Agriculture Bill

Written evidence submitted by Which? (AB22)

Which? is the largest consumer organisation in the UK with more than 1.3 million members and supporters. We operate as an independent, a-political, social enterprise working for all consumers and funded solely by our commercial ventures. We receive no government money, public donations, or other fundraising income. Which?’s mission is to make individuals as powerful as the organisations they have to deal with in their daily lives, by empowering them to make informed decisions and by campaigning to make people’s lives fairer, simpler and safer.

Executive Summary

1) Which? supports the move away from direct payments to an approach based on public money for public goods, but we are concerned that the Bill does not take the opportunity to align farm support and wider incentives with consumer and public health priorities, including food safety. Amendments are proposed to this end.

2) To assure consumers an approach based on high standards will be pursued, a duty should be placed on the Secretary of State to consider the consumer interest of any interventions.

3) The agriculture transition period must be used to evolve agriculture policy in a way that is aligned with wider policy and consumer expectations and as such this should not be put on hold as the new public money for public good approach is implemented.

4) The Clause 10 powers allowing the Secretary of State to modify retained EU legislation on the EU fruit and vegetable aid scheme in England should be clarified to explain what alternative measures or incentives would be introduced by the Secretary of State to achieve the pre-existing public health objectives better than at present. This is one of the few aspects of the current CAP support which is consistent with public health aims.

5) With respect to the collection and sharing of data - Which? welcomes the inclusion of the health of people and the safety or quality of food and drink in the list of purposes relating to the functions of public authorities.

6) Any labelling, marketing or compositional standards that are introduced should fully reflect consumers’ needs and interests. The Bill should specify that marketing and quality standards need to be developed with a primary focus on consumer interests and in co-operation with other relevant departments and agencies.

7) Regulations to enhance fairness across supply chains must take in to account any impacts for consumers.

Introduction

8) Which? welcomes the opportunity to submit evidence to the Agriculture Bill Committee. This is a crucial time for food policy - the decisions and policies put in place now will shape people’s food choices for many years to come.

9) As we leave the EU, there is an opportunity to reshape food and agriculture policy, addressing the disparate approach to policies relevant for our food that has evolved over many years and ensuring that there is finally a joined up approach around common objectives. The needs and views of people who consume food need to be addressed, along with those who produce food.

Consumer expectation

10) Which?’s consumer research shows that consumers expect future policy to promote high standards. Our recent research focused on Brexit and food standards, using an online forum and a survey which were representative of the general population. This found that people expect there to be high standards in place, that they associate UK-produced food with high safety, quality and welfare standards, and that they do not expect there to be any lowering of standards after the UK leaves the EU. If anything, they expect standards to be enhanced. 93% of people think it is important that existing food standards are maintained.

11) Our survey also highlighted strong support amongst consumers for buying food produced in the UK: 81% of people said it was important to buy UK-produced milk; 78% in the case of dairy products; 77% for poultry and 72% for red meat and meat products. 71% of people told us that they would not buy food items produced to lower quality standards if they were cheaper than they currently are – a finding that was consistent across socio-economic groups.

12) The Agriculture Bill will shape the framework for future farm support and for marketing regulations that will affect food composition and quality. It is essential that this reflects consumers’ needs and priorities, but at the moment consumer interests are largely absent.

Public money for public goods

13) The focus of the Bill, following on from the Health and Harmony White Paper, is to move away from direct payments to an approach based on public money for public goods. We support this approach in principle, but are concerned that the Bill does not take the opportunity to align farm support and wider incentives with consumer and public health priorities, including food safety.

14) A recent Which? survey found that 7 in 10 (69%) of people thought that the government should provide financial support to farmers. 10% disagreed, with 13% saying that they neither agreed or disagreed and 8% saying that they did not know. When we asked people what this support should be based on, animal welfare, food safety and animal health were people’s top priorities [1] .

15) Part 1, Clause 1 (1) sets out the Secretary of State’s powers to give financial assistance. The purposes listed are: (a) managing land managing land or water in a way that protects or improves the environment; (b) supporting public access to and enjoyment of the countryside, farmland or woodland and better understanding of the environment; (c) managing land or water in a way that maintains, restores or enhances cultural heritage or natural heritage; (d) mitigating or adapting to climate change; (e) preventing, reducing or protecting from environmental hazards; (f) protecting or improving the health or welfare of livestock; (g) protecting or improving the health of plants. An additional criteria needs to be added: "( h) improving food safety, public health and wider consumer interests in relation to food".

