The European Commission has published ‘Building Food 2040’, a synthesis of the stakeholder input gathered to inform the new EU research and innovation (R&I) strategic agenda for food systems (European Commission, 2026a). The report, edited by the Directorate-General for Research and Innovation, analyses 631 survey responses and 63 written submissions – position papers, policy briefs, roadmaps and vision statements – collected in March 2026 across the European food-system landscape.
From Food 2030 to Food 2040, the policy context
Food 2030 has been, since 2016, the R&I policy framework designed to advance sustainable, resilient, inclusive and healthy food systems through a systemic approach. Between 2017 and 2024 it supported 117 EU-funded projects, for an investment of approximately €770 million (European Commission, 2026b). Its eleven pathways for action – set out in the 2023 update – have guided food-systems R&I under Horizon Europe (European Commission, 2023).
Food 2040 originates in a commitment taken in the 2025 Life Sciences Strategy, where the Commission undertook to deliver a strategic R&I agenda on food systems capable of fostering competitive, sustainable and resilient solutions. The public survey opened on 27 February 2026 and closed on 13 March 2026, with the explicit aim of building an evidence base for the successor agenda (European Commission, 2026b).
A consultation dominated by academia
Research institutes and academia account for 51.5% of respondents, confirming the mobilisation capacity of the Food 2030 framework within the scientific community. Individual citizens follow at 9.4%, ahead of agriculture and farming (8.4%), government and policy actors (7.8%) and NGOs (7.6%). Conversely, food manufacturing and processing represent only 6.7% of the sample, and retail, distribution and logistics a mere 0.3% – an imbalance the Commission itself acknowledges, calling for deeper engagement with post-farm-gate actors to ensure practical relevance and market uptake.
Geographically, Spain and Germany provided most answers, while Belgium, Ireland, Finland and Denmark showed the highest participation relative to population. The distribution matters: an agenda designed to close the distance between laboratory and market is being shaped, for the most part, by the actors located at the laboratory end of that distance.
The eleven pathways under scrutiny
Respondents broadly recognised the added value of the systems-thinking approach introduced by Food 2030. Yet more than a third of participants declared themselves insufficiently familiar with the framework to assess its impact, a finding that argues for stronger communication and stakeholder engagement in the next phase.
Asked how the current pathways could evolve, 59.4% requested better alignment with real-world food systems, 38.7% clearer objectives and expected impacts, and 30.9% a simplification or consolidation of the eleven pathways, accompanied by more robust monitoring and progress indicators. The direction of travel is towards fewer and more operational priorities, with measurable outcomes attached.
Top priorities: environment, health, resilience
Three priorities emerge at the top of the quantitative ranking:
- reduced environmental and climate impacts of food-system actors beyond the farm gate leads with 46.4%, followed by
- improved human health through healthier dietary habits (44.7%) and
- increased resilience and preparedness of food systems, including strategic autonomy and crisis management (44.1%).
Protein diversification, circularity and short supply chains
Open-ended responses reinforce three recurring themes: protein diversification and the scale-up of plant-based production; circular economy and value-chain circularity, including food-waste valorisation; and local food-system resilience built on regional short supply chains and decentralised infrastructure.
The health finding is linked by the Commission to protein itself: submissions call for greater strategic attention to alternative protein sources, clearer and updated terminology around nutrition and sustainable diets, and reduced import dependencies for feed and food inputs, including additives, ingredients and micronutrients.
Bridging the ‘valley of death’
A central message concerns the well-known ‘valley of death’ between promising research – up to Technology Readiness Level 6 – and its commercialisation at scale. Echoing the concerns on European competitiveness raised in the Draghi report (Draghi, 2024), stakeholders identified predictable regulatory pathways, access to capital and adequate industrial infrastructure as the enabling conditions for the uptake of novel ingredients, sustainable proteins and other food innovations.
Suggested remedies include connecting R&I funding with pilot plants, demonstration facilities, bio-manufacturing capacity and public–private shared infrastructure, alongside targeted support for sectors facing critical import dependencies, such as domestic aquaculture and plant-based protein processing. Faster EU regulatory procedures recur across submissions as a condition rather than an accessory.
‘Regulatory by design’, from laboratory to market
The distance between scientific validation and legal marketability is precisely where our WIISE benefit company has concentrated its contribution to European research consortia. The method – ‘regulatory by design’ – consists in determining the legal qualification of a research result at the outset of a project rather than at its end:
- whether a substance qualifies as a food, a food supplement, a feed additive or a cosmetic ingredient;
- whether it falls within the scope of the novel food regulation;
- which safety data its authorisation will require. A result that is technically validated yet legally unmarketable is a failed exploitation, however sound the underlying science.
Two examples illustrate the approach:
- in ProFuture, dedicated to microalgae proteins, the analysis of four target species produced a roadmap for joint authorisations under Regulation (EU) 2015/2283, enabling SMEs and research organisations to share the cost of safety dossiers otherwise prohibitive for individual applicants;
- in EcoeFISHent, the legal work addressed the regulatory obstacles to the transition of fishing side-streams from the status of animal by-products – under Regulation (EC) No 1069/2009 – to that of high-value raw materials for food, feed, nutraceutical and cosmetic uses.
The approach continues in FAF (Future-proof microalgae-based foods), launched on 1 April 2026 under the FutureFoods partnership in Horizon Europe, where WIISE benefit acts as regulatory partner for the entry of microalgae into mass-market foods (Dongo & Della Penna, 2026a).
