreover, products purchased with funding from FEAD
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in the regular food supply chain, and thus not related to redistribution of food losses to food
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donations were not considered for microbiological analysis. Some products offered for food
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donation, in particular at the social restaurant that was visited, included on-site grown or on-site
produced prepared foods. In total 72 samples were taken for microbiological analysis, 30 food
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samples taken at social grocery A (in Bruges), 16 food samples taken at social grocery store B (in
Ghent), 8 samples taken at a social restaurant (in Ghent) and 17 samples taken at a food distribution
center (in Ghent). All samples were transported in a cool box at 4C to the laboratory, after which
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microbiological analyses were performed within 6 h of sample collection. Microbiological parameters

for analysis included enumeration of quality indicators (total viable count, lactic acid bacteria, yeasts
and molds) and hygiene indicators (Escherichia coli, Enterobacteriaceae, coagulase positive
staphylococci) and detection of pathogens (analysis of L. monocytogenes and Salmonella per 25 g;
enumeration of Bacillus cereus). Exact selection of parameters for analysis was depending upon the
type of product sampled (Table 1). Standard microbiological analysis was performed by taking a
representative subsample of 10 g and homogenize it for 1 min in 90 ml of sterile peptone water. For
microbial enumeration tenfold serial dilutions were made in sterile peptone water. Detection of
Salmonella and L. monocytogenes was executed by taking subsamples of 25 g and homogenize for 1

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min in respectively 225 ml of buffered peptone water for the detection of Salmonella and in 225 ml
of demi-Fraser for the detection of L. monocytogenes. For each sample also the mode of storage
(refrigerator, freezer, ambient), storage temperature at the time of sampling (if readable from
refrigerator/freezer display), the type of shelf life date (use by or best before) and number of days
before end of shelf life date was registered.

3. Results and discussion

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3.1 Flow chart of the donation/acceptation chain in Belgium
The final flow chart of the Belgian donation/acceptation chain is shown in Figure 2. Different flows

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could be distinguished, i.e. information/communication flows, financial flows, product flows through
the food banks, product flows directly to the food charity organizations and finally, flows of

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purchased products from the regular food supply chain.
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EU Member States can invoke financial support to purchase food for the most economically deprived
of the society from two major programs or funds. The largest one is the Fund for European Aid to the
Most Deprived (FEAD), which is rooted in the former European Union Food Distribution program for
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the Most Deprived, which was funded from the Common Agricultural Policy (CAP) budget. However,
reform of the CAP obliged buying goods on the open market for donation, shifting from an
agricultural purpose to a social one. Eventually in 2014 the FEAD fund was launched which is not
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related to the CAP program anymore (Caraher, 2015). This fund disposes of 3.8 billion euros for the
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period 2014-2020, which can be used to financially support the EU Member States provided that the
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Member State itself is co-financing for at least 15%, and a clear and justifiable program is proposed
(EC., 2016b). The second major fund supporting food donations in Europe is the fruit and vegetables
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free distribution fund. In order to prevent market price decrease due to too large stocks in primary
production, this fund compensates up to 5% of their total market volume if the farmers donate these
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surpluses to charities (EC., 2016a). Information and communication flows are mainly related to
activities of the Belgian Public Centers of Social Welfare (OCMW). The OCMW determines how many
people live in poverty in Belgium and communicates this to Europe. This influenced the amount of
financial support Belgium received from the FEAD fund for the period 2014-2020. More or less half of
the food collected by the food banks is originating from the FEAD-fund (BIO_by_Deloitte, 2014).
Belgium received for the period 2014-2020, 73.8 million euros through the FEAD program and
invested 14.3 million euros through own national means. This money is received by Federal Public
Service Social Integration (FPS SI), which decides, based on the needs and orders of the food banks
and food charity organizations, which goods will be purchased. The destination of the financial

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support from the FEAD program goes to food products, as defined by the FPS SI in their operational
program which had to be approved in order to get the European support. The food products are then
distributed to the local food banks which make sure the food reaches the people in poverty (OVAM,
2012). The major requirement in order to receive FEAD-products is that these have to be offered for
free to the economically deprived persons (FPS_SI, 2015). Besides the support from EU, food banks in
Belgium also receive donations (financial or food in kind) from (large-scale) food processing
companies, food wholesalers and retailers. Also within Belgium, fruits and vegetables auction A and
auction C (vide supra) donate surplus food (left over fruits and vegetables which are not sold) to food

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banks. Auction B donates directly to local charity organizations.

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Products from the food banks are then further distributed to more than 620 charity organizations
connected to the food banks, spread over the ten different provinces in Belgium. All food products

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obtained from food banks have to be distributed for free to the economically deprived persons.
Redistribution is mainly (73%) organized through composite food parcels distributed through food
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charity organizations. Social groceries and restaurants together account for 24% of food aid. These
three types of food aid can be publicly or privately organized. Organizations in the public sector can
count on support from the food banks. The remaining 3% of food aid consists of smaller local
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initiatives such as food tokens distributed by social assistance centers (OCMWs) to be used at
dedicated shops, food donation initiatives purchasing mainly food products with own means
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(without providing packages), etc.(Vandevoort, 2013). For these other types of local community
initiatives often also in order to reach the target population (economically deprived persons), local
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social assistance centers are consulted.

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Based on data obtained from the local food bank West-Flanders, it can be concluded that 92.7% of
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the Belgian charity organizations are connected to a local food bank. For social groceries and social
restaurants, only 1.2% and 6.1% are connected to a local food bank respectively. These low
percentages are caused by the requirement of FEAD to offer food for free in order to get products
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from the food banks. Social restaurants and social groceries are often not able to fulfill this
requirement and charge still a minimum cost. Food charity organizations which are not connected to
food banks acquire their products mainly through local donations/gifts. Local food processing
companies (often small and medium scale enterprises), local shops (often franchise shops of retail
groups), and also interviewed auction B and C donate directly to local food charity initiatives. The
received food products through donations are then supplemented with food products purchased in
the regular food supply chain. In publicly organized social restaurants people in poverty can obtain a
discount token after social examination by the Public Centers of Social Welfare (OCMW) to get hot
meals at a reduced price (Vandevoort, 2013). The private social restaurants offer meals to everyone

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(without proof of being economically deprived) at the same low tariff (Poverello, 2015). Social
groceries can also operate publicly or privately. After an examination of the social situation, an
access card can be obtained. Food is offered at a reduced price, but, in case these social groceries
acquire products from food banks or FEAD financed products, these food products have to be offered
for free (Social_groceries_Flanders_vzw, 2012).

