CONCLUSIONS and RECOMMENDATIONS
from the Reports of recent
Nuffield/BEMB Scholars
Nick Chippindale's Report
Nick was awarded a Nuffield Farming Scholarship in 2009 to study "The 2012 cage ban and its effect" in relation to the British egg producer and industry.
His Conclusions were as follows:
After completing my study ‘The 2012 EU ban on conventional cages and its effect’, I have drawn the following conclusions. It should be noted that this is a rapidly evolving situation, both in Europe and elsewhere, and hence my assessments will undoubtedly be modified as changes take place.
1. Increased production costs
The more space per hen the higher the cost. The switch to 2012 compliant systems increases the cost of production by 8% in enriched cages, up to 10% in enriched colony systems, up to 22% in barn systems and at least 25% in free range systems. Feed costs in the EU are generally up to 30% higher than the USA, Brazil, Argentina and India giving non EU countries a significant advantage in production costs.
2. Further polarisation of the Industry
Many smaller producers across the EU are unlikely to reinvest in 2012 compliant systems and will exit industry by 2012 or when market conditions dictate.
3. Increased threat of imported ‘illegal’ and lower cost shell eggs
If the Directive is fully enforced across all member states, eggs will become short .This shortfall can’t physically be filled by other European producers (Switzerland, Austria, and Norway) resulting in imports of eggs produced in lower welfare systems from outside the EU.
4. Increased threat of imported egg products from outside the EU
As the majority of food manufacturers buy raw materials purely on price, they may look to import cheaper products from outside the EU. This may also be the case if EU supplies tighten or in order to avoid perceived potential market volatility. Non EU countries can produce egg powder up to 25% cheaper than in the EU. If import levies are reduced then non EU countries will be at a significant cost advantage especially following the implementation of the Directive, as the EU cost base will have increased further.
5. The danger of oversupply and market volatility
From a producer perspective, if the ban is not fully enforced then potential over supply will cause volatility in the market. Volatility can lead to a loss of confidence in the supply chain and a potential loss of competitiveness in the market place.
6. Further action against intensive food production by animal welfare pressure groups
The EU ban on conventional cages is viewed by some animal welfare groups as the first step towards banning cages outright. Animal welfare groups will continue to influence and accelerate any legislation in relation to improving animal welfare despite the paradoxical issues it creates in the market.
7. Market Distortion
The Directive has led several member states to introduce grant aid in order to sustain production. However this could lead to an influx of new entrants, particularly in non-cage production, potentially flooding the market.
8. Globalisation of commodity supplies
The general pattern emerging in the egg industry is that the bigger producers are getting bigger and view the market as global.
Matt Davies' Report
Matt was awarded a Nuffield Farming Scholarship in 2008 to study "IPPC legislation and ammonia mitigation techniques for the poultry industry".
His full report will be published shortly but, in brief, he studied the following areas:
Pre-Excretion
Dietary Manipulation
Feed and Water Additives
GeneticsPost-Excretion
Livestock Housing
Manure Storage
Manure Processing
End of Pipe Techniques
Remodelling
His Conclusions were:
Before any serious investments are made it is strongly advisable to have the EA model scrutinised and challenged where necessary. Beyond this, using a dirty water system to drip irrigate a tree border seems logical as this would also deal with wastewater; furthermore there is the added benefit of grants being available for planting native woodland.
As the 2012 cage ban looms and old deep pit systems are replaced, it would be wise to opt for a belt-clean system. Acidifying feed or water is a method of controlling salmonella; this also has the effect of acidifying manure thus reducing ammonia release. Both methods have multiple benefits of which ammonia reduction is a side effect. At the moment Natural England is reviewing the ammonia deposition rates allowable on each of its sites. I see no reason therefore why anyone should start work on reducing emissions until these figures have been confirmed, particularly as the EA and Natural England have been allowed extra time to get their houses in order. Will they extend the same courtesy to the farming community?
