Memorandum submitted by the RSPCA (SFS 03)




Executive summary

The challenges facing the agricultural industry in meeting future projected global demand for food need to be taken in the context of a sustainable humane agricultural policy, which will include raising farm animal welfare standards. The UK's position on CAP reform is clear and supported by the RSPCA as it is predicated on a sustainable agricultural model. The main challenge here is convincing the EU-27 that a move towards this type of CAP is required post 2013. Welfare improvements in the way animals are farmed have been made in specific sectors such as pigs, chickens and laying hens. However these improvements could be contrary to meeting present forecasted global demand for meat and could put the EU at a disadvantage to products being more intensively farmed in other countries. Further work is required in this area. Scientific data is patchy in what is required from the British livestock industry to meet UK greenhouse gas reduction figures. These data are needed to inform policy but any policy change could also be contrary to the need to meet projected global demand. Finally the economic climate is an important indicator of how consumer demand reacts to financial constraints. Sales of RSPCA Freedom Food products to date are robust showing strong consumer demand for higher welfare products and a desire for a sustainable agricultural model in the UK.


1. The RSPCA is pleased to respond to the consultation looking at what the challenges the UK faces in responding to the call to increase food production by some 50% by 2050. The RSPCA believe that there are three important and competing issues that need to be considered in the question of whether the UK is able to meet projected food supplies in 2050:


The reform of the Common Agricultural Policy

The importation of products from outside the UK and the limits on reducing such products

The impact of the debate on greenhouse gases and its relationship with agricultural products


2. The CAP is at a critical stage in its on going evolution. The RSPCA agrees that the CAP needs to be reformed to provide support to farmers more efficiently and be responsive to consumer demands, which include assistance to improving animal welfare. Whilst welcoming the 2008 agreement on the Health Check the RSPCA believes that this agreement only tinkered around at the edges of the CAP and did not address the real reform which has to occur if the CAP is to be fit for purpose. The real debate on the future of the CAP will focus on the post 2013 period and has already started. The concern that some countries and interest groups will use the excuse of the need for increased food production to argue against transforming the CAP into a model for sustainable agriculture was highlighted in the autumn of 2008 when the French Presidency issued such a document on the future of the CAP. This proposed the need for new instruments to support production and that the Single Farm Payment is no longer fit for the new challenges being faced, although it is only three years old.


3. The RSPCA believes that the CAP can and should respond to the needs for increased and better (i.e. more humane) food production. These needs must be met by considering sustainability issues such as environment, animal welfare and landscape maintenance. This can only be done by shifting subsidies from Pillar 1 to Pillar 2, where the majority of these targeted payments can be made. It also comes at a time when the Pillar 1 Single Farm Payment is a relic of the old CAP and only seems to deliver a blunt method of payment to farmers that is not targeted either at delivering a sustainable agricultural model or indeed at securing increased food security (hence the French proposal to return to the unreformed CAP where payments where made to farmers simply to produce more and protect farmers from the vicissitudes of global farm prices, particularly on grain. This model resulted in the infamous wine lakes and butter mountains of the 1970s and 1980s and is outdated. At present Pillar 1 payments represent 77% of CAP payments.


4. The terms of the CAP have not changed in over 50 years. The original aim, under the Treaty of Rome, namely to maximise the production of agricultural products has not been altered although debate on agreeing aims for a 21st century CAP started in the past few years. The pro-reform group, which includes the UK but is still a minority of States of the EU-27 want a CAP that delivers benefits to farmers, consumers and is responsive to market demands and fluctuations.


5. There have not been any long term sectoral review studies in the EU on the economic consequences on a livestock industry of adjusting to lower levels of support whilst moving towards a less intensive system. However economic studies in New Zealand, which went from a heavily farm subsidised system to a non subsidised system in a relatively short time period found farm bankruptcies went up in the short term but in the long term it has not effected the global competitiveness of the farming sectors. Whether this model can be applied to the EU has not been tested and further work needs to be done particularly in light of the food security issue.


6. The CAP was successful in helping the farming industry to increase output and put an end to food shortages in the two decades after its establishment. However, this increase in production came at the price of an intensification of farming, with negative consequences for animal welfare, biodiversity and the environment. Two examples will be given. The average milk yield of the dairy cow in the UK increased from 6,000 litres per annum to 18,000 litres over a ten year period to 1998. At the same time there has been increasing levels of welfare problems such as mastitis and lameness in the dairy cow and the UK is thought to have one of the worst rates of dairy cattle lameness in the world. The growth rate for chicken bred for poultry meat has increased hugely over the past four decades[1]. In 1958 a slaughter weight for broiler chicken was reached at 70 days of age whereas by 1996 it was reached at 42 days and is now around 35 days. It is estimated that the reduction to slaughter weight for commercial broilers has been consistently reduced by about one day per year in the past four decades.