As main findings from the flow chart, it can be stated that the donation/acceptation chain is a very
complex system with a lot of fragmentation at the acceptation side: several small food charity

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organizations exist, some connected to food banks, others not, some distributing food products for
free, others not. This leads to a fragmented situation resulting in confusion both for acceptors and

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donors. Most donated products are originating from purchase with the FEAD fund. With the huge
amounts of surplus food from the regular food chain in mind, it could be better to make an effort

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increasing food donations from the regular chain by facilitating and encouraging surplus food
donations. This could be done by VAT incentives or legally obliging food donation (e.g. case of French
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supermarkets, vide infra). An important initiative facilitating food donations in Belgium between
donors with surpluses and charity organizations was launched in October 2015. The Gift Exchange
Fair is providing an online platform with professional tools in order to bring donors and acceptors
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together (Schenkingsbeurs, 2015).

3.2 Identified bottlenecks in food safety, food safety management and

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traceability in the food donation/acceptation chain

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Regulators
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Based on the interviews with the regulators i.e. the European Commission, the Belgian Food Safety
Authority (FASFC), and the Flemish government legislative obligations and regulations could be
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deepened. Evidently, countries need to follow EU legislation; in particular: EU Regulation 178/2002,

also better known as the general food law (EC., 2002), EU Regulation 852/2004 concerning food
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hygiene (EC., 2004a), EU Regulation 853/2004 concerning food hygiene for products of animal origin
(if applicable) (EC., 2004b), EU Regulation 1169/2011 concerning food information to consumers (EC.,
2011) and EU Regulation 223/2014 concerning the Fund for European Aid to the Most Deprived (EC.,
2014). For all operators in the agro-food chain also EU Council Directive 374/1985 concerning
product liability applies (EEC, 1985). Donors are responsible for product hygiene and food safety until
the moment charity organizations or food banks accept the donated products. In practice often a
form is signed in which the transfer of responsibility is described.

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At this moment, there is no harmonized EU policy concerning food donation/acceptation, which

means that each member state is implementing its own rules (BIO_by_Deloitte, 2014). Based on the
comparative study on EU Member States legislation and practices on food donation and the
interviews with regulators from the current study, an overview was made of relevant EU legislative
issues/topics concerning liability, GHP and HACCP based procedures, labeling and date of minimum
durability, and traceability, possibly creating barriers for donation of food to food banks or charity
organizations (BIO_by_Deloitte, 2014; EC., 2002, 2004a, 2011; FASFC, 2017; RD., 2003) (Table 2).
Also, how Belgium is dealing with these issues/topics is explained.

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The Belgian FASFC has published a circular letter concerning provisions applicable to food banks and

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charity organizations in order to promote food donations and to allocate a framework on Belgian
level (FASFC, 2017). This includes provisions concerning flexibility on shelf life date, labelling and

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traceability (see Table 2). Additionally to the Belgian approach in Table 2, also freezing of food
products such as raw prepacked meat or fish is allowed at the latest on the use by date (based on
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the Advice 05-2015 of the Scientific Committee of the FASFC on the evaluation of the risks of freezing
prepackaged foodstuffs on the final use by date (SciCom, 2015)), date of freezing and immediate
consumption after thawing has to be indicated on the label. Distribution of the frozen products
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should happen between 48h and 2 months.

In the study of BIO_by_Deloitte (2014) some other more economical oriented barriers are
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mentioned. One is dealing with tax legislation (Council Directive 2006/112/EC), an issue which lacks
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clarity and is still ambiguous. Food donations are taxable, meaning that VAT has to be paid on the
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purchase price at the moment of the donation adjusted to the state of the goods at that time. This
leaves quite some room for interpretation for the EU Member States. However, most Member States
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set the value of the donated food close to zero, as such VAT is negligible. Additionally, tax credits and
tax deductions can encourage the donation of surplus food (BIO_by_Deloitte, 2014). The study also
points out the fact that several EU Member States introduced economic incentives which make it
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more financially profitable to choose for lower stages of the waste hierarchy (e.g. anaerobic
digestion) instead of using the food which is still fit for consumption for donation purposes. This
barrier was also addressed by Garrone et al. (2014) stating that low tariffs for waste collection and
treatment discourage food companies to look for uses of surplus food still for human consumption
such as food donation instead of discarding as waste. Indeed, the EU Directive 2008/98/EG advises to
take up the waste hierarchy in national legislation prioritizing feeding humans through waste
prevention and donation over waste management options. However, only few member states (e.g.
Belgium) did implement this in national legislation. Specifically for Belgium, the Flemish region
created the Decree on the sustainable management of material cycles and waste

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(Flemish_government, 2011). The divergent approaches between the EU Member States can also be
illustrated by the case of France, where since 2015 supermarkets with a surface area larger than 400
m are obliged to donated surplus food to charities (Lgifrance, 2016; VILT, 2016).

The most important conclusion drawn from the interviews with regulators is the lack of harmonized
and unambiguous EU legislation or guidance concerning food donation and acceptation. Each
member state is searching for its own solutions to overcome this (for example circular letter in
Belgium (FASFC, 2015), vide supra), which leads to fragmentation and confusion for all stakeholders.

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Recently the European Commission launched an EU Platform on Food Losses and Food Waste which
brings together public entities (Member States, EU bodies, international organizations) and several

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stakeholders in the food value chain including also the consumer- and other non-governmental
organizations (DGSANTE, 2016b). The major goal of the platform is to achieve the Sustainable

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Development Goals (SDG) concerning food loss and waste reduction targets (United_Nations, 2015)
without compromising food and feed safety and/or animal health. Part of the agenda is facilitation
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of food redistribution for which guidelines are expected to be developed to facilitate the donation
process (DGSANTE, 2016a).
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Facilitators
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The interviews with facilitating bodies in Belgium provided evidence demonstrating the importance
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of the Federal Public Service (FPS) Social Integration in the donation/acceptation process. Financial
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means from the FEAD program and own national funding is maintained by this public service (14,3
million euro per year (2014)). Food products are bought through public tenders for food companies
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(EU or non EU based) with the best price-quality offer. Also here the barrier of subcontracting for
cheap non-European products was mentioned, which is not a sustainable procedure as food losses
(and more specific surplus food) are still present in Europe and can be better exploited instead of
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buying food products.

