APPENDIX 10
Memorandum submitted by The British Poultry
Meat Federation (S 15)
INTRODUCTION
1. The British Poultry Meat Federation (BPMF)
represents all parts of the UK poultry meat production chain from
breeding, hatching and rearing through to slaughtering, primary
processing and further processing. BPMF Members account for around
95 per cent of total UK poultry meat production, which exceeds
1.5 million tonnes annually. This is 50 per cent more than pork
and bacon and twice the volume of UK beef production. The UK poultry
sector consumes around 20 per cent of the UK annual wheat crop
and 7 per cent of the barley harvest. The UK is the second largest
poultry meat producer in the EU after France. EU poultry production
is unsubsidised.
ELEMENTS OF
THE NEXT
WTO ROUND
Tariffs
2. It is our firm view that the greatest
threat to EU agriculture and rural employment comes from reduction
or removal of EU tariffs across the board, and not from any change
in the remaining "blue box" supports. The greatest negotiating
effort must be placed on preserving tariff protection and the
safeguard clause.
3. WTO tariff reductions will not open up
any significant exporting opportunities for EU poultry meat producers
and there would be no offset for the increased and cheaper access
to the EU market for Third Countries' poultrymeat.
4. We are strongly of the view that tariffs
on poultry meat must not be sacrificed in any trade off to preserve
the few remaining subsidies in the "blue box" still
enjoyed by other sectors. In this respect it should not be forgotten
that the poultry industry is the biggest consumer of EU cereals
and every tonne of chicken breast imports from Third Countries
means around six tonnes less of EU cereals consumed as poultry
feed. EU cereal interests are directly linked to the well being
of the EU poultry sector.
5. MAFF and EC Commission projections of
EU wheat and coarse grain intervention stocks post-Agenda 2000
assume continuing positive growth in EU poultry meat consumption.
The big increases predicted in EU cereals stocks will be even
greater and more damaging, if the forecast increases in EU poultry
meat consumption are allowed to be taken by increased and cheaper
imported poultry products.
6. We have responded to MAFF's Consultation
Document on the next Round, issued in July 1999. Table 2, in Annex
B of MAFF's Document (attached [not printed]) compares the gap
between landed costs and EU institutional prices. The figures
confirm that there is little room for further cuts in tariffs
on poultry meat compared with most other agricultural products.
We would expect any unavoidable cuts in tariffs to be applied
to those sectors that are currently most protected, ie where the
gaps are largest.
7. In considering greater use of the green
box exemptions, the poultry sector would wish to be considered
as eligible on equal terms as any other sector for environmental
and other non-production related schemes. Environmental and other
assistance schemes must not be simply the current subsidies paid
to the same sectors dressed up in more acceptable clothes. They
must be available to all in the rural sector able to meet the
environmental and social objectives set.
Exports
8. The Commission's projected draft budgets
for export refunds make no provision for subsidised poultry meat
exports after the end of the current Uruguay Round Agreement,
even though the Agreement itself does not preclude subsidies.
As long as EU cereal prices are above world prices and as long
as UK and EU labour and social-security costs, and environmental
and animal welfare requirements are significantly more onerous
than those imposed on our international competitors, then we would
wish to have export refunds on EU poultry meat.
9. However, the emphasis of any export refunds
must be on poultry cuts and not on whole birds as at present.
The whole bird refunds benefit a few companies in France and Denmark
producing whole birds mainly for the Middle East market. The greater
part of the EU poultry meat industry is adding value by cutting
birds. Refunds are needed to help dispose of those cuts which
are not in demand in the EU. Such refunds would help most EU producers
rather than just a few companies as at present.
10. Under the same principle in paragraph
9, assistance schemes for exports from the EU should be framed
to encourage the maximum degree of added value within the EU.
Exporting subsidised EU cereals benefits the importing country
more than the EU, whereas exporting the various products utilising
EU cereals gives greater benefit to EU economies. This principle
should guide EU negotiations on export subsidy schemes in the
WTO Round.
11. We agree that less obvious forms of
export subsidy such as export credits, export guarantees, and
food aid should be dealt with in the same way as export refunds.