16) In addition, Clause 1 (1) (2) states that "The Secretary of State may also give financial assistance for or in connection with the purpose of starting, or improving the productivity of, an agricultural, horticultural or forestry activity". We understand the need for this provision, but are concerned about a focus on productivity in isolation without reflecting the importance of what is produced and how. There needs to be a shift from a focus on merely producing more (as though this is the end goal) to one that recognises that productivity has to be in line with other policy goals. This includes reflecting what is needed and expected by consumers. If this is not satisfied, there will be no market. There also needs to be alignment with other outcomes, including environmental protection and promotion, animal health and welfare, plant health and crucially food safety and quality, public health and consumer acceptability – so that productivity is carried out sustainably, in the broadest sense. Additional wording should therefore be included within Clause 1 (2) so that it states "The Secretary of State may also give financial assistance for or in connection with the purpose of starting, or improving the productivity of, an agricultural, horticultural or forestry activity in line with achieving the wider outcomes set out in Clause 1(1) and taking into account consumer attitudes and market acceptability of how this is achieved."

An approach based on high standards

17) More generally, the Agriculture Bill must be used to assure consumers that they will continue to have access to food produced to high quality standards. We suggest that a duty is therefore placed on the Secretary of State to consider the consumer interest of any interventions, including but not limited to financial assistance, and to preserve and promote high standards of food safety and quality in line with consumer expectations. This should be an over-arching requirement and so we suggest that it is included within Part 9, Final Provisions, as a new clause.

Transition period

18) The Bill will allow an agricultural transition period of seven years, beginning in 2021, with direct payments ending in 2027. During this period, it is important that agriculture policy continues to evolve in a way that is aligned with wider policy and consumer expectations and is not put on hold as the shift to the public money for public goods is steadily implemented.

Aid for fruit and vegetable production

19) Clause 10 allows the Secretary of State to modify retained EU legislation on the EU fruit and vegetable aid scheme in England. This provides financial aid to producer organisations in the fruit and vegetable sector, with the aim of helping them to increase their competitiveness, improving planning of production and quality of produce, and helping them reduce their environmental impact. As this is one of the few aspects of the current CAP support that is consistent with public health aims (to increase consumption of fruit and vegetables), clarity is needed on what alternative measures or incentives would be introduced by the Secretary of State to achieve these objectives more effectively. The benefits of consuming more fruit and vegetables are clear from both a public health and environmental perspective.

Collection and sharing of data

20) Part 3 deals with collection and sharing of data. Part 3 (12) (1) gives the Secretary of State powers to require a person in, or closely connected with, an agri-food supply chain to provide information about matters connected with any of the person’s activities connected with the supply chain so far as the activities are in England – and in (12) (2) to make regulations to this effect. Clause 13 specifies how this is to be interpreted, with Clause 14 specifying requirements that the purposes for which the information may be processed to be specified. We welcome the inclusion of the health of people and the safety or quality of food and drink in the list of purposes relating to the functions of public authorities.

Marketing standards and carcass classification

21) The extent to which food marketing and quality standards have been developed via the CAP, rather than as part of the wider body of food labelling and composition legislation has been an anomaly of the EU food regulatory framework – whether in relation to poultry or jam standards for example. There is now an opportunity to align this approach and ensure that any labelling, marketing or compositional standards that are introduced fully reflect consumers’ needs and interests.

22) Clause (20) (2) sets out an extensive list of characteristics that these regulations may cover including aspects such as presentation and labelling to the water content and type of farming and production method. (20) (4) specifies aspects relating to the classification, identification and presentation of bovine, pig and sheep carcasses. The Bill should specify that these marketing and quality standards need to be developed with a primary focus on consumer interests and in co-operation with other relevant departments and agencies. This includes for example, the Department of Health and Social Care (DHSC), the Food Standards Agency (FSA) and Public Health England (PHE). This should be included as a new (20) (5).

Producer organisations and fairness in the supply chain

23) Diverse supply chains allow for quality and choice which is important for consumers. When making any regulations for this purpose of enhancing fairness across supply chains, the wider implications, including any impacts for consumers must also be taken into account .

Conclusion

24) While the emphasis of the Agriculture Bill on "public money for public goods" establishes an important principle, it is currently deficient in how it deals with the consumer interest in agriculture policy and the extent to which agriculture policy interacts with other government policy to shape consumers’ choices. This needs to be addressed by amending the Bill so that its scope is broadened to align with future agricultural support and wider supply chain incentives with food safety, quality, public health and broader consumer interests.

October 2018


[1] Populus, on behalf of Which?, surveyed 2100 UK adults online between 19th and 20th September. The data were weighted to be demographically representative of the UK population

 

Prepared 25th October 2018