Barriers discussed by facilitators include 1) insufficient coordination (e.g. in logistics, transport)

between many individual food banks/food charity organizations indicating the need for better
collaboration and exchange, 2) difficulties to set up agreements due to these food banks/food charity
organizations often working with a team of exchangeable volunteers which often have insufficient
knowledge on food safety management which detracts from gaining trust in dealing in particular with
perishable foods, and 3) due to the small scale of many initiatives, a lack of flexibility of individual
food banks/food charity organizations to react quickly to changing situations in type and quantity of

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food stuffs being available. Overall lack of efficient communication and the lack of a harmonized
approach among those initiatives involved was indicated as a bottleneck during the interviews. The
importance of a suitable managerial approach, focusing on better organization, structure and
professionalization of food banks and charity organization, was also addressed by Santini and
Cavicchi (2014) who studied the Italian food donation chain.

The Belgian Federation of Food Banks also uttered that the product range could be extended by
enabling fresh products, such as fresh fruit and vegetables, now sometimes available but needing

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high throughput due to the perishable nature of these fresh foods. It would be convenient to be able
to process this type of fresh produce into soups, apple sauce, juices, marmalades, etc., as such

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converting them into longer shelf life end products offer and thus facilitating logistics and
distribution. However, present day, this type of processing is difficult to organize because no

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economy of scale can be applied as food losses (product type, amount) vary each day. In addition, if
processing of food occurs, one needs to comply with more complex food hygiene and food safety
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regulations (both GHP and HACCP instead of solely GHP and traceability), which especially if working
with volunteers is not obvious to set-up and implement.
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Several of these issues in the Belgian food aid system, are not impeding the Dutch food
donation/acceptation system. From an interview with the food safety responsible working as a
volunteer for the Dutch food banks, it seems that, although also working with volunteers, a central
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organized structure and harmonized way of working is being set-up at the food banks in the
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Netherlands. Although the Netherlands do not invoke FEAD funds, the well-organized donation
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system enables a sufficient provision of food to the economically most deprived persons. The system
is coordinated at a national level by experienced volunteers who can streamline the donation process
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as a whole. Moreover, they form one central contact point for information for individual food banks
on how to deal with food legislation and food safety issues. Several initiatives/actions effectuate an
increase in trust between donors and acceptors of food surplus of food losses, and, as such also
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facilitate in sufficient donations from both food processing companies and retailers. For example, the
use of uniform food bank labels, makes sure the consumer gets all necessary information and allows
unlabeled food products, such as surplus food from pilot productions of new products, to be donated
without legal problems. Furthermore, perishable food products are frozen by Dutch retailers. Whilst
in Belgium freezing has to be executed by food banks/charity organizations which do not dispose of
professional freezers to guarantee quick freezing and also cooled/frozen transport is often not at
hand in these organizations, which impedes adequate time/temperature control. Additionally, the
association of Dutch food banks developed a manual (Food_Banks_Netherlands, 2014) with
guidelines related to food safety, incorporating the relevant legislation and providing clear and

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detailed requirements related to infrastructure, temperature control, waste disposal, personal

hygiene, etc.

Donors- food industry

General barriers mentioned by donors are the administrative burden, financial burden (cost to
donate should not exceed cost of waste disposal), lack of storage capacity at the donor to set aside
food losses if not immediately picked up by the food banks/food charity, lack of (cooled) transport
(capacity) at the acceptor side , and inefficient communication due to the food banks/food charity

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organization often working with volunteers. Specifically for the food processing industry, it can be
stated, based on our interview with an expert of the Belgian Association of the Food Industry, that

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most of the donated products are products exceeding the internal/commercial sell by date, i.e. the

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date by which a perishable product must be sold by the food processing company to a distributor, so
the latter has sufficient time to sell it to the consumer. As a matter of fact, this was also identified by
Garrone et al. (2014) as the main reason for the generation of surplus food in Italy. An important
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barrier mentioned by the expert of the Belgian Association of the Food Industry is the fact that semi-
finished products cannot be donated as such, because they are not packaged nor labeled, and often
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end up at feed processing companies or waste disposal. Packaging and labeling of these semi-
finished products by the food processing company itself before the donation is a too high financial
burden. If packaging and labeling would be executed by food banks or charity organizations, this can
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also involve issues, as for packaging of products, additional legal requirements must be met and
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insufficient knowledge of volunteers about legal aspects of label information could provoke food
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safety problems. The latter could be overcome by a uniform food bank label (cfr. Dutch food banks,
vide supra) which is approved for use by the competent national food safety authority.
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Donors- fresh produce auctions

Interviewed fresh fruits and vegetables auctioneers criticized the fact that products exceeding the
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maximum residue limits as imposed by European legislation cannot be sold nor donated. However, as
these maximum residue limits are mainly based on the concentration of residues found when
applying Good Agricultural Practices, exceedance does not pose a direct link to toxicological effects.
Therefore, the interviewed auctioneers proposed to allow donation of these MRL-exceeding
products. Still, a case-by-case risk assessment has to be made to guarantee that there is no public
health risk upon consumption. In addition, with the fourth deadly in : indignity (Poppendieck,
1998) in mind, this should not be considered as an option, as it would be a really stigmatizing action
to allow the donation of food not meeting legal requirements to these vulnerable individuals.

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Donors- retailers

Regarding the donation process for the retailers/supermarkets, it could be concluded that every
retailer has its own strategy. The standard procedure for donation of products for the three
interviewed retailers varied from donation of pre-packed food already 4 days before use by date up
to donation in the late afternoon (after 16h) of the use by date. This has major implications for the
acceptors (food banks or local charity organizations), as this determines the time they have to
redistribute the products to the most deprived. The latter (donation at the use by date) requires

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immediate redistribution which is not always feasible, as mainly volunteers are working in the charity
organizations which are less flexible in availability and transport mode to pick up the (almost) expired

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food stuffs at the defined retailer. The national food banks are mainly getting food stuffs from the
retailers central warehouses whereas local food charity organizations usually get donations from

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local shops. However, the latter have to comply with certain requirements, being different
dependent upon the retailer or local shop concerned in order to receive the products. For example,
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the fact that received products have to be distributed for free, and most big retailers only donate to
charity organizations connected to food banks. For some retailers also the distance from the local
shop to the charity organization has to be restricted (within a certain number of kilometers). Shelf
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stable products are not often donated by retailers, as there are no losses because of an optimized
stock management. The same applies to frozen products. Most donated products are fresh fruits and
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vegetables and ready-to-eat composite products (such as cooked meat products, Deli-based salads).
Donation of fresh meat and fish is very limited, as these products are very susceptible to
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microbiological deterioration, and pose the need for strict control of the cold chain to prevent
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potential outgrowth of food borne pathogens.

