7. We consider that the following raises questions of political importance,
but make no recommendation for its further consideration at this stage:--
Ministry of Agriculture, Fisheries and Food
(17738) 12197/96 COM(96)596 |
Proposal for a Council Regulation laying down general rules for the
application of measures to improve the production and marketing of honey. |
Legal base: |
Articles 42 and 43; qualified majority voting.
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Background
7.1 The Commission proposal follows consultation on its Communication on the
situation of European Apiculture which we considered on 19 October 1994[12] and judged to be politically important but not for debate. The importance
of beekeeping and honey production varies considerably between Member States and within Member
States. Of 435,000 beekeepers in the European Union, only 13,000 are professional beekeepers,
although they have 42% of all the hives in the Union. At present there is no specific market
organisation for honey, but intermittent aid has been given for various aspects of apiculture. The
proposal would extend the scope of the Common Agricultural Policy by providing a permanent programme
for apiculture, the elements of which would be 50% reimbursed by the Community. It is not clear
to what extent national arrangements would be superseded or constrained by the proposal.
The proposal
7.2 The proposed regulation lays down measures for improving general conditions for
the production and marketing of natural honey. The measures would have to be included in national
programmes for each year and cover:
a) technical assistance to beekeepers, including training;
b) control of varroasis[13] and
related diseases. Measures to improve harvesting storage and packaging of honey;
c) rationalisation of transhumance[14];
d) chemical analysis of honey; and
e) research to improve honey quality.
7.3 The regulation would require the setting up of national programmes; 50% of the
financing of these national programmes would be borne by the Member State and 50% by the Commission.
The Commission would lay down implementing rules to cover expenditure incurred by the national
programmes, particularly payment applications, time limits for submission of applications and
conditions to be met by applicants. The estimated cost is given by the Commission as 15 million
ECU (£11.06 million) per year. The national programmes would be drawn up in close
collaboration with professional beekeepers' organisations and measures included in them could not
duplicate operational programmes included in structural schemes for objective 1, 5b and 6 regions
of the Community[15].
The Government's view
7.4 The Government's view as expressed on the earlier document has not changed. It
queries the value of Community action and is particularly concerned about the mandatory nature of
some of the proposed measures. It considers that the proposal fails the test of subsidiarity. In
his Explanatory Memorandum of 10 January, the Minister of State at the Ministry of Agriculture,
Fisheries and Food (Mr Baldry) states that the Commission Communication
"was overwhelmingly supported by most Member States and agreement of the proposed
measures by the Council is likely. The Government will wish to question the economic justification
for the measures and also consider the effects on UK public expenditure. The mandatory nature of
the proposed national programmes will also be questioned; expenditure of this nature is something
which might best be left to Member States."
7.5 He believes that a Compliance Cost Assessment is not necessary as the proposal
would not regulate the activities of businesses in the UK.
Conclusion
7.6 The fact that there has been no programme for the common organisation of the
market for honey since the inception of the Community lends weight to the Government's view that
the case for the present proposal has not been made out. It is not clear from the papers what the
precise effect of the national programme would be on the many amateur beekeepers in the United
Kingdom and in other parts of the Community. For example, would they be required to keep records,
make returns or have limits put on the timing of movement of hives under transhumance arrangements?
7.7 Although professional beekeepers have 42% of all hives in the Union, there
are only 13,000 of them compared to 422,000 "non-professionals". This could create
problems in preventing fraud and maintaining adequate checks on implementation of different measures
in national programmes. The section on fraud prevention indicates that "existing registers of
beekeepers in the Member States should facilitate these checks". It is not clear whether there
is a register of all beekeepers, including those who are not professional honey producers. We would
like to know whether such a register would be obligatory, and what it would cost.
7.8 The justification given by the Commission for aid to this sector is
inconsistent. On the one hand it suggests that assistance for honey analysis is required because
honey analysis is very expensive, but on the other it argues that aid for training courses is
necessary because the courses are very popular and "beekeeping associations need assistance
in order to meet the demands". If there is such a demand for the courses, it would seem that
they could be self-financing.
7.9 We would like a clear indication from the Government of the exact implications
of the drawing up of the national plan, the mandatory nature of the provisions to which it alludes
and a clear indication of whether any burdens would be put on amateur bee keepers through
registration or reporting provisions. We would also like to know whether the Commission proposal
would prevent action at national or local level, for example on transhumance, where the movement
of hives into Kent or into Yorkshire depends on local seasonal factors which could not easily be
encapsulated in a national plan produced for Commission approval months in advance. Meanwhile, we
are not clearing the document.
12.(15515) 8166/94; see HC 48-xxvi (1993-94), paragraph 44 (19 October 1994). Back
13.The disease varroasis is caused by the varroa mite, which causes irritation and
disrupts the proper functioning of bee colonies affected by it; once introduced into a colony it
is difficult to eradicate. Back
14.Transhumance is the movement of hives to different areas to obtain pollination
or maximum honey production from seasonal flowering. Back
15.These are areas which qualify for structural aids for promoting the development
and structural adjustment of the regions who development is lagging behind (objective 1),
facilitating the structural adjustment of rural areas (objective 5b), and assisting of low
population density (objective 6). Back
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