Supplementary memorandum submitted by
LEAF
Thank you for the opportunity to respond to
the committees questions about LEAF Marque and our views on environmental
labelling on 9 January.
We were pleased to be able to respond constructively
on our thoughts and experiences in the development of environmental
labelling, specifically relating to food.
One point however was that we picked up that
there were concerns raised about the independence of the verification
of the LEAF Marque standard and we wanted to clarify the robustness
of the standard and indeed its independence, openness and benefit
to consumers.
LEAF Marque is a certification standard for
farmers and growers. LEAF Marque provides stronger environmental
credentials to the existing farm and food assurance schemes. LEAF
Marque standards are applied to the whole farm, under the management
of the member's business; this includes land that is let and land
that is rented (standards apply to the business's areas of responsibilities).
As a fully integrated scheme, members must demonstrate
continual environmental improvement through their land management
practices across the whole farm. The environment includes key
resources and specifically soil, water, biodiversity and air quality.
Members of the scheme are assessed according to their: organization
and planning; soil management and crop nutrition; crop protection;
pollution control and waste management; energy and water efficiency;
wildlife and landscape; animal husbandry and the environment.
To qualify to use the LEAF Marque Logo the business
must comply fully with all the Critical Failure Points (CFP) set
out within the standards by an independent Technical Advisory
Committee and only after inspection and certification by an authorised
inspection and certification body that has issued the farm a certificate.
A LEAF Marque certificate covers the production Unit in totality
and is not limited to defined crops or enterprises within the
farming business.
Farmers and growers who are LEAF Marque certified
have been independently inspected, at least once a year, by food
certification organisations licensed by the United Kingdom Accreditation
Service (UKAS). The LEAF Marque is the consumer's assurance that
the producer operates their business and production processes
to the LEAF Integrated Farm Management principles and to high
environmental standards. The care and attention demanded by an
Integrated Farm Management system, required as part of the LEAF
Marque, has environmental benefits in its own right—for
full health, biodiversity and a living countryside.
LEAF Marque is an accredited scheme to EN450011
to ensure that consistent inspections and certifications are carried
out by multiple certification bodies worldwide. There are five
inspection bodies for this scheme: EFSIS Ltd (Now SAI Global Ltd),
National Britannia Certification Ltd, PAI Certification Ltd, CMi
Certification Ltd and SFQC Ltd. All are UKAS accredited to EN45011
for LEAF Marque.
A technical advisory committee comprising key
environmental, farming government and consumer representation,
including retailers, RSPB and WWF, review the standard throughout
the year to account for legislative changes and technical or scientific
developments. The reviewed standard is launched on the 1 January
each year. This standard is freely available on the LEAF website
www.leafmarque.com
The scheme is open to all producers that meet
the standards. The standards are available in English, French
and Spanish.
To LEAF, the scheme owners, this credibility
and consistency are paramount. However we believe that assurance
is not just about inspection and certification, for LEAF it is
a range of tools for the farmer, the food chain and the consumers,
including the ability for the food chain to verify product status
and the consumer to trace its food using our LEAF Tracks system.
LEAF has also developed a custody and warranty agreement process
which tracks LEAF Marque produce and composite ingredients and
products giving LEAF the ability to carry out product audits.
This system also allows us to facilitate trade in LEAF Marque
produce by the population of directories for the food chain and
the consumer.
Not only can consumers trace the farmer who
produced their food to LEAF Marque standards through LEAF Tracks,
but they are also able to visit farms to talk, discuss and understand
more about their food. LEAF's work is specifically to avoid consumer
confusion and to provide clear messages through traceability and
opportunities for consumers to understand more about what they
are buying, a true example of sustainable consumption.
LEAF Marque works closely with key retailers,
including Waitrose, Marks & Spencers, Wholefood Markets. LEAF
Marque produce is increasingly available in ASDA, Sainsbury's
and Tesco as well as other retail and processing outlets, some
of which is labelled, some meeting the standards but using the
retailers own label.
To add to the above I have attached a full listing
of the organisations represented on the LEAF Marque Technical
Advisory Committee, a brief description of UKAS and also a letter
from the NFU in order to clarify their position and recognition
of support for LEAF Marque.
We remain concerned about the recommendation
from Defra to develop an environmental label. We do, however,
welcome the opportunity to work with Defra to build the understanding
and value of the current farm assurance schemes, not only among
the industry but also among consumers.
25 January 2008
LEAF MARQUE TECHNICAL
ADVISORY GROUP
This group meets at least three times a year
to discuss the standards. The standards are freely available on
the LEAF website www.leafmarque.com in English, French and Spanish.
