The Common Agricultural Policy after 2013 - Environment, Food and Rural Affairs Committee Contents


Supplementary written evidence submitted by the Agriculture and Horticulture Development Board (AHDB)

Given that the UK farms tend to be larger than the EU average, how likely is it that any scheme to support "small farmers" will be of benefit to UK farmers?

1.  Based on the concept that a small farmer is one who farms a small area, any scheme to support "small farmers" is likely to only benefit a minority of UK farmers. According to the Farm Structure Survey of 2007[20] (FSS 2007) in the UK only 39% of holdings (of more than one European Size Unit)[21] were smaller than 20 hectares in size. This compares to 39% in Ireland, 40% in France, 52% in Germany, 69% in Austria, 78% in Spain, 92% in Bulgaria and 97% in Romania.

2.  Based on the assumption that 20 hectares is the cut off point for designating a "small farmer", less than 40% of UK farmers would stand to benefit under any such scheme. Additionally these holdings only account for 4% of the utilised agricultural area of the UK. Many of these small farmers are engaged in livestock farming with over 80% of the land being permanent pasture and meadows. Cereals or forage crops account for most of the very small amount of cropping in this category. So, while such a scheme has the potential to be beneficial to some farmers in the UK, the majority will see little or no benefit.

3.  Many small farmers are actually part-time farmers either due to another job outside of the holding or semi-retirement. The FSS 2007 indicates that more than 75% of UK small farmers are considered part-time, with most of these putting in under half of their time to the agricultural business. The survey indicates that small farmers are also more likely to be over 65.

4.  As such it is likely that any scheme that supports small farmers will be of little benefit to UK farm businesses as either they will be too large to qualify for the support or they are only engaged in farming on a part time basis. However, small farmers who are engaged in farming in a full time capacity may be able to benefit from such a scheme. In addition, it is possible that the definition of a "small famer" could be set even lower than the assumed level of 20 hectares which would further reduce the benefit to UK farmers. Finally, the support for small farms may distort the market (depending on the approach used) which potentially could have adverse effects on maximising competitiveness/food production, and minimising Green House Gas emissions.

The Commission has recently published its "Milk Package" including proposals to improve the functioning of the supply chain. In your view, are the sorts of measures in the proposal sufficient to rectify the current imbalances and ensure a fairer return to farmers?

5.  The proposals could help to improve market signals to producers which would help make the market work more efficiently. Whilst the use of written contracts between producer and processor is already common place in the UK, there is much debate in the industry about whether the structure of these contracts hinder the market from operating efficiently. The European Commission proposals could address this issue by ensuring certain common elements are included within contracts.

6.  The key issues of pricing and notice periods within written contracts still remain as problems in the UK milk market. Firstly, only Tesco's and one other additional contract we are aware of have a clear pricing structure with market indicators or other factors explicitly linked to setting the price. Secondly, those buying milk are able to change the price at short notice, or even retrospectively, without the option of a farmer ceasing supplies of milk to that buyer without a long notice period in most cases. Finally, many contracts do not specify the monthly volume of milk to be produced and this reduces the predictability of supply for processors.

7.  The European Commission proposals will be of greatest benefit to the UK dairy industry if they instigate change in the areas outlined without dictating a one-size-fits-all approach. For example, all contracts must be set up with a core principle that price changes must be agreed, and if there is no agreement, farmers can leave within a reasonable period However, the mechanisms for setting prices within contracts can be very different and should be left to the commercial world. For example, price setting on a milk-for-cheese contract could be very different to that within a liquid milk contract. Contracts could specify prices in different ways such as:

—  xxppl for the next six months for a liquid contract possibly with the retailer agreeing an appropriate wholesale price for the same period.

—  Price formula of AMPE (Actual Milk Price Equivalent)[22] indefinitely for a commodity processor.

—  Price formula of MCVE (Milk for Cheese Value Equivalent)[23] + 2ppl indefinitely for a cheese processor.

The exact details of contracts should vary depending on different circumstances and it should be left to commercial organisations to decide on these. However, key principles should be addressed by contracts, so price changes are agreed and producers are able to easily and relatively quickly move to another buyer if this isn't the case. This would aid clear market signals and an effective supply chain.

The CAP provides a basic income safety net to farmers. One argument for its retention is that it compensates farmers for the poor returns they receive for their products from processors and retailers. If direct income support were abolished, would you anticipate that any action would be taken by retailers and/or processors to secure their supplies?

8.  Removal of the income safety net would increase the exposure of farmers to fluctuations in prices and production levels and this may incentivise processors and retailers to provide greater support to their suppliers in order to ensure that the flow of food and inputs they require continues. It is important to note that action along these lines is already occurring in many agricultural supply chains in the face of volatile commodity markets. In the feed compounding sector, for instance, it is common for compounders to enter into forward-buying contracts with producers that cover many months ahead of the current market. This has been crucial to them in recent months, allowing them to secure supplies at set prices when raw material (particularly cereal) values have been highly volatile.

