APPENDIX 11
Memorandum submitted by the Crop Protection
Association (F 14)
1. INTRODUCTION
1.1 The Crop Protection Association (formerly
the British Agrochemicals Association) is the United Kingdom trade
body representing those companies engaged in the manufacture,
formulation and distribution of crop protection products for agriculture,
forestry, horticulture, gardening, industrial, amenity and Local
Authority uses. The Association's members account for more than
95 per cent of sales in the UK crop protection market at manufacturer
level and approximately 80 per cent of the market at distributor
level.
1.2 The Association is an active member
of the European Crop Protection Association that represents the
industry within the European Union and the Global Crop Protection
Federation that has a similar role world-wide.
1.3 As the voice of the crop protection
industry within Great Britain, the Association's aims and objectives
are in line with the Government's policy of optimising the use
of crop protection chemicals for the effective control of pests
whilst protecting food, human health and the environment.
1.4 The crop protection sector is a dynamic
part of the UK chemicals industry and has close connections with
the pharmaceuticals and fine chemicals sectors. Member companies
had total sales in 1998 of £480 million and significantly
contributed to foreign earnings with export sales of £1,096
million. Member companies employ a total of 8,000 staff. The crop
protection sector is innovative and has always been at the forefront
of technical developments. It maintains a close and vibrant relationship
with Universities and other research institutes both in the UK
and abroad.
2. BACKGROUND
2.1 Organic farming has been described as,
"an approach to agriculture where the aim is to create integrated,
humane, environmentally and economically sustainable agricultural
production systems with maximum reliance placed on locally or
farmed derived renewable resources and the management of self
regulating ecological and biological processes and interactions
in order to provide acceptable levels of crops, livestock and
human nutrition, protection from pests and diseases, and an appropriate
return to the human and other resources applied. Reliance on external
inputs whether chemical or organic is reduced as far as possible."
Contrary to the popular layman definition, organic
farming is not simply farming without the use of pesticide and
fertilisers.
2.2 Organic production and marketing is
a growing reality all over the world. Within the EU, likely demand
for organic products far exceed supply even though the amount
of land farmed organically across the region has grown by about
a third since 1995. Within the UK, organic farming made a noticeable
expansion in the mid 1990's and has continued to increase at a
rate of about 25 per cent per anum since then. This expansion
of organic production may be attributed to a broad range of factors.
2.3 Over the past 15 years the organic movement
has promoted its philosophy and its products with enthusiasm and
with great commitment. To create its niche in the market, it attacked
pesticides, fertilisers and conventional farming with varying
levels of misinformation. So far it has made relatively minor
inroads into conventional farming but it has got much coverage
in the media, is being actively promoted by the major supermarkets
and is gaining increasing political influence, especially since
the onset of the BSE scare. Gardeners, too, have progressively
adopted organic methods.
2.4 Organic "evangelists" often
state that their way of farming is the only one which produces
safe food, looks after the environment properly and is ultimately
sustainable. The public accept these statements at face value
but most agriculturists know they are flawed. They have a growing
fear that the organic farming agenda has the potential to mislead
agricultural policy-making in the European Union and in Britain
to the detriment of conventional farming.
2.5 Many of the claims that organic produce
is healthier, tastes better or is better for the environment are
based on personal views or "feelings". Contrary to the
claims of the Soil Association little scientific or objective
evidence exists to support these claims. Organic farming principles
may well have positive effects on people, the environment and
livestock but such benefits are almost impossible to quantify.
In many cases, the philosophy is not yet matched by current knowledge.
3. MARKET TRENDS
AND CUSTOMER
DEMAND
3.1 The levels of organic premia vary between
commodities, which may be a reflection of the balance between
supply and demand for the product. Cereals and vegetables are
typically marketed at 50-60 per cent premium over the conventional
equivalents.
