Memorandum by the National Farmers' Union
(NFU)
1. The National Farmers' Union of England
and Wales represents some 60,000 farmers and growers in England
and Wales. Through its initiatives, priorities and policies, including
the Common Agricultural Policy (CAP), the European Union (EU)
defines to a large extent the environment within which our members
operate. As such, the European Commission's annual legislative
and work programme for 2007 is of the uppermost interest for our
organisation.
2. The NFU would like to thank the Committee
for the opportunity to present this submission. Given the very
wide range of topics covered by the Commission work programme,
this submission does not attempt to provide a comprehensive analysis
of the programme but would instead focus on some of the individual
proposals of specific interest for the agricultural sector as
well as providing general comments on the general direction and
some of the overall priorities of the programme.
3. The Commission work programme highlights
a number of overall priorities, including the intent to undertake
a comprehensive institutional review, an issue of crucial importance
given the impact of institutions on the capacity of an enlarged
EU to successfully reform its policies in a successful and effective
manner. Of special interest for the NFU is to ensure that any
institutional reform facilitates the adoption of policies and/or
reforms (without resorting to the granting of exceptions and special
deals to certain member states that have, in the past, undermined
the commonality of policies, most notably in the context of the
2003 CAP reforms and of the budget deal in December 2005).
4. The Commission work programme draws attention
to the importance of communication and, more specifically, of
communicating Europe (and its policies, objectives and realities)
to its citizens. The NFU fully agrees with this overarching objective
and firmly believes that, in this context, it is essential to
communicate the importance of the agricultural sector and to inform
the public about the objectives and workings of the CAP (most
notably on the rectification of the misconceptions on agricultural
trade, see paragraphs 13 and 14 below). We also agree with the
Commission that this is an objective that is better achieved through
close cooperation between the different stakeholders involved,
including national governments. Our support for this objective
and engagement in its delivery is clearly demonstrated through
our "Farming Matters Campaign" and our support for the
work currently being undertaken to mark 2007 as the Year of Food
and Farming.
5. The overall drive for better regulation
and administrative efficiency is to be welcome as is its prioritisation
as one of the overarching priorities for 2007. The NFU considers
such a drive essential in order to maximise the competitiveness
of the EU in general and the agricultural sector in particular.
Given the high number of regulations affecting the agricultural
sector, the NFU awaits with interest the Better Regulation Strategic
Review planned for adoption in November and, in the meanwhile,
has already started to contribute to the specific simplification
initiatives concerning agricultural legislation (see paragraph
8 below).
6. One of the central tasks of the Commission
has always been (and will continue to be) to ensure the adequate
implementation of EU policies and to ensure that they fulfil their
objectives. Simultaneously, simplification and the creation of
a better regulatory regime appear as one of the overarching objectives
of the Commission for 2007 (see paragraph 5 above). Both overarching
goals are combined in the specific objectives of reviewing the
cross-compliance regime and to ensure that the 2003 CAP reform
is working properly.
7. The NFU has significant concerns about
the future development of the cross-compliance instrument in the
years ahead. There are already wide differences between the Member
States in the way that the cross-compliance measures are defined,
their number and scope and their monitoring. In addition, cross
compliance has grown from an instrument that seeks to assure good
agricultural practice to one that increasingly prescribes agricultural
activities and precludes flexible land use by impacting on even
the simplest agricultural operation or land transaction. Another
concern arises in relation to potential calls for the addition
of further statutory management standards that would be better
serviced through site specific solutions rather than European
or national defined verifiable standards. The NFU believes that,
in order to address these issues, the review of the cross compliance
regime should focus on a rationalisation exercise aimed at eliminating
unnecessary complexities and the potential for competitive distortions.
8. The proper functioning of the CAP will
be the focus of much debate in 2007 at the EU level. In the first
instance, work will focus on the issue of administrative simplification,
including the proposal to merge the 21 Common Market Organisations
(CMOs) into a single CMO. The drive for administrative simplification
is to be welcome but should not result in any case in lack of
consideration for the specificities of different agricultural
sectors. Discussions will also progress on the 2008 Health Check
of the CAP. The NFU believes that work should focus on addressing
the distortions created by the concessions made in 2003 in order
to reach agreement and not on budgetary issues and/or on mapping
further radical reform of the CAP.