Representation on this committee includes:
LEAF, Farmers and Growers, Natural England,
UKAS, Waitrose, CMI certification Ltd, RSPB, Defra, National Britannia
Certification, FEC Services, Defra, Bayer Crop Science, EFIS,
SFQC, AERU, University of Hertfordshire, FWAG, PAI Ltd, Environment
Agency, Freedom Foods Ltd, WWF.
The LEAF Marque Technical Advisory Committee
reports to the LEAF Marque Management group. This group includes
representation from:
LEAF, Marks and Spencer, Assured Food Standards,
Farmers and growers, Imperial, Bakkavor Ltd, Harper Adams University
College, Everysite, Taste of the West, Waitrose, WFFU.
UKAS SUMMARY
UKAS is the sole national accreditation body
recognised by government to assess, against internationally agreed
standards, organisations that provide certification, testing,
inspection and calibration services. Accreditation by UKAS demonstrates
the competence, impartiality and performance capability of these
evaluators.
Accreditation by UKAS is the key to ensuring
that consumers, suppliers, purchasers and specifiers can have
confidence in the quality of goods and in the provision of services
throughout the supply chain.
UKAS is a non-profit-distributing company, limited
by guarantee, and operates under a Memorandum of Understanding
(MoU) with Government. The MoU was originally signed following
the setting up of UKAS in 1995, but Appendix 1 is regularly reviewed
and updated to cover the activities to which the recognition applies.
These activities are normally described through reference to specific
International, European or British standards.
Accreditation by the United Kingdom Accreditation
Service (UKAS) is the key to ensuring that consumers, suppliers,
purchasers and specifiers can have confidence in the quality of
goods and in the provision of services throughout the supply chain.
The recognition that this MoU provides demonstrates
the national recognition that UKAS enjoys, which is essential
for membership of the European co-operation for Accreditation
(EA) and the international associations of national accreditation
bodies.
The certification bodies which are accredited
to EN45011- General requirements for bodies operating product
certification systems by UKAS which certify eligible schemes under
this measure are listed below:
— CMi certification Limited.
— National Britannia certification
Limited.
— Product Authentication Inspectorate
Limited(trading as Product Authentication International).
— SAI Global Assurance Services Limited
trading as EFSIS.
— Scottish Food Quality Certification
Limited.
Independence of the inspection bodies
The EN45011 standard provides assurance of the
independence of the inspection body, through UKAS accreditation,
as required by Article 32(1)(b). The main principles UKAS adheres
to in providing assurances to national and internationally recognised
standards are independence, third party check of standards and
written procedures. Consequently, the organisations which own
the quality assurance schemes (ie the standard setting bodies)
must be separate from the inspection bodies.
Responding to market opportunities
Standard setting committees are a common feature
of quality assurance schemes. They provide a mechanism to keep
the standards under review. The aim of such reviews is to ensure
the scheme continues to reflect new industry and consumer concerns
in a changing marketplace. New standards may consequently be added
or existing standards increased in scope and/or stringency. This
mechanism also ensures that new legislation is incorporated in
the future.
EAC ENVIRONMENTAL
LABELLING SUB
COMMITTEE—FROM
THE PRESIDENT
OF THE
NFU
Thank you for your letter attaching the transcript
of the oral evidence, which Robin Tapper and I recently gave to
the Environmental Audit Sub Committee on Environmental Labelling.
I assume that this was in response to the Farming
Today report (10 January 2008) on the findings of the Sub
Committee and importantly your evidence to it. Certainly from
the NFU perspective, the transcript of our evidence is accurate
and, on re-reading it, I believe that we have been totally supportive
of the aims of LEAF to the point that it was stated that we "in
fact encourage it".
I share your concerns about the ideas of a Defra
inspired marque which is ill conceived, unnecessary and does nothing
to enhance the consumer offer beyond that offered by existing
schemes. We did not support this concept at the hearing. Indeed,
we have been working hard to convince Defra to drop it.
As we have discussed previously, the NFU take
its environmental responsibilities very seriously. This is why
we are keen to work with LEAF and where possible promote its good
work. Naturally therefore we fully recognise and accept the value
which the LEAF Marque brings in improving environmental awareness
and standards primarily in the produce sector. We also recognise
that the LEAF Marque is regularly reviewed, amended and independently
inspected. Importantly, as compared to Defra/BSI's ideas it is
also market driven, and farmers will only participate if they
want to and/or they get market reward.
The NFU's primary aim must be to maximise opportunities
for its members. To this end, the Red Tractor is vitally important
as a way of differentiating ourselves in the market place. Moreover,
it has to be accepted that no other agricultural assurance scheme
has the universality and infrastructure of the Red Tractor and,
with the exception of the Lion scheme for eggs, greater consumer
recognition.
I am also very conscious that you have not received
our draft NFU/LEAF protocol. Richard and I are still finalising
this and it should be with you shortly. Please accept my apologies
for the delay.
17 January 2008
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