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Again the lack of (cooled/frozen) storage capacity and logistics of the charity organizations are
mentioned as barriers. Also a lack of structure, organization and lack of knowledge on food hygiene
by the volunteers involved, popped up again. Some retailers mentioned the possible damage to their
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brand name if the goods are not well kept (refrigerated) and distributed. Also fear for development
of parallel circuits where goods are sold at a lower price and the difficulty of finding a charity
organization with sufficient capacity and a stable team of volunteers to build a long lasting
relationship, were considered as bottlenecks by the interviewed retailers. The latter difficulty varies
depending upon the region, as some regions house more charity organizations than others. Donating
products requires additional efforts of the retailer as they should keep in touch with every charity
organization and keep track in a register of which charity organization is coming when to collect
which of donated products.

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Acceptors social restaurants, groceries and food banks

The interviewed social restaurant was, as most of the social restaurants, not connected to the food
banks and did not prepare meals with donated food products. All food stuffs in the restaurant were
bought in the regular food chain and the visited restaurant also used own-grown vegetables. Both
the social grocery and the food distribution organization received donations mainly from food banks
and local shops, being independent shops (such as bakery or butcher shop) or subsidiaries from

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national operating retailers. In order to broaden the product range, many products are also bought in
the regular food supply chain. Although the demand for meat/fish is high, there is only a limited offer

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of fresh meat/fish as these products are susceptible to microbiological spoilage/contamination and

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more expensive.

The interviews revealed that due to the fact that these organizations are working with volunteers,
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which have restrictions in time allocation to the food charity work, the process of organization and
planning of pick-up and transport of donated food were recurring issues for the acceptors. The fact
that still a small contribution has to be paid in order to receive food in social groceries and social
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restaurants, remains a thorny issue. Besides food banks, a lot of donors demand that their donated
products are offered for free, in order to inhibit parallel circuits, in which donated products are sold,
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inducing competition for the original donor. For the acceptors, this is not maintainable as also
operational costs (e.g. transport) should be covered.
E
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A striking critique on the acceptor side was the fact that donation of food is sometimes only a shift of
the food waste problem at the expense of the food banks and charity organizations. At times,
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retailers and food processing companies oblige acceptors to take a whole batch of one product, of
which, after better inspection at arrival at the charity organization, already a huge part seems to be
not consumable anymore (e.g. fruits and vegetables with rotten parts). This issue was also addressed
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by Garrone et al. (2014) who state that distribution practices can be excessively driven by donors
supply choices and dissociated from client needs in some cases. Also Winne (2008) argues that food
processing companies should not exploit food banks/charity organizations to get rid of their surplus
products.

It is not always so easy to judge acceptability of a product for food consumption. Therefore, it is
important for both acceptors and donors to agree on what is acceptable and under which
conditions the food is acceptable to donate/accept, so that donated goods are still fit for
consumption (not spoiled and still safe to eat) to deprived persons. As a potential help for these

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accepting organizations in some EU Member states guidelines/guides are available, as a result of an

interaction between competent authority and national food banks or requests for clarification by
retailers/food companies wanting to donate to food charity organizations (e.g. Finland, the
Netherlands). However, a more harmonized approach on EU level would be beneficial. On a
European level, FEBA, FoodDrinkEurope and Eurocommerce recently (June 2016) launched the guide
Every meal matters (FoodDrinkEurope, EuroCommerce, & FEBA, 2016) with the goal to facilitate the
donation/acceptation process. General information on food loss (and prevention) is given and also
what can be donated and who can be donated to is discussed. However, this guide lacks a practical

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approach focusing on hygiene and food safety issues, as only traceability is covered. The guide which
is expected to be published by the EU Platform on Food Losses and Food Waste facilitation of food

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redistribution could be a solution here (vide supra)(DGSANTE, 2016a). Still, the question remains

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how this guide and information will reach all stakeholders and whether training and education will be
organized in order to make sure they can grasp the message.
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To have some objective information on whether what is donated or rather offered as food stuffs to
economically deprived persons, a case study was elaborated assessing microbiological quality,
hygiene and safety of these foods at a social restaurant, two social groceries and a food distribution
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organization.

3.3 Case study microbiological hygiene and food safety of donated products
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3.3.1 Characterization of the accepting charity organizations and donated products

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Social groceries A and B offer both purchased products (from the regular food supply chain) and
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obtained products through donations from local food processing industry, bakeries, butcheries,
restaurants and two supermarkets. Moreover, social grocery A also offers via FEAD purchased food
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products. Additionally, own made soup (frozen) and jam are provided in both groceries. In the social
restaurant all food products to prepare the meals are purchased from the regular food supply chain,
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except for some fruits and vegetables which are own-grown. The one food distribution center visited
obtained products through donations of the FEAD fund, the local food bank, local bakeries and
supermarkets. Some products are also purchased.

From the 72 food products under consideration 39 originated from local supermarkets, which makes
supermarkets the main donor of perishable products. 18 samples were originating from own
cultivation or production and only 10 samples were donations from food banks. The latter can be
explained by the fact that food banks distribute mainly products which are shelf stable and as such,
not considered for microbiological analysis in this study. The remaining food products originated
from a local food processing company (2 samples), a local bakery (2 samples) and a sheltered

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workshop (1 sample). It could also be concluded that cooked chilled (ready-to-eat or ready-to-be-
reheated) products/meals are the most often donated perishable products (46/72). Also fresh
vegetables were donated quite often (14/72). Quickly perishable products such as raw meat and raw
fish are only sporadically donated, which resulted in no samples of this product category. Twelve of
72 samples were products of animal origin, but these were all processed meat or fish products, or
cheese (12/72). From the 72 analyzed perishable food samples, 45 food samples were refrigerated,
23 were frozen and only 4 samples (mainly fresh fruits and vegetables) were stored at ambient
temperature at the time of sampling. This demonstrates the importance of having available sufficient

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cooling and freezing capacity for the charity organizations if they need or want to accept perishable
food products. If products were stored in refrigerated conditions temperatures read from the

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refrigerator display were ranging between 2C and 8C. However, it is important to note that if a

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temperature of 8C was observed, that particular refrigerator had just been filled and had been open
for a longer period, which might explain the somewhat higher temperature. Freezing temperatures
observed were ranging between -32C and-20.4C. It could be concluded that all products were
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stored at temperatures not exceeding the in Belgium legally prescribed temperatures (RD., 2014).

