Annex 3
Letter from the Chief Executive of the
BEIC to Rt Hon Richard Caborn MP, Minister for Trade, DTI
WELFARE OF LAYING HENS AND THE WORLD TRADE
ORGANISATION
Thank you for your letter of 23 February 2000,
in response to a copy of a letter to the Rt Hon Nick Brown MP
which I sent to you.
In your letter, you point out that our next
meeting with Nick Brown will provide an opportunity to raise the
issue of the WTO and animal welfare standards. I must inform you
that the British Egg Industry Council (BEIC) has raised this matter
on many occasions with Nick Brown and the Minister is well aware
of our concerns. He was fully supportive of the BEIC writing to
you to seek a meeting to discuss the issues in more detail.
I am aware that you recently met both Compassion
in World Farming and the RSPCA who have been working with us on
this matter. However, I believe that it is important for you to
appreciate that the issue of animal welfare and the WTO is not
just of concern to welfarists. If animal welfare is not recognised
and pursued through WTO, there is a real chance of parts of the
UK egg industry disappearing through the lack of a level playing
field.
The egg industry is the first to be put in this
unique position, but others will follow. For us, the EU has already
agreed radical new welfare standards through the Council of Agriculture
Ministers, There is, therefore, not an option open to us of not
progressing towards implementation of these new rules.
Of the 270 million laying hens in the EU, it
is currently estimated that 90 per cent are housed in cages, with
10 per cent in alternative systems of production. In fact, over
70 per cent of the barn and over 50 per cent of the free range
laying hens in the EU are housed within the UK.
The costs of implementing Council Directive
99/74/EC are enormous. At the present time 80 per cent of laying
hens in the UK (25 million birds) are housed in conventional cage
systems, which will be banned by 1 January 2012. In the UK the
capital cost alone of moving to either enriched cages or alternative
systems (barn and free range, etc) will be £452.5 millions.
Besides the capital costs of this welfare legislation,
the cost of production will also increase. By way of example,
the USA and other third countries typically stock birds in cages
at 350 cm2/bird, whereas in the EU the current requirement is
to stock at 450 cm2/bird. This results in our production costs
being 7 per cent higher. By 1 January 2003, the stocking density
in the EU will decrease to 550 cm2/bird, which will disadvantage
our industry even further, with costs then being some 14 per cent
higher than third countries. This assumes that we can purchase
cereals at the same price as third countries, which is not the
case. In fact, feed costs in third countries are some 40 per cent
lower than in the EU.
Our industry will be unable to compete. In the
Commission's communication on the protection of laying hens—COM
(1998) 135 Final (March 1998)— they said that if the EU
import duty was further reduced by 33 per cent in the years up
to 2010 then the EU industry would no longer be competitive if
their costs increased by 10 per cent. In fact the minimum cost
increase will be between the conventional cage at 450 cm2 and
the enriched cage where running costs will increase 24 per cent.
You indicated in your letter that you do not
believe it is realistic to expect any significant progress on
animal welfare issues in the WTO for the time being. This is confirmation
of what our industry has been fearing, such concerns having been
raised with MAFF and the European Commission.
What can we do about this? As Trade Minister,
it is vital that you appreciate the real economic implications
for the UK industry of this issue. We would like to come and discuss
our concerns with you. In particular, we are seeking your help
to ensure that our market is not undermined by cheap imported
eggs. Whilst additional help should be provided in the form of
an expansion of the WTO criteria so as to provide that eggs and
egg products can only be traded between countries with the same
welfare standards, if this should prove to be non negotiable,
then there should be no further reductions in import tariffs,
or increased market access for third country eggs or egg products.
Indeed, additional levies should be imposed on imports from third
countries which do not have the same strict welfare rules as the
EU.
By way of background, the British Egg Industry
Council (BEIC) is an inter-professional organisation of 11 trade
associations in the UK, which cover all aspects of the egg industry—breeding,
hatching, rearing, laying, packing, egg processing and marketing.
Besides its role in lobbying on issues of concern, it also finances
publicity and advertising campaigns and research and development.
It is recognised by Government and Parliament as the substantive
voice of the egg industry. BEIC is funded by a voluntary levy
on a number of packers and producer/packers who between them represent
some 74 per cent of UK egg production.
I am copying this letter to Nick Brown.
I look forward to hearing from you.
10 March 2000
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