7. Over the past ten years in particular EU scientific reports have demonstrated that the welfare of animals contained in intensive systems has been compromised. EU farm ministers have responded to this by deciding measures to reduce the rate of intensification albeit at a sector policy level rather than at a CAP level. Directive 1999/74 bans the unenriched battery cage, a decision agreed in 1999 and finally confirmed during the French Presidency in 2008. Regulation 2001/88 will phase out the sow stall system in the EU by 2013, though it was made illegal in the UK in 1999. Directive 1997/2 prohibited in 2006 the system of keeping calves in crates where movement is restricted and Directive 2007/43 sets a maximum stocking density for chickens for meat, due to enter into force in 2010. So a direction has been agreed at a sector level that farming needs to be responsive to consumer desires for a more humane farming system. One of the consequences of this may be that this is incompatible with achieving food security at a national or indeed EU level even on those sectors such as pigs, eggs and beef where the EU has to date been self sufficient.


8. So any debate on food security needs to look at the flexibility and direction of global trade rules. The UK is one of the foremost proponents of agricultural liberalisation, a position underlined in the 2007 Government paper Vision for the Common Agricultural Policy. Whilst the RSPCA also agrees with the concept of trade liberalisation the two goals as set out in the paper of producing high welfare standards and being internationally competitive in all sectors without subsidy or protection are often incompatible. There is a causal relationship between raising animal welfare standards (within many instances, an explicit increase in costs) and the risk of being undermined by imports from third countries where standards maybe at a lower level. This will lead to the industry becoming uncompetitive in its own market place let alone in the export market and of course effect national food security.


9. There are a number of studies showing this relationship and its effect on competitiveness. In the egg sector, there will be an economic consequence of raising welfare standards under Directive 1999/74. Moving from the standard in 1999 this equates to a price differential of about 11p/dozen eggs moving to the enriched cage system, 15p moving to a barn multi-tier system or 36 p/dozen eggs moving to a free range system[2]. Economic research on laying hen standards in the third world countries expected to export to the EU shows that standards are more intensive than the 750 cm2 space allowance per bird that will apply from 2012 in the EU. It reveals a competitive advantage from the main exporting countries. Those using a standard of 350 cm2 would have a price advantage in the trade in dried eggs of 3p before any changes in the DDA are enacted. Any agreed changes in tariff reduction will decrease the competitiveness of the EU egg industry.


10. Similar economic analysis has occurred in the broiler sector[3] and the pig sector[4]. In the broiler sector, economic analysis shows that there will be a 11% increase in cost of production from the present broiler stocking density of 38 kg live wt/2 to a reduced stocking density of 30 kg lw/m2. This equates to an annual cost to UK industry of 101 million. Even keeping the present stocking density but not allowing the practice of thinning the birds (taking out birds during the growth cycle as the maximum stocking density is reached) would cost the industry in the UK 42 million annually. In the pig sector analysis of the difference between sow production under a higher welfare scheme in Germany and the baseline standards shows a difference of 8.45 in production costs per weaner.


11. This is an issue that needs to be addressed as, despite the failure to date of the Doha Development Round negotiations after eight years, it is likely that during the next 10 years agriculture will become more open to global competition as tariffs are reduced. Bilateral agreements will fill the vacuum of any WTO failure. The EU is currently discussing bilateral agreements with ASEAN, Canada, the Republic of Korea and the Andean Community.


12. The European Commission has made it clear that it is committed in bilateral trade negotiations to ensuring the issue of higher welfare standards are addressed in such agreements. The existing agreements which have language contained in them on ensuring compatibility in animal welfare standards and could be a useful model of how to ensure that the twin goals of improving animal welfare and trade liberalisation can occur in parallel.


13. The final part of the jigsaw is the effect of greenhouses gases and climate change both on and from farming which has created new challenges for policy demands. This is in the early stages of being tackled and its implications on food security is an area still being looked at. The 2008 report from the Committee on Climate Change placed agricultural emissions in the UK as fifth most important emission source (after power stations, residential, industry, transport).[5] Its main recommendation was that the government develop a policy framework as agriculture policy was at an earlier stage than any other sectors. Some of the recommendations from the report such as creating a decline in UK emissions by measures such as use of using new technology or eating less carbon intensive types of meat obviously impact on food security.


14. The RSPCA believe that further research is required in the area of assessing the impact of different diets or farming methods on specific greenhouse gas emissions, and also ensuring that any mitigating effects arising from policy decisions should be proofed against effects on animal welfare and the environment.