A third example broadens the picture. In CamelMilk, a PRIMA project on the camel-dairy value chain across the Mediterranean, the legal work ran along two tracks:
- the first concerned the conditions governing the importation of products of animal origin from non-EU countries – official-controls requirements, establishment listing and the hygiene standards to be met by production systems in Algeria and Türkiye – alongside the novel food status of camel milk and the simplified procedure for traditional foods from third countries under Regulation (EU) 2015/2283;
- the second track, shared with ProFuture, addressed the valorisation of nutritional and health properties: a review of the scientific literature identified which nutrition claims could be substantiated on the basis of composition, and which health properties might justify the design of clinical studies capable of sustaining an authorisation dossier under Regulation (EC) No 1924/2006, subject to EFSA assessment and Commission authorisation.
The same criterion applies to measurement. In WASTELESS (Horizon Europe, 2023-2026), our technical-legal mediation addressed the regulatory architecture of the blockchain-based electronic registry and its synchronisation with EU statistical nomenclatures, alongside the compliance pathways for turning side-streams into authorised food and feed ingredients. The baton now passes to HomeWISE, devoted to the measurement of household food waste through digital tools, where WIISE benefit oversees the legal and ethical dimensions – personal data protection, use of artificial intelligence, Member States’ reporting obligations (Dongo & Della Penna, 2026b).
Beyond individual projects, our work extends to the evolution of the rules themselves;
- on proteins, the European protein strategy adopted in Strasbourg considered the request – advanced among others by the Horizon4Proteins cluster of consortia, in which our team participates – for a simplification of novel food procedures and for effective access to authorisation by SMEs, innovative start-ups and research institutions, today often burdened with disproportionate costs (Dongo & Della Penna, 2023);
- on circularity, our review of the EcoeFISHent results on marine collagen identified the administrative complexity of ABP categories as a structural obstacle, proposing risk-based classification, streamlined approval of established processing methods and an expedited pathway for nutraceutical and cosmetic applications, with HACCP systems in place (Dongo, 2025).
The point deserves emphasis in the Food 2040 debate. The consultation frames regulatory predictability as an enabling condition for scale-up, and the framing is correct as far as it goes. It remains incomplete where regulatory analysis continues to be treated as a downstream compliance exercise, appended to a project once the science is settled, instead of a design parameter which is necessary from the proposal stage.
Provisional conclusions
The consultation confirms strong stakeholder interest in a renewed, more operational set of pathways that preserve the breadth of the Food 2030 approach while making expected impacts, indicators and implementation mechanisms explicit.
Whether Food 2040 will succeed in translating research excellence into deployment – reinforcing the connections between food science, industry, public policy and citizens – will depend on the political will to match ambition with investment, and on the parallel reform of the authorisation procedures that currently determine how long a validated result waits before it can reach the market. Ambition without regulatory reform reproduces the ‘valley of death’ the agenda sets out to bridge.
Dario Dongo
Credit cover IRTA
References
Institutional reports and policy documents
Draghi, M. (2024). The future of European competitiveness – Part A: A competitiveness strategy for Europe. European Commission. https://commission.europa.eu/topics/competitiveness/draghi-report_en
European Commission, Directorate-General for Research and Innovation, Gallina, A., & Pelissier, P.-M. (Eds.). (2026a). Building Food 2040: Stakeholder input for the new EU R&I strategic agenda for food systems – Analysis and synthesis of the results from the open consultation survey. Publications Office of the European Union. https://data.europa.eu/doi/10.2777/2306913
European Commission. (2026b, 27 February). The Commission launches public survey for shaping Food 2040, the upcoming food systems research and innovation agenda. EU Agri-food Platform. https://transition-pathways.europa.eu/agri-food/news/commission-launches-public-survey-shaping-food-2040-upcoming-food-systems-research
European Commission, Directorate-General for Research and Innovation. (2023). Food 2030 – Pathways for action 2.0: R&I policy as a driver for sustainable, healthy, climate-resilient and inclusive food systems. Publications Office of the European Union. ISBN 978-92-68-01289-5. https://research-and-innovation.ec.europa.eu/knowledge-publications-tools-and-data/publications/all-publications/food-2030-pathways-action-20-ri-policy-driver-sustainable-healthy-climate-resilient-and-inclusive_en
European Commission, Directorate-General for Research and Innovation. (2026c, 13 July). New report published: Building Food 2040 – Stakeholder input for the new EU Strategic Research & Innovation Agenda for Food Systems. https://research-and-innovation.ec.europa.eu/news/all-research-and-innovation-news/new-report-published-building-food-2040-stakeholder-input-new-eu-strategic-research-innovation-2026-07-13_en
Related articles
Dongo, D. (2025, 10 May). EcoeFISHent: collagen from fish discards – a practical & policy model. Food Times. https://www.foodtimes.eu/research/ecoefishent-mediterranean-fish-collagen-valorisation/
Dongo, D., & Della Penna, A. A. (2023, 27 October). European protein strategy, the new resolution. Food Times. https://www.foodtimes.eu/planet/european-protein-strategy-the-new-resolution/
Dongo, D., & Della Penna, A. A. (2026a, 16 March). Future-proof microalgae-based foods (FAF): the research project. Food Times. https://www.foodtimes.eu/research/future-proof-microalgae-based-foods-faf-european-research-project/
Dongo, D., & Della Penna, A. A. (2026b, 21 July). HomeWISE, the EU research project to measure and reduce household food waste. Food Times. https://www.foodtimes.eu/research/homewise-eu-research-household-food-waste/
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
