APPENDIX 26
Memorandum submitted by the United Kingdom
Agricultural Supply Trade Association (UKASTA) (F35)
1. BACKGROUND
TO UKASTA
The United Kingdom Agricultural Supply Trade
Association (UKASTA) represents more than 350 companies and cooperatives
in the agricultural supply industry. Members comprise crop traders,
animal feed manufacturers and agricultural merchants who supply
products and advisory services to farmers for feed, seed, fertilisers,
forage additives, and agrochemicals. Their combined annual turnover
is £5 billion.
2. UKASTA'S INTEREST
IN ORGANIC
ISSUES
The principal area of concern to UKASTA for
the purposes of this submission is the seed sector. This has become
an area of particular concern to UKASTA members as the derogation
allowing the use of non-organic seed within organic farming systems
comes to an end on 31 December 2003. A combination of uncertainty
over the possibility of a further renewal of the derogation, concerns
about the quality of imported seed, and above all, the burden
of regulation within the organic sector as a whole has meant that
many seed companies are considering not becoming involved. This
could have serious repercussions for the whole UK organic movement
in the short to medium term.
UKASTA represents the bulk of the UK seed trade,
and therefore is well placed to represent the concerns of member
companies to the Committee.
3. ROLE OF
ORGANIC CERTIFICATION
BODIES
The principal concern of UKASTA members regarding
organic certification bodies is that of "gold-plating"
of UKROFS regulations. The Soil Association has been working for
some time on a standard for organic seed certification which it
has hoped to have adopted by the other certification bodies. Staff
within the Soil Association have been very open about their intention
of exceeding by a considerable margin the standards required by
UKROFS.
While the highest standards are to be encouraged,
it is the belief of UKASTA and many within the UK seed trade,
that in raising standards to the levels envisaged by the Soil
Association and others, companies will be discouraged from investment.
For example, staff within the Soil Association have made it clear
that they foresee a role in policing pricing structures of organic
seed at some stage in the future. Market forces rather than a
certification body should govern prices, but the fact that intentions
such as this are aired in public drives seed companies from involvement,
and more importantly, investment in the organic sector.
There are other examples of certification bodies
making statements similar to this regarding pricing and market
structure, and they have begun to have an impact on the seed trade.
UKASTA would suggest that the solution to making UK organics more
accessible and commercially attractive as a sector (and ensuring
that the UK is not dominated by organic imports) would be to increase
the involvement of UKROFS in the regulatory process.
UKASTA would suggest that the current situation,
whereby commercial bodies have semi-statutory powers is to the
advantage of nobody except those certifying bodies. There are
currently eight organic certification bodies, all operating to
different standards, and this is causing confusion in itself.
It would therefore be better if all organic standards were laid
down by Government and the organic certification bodies concentrated
on inspections, information dissemination and marketing.
This would, at a stroke, remove the situation
whereby certification bodies produce the regulations and then
charge farmers and suppliers for inspections to ensure that these
rules are being observed.
4. ORGANIC STANDARDS
AND TOLERANCES
It takes 10-12 years, and costs in the region
of £2-3 million to develop a new seed variety and bring it
to the market. The fear of involvement in the organic sector,
for the reasons already outlined, may well act as a break on plant
breeders investing in specialist organic seed varieties.
Organic farmers operate in no less a commercial
environment than their conventional counterparts. Their demand
for the latest varieties is therefore just as strong, and is supported
by their customers. The seed industry is therefore looked to for
a programme of development of specialist organic varieties, bred
to deal specifically with organic systems if the organic sector
is to continue to grow in the UK. Our fear is that this will not
happen in the current environment.
If this does not happen, the UK will be reliant
on using imported seed, that may have been produced to lower standards,
and the traceability and integrity of organic food may ultimately
be questioned. The concern of UKASTA is that at this stage many
within the seed trade see few potential benefits from investment
in organic seed breeding programmes within the current regulatory
climate.
5. THE ROLE
OF TRADE
ASSOCIATIONS
Trade Associations such as UKASTA can be helpful
to the development of the UK organic market in that they can act
on a cross-sectoral basis. The experience within the staff and
the breadth of membership, particularly of UKASTA mean that we
are able to identify potential problems and will have an understanding
of how an issue for one sector may impact on another.
Trade Associations are also involved in the
various farm assurance schemes that have been introduced to try
to provide full traceability through the food chain. Farmers are
audited by these schemes and there may be a potential, at some
stage in the future, for combining various audits into one. This
could perhaps include an extension to cover the on-farm auditing
of organic standards.
6. IMPORTS
There is concern amongst UKASTA members that
there is a disparity between the standards of organic practice
in the UK, as regulated by the certification bodies, and those
of other countries, both within and outside the EU, from where
the majority of UK organic food is currently sourced.
This situation is unlikely to be resolved in
the short term, and acts as a disincentive for involvement. For
UKASTA members, the biggest impact of this is again on the seed
trade. The incentive to invest, not only in new varieties, but
also in dedicated handling facilities, and in the future, dedicated
seed cleaning lines, simply does not exist with the current market
situation. This particularly galling when there is an undoubted
desire by UKASTA members to be at the forefront of the organic
movement, producing organic seed to complete the organic "chain".
It is probable, however, that without substantial
movement on the issues raised in this paper, the future of UK
organics will continue to be dominated by imported seed, and probably
also by imported food.
7. CONCLUSIONS
In the recent past, organic food has moved from
being a niche towards becoming a mainstream product. The last
few years have seen a dramatic growth in the organic sector, and
it is the only area of food retailing where this growth, at the
expense of conventional food, is predicted to continue.
The aim of UKASTA in this submission has been
to highlight the concerns of our membership regarding the control
systems in place for this market. UKASTA believes that the current
regulatory regime is no longer adequate particularly if the market
growth is as significant as has been predicted.
Without changes to the way the sector is regulated,
we believe that many plant breeders and seed traders will choose
to avoid the organic market altogether, and that this in itself
will have serious long term repercussions.
12 June 2000
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