15. The European Parliament's Committee on Climate Change in their December 2008 report again recognises that the cultivation of cereals and soya as feed for livestock is responsible for substantial greenhouse gas emissions, and asks for a switch from intensive livestock production to extensive sustainable systems. However this switch, which the RSPCA would support, is incompatible with the present increases that are occurring in total global meat consumption and in particular the rises in poultry and pig production in developing countries such as India and China. World meat production is expected to double by 2050 and is growing highest in developing countries particularly for pigs and chickens which grew by 75% in the past five years[6]. The switch also seems to be incompatible with calls for better food security at a national or EU level and is a policy decision that could be difficult to implement.


16. However the 2005 report from the UN's Food and Agriculture Organisation, whilst recognising that livestock ruminants particularly those in developing countries produced large amounts of greenhouse gasses which was unsustainable, called for a reduction in livestock greenhouse gasses by proposing the reduction would be achieved by the intensification and industrialisation of livestock production as the long term outcome[7]. Clearly some policy direction is required.


17. The majority of the UK's 20% decline in non CO2 emissions from agriculture that is predicted out of the 1990-2010 period to be largely met by the reforms to the CAP (mentioned in paragraphs 2 and 3) which introduced various reforms to the dairy payments and introduced in the UK a decoupled Single Farm Payment. This reduced the number of farm animals, particularly cattle. The numbers of dairy cattle in the UK fell by 28% in the 15 years to 2005 from 2.8 million to 2.0 million cows[8], a decline which continues. The UK herd fell by 4.5% between June 20005 and 2008 to 1.9 million dairy cattle[9]. The rate of decline is comparable to France and Italy, two of the other main dairy producer countries in the EU which lost 26% and 29% respectively of their dairy cattle population in the same time period (1990-2005).


18. The dairy and beef herd example shows clearly the conflicting effects between the CAP reform, combating reduction in agricultural greenhouse gas emissions, improving animal welfare and providing for food security.


19. The decline in the UK's dairy herd has created self sufficiency and supply issues for the UK's beef industry as in the past over half the UK's beef has been sourced from calves born to dairy cows. A long term drop in dairy beef production is inevitable in the latter part of this year due to the shortage of dairy heifers. As UK beef cattle numbers also continue to decline, it is predicted that this will result in a drop of 19% in UK beef production by August-December this year. The dairy sector reform agreed as part of the Healthcheck package in 2008 could have an additional negative impact on the beef sector. The RSPCA has been advocating the absorption of black and white (Holstein-Freisian) bull calves into the UK's finishing beef system to fill this hole, animals which are currently shot at birth on farm but high grain prices have previously made this uneconomic.


20. Finally the current economic climate has given some useful information on consumers' reactions to higher welfare food and organic food. Organic food has seen a slump by about 20% in the past year (2007/8) and is projected to drop a further 50% by 2010. This seems to be related to the current economic situation and anecdotal information suggests that shoppers are moving away from organic meat products into higher welfare products such as Freedom food. This may be related to price (Freedom food products are priced invariably between baseline standards and organic standards) but no qualitative work has been done on this.


21. To date the economic climate doesn't seem to be acting on Freedom Food sales which seem to be holding up and in some areas such as chicken, pigs and eggs are reporting year on year growth in numbers of animals covered (2007/8) of 25%, 13% and 6% respectively. It isn't clear yet if this divergence between sales in organic and Freedom Food will continue into 2009, though it is expected that sales of Freedom Food chicken and pigs will remain robust on the back of the Channel 4 programmes on food due to air in January. The RSPCA believe that these data show that consumers still choose higher welfare products in economically challenging times and underlines the importance of provenance in food to consumers.


22. In conclusion, it is unclear how the UK Government, which is committed to trade liberalisation, a strong British agricultural sector to meet increasing global demand and raising welfare standards will ensure that these difficult and possibly conflicting relationships will be effectively addressed. The UK has been very clear in the direction it desires for the CAP but a clear policy direction to address the issues above and in the context of meeting UK greenhouse gas agricultural reduction targets, is required.


January 2009

[1] Walker et al 2005. Limits to performance of poultry in Sylvester-Bradley & Wiseman Yields of farm species constraints and opportunities in the 21st century. Nottingham UP.

[2] The Case against Cages 2005 RSPCA, Hard boiled Reality 2001 RSPCA

[3] The economic consequences for the broiler industry of legislatively enforced reductions in maximum stocking density. Centre for Rrual Research, Exeter Univeristy 2005

[4] Effect of higher welfare standards on the costs of producing beef and pork in the EU. Bondt et al 2004 Agricultural Economics Research Institute The Hague.

[5] The Climate Change Committee Building a low carbon economy - the UK's contribution to tackling climate change 2008

[6] FAO world report 2008

[7] Steinfield H, Gerber P, Wassenaar T, Castel V, Rosales M & de Haan C. 2006. Livestock's long shadow: environmental issues and options. FAO

[8] Eurostat 2008

[9] DairyCo Datum 2009