Select Committee on Environment, Food and Rural Affairs Seventh Report


6  Verifying food information: food assurance schemes

139. Food assurance schemes are intended to provide consumers with a greater degree of information about the product assured, such as the way in which it has been produced, or an assurance that certain standards have been met. Some schemes exist with the purpose of assuring consumers that they are purchasing, for example, an organic product, or fish from a sustainably managed fishery.

140. There are a great many such schemes. Evidence suggested there might be at least 30 of them.[199] Examples include the RSPCA's Freedom Food scheme[200], LEAF (Linking the Environment and Farming)[201] and the British Farm Standard (the "Little Red Tractor").[202]

Legal requirements relating to farm assurance schemes

141. Food (or farm) assurance schemes are a category of product certification schemes. The internationally recognised rules for operating product certification schemes are set out in the International Standards Organisation (ISO) Guide 65, which is analogous to European Standard EN 45011. Product certification schemes are voluntary initiatives, although for some schemes, compliance with EN 45011/ISO 65 is a statutory requirement. FSA guidance states that all UK food assurance schemes should be accredited to EN 45011 by the UK Accreditation Service (UKAS).[203] Nevertheless, assurance schemes are privately owned and operated.[204] They are not subject to any regulation other than assurance processes and certification dependent on those who run the individual scheme or schemes.

Evidence received

142. Clive Dibben, an independent consultant working in the food certification and rural enterprise sectors, stated that "it is widely recognised, even by the [food assurance] schemes themselves, that they seek to mirror legal requirements rather than exceed them".[205] Dr Richard Baines of the Royal Agricultural College concurred with this view:

    Most farm assurance schemes claim to encourage or ensure that systems of production meet consumer (or retailer) aspirations. However, the majority merely underpin legal farming in terms of environmental protection and animal welfare. This is why there is no premium for farm assured.[206]

143. He told us that consumers did not really gain anything from such assurance schemes and suggested that many schemes do not in fact even properly guarantee food safety.[207] As an example, Dr Baines pointed to the British Farm Standard, or 'little red tractor', scheme, which he claimed was not actively managing safety because it did not require its member schemes to have HACCP in place. He stated that consumers were nevertheless being told that food carrying the little red tractor logo was safe.[208]

144. However, Dr Baines noted that some schemes do in fact exceed minimum legal requirements in terms of their systems of production. These included the adoption of integrated crop management in the Assured Produce scheme, additional environmental auditing under the LEAFMarque scheme and higher than legally mandated animal welfare under Freedom Foods.[209] Dr Baines concluded that, although "other schemes claim to … promote systems of production that are environmentally and animal welfare sensitive, yet they merely require members to meet minimum legal requirements in these areas".[210]

145. Some evidence noted the confusion caused by the number of schemes. The NFU thought there were probably too many of them.[211] Which? argued that there was a growing sense of confusion surrounding the many assurance schemes, and the public needed to be made more aware of what they really meant.[212] In 2003, the National Consumer Council (NCC) carried out a study of consumers' views on voluntary food labelling, including food assurance schemes. It concluded that the proliferation of labels and logos has caused confusion and information-overload among consumers. The NCC's research showed that consumers did not understand what the majority of the labels and logos mean, and that food assurance schemes were most often used as a marketing tool rather than a way of informing consumers and offering real choice.[213] The NCC recommended that, in the absence of legislation, the FSA should "develop, champion and promote" a code of practice for food assurance schemes and should encourage maximum take up of the code across the food industry.[214] On this point, Mr Dibben commented that "various attempts have already been made to develop an overarching body to explain the merits of assurance schemes to UK consumers and to act as an authority on all UK assurance matters. As yet none has succeeded …".[215]

146. The FSA stated that it would like to see some degree of collaboration between assurance schemes in order to provide the consumer with information with which to compare different schemes.[216] In August 2003, the FSA published advice to scheme operators, which recommended that the following information should be easily accessible and clearly communicated to consumers:

  • what the scheme seeks to achieve and what advantages it offers consumers
  • in what ways, if any, the scheme standards exceed the legal minimum
  • how the scheme ensures that its standards are being met by member producers
  • the scheme's arrangements for monitoring delivery of standards, for example through analysis of scheme produce
  • how instances of non-compliance are dealt with, and
  • the evidence base for any specific claim—for example, on food safety or quality.

