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Umsögn um Nordic Nutrition Report 2023

Updated: Aug 30, 2023



Umsögnin var skrifuð og send inn á ensku.


Overall comment

Ungir Umhverfissinnar (UU) deeply appreciates that the authors of NNR2023 studied, analyzed, and included the environmental impact of each examined category. UU believes that consumption of plant-based proteins should be prioritized over meat and dairy products, as these have a significantly higher carbon footprint and are more destructive to the environment and biodiversity, as is noted within NNR2023. Studies have shown that decreasing animal product consumption is necessary for the Nordic countries to fulfill their climate obligations and protect their unique shared ecosystems and biodiversity. According to the “More Money, More Meat” report by the NGO Compassion In Farming published in May 2023, Denmark, Finland, Iceland, Sweden, and Norway are in the top 25 countries for animal-based product consumption. This amount of consumption is not conducive to living within the earth’s planetary boundaries and works against domestic targets and international obligations of the Nordic countries.


Given the importance of a just transition, UU wants to encourage governments to put in place support schemes for dairy and meat farmers as they diversify their operations, whether switching to producing alternative crops, restoring ecosystems, or otherwise.


Comment on red meat

P. 138, para 2: “The reduction of red meat consumption should not result in an increase in white meat consumption. To minimize environmental impact, meat consumption should be replaced by increased consumption of plant foods, such as legumes.”


UU completely agrees that the reduction of red meat consumption should not lead to an increase in white meat. UU also recognizes that the new guidelines that recommend 350 grams per week is a significant decrease of what most, if not all, Nordic and Baltic countries are currently consuming and applaud this new guideline. However, UU would like to call for an even lower recommended amount of red meat consumption given that leading a fully plant-based lifestyle is both better for human and planetary health which should be a priority.


Comment on white meat

P. 140, para 1: “To minimize environmental impact, consumption of white meat should not be increased from current levels, and preferentially be lower”.


While UU agrees that white meat consumption should not be increased, UU strongly encourages the wording to be stronger than just a preference for a lower consumption. We would like the recommendations to advise a firm and significant decrease in white meat consumption. Even though white meat is not as environmentally destructive as red meat, its consumption must decrease significantly if a diet within planetary boundaries is to be achieved.


Comment on milk and dairy

P. 142, “Overall science advice: 250-500 gram/day of predominantly low-fat milk and dairy products (10 g cheese is similar to 100 g milk). If consumption of milk and dairy is lower than 250 gram/day, products may be replaced with fortified food equivalents or other foods.”


Iceland reportedly averages 595g of dairy consumption per person per day. While the 250-500g/day guidance would encourage a decrease of dairy consumption, it would only be minimal, as decreasing by a mere 95 grams would then fall within the guidelines. As with the red meat recommendations, UU calls for a radical decrease in the recommended intake of dairy consumption given the fact that plant-based alternatives provide all the required nutrients contained in dairy products and are in most cases much less destructive to the natural environment and the climate.


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Emily Richey-Stavrand, hringrásarhagkerfisfulltrúi, sendi umsögnana til Norrænu ráðherranefndarinnar 26. maí 2023.

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