Memorandum submitted by The Fresh Produce Consortium (SFS 54)



1. Introduction The Fresh Produce Consortium (FPC) is the UK's trade association representing the complete spectrum of the fresh fruit and vegetable produce industry: from growers, importers, wholesalers, retailers, distributors, packers, food service organisations and other allied organisations. Among our members are a number of wholesale market tenants' associations, as well as individual companies trading at markets.

2. Executive Summary FPC welcomes the inquiry by the Environment, Food and Rural Affairs Committee into securing food supplies up to 2050. We believe that the fresh produce industry has a pivotal role in helping the Government deliver its strategy 'Food Matters', and welcome the recognition that long-term food security, sustainable food production and consumption must be delivered in a global context.

3. There are a number of actions identified in the strategy to which FPC and its members can contribute: from meeting strategic policy objectives to achieving food production in a low-carbon world, calculating greenhouse gas emissions from agriculture, reducing excess packaging and increasing re-use and recycling, to reducing food waste and recovering energy.

4. Until recent price rises last year there had been an actual long-term decline in real UK food prices, with the average UK household spending 9.2% of weekly expenditure on food in 2007 compared to 20% in the 1960s.

5. The UK is more self-sufficient than before and after the Second World War, with UK production of 60% in all foods and over 74% in foods which can be produced in the UK.

6. Around 60% of fruit and vegetables are imported into the UK, providing us with produce outside the UK season as well as varieties which simply cannot be grown in the UK.

7. Government investment in research and development, as well as training, is essential to ensure that the industry is equipped with the necessary resources to meet the challenges of delivering food security in 2050.

8. In addition, the fresh produce industry would welcome further support to remove unnecessary documentary processes imposed within the UK which put the UK on an unequal footing with regard to other EU member states and third countries which apply and interpret the same legislation in a less bureaucratic manner.

9. 'Global not local' Research indicates that about 83% of greenhouse gases are created in the production phase of food, with transportation representing only 11% of the life cycle of greenhouse gases. The Fresh Produce Consortium is working with the Carbon Trust and others to look at how we can identify sources of emissions and reduce the carbon footprint of companies and their products.

10. Sectors of the industry like the wholesale markets are well placed to provide local supplies of affordable, good-quality fresh fruit and vegetables. The potential for local markets to contribute both within local communities and their economy is significant. Independent retail markets are a key customer group for wholesale market traders and an important element of the local economy.

11. According to the Food Climate Research Network studies have shown that some imported products will have been grown or manufactured in less greenhouse gas intensive ways than their UK counterparts, with savings from greater efficiency outweighing negative impacts of additional transport. It is therefore essential to balance transport emissions with other factors when evaluating and fully understanding the environmental impact of fresh produce, regardless of its origin.

12. Encouraging a healthy diet. The total quantity of fruit and vegetables marketed in the UK in 2006 was 8.1 million tonnes. Since 1996 the market volume has grown by 1.2 million tonnes, or 16.8 per cent. The market still has the potential for further expansion in order to meet consumption targets of 5-a-day. If the entire UK population were to eat the recommended 5-a-day, actual consumption would be in the region of 8.8 million tonnes.

13. In addition, the industry's campaign 'Eat In Colour' is ideally placed to provide consumers of all ages with advice on how to enjoy eating healthily and to reach the recommended 5-a-day target.  We recently published the findings of a TNS consumption survey which indicates that on average consumers are eating 2.5 servings of fruit and vegetable a day. Without a dramatic change in eating habits it could take another 25 years for consumers to meet the recommended 5-a-day.

14. With rising obesity levels across Europe it is essential that we encourage more people to eat fresh fruit and vegetables and that we can continue to provide a sustainable supply of fresh produce against the challenges of feeding an increasing world population, competing pressures on agricultural land and the impact of climate change.

15. The role of Defra. FPC wishes to ensure that consistent standards allow businesses to trade effectively in the UK and across Europe.  We are concerned that the revised Marketing Standards, as stated by EU and UK Government representatives, are being promoted as a simplification when in effect, subject to clarification of Defra's interpretation, they are likely to introduce additional layers of bureaucracy, complexity and cost to the fresh produce industry.