The FSA also planned "to carry out a survey of the consumer information available from scheme operators and to publish a collation of this information to help inform consumer choice."[217]

147. Dr Baines noted that, where schemes do require producers to meet additional conditions, there was no evidence of this adding value for those who deliver these enhanced conditions.[218] To deal with this problem, he argued that producers delivering such additional requirements should be adequately rewarded, and that labelling should differentiate foods with these extra assurances so those consumers interested in such foods can identify and preferentially source them.[219] He acknowledged that, if such a system were to work, consumers would have to be prepared to pay for the added value of the product, and that premium should then flow to the producer. Dr Baines cited one example of a product where producers had received a premium for committing to a higher level of biodiversity, and this cost had been passed to the consumer in terms of a higher price.[220]

Farm assurance schemes and non-own-brand labels

148. Large retailers sell both their own-brand products and also food produced under recognised assurance schemes. Dr Baines felt that the aim of the main multiple retailers was to promote their own brands of food. "Any additional 'assurance label' has the potential to dilute their own brand".[221] He suggested that, although the supermarkets claim to sell only farm assured products, this could not in fact be the case:

    … the main retailers claim that the producers who supply 'their' integrators [processors] are farm assured … [yet] there is no formal audit of this in the [British Retail Consortium Standard] or equivalent standards … there is no audit trail to ensure only assured produce reaches and is sold by the retailers.[222]

149. However, the FDF told us that it had "great sympathy" for the general aims of farm assurance:

    To ensure that consumers have reliable information, ethical and associated logos relating to production methods should be backed by established schemes, information on which is accessible to consumers and compliance with which is independently audited.[223]

The FDF told us in evidence that, although there was no "fundamental requirement" for retailers to sell farm assured produce, individual companies might well build this into their specifications, on a company basis.[224] "Broadly speaking, the issue is to source materials to the required standards of safety and quality from wherever they happen to be available."[225]

The British Farm Standard—the little red tractor

150. One of the best-known assurance schemes in the UK is the 'little red tractor', which, according to the NFU, has a 47% recognition level among the public.[226] The NFU is a part-owner of the scheme, which was set up in 2000. The scheme is run by a separate organisation, Assured Food Standards (AFS), an organisation which is "owned by sections of the agri-food industry, including several of the farm assurance schemes, the National Farmers' Union and the Meat and Livestock Commission".[227] The NFU described the scheme as follows:

    Clear labelling of food with the red tractor logo denotes that it is farm assured … Through consolidation of all the assurance schemes under one logo, the consumer is better able to recognise farm assured product. Indeed a key driver in the development of red tractor was to reduce the number of logos associated with farm assurance to assist consumers in their purchasing decisions.[228]

One of the aims of the scheme, according to the NFU, was to "put a logo" on "a multitude of schemes … designed to give consumer reassurance".[229]

151. We heard some specific criticisms of the scheme. In 2002, the FSA argued that the AFS was not independent enough, and recommended that a new independent organisation should be established to govern the 'little red tractor' scheme:

    A new, independent governing body for Red Tractor schemes, along with measures to improve transparency and consistency across the board, are essential to meet the needs of the consumer.[230]

Subsequently, AFS was 're-constituted' to form 'AFS 2003'. However, Clive Dibben told us that this new body still did not have "a constitutionally independent structure and retains strong links with the industry … it is believed that the AFS 2003 Board retains a majority in favour of industry directors".[231] Mr Dibben suggested that AFS favours existing, industry-controlled schemes:

    As such any assurance scheme wishing to use the British Farm Standard mark will be required to operate in the same way as AFS's own schemes, rather than ensuring that any scheme deliver the equivalent outcome (essentially compliance with UK legislation).[232]

152. It is sometimes thought that food assured under the scheme is British.[233] Which? pointed out that the red tractor logo does not indicate that a food comes from British farms, as consumers often believe; it merely denotes that a food has been produced in accordance with the British Farm Standard. The FSA has also said that "research shows that people wrongly assume the red tractor logo indicates a British product, but the logo can also be used on produce sourced outside the UK."[234] The little red tractor scheme website also appears to give the impression that the scheme applies only to British farmers. Although it avoids stating that only British farmers are eligible for the scheme, it nowhere states that food carrying the logo need not necessarily have been grown on a British farm.[235]