9.  Adapting to market volatility is most efficiently achieved using a whole supply chain approach. Hence, an increase in the exposure of farmers to risk requires not just action from processors (and others in the middle of the supply chain) but all those involved in the chain. For instance, if processors are to enter into forward contracts with farmers, they may well seek similar arrangements with end-users (eg supermarkets) in order to share the risk burden. However, for such arrangements between different agents in the supply chain to be successful, it is essential that all parties fully understand the risks that they and others face.

10.  This has been seen to be very effective in the poultry feed supply chain, for instance, where cereal farmers, integrated poultry units and end-users have been successful in spreading the risks associated with volatile wheat prices across the whole chain. Given that feed wheat prices represent by far the largest part of the costs incurred by the chain, this has been crucial in ensuring the continued profitability of the relevant firms as feed wheat prices have risen over the last 12 months.

11.  Other examples of supply chains beginning to work on this include the dairy market, where Tesco have undertaken to pay farmers supplying them with liquid milk a milk price that covers their cost of production. Many other supermarkets have dedicated suppliers, with a premium price which also aids security of supply. As the examples already exist it appears likely that if the need arose more supply chains would become integrated and work better together.

12.  However, for those farmers not involved in more integrated supply chains (and the vast majority are not) and are in effect generally competing on the world market, they would probably be fully exposed to market volatility. Their profitability would depend on their competitiveness and how efficiently they used tools such as the futures markets (although these are not available in most sectors). In some production sectors it is clear that there is potential for efficiency to be improved and this lack of a safety net may stimulate improvements. However, it is likely that there might be significant other impacts, such as a drop in production, reduction in the number of farmers, abandonment of marginal land etc.

13.  An additional factor which should be considered when deliberating this point is how effective CAP is at providing a safety net in that in many cases subsidy payments get partially or wholly transferred in to the supply chain or capitalised in land costs/rents depending on how the supply chain is working. The amount of the payment that gets lost to farmers depends on factors such as how "decoupled" farmers consider the payment (ie do they continue to produce food even though the market price is too low because the subsidy payment allows them to do so), whether the market price is driven by world demand/supply factors or more regional factors, demand for land in a local area, are input costs higher than they otherwise would be without CAP support to farmers etc.

The Commission has recently released new proposals regarding an "income stabilisation" tool to help manage price volatility. What are your views on its utility for UK farmers, impact on competitiveness and budgetary and WTO implications?

14.  AHDB would need more details on how the proposed tool may work before being able to provide a full analysis of potential impacts. For instance, how will the scheme be funded—will it come from the rural development or direct payment budget? However, a few comments can be made based on the content that has been reported in the press and from the Commission.

15.  Reports coming out of Europe to date indicate that the tool may be restricted to provide support only where losses of income above 30% of average income occur and will be limited to compensating for a maximum of 70% of the total income loss. This is important for two reasons. It is expected that restricting the scheme to these levels would meet WTO "green box" requirements. Secondly, it shows that income fluctuations are only to be smoothed on the downside and hence the term "income stabilisation tool" could be misleading—as that may imply a system that reduces income fluctuations in both directions, such as Contracts for Difference (CfDs).

16.  It has also been suggested that the system will be voluntary since there is a varying appetite for such a tool within member states. Part of the reason for this is that it is seen to be complex from an administration point of view, with difficulties calculating the average income and current income loss for each producer in the member state. Only having the option available in some member states may affect competition within Europe, however restricting usage to situations where very large reductions in income occur should reduce the impact of this.

17.  AHDB would need more detail in order to fully analyse the system and compare it to the other systems that exist elsewhere in the world such as in the USA which may be of interest. However, early indications suggest that it is likely that there will be limited appetite for the tool from the UK farming industry given the extra complexity it adds to the CAP, the costs of administering the scheme and the potential erosion to the value of farmer's direct payments.

February 2011


20   Data taken from the Farm Structure Survey in the United Kingdom and from the equivalent surveys for other member states is available from Eurostat (http://epp.eurostat.ec.europa.eu). Back

21   For each activity ("enterprise") on a farm (for instance wheat, dairy cow or vineyard), a standard gross margin (SGM) is estimated, based on the area (or the number of heads) and a regional coefficient. The sum of such margins in a farm is its economic size, expressed in European Size Units (ESU) where one ESU is a 1200-euro standard gross margin. The ESU can be thought of as a measure of the economic size of a farm business based on the gross margin imputed from standard coefficients for each commodity on the farm. An ESU roughly corresponds to 1.3 hectares of cereals, one dairy cow or 25 ewes. In 2007, there were 183,000 enterprises of at least 1ESU recorded in the UK. Back

22   AMPE calculates the value of a litre of milk at the factory gate if it is turned in to butter and skimmed milk powder at the prevailing prices for those products and allows for the processors costs. Back

23   MCVE calculates the value of a litre of milk at the factory gate if it is turned in to mild cheddar, whey powder and whey butter at the prevailing prices for those products and allows for the processors costs Back


 
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Prepared 14 April 2011