16. Over and above the specific Marketing Standards for ten types of produce, the introduction of a new General Marketing Standard for all fresh produce means that products which have not been included previously will be covered by the new Regulations.  We assume that this will require the industry to register details for import notification for a considerably greater number of products via the online PEACH system which will certainly increase both workload and cost to the industry. 

17. The Regulations are due to come into force on 1 July 2009 and we are still awaiting the start of a full consultation with the fresh produce industry.  Our concern currently is that we will not have enough details or sufficient time in which to make a meaningful contribution to assist with the effective implementation of these new Regulations. 

18. Ensuring horticulture can meet the challenge of increasing global food production. The European Parliament's recent vote in favour of removing key products which are vital for controlling pests, weeds and diseases will jeopardise the ability of European horticulture to supply good quality affordable produce in a safe sustainable manner. Critically, this decision has been made with no full assessment of the wider impact on food supply.

19. Growers already have a limited range of products to protect horticultural crops, and in some instances there will be no viable alternatives for treating common pests which reduce yields and damage fresh produce. It may become uneconomic to grow some crops such as sprouts and carrots, and lower yields will mean hard-pressed consumers will have to pay higher prices for their fruit and vegetables, including apples, pears, raspberries, leeks, peas and beans.

20. Around 1.9 million less well off people in the UK are eating less than one serving of fruit and vegetables a day. Increasing food prices would deter them further from enjoying a healthy diet, adding to concerns about rising obesity levels and poor health.

21. In addition, it could become harder to manage pests and diseases globally. A limited range of crop protection products could lead to the intensive use of surviving active substances, increasing the risk of spreading resistant strains of pests and diseases.

22. International trade could be affected. A substance banned in the EU could still be used on produce imported from third countries. In theory the Commission should allow an import tolerance if supported by appropriate data, however this would allow produce to be imported which may contain residues of substances not approved in the EU. Refusing to grant an import tolerance despite risk-based evidence of safety being presented by a non-EU country could lead to a challenge by the World Trade Organisation.

23. The horticulture industry already leads in the adoption of integrated pest management systems and we will continue to press the UK Government and others to ensure that the industry has the necessary tools to provide a sustainable supply of fresh produce.

24. Integrating systems and using electronic processes A report by SITPRO ('The cost of paper in the supply chain' 2008) found that the current documentary systems cost the perishable food supply chain more than 1 billion annually.

25. UK perishable food imports for 2005 were valued at 25,960 million (flowers: 3.4% - 876m; vegetables and vegetable products: 98% - 2,535.1m; fruit and fruit processes: 11.9% - 3,097m). Exports from the UK totalled 10,761 million (flowers: 0.5% - 48.6m; vegetables and vegetable products: 2.9% - 313.6m; fruit and fruit processes: 8.3% - 892.8m).

26. The cost of document-related administration in the sector is estimated to be around 11% of the supply chain value per annum, with the generation of paper-related documentation estimated at 126 million a year. Nearly 13 million man hours in 2005 were estimated to have been taken up with entering data, chasing late or missing documents or preparing claims for deferment monies deposited with HMRC, equating to over 354 million a year.

27. A single consignment transaction, from grower to retailer, can comprise up to 150 documents (or up to 225 pieces of paper) which results in duplicate elements of information being entered up to 42 times.

28. There is enormous scope to simplify procedures between importers, exporters and authorities, and to integrate electronic systems to reduce these costs to the fresh produce industry. According to the SITPRO report, with the introduction of e-documentation and shared data through a 'single window' the chilled food industry could save at least 700 million, around 70% of the costs, and benefit from fewer inspections of consignments, and reduced clearance processing time. The fresh produce industry represents about 25% of the chilled food industry, and therefore could save around 175 million according to SITPRO's estimates.

29. There is evidence that several Government departments and agencies often require the same documentation, leading to duplication of resources by the industry. Improved sharing of data, transfer of documentation and better integration of Government departments and agencies would also reduce unnecessary bureaucracy.

30. Government investment - research and development, and training for future workforce There is a need for Government to invest further in research and development to support the industry. It is vital that the industry continues to make advances and develops the necessary tools to meet the challenges of increasing food production.

31. Government support is needed to encourage young people to develop careers in food production and to provide the necessary training. The fresh produce industry has to compete with other industries which have greater investment in this area and which are perceived as more attractive by a younger generation.


January 2009