Donors donation strategy can differ which results in a variable remaining shelf life (i.e. number of
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days that food products are donated to the acceptors before the end of shelf life (vide supra)). From
the 72 perishable food samples 22 samples had a best before label, 36 had a use by date and the
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remaining 14 samples were mainly fresh unpacked vegetables which do not need a shelf life label. At
the moment of sample collection, 2 samples were at 1 day before exceedance of the best before
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date, 2 samples at 2 days, 2 samples at 3 days and 2 samples at 4 days. However, most product
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samples (14 of 22) were at more than 10 days before exceedance of the best before date; these
were all frozen products, with an extended shelf life because these products can still be offered to
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consumers after the end of the shelf life. However, guidelines on maximum restricted time for
distribution of frozen foods from the circular letter of the Belgian Food Safety Agency (FASFC, 2017)
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should be respected. Important to note is that, except for frozen products, no food samples
exceeding the best before date were offered, although this is allowed for non-perishable products
with a best before date according to the circular letter (FASFC, 2017). Looking at the samples with
use by dates, 9 food samples were still offered at 0 or 1 day(s) before exceedance of the use by
date. This means that the redistribution to the economically deprived persons should happen very
fast. However, if this is not the case, products can still be frozen (at the latest on their use by date)
to extend the shelf life according to the Belgian authorities (FASFC, 2017). This could be noted from
the large number of food samples (14 food samples of 36) in this category that were held as frozen
products (offered at more than 10 days before exceedance of the use by date). Freezing of food

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products at the end of the shelf life is often performed by the charity organizations in order to have
more flexibility and less time constraints to organize food redistribution, but this does warrant
sufficient freezing capacity to enable quick freezing upon reception of donated perishable foods and
thus ensure maintenance of safety and quality of these products. For the remaining of the samples
with a use by date, 5 were at 2 days before exceedance, 2 at 3 days, 3 at 4 days, 1 at 6 days, 1 at 7
days and 1 at 8 days before exceedance of the use by date. The 14 food samples (fresh vegetables)
without shelf life label were assessed visually on their acceptability for consumption. Five of these 14
samples already showed brown spots, one had mold spots and two did not look fresh anymore (e.g.

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wilted leaves). Similar studies as the present one, investigating how many days exactly before end of
shelf life food products are donated or offered to deprived persons could not be found in scientific

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literature. However, several studies recognize that donation is often near the end of shelf life

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(Bonaccorsi et al., 2016). An interesting approach concerning the time of donation is suggested by
Aiello, Enea, and Muriana (2014) and Muriana (2015), who developed a mathematical model to
determine the optimal time to withdraw products from the retail shelves for distribution to other
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destinations such as food donation to charity organizations, maximizing retailer profit. The
complexity of the donation/acceptation chain is reflected in the complexity and large amount of
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model parameters taken into account in the model (salary of employees involved, value of donated
foods, disposal costs, transportations costs, etc.).
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3.3.2. Microbiological analysis of the food samples

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In order to present and discuss the data of microbiological analysis of this study, the 72 food samples
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were divided into 3 food categories: fresh vegetables (n = 14) , foods of animal origin (meat, fish,
dairy; n = 12 ) and cooked chilled (ready-to-eat or ready-to-reheat) meals or meal components (n =
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46). Results were compared with the microbiological threshold values for marginal quality and
unacceptability of the food as recommended in the internal microbiological guidelines of our
laboratory at Ghent University (Uyttendaele, Jacxsens, De Loy-Hendrickx, Devlieghere, and Debevere
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(2010)). These threshold values are shown in Table 3.

With respect to overall microbiological quality, 6 of the 14 vegetable samples, one of the 12 foods of
animal origin and one of the 46 cooked chilled meals/meal components showed quite high levels of
contamination of yeasts at the time of sampling indicating marginal to unacceptable microbiological
quality of these foods. For lactic acid bacteria and total viable count respectively the number of
exceedances was none (of 14) for vegetable samples, 4 of 12 and 3 of 12 for foods of animal origin,
and 7 of 46 and 11 of 46 for cooked chilled meal/meal component samples. This corresponds to a
total of 22 of 72 food samples in which a certain degree of microbial growth potentially affecting the

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wholesomeness and sensorial quality of the food had occurred. Twelve of these samples had a use
by label, 4 had a best before label and the remaining 6 were fresh vegetables and one dessert
without an end of shelf life label (tartlet with cream and raspberries from a bakery). However, as it
was noted that none of the products are offered at the charity organizations after exceeding their
best before or use by date, this might indicate that the shelf life period, determined by the
producer, is estimated to be too optimistic or set not taking into account reasonably foreseen
temperature abuse that could have occurred during transport and storage thus explaining a certain
degree of quality reduction observed upon analysis. Overall, to provide also to economically deprived

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persons wholesome food meeting the indicated quality and labeling standards at the time of
consumption, it is important not allowing distribution of perishable products after their use by date

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(FASFC, 2017). According to the circular letter of the Belgian Food Safety Agency concerning food

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donations (FASFC, 2017) best before labeled products can still be distributed after exceeding their
expiry date, however, also in the latter case with a proposed time restriction for distribution. For
example, hard cheeses like Gouda and margarines can still be consumed up to 2 months after
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exceeding the best before date, on the condition that no defects are visually observed.

Considering the sanitary status of food samples, this was measured by enumeration of established
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hygiene indicators such as E. coli, Enterobacteriaceae or coagulase positive staphylococci in the 72

food samples. Coagulase positive staphylococci were never detected in any of the samples. In two
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products E. coli was present in low numbers: pea pesto (1.8 log CFU/g) and endive soup (2.0 log
CFU/g). Enterobacteriaceae were found in high numbers in one meat product: Mortadella (6.7 log
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CFU/g). This meat product was sampled at the end of shelf life, as such, these high numbers of
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Enterobacteriaceae could be a result of outgrowth of some psychrotrophic species during prolonged

storage in the cold chain and thus do not necessarily indicate temperature abuse or high initial levels
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due to unhygienic production. Still these high numbers are quite exceptional to find in a cooked meat
product. In addition, the Mortadella sample also showed presence of L. monocytogenes in numbers
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(3.5 log CFU/g) exceeding the threshold limit of 100 CFU/g (2.0 log CFU/g) for ready-to-eat foods and
thus non-complying with the European legislation with regard to L. monocytogenes in ready-to-eat
foods (EC., 2005). As it concerns a pre-packed sliced meat product, the L. monocytogenes
contamination most likely occurred during food manufacturing, and growth to high numbers was
supported during shelf life. Possibly enhanced growth leading to elevated numbers of both
Enterobacteriaceae and L. monocytogenes in this sample occurred due to temperature abuse, but it
could not be traced back whether a disruption of the cold chain happened either at retail phase or
after food donation during transport to and storage of the Mortadella package at the social grocery
shop. Still, this microbiological analysis of this perishable meat product sample showed the need to