3.2 Consumer demand for organic products
continues to rise. This drive towards consuming more and more
organic foods is largely in response to concerns about the safety
of conventionally produced foods. The number of high profile food
scares over recent years has caused many consumers to lose confidence
in the food supply chain. Their search for alternatives has led
many consumers to turn to organic foods, which they perceive to
be safer and healthier. Active campaigns from the food media have
established concerns amongst consumers that influence their demand
for organic produce. These include; concerns about genetic modification
technology, pesticide residues in food products, use of antibiotics
and general animal welfare issues. Environment issues are of increasing
importance and some consumers are now choosing to purchase organic
foods as a way registering their positive support.
3.3 Much of this trend is connected with
media interest and a strong marketing initiative by elements of
the organic movement. Virtually all of the public concerns about
GMOs have been antagonised by speculative comments from the organic
movement that appear to have little foundation in scientific reality.
3.4 The increasing profile of organics in
the media, supermarkets and other consumer-focused events has
helped too to raise awareness and thus influence demand. Also,
most importantly, a gradual decrease in retail price premia either
deliberately set by retailers or as a result of increases in available
volumes, have meant that more main stream consumers are able to
afford to purchase organic products.
3.5 Overall, the future development of organic
production and consumers demand seems set to continue to rise.
Speculation about the final market share that the organic sector
will capture is not easy but some estimates suggest that it is
unlikely to rise above 12 per cent of total consumption. It is
evident that organic production will remain a minority part of
the market for the foreseeable future. An important constraint
on the development of the sector is the difficulty of ensuring
efficient marketing that meets consumers' expectations. Consumers
are very demanding both in terms of the range and presentation
of food products and of year round availability. It is unlikely
that the majority of UK consumers will wish to support the aims
of the organic movement by purchasing produce at high premia.
The core support for organic production remains within the urban
middle ranking socio-economic groupings.
4. THE ROLE
OF ORGANIC
CERTIFICATION ORGANISATIONS
4.1 In the UK the United Kingdom Register
of Organic Food Standards (UKROFS) is the body that has been appointed
by UK agricultural ministers to carry out the function of organic
certification. UKROFS also licence and supervise private organic
certification organisations that carry out farm inspections and
certifications.
4.2 There are seven approved organic certification
bodies operating in the UK. They all operate privately but are
all subject to inspections to ensure that their systems and the
standard of their inspections conform to the EC Regulation.
4.3 Organic Certification organisations
have played a very important role in the development of the organic
sector. They have been very effective in defining standards for
production, processing and direct marketing. In addition, they
have helped to raise consumers' awareness and confidence in organic
foods and in so doing contributed to the overall development of
the market.
4.4 Our Association is concerned that although
the UKROFS licensed certification organisations are basically
similar in their interpretation and implementation of the UKROFS
standards there is still a significant variation. We would prefer
to see a single UK organic standard being implemented by all the
certification bodies. Also, we feel that all the bodies should
adopt the UKROFS standard, which is the UK interpretation of the
EU Regulation.
4.5 Variations occur in standards between
EU member states, and this causes producers and consumers great
concerns. We believe that many of the imported products, even
those from approved third countries, are not produced to the same
rigorous standards that apply in the UK.
5. THE ROLE
OF FARM
ASSURANCE SCHEMES
5.1 Farm Assurance has been developed by
conventional farming to provide a system to ensure that customers
and final consumers have confidence in British farm products.
Farm assurance schemes were set up in each sector, in response
to consumers' concerns about specific issues related to the safety
of UK farm products. This is following a number of high profile
food safety cases (eg BSE and Salmonella in eggs), that have had
the effect of diminishing consumers' confidence in the integrity
of producers' on-farm activities.
5.2 Farm assurance schemes require conventional
producers to demonstrate that products are produced, handled,
stored and delivered in a manner that complies with all legal
and voluntary codes of good practice. The standards are established
by industry-wide representative groups in each commodity sector
and cover issues related to food safety, product traceability,
pesticide residue in produce, use of antibiotics, storage, transportation,
animal welfare as well as a response to environmental concerns.