9. The NFU welcomes the plans to reform
the wine and fruit and vegetables regimes and the opportunity
it provides to bring these sectors in line with other (recent)
agricultural reforms by, among other measures, the elimination
of restrictions on the planting of fruit, vegetables and potatoes
on Single Farm Payment (SFP) eligible land in member states or
regions operating an area payments system. We believe that the
reforms should aim at the establishment of clear and simple rules
that prioritise market signals, increasing the competitiveness
of the industry and the reinforcement of the environmental, social
and economic fabric of rural areas.
10. The NFU also welcomes the overarching
emphasis on initiatives and policies aimed at winning the battle
against global climate change, such as the White Paper "Towards
a European Climate Change Adaptation Programme", the work
on the European Strategic Energy Review and the Communication
on Water Scarcity and Droughts. This work is of special interest
for the NFU, given the complex and multi-faceted interdependence
between the environment and the agricultural sector. We believe
that any effective strategy against climate change needs to recognise
the positive contribution that EU agriculture can make in the
fight against climate change and its consequences, while ensuring
that the productive capacity of the agricultural sector (an increasingly
crucial issue, given the expected impact of climate change on
global food supplies and the negative impact of transferring production
to overseas countries with lower environmental standards) is not
curtailed.
11. The European Strategic Energy Review
appears as one of the specific policy proposals for the year to
come. The NFU would like this much needed review to recognise
the essential role to be played by the agricultural sector as
a source of bioenergy and to set more ambitious objectives for
the share of bioenergy in overall EU energy consumption. We believe
that, in doing so, the EU would be fulfilling several of the overarching
objectives highlighted in the Commission work programme such as
the aim to increase energy security, helping tackle climate change
(see paragraph 9 above), contributing to the competitiveness agenda
and modernising the (rural) economy.
12. A further Commission work priority for
2007 is the definition and launch of the new generation of rural
development programmes. Given the importance of rural development
programmes for the farming community, the NFU views with profound
regret the current delay resulting from the dissent between the
Commission and the European Parliament on the implementation on
(voluntary) national modulation.
13. As a sector operating within global
markets, British farmers take special interest in the EU trade
agenda and the whole range of initiatives included in it. On the
multilateral front, the NFU would like to see a successful outcome
to the Doha round of trade negotiations, but one that does not
come at the expense of EU agriculture. We believe that trade negotiators
need to take into consideration the complex dynamics of agricultural
trade and the importance of the multifunctional nature of agriculture
as well as the fact that the recent and ongoing CAP reforms have
put the EU well ahead of other developed countries in the liberalisation
process.
14. The NFU recognises the intertwining
of the trade and development agenda and the need for the EU trade
agenda to continue reflecting the EU commitment to development
via the granting of special and preferential treatment to developing
countries (such as the ongoing negotiations on Economic Partnership
Agreements with the ACP countries and the review of the application
of the Generalised System of Preferences). Similarly, the preferential
trade agreements with countries in the European neighbourhood
should reflect the commitment to stability in the region. In its
preferential trade agreements, EU policies should recognise the
distinctive characteristics of the agricultural sector and the
complex relation between the multilateral and bilateral/regional
trade agenda.
15. The EU environmental agenda is expected
to progress through, among other initiatives, the review of the
group of Industrial Emissions Directives, including the Integration
Pollution Prevention Control (IPPC) directive, and the revision
of the National Emissions Ceiling Directive. Given the small and
medium size of agricultural businesses, the application of the
proportionality principle of crucial in order to reconcile these
environmental objectives with the competitiveness agenda. Any
regulatory proposals should taken into account the competitiveness
impact of regulation, especially in the face of increased non-EU
import competition and of the imbalances in the food supply chain
that prevent agricultural producers from passing on the additional
costs resulting from the regulation.
16. The NFU recognises the importance of
high standards in animal health and welfare as one of the defining
characteristics of the European agricultural model and will be
contributing to the ongoing work on the Animal Health and Welfare
Action Plan. The Plan should set clear objectives for animal health
and welfare that are coherent and consistent with other policies
(most notably with the minimisation of the regulatory burden that
appears as an overall EU objective, see paragraph 6 above). It
is also essential that the necessary budget is made available
by the EU in order to effectively deliver these objectives.
17. As representatives of primary food producers,
the NFU is particularly interested in the White Paper on Health
Strategy and the White Paper on Nutrition and the related initiatives
to amend food and nutritional labelling legislation. Given the
importance of nutrition, clearer labelling is to be welcome and
should focus not only on the nutritional context but also on traceability
issues. We believe that this approach, based on improved information,
is always preferable to the "choice editing" that has
been postulated in certain arenas.
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