NON TARIFF
BARRIERS
The Precautionary Principle and food safety
12. We believe that common rules ensuring
food safety and animal health are far more important than the
issue of farm animal welfare in these WTO negotiations. Emotive
and vociferous arguments on animal welfare must not be allowed
to divert attention from the fundamentally more important issue
of common rules ensuring equal treatment on human and animal health
grounds.
13. We note that the EU Council's Conclusions
on the EU approach to the next WTO Round seek to obtain a clearer
general recognition of the precautionary principle.
This is essential. We are particularly concerned
by the EU's inconsistent use of the principle in respect of imports.
Certain antibiotic growth promoters are banned within the EU for
meat animals but imports of meat from animals fed with these substances
in Third Countries are permitted. In the case of hormonal growth
promoters the ban applies both to domestic use and to imported
meat from animals fed with these substances. Both bans are ostensibly
to protect human health but have more to do with politics in our
view, and as a result the treatment differs markedly between sectors.
This difference must call into question the validity of the public
health claims on which the bans are predicated.
14. Any decision to invoke the precautionary
principle must be taken according to known rules agreed in the
WTO context and must apply equally to all production irrespective
of country of origin.
Animal welfare
15. Bird welfare is accorded high priority
by the British poultry meat industry and we believe we operate
to the highest standards of any country. However, there is no
universally held concept of animal welfare. There is not even
total agreement amongst scientists as to how to measure welfare.
We understand and have sympathy for the objectives behind the
wish to bring animal welfare within WTO rules. However, because
of the complexity of the issues and the cultural differences involved,
there is a real danger that any rules arrived at are likely to
be very simplistic. This could work against the interests of the
high investment livestock farming which is the backbone of most
European meat and milk production.
16. For example, for poultry rearing we
could imagine that stocking rate might be one such simplistic
measure. On its own, any particular stocking rate does not indicate
good welfare. Other, equally important parameters of welfare must
be taken into account such as the quality of housing and the capacity
of the equipment.
17. It is highly unlikely that voluntary
codes of welfare practice, most favoured in the UK, would be acceptable
in place of specific regulations or commonly enforced EU directives,
as evidence of more stringent and higher welfare standards in
the EU.
18. Establishing common WTO standards for
animal welfare would be likely to take a very long time and ensuring
all producers around the world conformed to them even longer.
Instead, we propose a possible approach based on tariffs. Common
rules (but not common standards) could be agreed that permit a
country which has manifestly higher and legally enforced standards,
to impose additonal tariffs on imports from countries without
such legal requirements in place. The need to have to be able
to demonstrate to a WTO disputes panel that particular legal requirements
constitute higher welfare standards, in order to justify higher
tariffs, should constrain countries' attempted use of animal welfare
as non-tariff barrier to trade.
IMPLEMENTATION OF
EXISTING GATT COMMITMENTS
19. We would expect the existing commitments
in the GATT Agriculture Agreement to have been implemented by
all Contracting Countries before any new trade liberalisation
commitments are entered into by the EU. For example, the USA,
the world's largest poultry meat producer, is effectively closed
to poultry meat imports from lower cost producers such as Brazil
and Thailand. The EU, on the other hand has long been open to
imports from Third Countries and now it even appears to be considering
removing the remaining tariff protection in the cases of Brazilian
and Mexican poultry meat. Clearly, the existing WTO rules are
being applied very selectively and unfairly by different countries,
in particular by some of those which claim to be the greatest
advocates of free trade.
BILATERAL FREE
TRADE AGREEMENTS
20. The EU poultry meat industry is very
concerned that the EU is embarking on negotiations of FTAs with
Mexico and with the MERCOSUR group of countries in advance of
the outcome of the WTO Round. We are not clear about the mandate
for the MERCOSUR negotiations and are extremely worried that poultrymeat
may be included within the proposed agreement while other, subsidised,
EU agricultural sectors will remain outside and protected.
21. It would be iniquitous if the EU poultry
industry had to face tariff-free competition from imported Brazilian
poultry meat but still had to source its largest input, cereals,
at inflated prices from a protected EU cereals sector. The same
rules must apply to all parts of the chain. If EU cereals and
beef are to be excluded then so must poultry meat. Either way,
it is essential that the FTAs are concluded only within the context
of any new WTO rules.
5 November 1999
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