5.3 Though the schemes are designed and
implemented by industry groups in each sector, they operate as
totally voluntary schemes and producers therefore make their own
decisions about whether or not to join. The number of producers
that are registered with the various schemes however, is relatively
high because many retailers and customers have tended to make
scheme membership a condition of supply.
5.4 Our Association has had a strong role
in such schemes and believes that they have done much to increase
confidence in UK food produced by conventional farming techniques.
5.5 Although farm assurance schemes and
those for organic production have similar objectives to achieve
high food safety standards, product traceability, high animal
welfare, and response to environmental concerns there is one important
difference. This is that farm assurance schemes have independent
verifiers to check producers' compliance with scheme standards
whereas organic farms are not inspected by independent bodies.
We believe that this system is not entirely fair to the consumer
and creates a wrong impression of the standards between the two
systems of production. We would support an independent verification
body such as CHECKMATE that operates for many of the conventional
Assurance schemes.
6. THE AVAILABILITY
AND SUITABILITY
OF PUBLIC
AND PRIVATE
ASSISTANCE FOR
ORGANIC CONVERSION
6.1 Organic farming increasingly being accepted
by producers and policy makers as a viable form of production
and the uptake in conversion has increased dramatically over recent
years. Growth of the sector has been estimated at 20 per cent
increase per annum since 1996.
6.2 The increase in organic production has
partly been achieved as a result of the EU application of policies
to support organic conversion and farming as part of the agri-environment
programme, EC Regulation 2078/92. This Regulation was implemented
in 1993 and provided the financial basis on which to support conversion.
Other EU policy measures have supported organic farmers.
6.3 In 1998 a second programme of assistance
to organic farmers was introduced in the UK. It was called the
Organic Farming Scheme (OFS) and offered grants of up to £450/ha,
ie twice that paid under the previous scheme. Consequently, there
was a rapid increase in the uptake of the grant with the resulting
expansion of the UK organic supply base. Unfortunately, after
only four months of operation, the scheme ran out of funds and
was closed for a review and consultation with the organic sector.
The objective of the MAFF review is to identify a more effective
means of administering the limited financial resources available
to support conversion. We understand that the scheme is expected
to be reopened in April 2001.
6.4 Now that organic production has established
itself as a viable method of fulfilling a niche market we believe
that the Government must carefully consider what level of intervention
it wishes to introduce. High levels of support could distort the
market, cause over supply and result in new entrants leaving the
sector once prices for organic and conventional produce equilibrate.
The question is whether Government should exert this type of influence
that it does not seek in some other agricultural sectors. Farmers
are opportunities and will seek new markets if these are financially
viable either due to Government support or true market returns.
7. OUTLETS AND
DISTRIBUTION SYSTEMS
FOR ORGANIC
PRODUCE
7.1 We would stress that if farmers are
unable to make an adequate return on capital—both working
and fixed capital—then they will be most unlikely to continue
farming organically. The most common barrier to entry into the
market is fear of oversupply.
7.2 We believe that a balance must be struck
between conventional and organic farming. Interference with market
forces by distorting the requirement for organic produce could
affect UK agriculture as a whole and may also affect individual
farming businesses.
7.3 In the majority of cases organic produce
is more expensive than conventional produce. For this reason the
market will be limited to a minority of the UK market who believe
the often-erroneous claims about organic produce.
7.4 There is bound to be some element of
retail premium for most organic products and this is often attributed
to a payment for the perceived benefits of organic production.
Similar benefits are attached to the majority of UK farmers who
produce using Integrated Farming Management (IFM) techniques.
We believe that consumers are often misled into believing that
they are providing significant and tangible support to environmental
systems rather than supporting the deeply held philosophical beliefs
of a small sector of the farming community.
7.5 The Government clearly needs to be aware
of the demand profiles and determine whether the UK is prepared
to invest in home production or continue our dependence on imports
for this niche market. For either option we need to ensure that
the standards of organic production and/or processing are equivalent
to those expected of conventional producers and processors. We
must not have dual standards and thus unmatchable competition.