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maintain cold chain and respect shelf life is of importance to ensure food safety of donated food
stuffs.L. monocytogenes was also detected (in 25 g) in two meat sausage rolls, and in one veggie
burger (spinach burger) but these three samples concerned no ready-to-eat foods, intended to be
heat treated before consumption, and the pathogen was not present in elevated numbers (< 10
CFU/g). Furthermore, Salmonella was absent per 25 gram in all food samples analyzed and B. cereus
could not be enumerated (< 10 CFU/g), thus no food safety issues were revealed concerning these
food borne pathogens.

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Only one other study performing microbiological analysis of donated food products was found in
scientific literature (Bonaccorsi et al., 2016). However, the latter study analyzed in particular food

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items that were not within the scope of our present survey. The authors analyzed mainly raw fresh
meat (and some pizza), whereas in our survey, this was not available as very few fresh meat is being

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donated in Belgium, thus making comparison of observed microbiological quality not appropriate.
Bonaccorsi et al. (2016) simulated the freezing of end of shelf life donated products (raw rabbit meat,
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raw poultry meat and ready-to-(re)heat pizza) with a domestic freezer in a charity organization and
evaluated the effect on microbiological quality. The authors concluded that after preparation and
thus heat treatment, all analyzed microbiological parameters were significantly reduced and
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concluded that freeze-thawing of fresh ready-to-cook products at charity organizations does not
pose a safety risk. Still, some remarks can be made about these findings. Bonaccorsi et al. (2016)
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executed slow thawing at 4C and appropriate heat treatment during meat/pizza preparation to
appropriately control microbiological contamination. However, as mentioned by Vidgen and Gallegos
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(2014), economically deprived persons often lack sufficient knowledge of appropriate food handling
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and food preparation practices. Several consumer based research studies have pointed out that after
purchasing, improper food transport, handling (cross-contamination), storage and cooking frequently
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happens, thus enabling survival, distribution and multiplication of micro-organisms (Anderson,

Shuster, Hansen, Levy, & Volk, 2004; Beumer & Kusumaningrum, 2003; Kennedy et al., 2011). In
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addition, opportunities for cross-contamination and transfer of pathogens from fresh meat when
manipulating raw meat samples at the food charity, e.g. in case of needing portioning of bigger
lumps of fresh meat that might be donated, or when handling at the food charity both raw fresh
meat and to other ready-to-eat food items were not considered in the study of Bonaccorsi et al.
(2016). The latter type of cross-contamination and other inappropriate handling at the consumers
home may also jeopardize food safety and quality of donated food. In summary, appropriate training
on food safety management at the charity organizations and investing at these centers in food
literary of economically deprived persons involved is recommended.

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3.4 Study limitations

A first limitation which could be identified, deals with the interviews of stakeholders. In total 21
interviewees were consulted, which could seem limited. Still, all key stakeholders along the food
donation/acceptation chain were represented. It is true, however, that 4 interviewees representing
the acceptor side is proportionally rather small, but by including the key overarching organizations
(such as KOMOSIE npo and FEBA) which are in close contact with the separate accepting charity
organizations, a lot of information about the acceptation side could be captured. Still, it should be
noted that the flow chart (Figure 2) and findings as described in the current research are based on

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consultation with a limited number of interviewees and could therefore miss certain pathways.

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A second important remark is related to the sample size for microbiological analysis. Only 72 food
samples were taken, as the researchers were restricted due to the limitation of perishable food

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products being offered in the food charity organizations. Also ethical reasons contributed to the
small sample size, in order not to deprive further the offer of these type of food products at the food
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charity centers. Still, it was not the objective of the study to perform extensive testing of food
samples, but rather to serve as a case study to get an initial idea of food quality and safety of
donated food products, as this is still lacking in scientific research. As such, the microbiological results
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obtained in this research are not representative for the whole food donation/acceptation chain in
Belgium.
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4.Conclusions
E
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After prevention of food loss, according to the waste hierarchy, redistribution of the surplus food to
most deprived population is the most sustainable and appropriate option to reduce food losses,
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surely of surplus foods. Specifically for Belgium, this occurs in a donation/acceptation chain, existing
aside the traditional regular agri-food chain. Interviews with donors, acceptors, regulators and
facilitators in this donation/acceptation chain unveiled that this chain is far less structured and
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organized, and that the fragmented landscape of several small food charity organizations, each
having their own way of working and usually relying on a number of ad hoc volunteers to get work
done, lacks professional food safety management. This is a bottleneck for smooth communication
and trust between donors and acceptors. It impedes the flow through of surplus food, and in
particular the donation of perishable foods. Barriers which were often mentioned were: i) insufficient
(refrigerated/frozen) storage capacity and logistics in food banks and charity organizations, ii)
insufficient knowledge of food labeling and food hygiene requirements and food safety management
systems needed and imposed by the EU and national competent authorities (food safety agencies),
and iii) the obligation to offer food products bought with FEAD financing for free, thus not being able

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to cover investments in infrastructure (refer to i) or more professional training (refer to ii) needed.
Moreover, most acceptors mainly employ volunteers, which results in less flexibility, high employee
turnover and impedes the efficient transfer of (hygiene and food safety) knowledge and
communication. That is why regulators and donors are advocating professionalization of charity
organizations. In addition, although at national level some flexibility & clarification is provided by
competent authorities, European legislation did not anticipate on the existence of this alternative
food chain yet and actually imposes accepting charity organizations to comply with the same legal
requirements as operators in the regular agri-food chain.

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Based on the case study in which the microbiological quality, hygiene and food safety of 72

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perishable food items in the donation/acceptation chain were analyzed, maintenance of the cold
chain during transport was found to be a first issue in this process, which was also mentioned in the

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interviews.

