APPENDIX 18
Memorandum submitted by the National Association
of British and Irish Millers (NABIM) (H19)
1. NABIM RESPONSE
TO THE
INQUIRY
NABIM is the representative organisation for
the UK flour milling industry. The main focus of the association's
activities relate to cereals; the attached memorandum [not printed]
sets out in full NABIM's position on the European Commission's
initial proposals on the Mid-Term Review of the CAP under Agenda
2000, which was drawn up in response to DEFRA's consultation earlier
this month. The following paragraphs summarise the Association's
views in relation to the four main issues identified by the Committee
in its terms of reference.
2. THE EXTENT
TO WHICH
THE PROPOSED
REFORMS TO
THE CAP ADDRESS
CONCERNS ABOUT
THE FUTURE
DIRECTION OF
THE POLICY—IN
PARTICULAR WHETHER
THEY WILL
ENCOURAGE A
MORE LIBERALIZED
AGRICULTURAL SECTOR
WITHIN EUROPE,
AND WHAT
IMPACT THE
REFORMS WILL
HAVE ON
NEGOTIATIONS FOR
THE ENLARGEMENT
OF THE
EU
NABIM welcomes the Commission's Mid-Term Review
proposals under Agenda 2000 as a positive step in the right direction
towards a more market-oriented CAP, encouraging a more efficient
and viable supply base for both UK and EU wheat production (see
point 1.2 of the attached memorandum). However, NABIM is extremely
concerned that the Commission's proposals concerning changes to
the EU's import duty system for wheat will severely reduce access
to high quality wheat not available within the EU, to the disadvantage
of UK millers, bakers and consumers.
A major challenge over the next five years will
be to retain food production within the UK, as companies make
new regional or global investment decisions and as the EU enlarges
(paragraphs 2.1-2.3). A key factor in retaining this production
will be the ability to continue to source appropriate, competitively
priced grain within the UK. In the last 25 years, the flour milling
sector has raised usage of UK wheat by 2.5 million tonnes, and
it now accounts for over 80 per cent of the total. Maintaining
this level of usage requires an efficient, competitive and cost
effective supply base. In terms of overall competitiveness, the
milling industry must also be able to continue to import necessary
high quality wheat from third countries without impediment.
NABIM would particularly like to draw the Committee's
attention to sections three and four of the enclosed Memorandum,
which cover the market support regime and import duty system for
cereals respectively.
With regard to enlargement, NABIM notes that
the detailed MTR proposals are not expected to be published before
November, and possibly even December. As the enlargement negotiations
are due to be concluded at the Copenhagen Summit in December,
NABIM would not expect the Mid-Term Review proposals to have a
notable effect on these negotiations, particularly given the seeming
political will to reach agreement by December. NABIM does believe,
however, that the broad MTR proposals, if adopted, could help
facilitate enlargement.
3. HOW THE
PROPOSED REFORMS
WILL AFFECT
BRITISH FARMERS,
IN PARTICULAR
WHAT WILL
BE THE
IMPACT OF
CAPPING AID
FOR LARGER
FARMS AND
DE-COUPLING
SUBSIDIES FROM
PRODUCTION LEVELS
NABIM welcomes the proposals to introduce a
single decoupled income payment per farm (see section two of our
memorandum), but is opposed to the proposed cap of
300,000 on direct aid payments as it disproportionately
affects UK farms and discriminates against the more productive,
larger farms (more than 80 per cent of UK cereal crops grown by
a small number of efficient producers).
4. THE PRACTICAL
EFFECT OF
THE NEW
CROSS-COMPLIANCE
CONDITIONS TO
BE APPLIED
TO THE
RECEIPT OF
AID, AND
WHETHER THE
CONDITIONS ADEQUATELY
BALANCE ENVIRONMENTAL
AND COMMERCIAL
CONCERNS
NABIM is in general supportive of the principles
of cross compliance but is not in a position to comment on the
detail of the proposals (points 2.6 and 6.1 of the enclosed Memorandum).
5. WHETHER THE
PROPOSED RE-ALLOCATION
OF FUNDS
FROM DIRECT
PAYMENTS TO
FARMERS (PILLAR
ONE) TO
RURAL DEVELOPMENT
(PILLAR TWO)
WILL PROVIDE
SUFFICIENT RESOURCES
TO ACHIEVE
ENVIRONMENTAL GOALS
AND TO
SUPPORT RURAL
AREAS
The main concern of the flour milling industry
is that the re-allocation of funds should not disadvantage the
competitiveness of UK cereal producers by comparison with others
in the EU (see section five of the enclosed Memorandum).
September 2002
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