153. Clive Dibben was critical of the NFU's role in respect of the scheme. He argued that the NFU had issued a press statement in 2003 which clearly implied country of origin attributes to the red tractor. He noted that certification schemes must permit access to all who are able to comply with their standards, and it was also questionable whether the use of a mark as a de facto country of origin label is consistent with the objectives of the EU single market or ISO Guide 65 with regard to the facilitation of trade.[236]

154. The NFU argued that they did not claim the tractor logo was 'British', but acknowledged that all the food assured under the scheme had, in fact, been British:

    no product has been licensed to the red tractor other than British product … what we cannot do because of the Single Market is state equivocally that the red tractor is British; that is illegal.[237]

Our conclusions

155. It is not at all clear that food assurance schemes are currently providing useful and meaningful information to consumers, and the proliferation of such schemes adds to the confusion. Few consumers are in a position to inquire into the veracity or reliability of the schemes' claims. Furthermore, even where schemes are sound, they may certify nothing more than that required minimum standards have been met—something consumers should be able to take for granted without the need for assurance by an external, private body. We believe that most consumers are likely to assume that the fact that a food carries an assurance scheme mark means that it has exceeded legal requirements in some respect.

156. We recommend that the Government should ensure the central registration of food assurance schemes. All schemes should have to be registered and approved by an identified body. The FSA would be an obvious candidate for the task. The purpose of such schemes should be to certify that the product carrying the mark has either been:

The registration body would have to satisfy itself that the operators of the schemes had appropriate verification systems in place to ensure that producers taking part in a scheme were fully meeting its requirements. We further recommend that the Government, in consultation with stakeholders, consider ways in which this kind of registration could limit the numbers of schemes in operation, and introduce some common elements in labelling, in order to make it easier for consumers to understand the schemes.


199  
Ev 40 [Sustain] and Q 230 [Product Authentication Inspectorate] Back

200   Ev 180 [RSPCA] Back

201   www.leafuk.org/leaf Back

202   www.littleredtractor.org.uk/whatis.asp  Back

203   FSA, Food assurance scheme guidance, 2003, p 2 Back

204   Ev 146 [Defra] Back

205   Ev 169, para 31 (emphasis added) [Clive Dibben] Back

206   Ev 104 [Dr Richard Baines]  Back

207   Qq 494-96 and ev 105, paras 2.5 and 2.6 [Dr Richard Baines] Back

208   Ev 106, para 3.2 [Dr Richard Baines] Back

209   Ev 106, para 4.1 [Dr Richard Baines] Back

210   Ev 106, para 4.1 [Dr Richard Baines] Back

211   Q 260 [National Farmers' Union] Back

212   Q 147 [Which?]. The Product Authentication Inspectorate made similar points: q 240. Back

213   Ev 208 [National Consumer Council]. See also q 234 [Product Authentication Inspectorate] Back

214   National Consumer Council, Bamboozled, Baffled and Bombarded: consumers' views on voluntary food labelling, February 2003, p 5 Back

215   Ev 170, para 34 [Clive Dibben] Back

216   Ev 143 [Food Standards Agency] Back

217   Ev 131, para 26 [Food Standards Agency] Back

218   Ev 104 [Dr Richard Baines] Back

219   Ev 107, para 6.2 [Dr Richard Baines] Back

220   Ev 107, para 6.2 and q 500 [Dr Richard Baines] Back

221   Ev 106, para 4.4 [Dr Richard Baines] Back

222   Ev 105, para 2.4 and ev 106, para 4.4 [Dr Richard Baines] Back

223   Q 516 and ev 116, para 29 [Food and Drink Federation] Back

224   Q 515 [Food and Drink Federation] Back

225   Q 515 [Food and Drink Federation] Back

226   Q 262 [National Farmers' Union] Back

227   www.littleredtractor.org.uk/contact.asp  Back

228   Ev 55 [National Farmers' Union] Back

229   Q 261 [National Farmers' Union] Back

230   FSA, 'Call for shake-up of Food Assurance Schemes', 9 July 2002  Back

231   Ev 170, para 37 [Clive Dibben] Back

232   Ev 170, para 37 [Clive Dibben] Back

233   For example, ev 63 [The Co-Op] Back

234   Ev 169, para 27; FSA press notice 9 July 2002, 2002/2035 Back

235   www.littleredtractor.org.uk Back

236   Ev 169, paras 26 and 28 [Clive Dibben] Back

237   Q 268 [National Farmers' Union] Back


 
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