Additionally, the case study confirmed the importance of not allowing distribution of perishable
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products after their end of shelf life (as stated in legislation) and demonstrated that freezing of
perishable products close to their end of shelf life could be an important way to extend time for
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redistribution and prevent quality reduction before the food reaches the economically deprived
persons. However, it should be clearly indicated that the latter considers products that were indeed
frozen near or at the end of shelf life to avoid that acceptors are deceived on the origin or quality of
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the product, and preferably clear recommendations for appropriate defrosting and need for
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consumption immediately after defrosting should be provided. To be able to guarantee hygiene and
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food safety of donated food products, every actor in the food supply chain needs to apply good
hygienic practices during production and storage of the donated food.
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In order to optimize the use of food losses for food donation to economically deprived persons an
intense cooperation will be necessary between all stakeholders, i.e. donors, acceptors, regulators
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and facilitators. Efforts should be made to harmonize and professionalize the donation/acceptation
chain. Facilitators (for example KOMOSIE in the Flanders region) play an important role here, in order
to make sure (legal and food safety/hygiene) knowledge and communication reach all accepting
charity organizations. Guidelines concerning food safety/hygiene and legal requirements, as set
available now by some national competent authorities are expected to be developed in the near
future by the European Commission. This, in combination with a better structure and organization
would make a substantial contribution in the harmonization and professionalization of the
donation/acceptation chain.

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Figure 1: Flow diagram explaining definitional framework: food loss, food wastage, surplus food and
food waste. Based on OVAM (2012), Tarasuk and Eakin (2005) and FUSIONS (2014).

Food and inedible parts removed from the food supply

RAW MATERIAL
chain
FOOD WASTE

Animal feed Bio based materials Compost

Plough-in Anaerobic digestion Bio-energy

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Co-generation Incineration Sewer Landfill

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Discards

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Still fit for human consumption FOOD LOSS
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SURPLUS FOOD (Primary FOOD WASTAGE

production, processing, (household, retail,
distribution, wholesale) catering)
FOOD FOR
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HUMAN
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CONSUMPTION
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Distribution Outside the food chain (not considered

Regular food anymore)
to people in
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food chain
poverty
Stays in the food chain (new destination
of food: e.g. food donations)
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Regular food chain

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Figure 2: Process flow of food donation/acceptation chain in Belgium based on interviews with
stakeholders, illustrating the fragmented landscape

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Table 1: Overview of microbiological analysis (sample type and analytical method) applied
for the different sample/product types. *: both raw/uncut and washed/cut vegetables

Parameter Method Sample/product

type (sample
weight)
Listeria ISO 11290- (washed and
monocytogenes 2:1998/Amd precut)*
1:2004 vegetables,
meat products,
fish, cheese,

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prepared
products,
desserts (25 g)

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(enumeration in
10 g)

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Salmonella Enrichment: (washed and
Buffered Pepton precut)*
Water (10 2h, vegetables,
41.5C) (Oxoid meat products,
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CM0509) fish, cheese,
Detection: prepared
GeneDisc Protocol products,
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(Raw Beef Meat) desserts (25 g)

(Pall,
GSTECSL206006)
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E. coli Count by Plating: (washed and

RAPIDE.coli 2 precut)*
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Medium (Bio-Rad vegetables,

356-4024) meat products,
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Incubation: 24 fish, cheese,

2h, 44C prepared
products,
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desserts (10 g)

Enterobacteria-ceae ISO 21528-2:2004 washed and

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precut
vegetables,
meat products,
fish, cheese,
prepared
products,
desserts (10 g)

Coagulase positive ISO 6888- washed and

staphylococci 1:1999/Amd precut
1:2003 vegetables,
meat products,
fish, cheese,

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prepared
products,
desserts (10 g)

Bacillus cereus Count by Plating: washed and

M.Y.P. Agar Base precut
(Oxoid CM0929) vegetables,
Incubation: 24 meat products,
2h, 30C fish, cheese,
Confirmation: prepared
hemolytic activity products,

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on trypticase soy- desserts (10 g)
sheep blood agar
(incubate 24 2h,

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30C)

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Total viable count Count by Plating: (washed and
Plate Count Agar precut)*
(Oxoid CM0325) vegetables,
Incubation: 120 meat products,
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2h, 22C fish, cheese,
Modified ISO prepared
4833:2003 products,
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desserts (10 g)

Lactic acid bacteria Count by Plating: (washed and

Man Rogosa precut)*
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Sharpe with vegetables,

overlayer (Oxoid meat products,
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CM0361) fish, cheese,

Incubation: 120 prepared
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2h, 22C products,

Modified ISO desserts (10 g)
15214:1998
CE

Yeasts and molds AFNOR NF V08- (washed and

059:2002 precut)*
vegetables,
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meat products,
fish, cheese,
prepared
products,
desserts (10 g)

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Table 2: Overview of relevant issues/topics from EU legislation, possibly creating barriers for
donation of food to food banks or charity organizations. EU legislative documents, interpretation on
EU level, identified barriers, example of (mis)interpretation by member state(s) and Belgian
interpretation are given. Based on the study of Bio by Deloitte (2014) and interviews with regulators
in the current study.

Issue/topic Legislation EU interpretation Barrier Example of Interpretation

EU level (mis)interpretation Belgium
by member state
Liability EU Council Actors taking part in Food donors may Italy introduced a The Belgian

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Directive food donation need to be more inclined national Good FASFC considers
374/1985 comply with EU to discard surplus Samaritan law, food banks/charity
concerning legislation concerning food instead of stating that food organizations as
product responsibility, liability, considering banks/charity final consumer (cfr.