7.6 General figures indicate that up to
70 per cent of all organic foods sold in the UK is imported. The
Soil Association's Food and Farming Report 1999, suggests that
for the fruits and vegetables sector, as much as 80 per cent is
imported, and for cereals the amount is 70 per cent.
8. REGULATION
OF ORGANIC
PESTICIDES
8.1 Contrary to public beliefs, a range
of crop protection and other materials is permitted within organic
farming systems. Although limited in number some of these materials
are applied to organic crops on a number of occasions each season.
Organic growers make much use of physical, mechanical and cultural
methods of controlling weeds, diseases and pests of their crops.
However, conventional farmers also use these techniques as part
of an Integrated Crop Management (ICM) systems. Such systems are,
to a greater or lesser extent, used by the majority of conventional
farmers.
8.2 The Control of Pesticides Regulations
(COPR 1986) implement Part III of the Food and Environment Protection
Act (FEPA 1985) and this applies to all pesticides in the UK.
The Plant Protection Products Regulations (PPPR 1995) were made
under the European Communities Act 1992 to implement Council Directive
91/414/EEC concerning the placing of plant protection products
on the market. Other regulations contain provisions to allow a
control and enforcement regime to be applied to plant protection
products and thus to give consistent controls on the use of crop
protection products. There are also a number of voluntary and
statutory codes of practice, which control the supply, storage
and use of crop protection chemicals in the UK.
8.3 The "organic" pesticides are
subject to the same influences of Directive 91/414EEC as conventional
crop protection products. However, the majority of the "organic"
materials are "old" having entered the market many years
ago. Materials such as copper sulphate and sulphur will be reviewed
under the existing EU programme but this is unlikely to occur
for the next few years. In the case of copper sulphate, little
information is available concerning the direct and indirect ecological
effects of the material or of the residue levels routinely found
on organic produce.
8.4 It is our view that all crop protection
materials used within organic farming systems must be subjected
to the same rigours of the registration process as "conventional"
products. We must stress that our member companies also sell and
develop materials for the biological control and organic markets.
However, the size of the organic market and the cost of submission
to the regulatory process severely limits the numbers of the new
products coming forward.
9. GENETICALLY
MODIFIED CROPS
AND ORGANIC
FARMING
Currently, there are no commercial GM crops
grown in the UK. A number of farm-scale trials are being undertaken
at sites throughout the country. Information derived from these
trials will be extremely important in providing scientific evidence
to understand the potential environmental issues.
The Soil Association has said that it is firmly
opposed to the development of GM technology as a matter of principle.
On this basis they would appear to have pre-judged the evidence
from the field scale evaluations.
Discussions between the Government, the farming
industry and others has led to the production of the SCIMAC Code
of Practice which set standards for further investigations into
this new technology. The main issue for organic farming appears
to be the separation distances between GM crops and organic crops.
Organic farmers argue that the risk of cross-pollination from
GM crops could undermine the organic status of the crops in question.
They are using this argument to press for the extension of separation
distances to six miles. This approach seems quite inconsistent
with the current approach to addressing the risk of cross-pollination
from conventional crops, where a degree of tolerance (5 per cent?)
is addepted industry practice. There should be a consistent approach
according to the standards already established by UKROFS.
The Government has taken the pragmatic view
that all GM crop-licensing decisions should be based on safety.
Before refusing to allow a GM crop to be grown next to an organic
farm, they will require evidence of a threat to human or environmental
safety. There must be a clear distinction made between the recognition
that pollen travels and an appreciation of the consequences of
that occurrence.
Aside from the lack of scientific evidence to
support the claims of the organic movement there appears to be
a more general issue at stake. Their aim seeks to create a liability
for pollen drift that could find it's way into organic ingredients.
