The Impact of Common Agricultural Policy Reform on UK Agriculture

Written evidence submitted by the

Royal Society for the Prevention of Cruelty to Animals (RSPCA)(CAP 10)

Executive summary

The reforms of 1999 and 2003 were important in obtaining measures to achieve animal welfare goods, but the few measures under Pillar II have not been adequately funded, and cross compliance is questionable as to its effectiveness to improve animal welfare. The Commission’s Communication (COM 2010 672/3), whilst advocating that farming communities need to be supported for animal welfare measures, does not contain any specific measures on improving or promoting animal welfare. The RSPCA fears that the proposals will achieve nothing to improve animal welfare under the CAP and may place British farmers at a competitive disadvantage in the EU.

1. The RSCPA welcomes the opportunity to comment on the effects of the CAP reform on British agriculture, as it relates to animal welfare.

2. How will the Commission’s proposals affect the ability of UK agriculture to be competitive in a global market?

Welfare improvements in the way animals are farmed have been made in specific legislation in the pigs, chickens, calves and laying hens sectors. There have been suggestions that these disadvantage the EU against products being more intensively farmed in other countries worldwide. For instance, studies in the laying hens sectors show a production cost difference of 8-10% when moving to the enriched cage system, and 46-59% when moving to a free range system [1] , [2] . Economic research on laying hen standards in the third countries expected to export to the EU shows a competitive advantage from the main exporting countries2. Economic analysis has also been done in the broiler [3] and pig sector [4] .

3. At present UK farm animal agriculture is not under threat from imports from non EU countries where standards are lower, with the exception of egg products. The beef and chicken imported under retailer own standards are at or above minimum EU standard and if stocking density is taken as an indicator of welfare, chicken is produced at or above the EU. However, liquid and dried egg are being imported at poorer standards than are currently in the UK. The CAP reforms do not contain any real incentives for producers to level this playing field.

4. There is little detailed information in the Communication to show how the reformed CAP payments will assist British farm animal agriculture exports compete globally. Assistance measures, such as marketing grants, have not been widely used in the UK and other measures such as financial assistance to change production systems have not been used at all. In Ireland producers were given incentives in 2010 to change over from battery cage systems to more extensive systems under Pillar II payments. There seems a mismatch between the lack of detail in the proposals and the Commission’s willingness to ensure higher welfare standards are addressed in bilateral trade negotiations.

5. Do the proposals ensure fair competition for British agricultural products within the European Union?

Outside of cross compliance, there are no compulsory measures to promote animal welfare in the CAP. The four devolved authorities have tended to take a laisser faire attitude to animal welfare under the CAP with only Scotland introducing a specific measure under Pillar II to promote animal welfare, which did translate into improvements in sheep and dairy cattle" [5] .

6. It is difficult to see how the proposals in the Communication, which contain no new compulsory measures will ensure fair competition for British agricultural products, particularly in those sectors such as chicken and pig production where British standards are above some of the other Member States and competition will be much greater than on a global level.

7. There is no incentive in the proposals to ensure that minimum legal standards are complied with, despite the competitive advantage for farmers in Member States where compliance with the legal standards is poor. As their production costs are generally lower, this can lead to trade distortion at intra-community level. Enforcement actions are generally not sufficient and the sanctions that are imposed to producers are not dissuasive or proportionate. The system of penalties and infringement procedures is slow and inefficient.

8. The Commission should undertake financial studies on the effects of differences in welfare standards and in enforcement of those standards on competition and this should inform measures that could be proposed under the CAP reform.

10. Will the proposals achieve the correct balance between productivity and sustainability?

No. The biggest part of CAP funding on animals still goes to the larger farms as direct payments, with no other condition than cross-compliance. The only potential measures promoting animal welfare in the first pillar are in Article 68 where member states can use part of their national envelope "for practising enhanced animal welfare standards". The Netherlands is the only Member State which is planning to use it for animal welfare in 2011. There are no incentives under the proposals that would change this position.

11. Do the proposals place the UK in a good position to help meet future food supply challenges?

The Communication contains no specific details on how it will meet consumer demands for animal welfare and ensure a future food supply. The proposals lack the introduction of any specific animal welfare measures, or non contractual actions into Pillar 1 payments, unless these could be introduced via the greening component proposal. The RSPCA would support measures to assist animal welfare under the greening proposal but it is not clear that this is the Commission’s intention. Without these measures it is unclear how the CAP can and should respond to the needs for increased and better (ie more humane) food production.

12. Will the proposals redress the inbalance in support to different sectors created by the historic basis of payments?

No, it is difficult to see how the present inbalance in historic payments will be corrected. Most pig, laying hens and meat chicken farms do not receive pillar I payments. The RSPCA has called for a substantial part of agriculture subsidies to be used to promote environmental protection and improvement of animal welfare, so being consistent with the objective of the EU Sustainable Development Strategy. Payments could be incentivized to improve the way animals are treated, for instance by tailoring subsidies only to those who respect the law, but the proposals contains no ideas on such areas unless animal welfare is tacked on to the environmental payment.

13. What aspects of the proposals should be made a common policy and which are best left to member states?

Mandatory policies should be implemented on Pillar 1 payments by keeping cross compliance measures on animal welfare and introducing an animal welfare measure in to the "greening payment" proposed under Pillar I. Payments under Pillar II, agreed in 2003, have suffered from a lack of funding which has resulted in few measures being proposed by Member States. Even though there are 90 rural development schemes under the 2007-13 programme that have programmes where animal welfare could benefit, only eight countries have taken the two specific animal welfare schemes under 16 different programmes. A common policy so that Member States introduce at least one animal welfare measure under Pillar II payments would rectify this. It would be left to Member State discretion which policy.

December 2010