APPENDIX 12
Memorandum submitted by the British Meat
Manufacturers' Association (S 17)
INTRODUCTION
1. The British Meat Manufacturers' Association
(BMMA) represents the interests of the UK meat manufacturing sector
and has 70 companies in full membership accounting for 100 manufacturing
sites. BMMA's members use meat to make products such as bacon,
ham, sausages, pies, burgers, pâtés and ready meals.
The meat manufacturing sector accounts for over half of the £10.5
billion spent on meat in the UK each year.
2. BMMA is grateful for the opportunity
to comment on the implications for UK agriculture and EU agricultural
policy of trade liberalisation and the World Trade Organisation
round. In response to the stated areas of difficulty, BMMA will
address animal welfare, scientific dispute and consumer resistance
as they relate to the meat manufacturing sector. Specific reference
will be made to hormones in beef and restrictions on trade in
GM foodstuffs.
SEATTLE MINISTERIAL
CONFERENCE OF
THE WTO
3. For the purposes of the Seattle Ministerial
Conference of the WTO, the Agriculture Council has resolved to
continue to develop the existing European model of agriculture
based on its multifunctional character. The decisions adopted
regarding the reform of the Common Agricultural Policy (CAP) within
the framework of Agenda 2000 will constitute the essential elements
of the Commission's negotiating mandate.
4. It has been made clear that:
"European agriculture as an economic sector
must be versatile, sustainable, competitive and spread throughout
Europe, including the regions with specific problems. It must
be capable of maintaining the countryside, conserving nature and
making a key contribution to the vitality of rural life. It must
also be able to respond to consumer concerns and demands regarding
food quality and safety, environmental protection and the safeguarding
of animal welfare."
5. BMMA accepts the general approach adopted
by the EU but appreciates that animal welfare and environmental
issues will be difficult to negotiate in global market terms.
With WTO's membership standing at 134 countries, most of which
are less developed than the EU, agreement on these issues will
not be easy. Forecasts point to a steady expansion in the global
economy. Against the backdrop of growth in the value of international
trade, many WTO members will be disinclined to change the goalposts
at this stage. The European Commission has published figures which
indicate that between 1988-97, the growth in the value of EU exports
in agricultural commodities and processed food products stood
at +70 per cent and +140 per cent respectively.
6. BMMA supports the need to increase the
access for manufactured food products to third country markets.
This might be achieved by reductions in tariff protection for
value added food products. Since the cost of reducing barriers
to exports to third country markets may be to reduce barriers
against imports from third countries, care should be taken to
ensure the continuing incentive to process food and therefore
add value within the EU.
7. BMMA supports equitable liberalisation
of world trade. There should be close relationships between raw
materials (either from inside or outside the EU) and value added
products, thus ensuring that the EU food industry remains competitive
both inside and out. So long as EU prices for agricultural commodities
are above the world level, restitutions are essential to achieve
competitively priced exports. Costs for pigmeat production are
set to rise due to higher feed costs, higher welfare standards
and, eg the reduction in the use of antibiotics. Beef and dairy
sectors are also vulnerable. There should be no further cuts in
export refunds in the current climate. To implement a cut in export
refunds would put the EU at a competitive disadvantage to the
USA.
NON-TARIFF
BARRIERS TO
TRADE
8. BMMA agrees with the need to take into
consideration the multifunctional role of agriculture including
environmental protection, safety and quality of food and animal
welfare. As stated above, these are difficult areas that will
not be afforded the same level of priority by all WTO members.
9. We support the proposal that the EU should
seek solutions that assure consumers that the WTO will not be
used to force onto the market products about whose safety there
are legitimate concerns. Some appropriate level of protection
is required.
SOUND SCIENCE
AND THE
PRECAUTIONARY PRINCIPLE
10. BMMA notes the proposals for an EU White
Paper on Food Safety which will be for the year 2000 and supports
the philosophy of "a single body of legislation based on
solid updated scientific knowledge". It is also noted that
the precautionary principle will be a top priority. It is essential
that trade decisions are taken in the light of sound science.
There is a place for the precautionary principle but as yet there
appears to be no agreed interpretation of the concept. The EU
might seek to obtain from WTO a clearer general recognition of
the principle but an agreed definition is required in the first
instance. It must not be used as a market protection mechanism.
11. The response to the potential dangers
involved in the use of hormones in beef illustrates the use of
the precautionary principle. A ban is in place but scientific
evidence is far from substantial. There are no fewer than 17 EU
commissioned studies investigating the potential dangers of hormone-treated
beef.
12. Independent scientific advisers in the
UK have now concluded that the scientific evidence in a recent
report does not support the EU ban on the use of hormonal growth
promoters in food producing animals or the import from third countries
of meat and meat products derived from animals treated with these
substances.
13. The evidence was provided by the EU's
Scientific Committee on Veterinary Measures relating to Public
Health and is the first part of an EU risk assessment which relates
to the ban currently in operation. Until the results of these
studies are available the ban on imports will remain in place
based on the precautionary principle.
ANIMAL WELFARE
14. The EU and, in particular, the United
Kingdom, are well aware of the high costs of implementing animal
welfare legislation. The UK pig industry is gravely disadvantaged
as a result of implementing legislation in advance of other member
states.
15. Whilst in principle we would applaud
the intention to establish international acknowledgement of animal
welfare rules as one of the EU's key negotiating points for the
WTO round, we are dubious as to the likelihood of success. A level
of prosperity is required before animal welfare becomes a priority
issue.
16. In order to satisfy consumers, imports
from third countries should be required to state the welfare criteria
or rules in existence and enforceable in that country. Consideration
should be given to additional tariffs on imports from countries
that cannot demonstrate adherence to international animal welfare
rules.
17. Adequate labelling will be required
to support such initiatives. Labelling rules must be equitable,
clear and consistent not only to provide consumers with the information
they need but also to meet the practical and commercial requirements
of manufacturers. Unrealistic and impractical labelling requirements
will ultimately let the consumer down. They will also penalise
the UK manufacturing sector if demands have to be met which foreign
competitors have no requirement or incentive to match.
RESTRICTIONS ON
TRADE IN
GM FOODSTUFFS
18. The BMMA supports the UK Government
in pressing for EU-wide regulations or labelling rules that indicate
the presence of GM materials. We also support proposals for a
de-minimus threshold of 1 per cent for ingredients for
foods from non-GM sources.
19. BMMA members could be severely disadvantaged
if retailers take a blanket decision to demand that feed for animals
should be GM-free. Given the current availability of identity
preserved GM-free soya and maize, it would be impossible to guarantee
wholly GM-free feed for all animals. The consequences of such
a decision would lead to demand far outstripping supply and producers
would be denied nutritionally valuable feed ingredients. Alternative
animal feed ingredients are limited as a result of the meat and
bonemeal legislation. The resultant rise in prices would make
UK producers less competitive and encourage significantly cheaper
imported products from countries where GM ingredients are used
in feed for meat, milk and egg production.
3 December 1999
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