This would turn the organic certification system into a content-based
system rather than a process-based one. It would seem that if
organic producers expect to sell a value-added product they must
take responsibility for its production and marketing. Equally
organic farmers need to recognise that other farmers choose to
grow crops conventionally and, in the future, may also choose
to grow GM crops. There has to be a sensible recognition that
these different approaches to agricultural production are all
equally valid and should b allowed to co-exist within reasonable
and mutually acceptable bounds.
10. CONCLUSIONS
10.1 Although the crop protection industry
is not opposed to organic farming per se we believe that many
of the claims from the organic movement must be treated with caution.
10.2 We believe that if a large-scale extensification
of crop production in UK is allowed to take place the nation will
be less able to feed itself. The wide scale adoption of organic
or very low input farming will severely and needlessly limit Britain's
ability to feed itself from the land currently cultivated for
crops. To sustain the present national yield of crops, large areas
of currently uncultivated land (including set-aside) would have
to be brought into crop production to compensate for:
(a) Yield reductions on each hectare averaging
about 30 per cent;
(b) Fewer food crop opportunities in the
rotation because of the need to grow fertility-building non-food
crops, such as clover and field beans;
(c ) More erratic harvests, with crop failures
through pest and disease attack common;
(d) More frequent need for fallow crop-free
to clean up fields where deep-rooted perennial weeds have taken
over, such as couch grass, docks and creeping thistle.
10.3 It is also clear that wildlife habitats
would be under greater pressure. Over the past few years, conventionally
managed farms have been able to concentrate production on land
better suited for growing crops, allowing them to return less
suitable parts of the farm to wildlife habitat and to adopt wildlife-friendly
management of field margins.
10.4 Severe restrictions on fertilisers
and crop protection products will reverse these trends significantly.
To maintain farm outputs, much more land will be needed leading
to greater encroachment on wildlife-rich woodland, moorland, heaths
and wetlands.
10.5 We also believe that food safety will
not necessarily be improved nor assured. Bacterial and fungal
contamination has caused all proven outbreaks of food poisoning
in the UK. This will not change; indeed, it may become worse as
greater reliance is placed on the use of potentially infective
animal manure's and human sewage. If these are not composted adequately
there is a tangible risk from organisms such as E coli and related
enteriformes.
10.6 If organic farming is applied to a
large proportion of UK production the present protection offered
by chemical fungicides against potent fungal toxins, such as mycotoxins,
will be lost.
10.7 It is also clear that pollution control
costs could increase. Environment Agency monitoring consistently
shows that animal manures and silage effluents are the principle
causes of agricultural pollution incidents. Again, increased reliance
on farmyard manure could result in more incidents or more costly
on-farm treatment methods. Heavy investment programmes by water
service companies may be increasingly needed to avoid bacterial
contamination of drinking water, another proven cause of outbreaks
of illness.
10.8 In summary, it is clear that organic
production fulfils a niche market which is geographically and
sociologically defined. It will never be able to replace conventional
production whilst maintaining volumes of output. Care must be
taken to ensure that organic production does not receive unfair
treatment or financial incentives that will damage conventional
farming systems or significantly distort the market place.
10.9 Farming must remain profitable and
productive. We believe that the key to maintaining a profitable,
productive yet environmentally responsible agriculture is the
practice of integrated Crop Management (ICM). This offers a common
sense approach, which combines the tried and tested traditional
methods with the sensitive and skilful use of modern technology
in all activities on the farm. Farmers practising ICM are demonstrating
that they can deliver profitable and productive agriculture using
modern techniques and still retain a rich and diverse wildlife.
10.10 Farmers must be able to retain all
pest control options and not be constrained to certain restricted
organic options. It should be noted that pest, disease and weed
control is an essential part of ICM practices. Farmers must have
the flexibility to choose from the widest range of control options
so that they can best match an environmentally sensible solution
to a particular problem.
10.11 The crop protection industry is committed
to promoting environmentally responsible use of our products within
a conventional farming framework that makes use of all suitable
techniques and systems.
11 June 2000
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