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liability traceability and food redistribution organizations can be the Good
(EEC, quality and safety. because of the considered as the final Samaritan Law in
1985) risks associated step in the food chain Italy)

SC
with liability of similar to final (BIO_by_Deloitte,
donated food. consumers, preventing 2014).
donors to get sued in
case of food safety
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issues
(BIO_by_Deloitte,
2014).
GHP and EU Good hygienic practices Flexibilities often In Portugal a If only
HACCP Regulation (GHP) and procedures not understood by consensual redistribution
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852/2004 based on Hazard Member States. misunderstanding activities are

hygiene Analysis Critical Semantic among all actors in performed and no
(EC., Control Points structures in the food chain, production (e.g.
2004a) (HACCP) must be in legislative texts including public repackaging,
place. Certain such as "when its institutions and making soup, etc.),
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flexibility is allowed in necessary", "if authorities, led to the HACCP procedures

implementation of the necessary", "if common belief that are not obligatory,
HACCP procedures, to applicable" etc . according to the EU only GHPs have to
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ensure these can be are often legislation it is be in place (EC.,

applied in all situations. misunderstood and forbidden to recover 2004).
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interpreted rigidly. prepared food or

If Member States meals for donation
choose to interpret purposes. As such, all
these rigidly, this prepared meals were
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can make food disposed of, although

donation more these were still fit for
difficult. consumption and
could be donated
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(BIO_by_Deloitte,
2014).
Labeling/ EU All prepackaged food The study of Several Member The Belgian
Date of Regulation products have to be BIO_by_Deloitte States (e.g. Greece, FASFC developed a
minimum 1169/2011 labelled with the legally (2014) showed Hungary, Spain) circular letter
durability concerning required (EC., 2011). that many have introduced concerning
food European food national provisions provisions
information After the use by date a donors were not which hinder donating applicable to food
to food shall be deemed to aware that certain of these expired food banks and charity
consumers be unsafe in accordance foods exceeding products, because of organizations
(EC., 2011) with EU Regulation the best before the risk of clarifying these
178/2002 (EC., 2002). date can still be liability/brand image issues (FASFC,
EU However, EU donated according but also the ethical 2017) .
Regulation legislation does not to the EU concern that
178/2002 ( prohibit the legislation. economically
general marketing/distribution deprived persons
food law) of foods after their best deserve food of equal
(EC., 2002) before date, on quality

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condition that the food (BIO_by_Deloitte,

is still safe and their 2014).
appearance is not
misleading EU
Regulation 178/2002
(EC., 2002).
Traceability EU All actors also those Food donors may In Belgium Charity
Regulation taking part in food be more inclined traceability organizations are
178/2002 donation need to to discard surplus requirements are considered as final
general comply with EU food, because of prescribed in Royal consumer. Only a
food law legislation concerning legal obligations. Decree of 14/11/2003 list of all
(EC., 2002) traceability. Flexibilities concerning self organizations at
should be arranged checking, compulsory which food was
on Member States notification and supplied should be
level, which can traceability (RD., kept by donors.

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lead to different 2003). Operators in Food banks and
approaches. the food chain need a charity
total identification of organizations only
both incoming and need to keep a list

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outgoing products and of all donors.
systems to identify the Clarified in circular
link between in and letter (FASFC,

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out (RD., 2003). 2017).
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Table 3: Microbiological threshold values for marginal quality and unacceptability of several food
categories as recommended in the internal microbiological guidelines of our laboratory at Ghent
University according to Uyttendaele et al. (2010): criterium for marginal quality/criterium for
unacceptable quality. (n= ) : Number of food samples in each category. TVC: Total Viable Count;
LAB: Lactic Acid Bacteria; NA: not applicable.

OVERALL QUALITY HYGIENE INDICATORS PATHOGENS

TVC LAB Yeast Mold
E.col Enterobact Coagulase B.cere L.monoc Salmonell
(log (log cfu/g) (log (logi eriaceae positive us ytogene a
cfu/g) cfu/g) cfu/g)
(log (log cfu/g) staphyloc (log s absent(A)

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cfu/ occi (log cfu/g) (log /present(
g) cfu/g) cfu/g) P) in 25g
Leafy vegetables intended for raw consumption (e.g. Lettuce, purslane) (n=6)
7.0 5.0 /7.0 4.0 4.0/ 3.0 NA NA NA 2.0 A
Vegetables (n=14)

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/8.0 /5.0 visually /3.0
Raw mushrooms and other vegetables like tuber and bulb vegetables (e.g. Leek, fennel) (n=5)

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NA NA 4.0 4.0/ 3.0 / NA NA NA 2.0 A
/5.0 visually 3.0
(Washed) precut vegetables (e.g. mixed vegetable, diced carrots) (n=3)
6.0 4.0 / 7.0 4.0 / 4.0 / 3.0 NA 3.0 / 3.0 NA 2.0 A
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/8.0 5.0 visually /3.0
Meat products (e.g. Cooked ham, cooked sausage) (n=6)
Products of animal origin (meat, fish, dairy)

4.0 / 4.0 / 6.0 3.0 / 3.0 / 1.7 / 2.7 / NA 3.0 / 3.0 3.0 2.0 A
6.0 5.0 visually 1.7 /
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5.0
Fish
-Cooked shrimps with modified atmosphere packaging (n=1)
(n= 12)

6.0 / 3.0 / 7.0 NA NA 3.0 / NA 3.0 / 3.0 NA 2.0 A

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7.0 3.0
-Smoked (dried/salted) fish with aw > 0.95 (e.g. smoked salmon) (n=2)
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5.0 / 4.0 / 7.0 3.0 / 3.0 / 3.0 / NA 3.0 / 3.0 NA 2.0 A

6.0 5.0 visually 3.0
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Cheese (e.g. Goat cheese) (n=3)

NA NA NA NA 3.0 / NA 3.0 / 5.0 3.0 2.0 A
3.0 /
5.0
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Ready-to-(reh)eat complete meals (e.g. lasagna) and meal components (e.g. cooked beetroot) (n=25)
Cooked chilled meals or meal components (n =

4.0 / 3.0 / 7.0 3.0 / 3.0 / 1.7 2.7 / NA 3.0 / 3.0 3.0 2.0 A
6.0 5.0 visually /1.7 /
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5.0
Ready-to-(reh)eat vegiburgers (e.g. mushroomburger, millet-poppy seed cake) (n=12)
4.0 / 3.0 / 7.0 3.0 / 3.0 / 1.7 2.7 / NA 3.0 / 3.0 3.0 2.0 A
6.0 5.0 visually /1.7 /
5.0
46)

Soups (n=6)
4.0 / 3.0 / 7.0 3.0 / 3.0 / 1.7 2.7 / NA 3.0 / 3.0 3.0 2.0 A
6.0 5.0 visually /1.7 /
5.0
Desserts (n=3)
4.0 / 3.0 / 7.0 3.0 / 3.0 / 1.7 2.7 / NA 3.0 / 3.0 3.0 2.0 A
6.0 5.0 visually /1.7 /
3.0

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Highlights

Food donation in Belgium is mapped, also the European framework is investigated.

Bottlenecks in legal framework and food safety management are identified.
The Belgian donation process is very fragmented and lacks coordination/harmonization.
72 donated perishable food samples were subjected to microbiological analysis.
Our study reveals the need for a more harmonized approach and concerted action.

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