What I have witnessed through visiting the world's poultry industries is that all of the different nations with all of their different legislations have similar aims and targets. It has been demonstrated to me that it is not just the UK facing this problem and that other nations are dealing with very similar issues, but turning them into further business opportunities. For instance, in Australia, Pace Farm's Eco brand sold exceptionally well and was a model farm. In Japan Akita Co has a very successful compost division. Great Mountain Poultry in Taiwan actively monitor their ammonia production as a partial marketing tool for improved welfare. In China DQ adhere to European environment and welfare standards as a marketing strategy and their investors insist on environmental monitoring of the surrounding area, as well as generating their own green energy.
My Scholarship has shown that in the vast majority of cases there are many routes that should not be too costly or involve large infrastructure changes to comply with IPPC legislation. Lastly, before farmers carry out work to reduce emissions, the EA must agree a reduction rate as a result of any changes they are planning to make.
Matt Davies
Mike Tyers' Report
Mike was awarded a Nuffield Farming Scholarship in 2007 to study :
"Ways in which poultry farmers can reduce their eco footprint".
The full report of Mike's study findings can be found by clicking here - it's about half way down the page.
Mike Tyers
Mark Williams' Report
Mark was awarded a BEMB-sponsored Nuffield Scholarship in 2005 to study "The Effectiveness of Trade Associations in Influencing Government Policy, with Particular Emphasis on Animal Welfare"
Mark is the Chief Executive at the British Egg Industry Council, an inter-professional trade association and the representative voice of the UK egg industry. He grew up on a poultry farm and completed the poultry course at Harper Adams Agricultural College. After experience working in the industry he became a regional poultry advisor for the NFU and later its egg specialist at national level. In 1999 he joined BEIC.
He undertook his study tour believing that the UK egg industry could learn from the experiences of trade associations in other countries with regard to how they have been successful in countering proposed legislation that could have been damaging to their industry, be it on agricultural or other issues.
The Conclusions and Recommendations from his Report are as follows:
CONCLUSIONS
- My subject is both fascinating and frustrating. Fascinating in that awareness of animal welfare issues is a growing phenomenon, albeit primarily confined to the developed world at the present time. Frustrating in that being employed in the thick of it, emotion is often seen to be clouding the issue, where science should dictate policy development.
- In the UK/EU a great deal of time and effort was spent lobbying between the publication of the Commission's proposals for a new Directive in 1997 and its adoption by the Council in 1999. Despite the industry's concerns, backed up by the presentation of scientific evidence, these were effectively ignored and the result was Council Directive 99/74/EC.
- My study has confirmed that other countries have learned from the EU's mistakes on animal welfare issues as they pertain to laying hens. While there are parallels that can be drawn between the UK/EU and those countries I visited, there are important differences too. In particular, the attitude of government to agriculture tends to be more supportive, with policies formulated to suit. It also helps when those not directly employed in agriculture have a family member or friend who is, thereby allowing for an appreciation of production methods.
- I thought that NAWAC's attitude in NZ to concentrate on welfare "outputs" (achieving the aim), rather than welfare "input" (defined as prescriptive standards), was to be applauded. The fact that industry was invited to draft the laying hen welfare code helped to provide producer "buy-in". Taken into account were: science, good practice, the use of available technology, consumer perspectives, the environment, conservation, and the economic implications of making changes. Probably one of the most refreshing aspects of my study visits was that both industry and regulators support scientific research to justify amendments to legislation. If the science is inconclusive, this is acknowledged and industry is not led down the wrong path. Notwithstanding the "EU Action Plan on Animal Welfare", I sincerely hope that UK/EU policy-makers will, in future, consider this option as a realistic way forward.
- It is naive of politicians and policy-makers to suggest that the additional costs the EU egg industry is faced with, as it implements the new laying hens Directive, can be absorbed or passed on to consumers. What I find unacceptable is that legislators have been prepared to prohibit a system of production in the EU, yet are not prepared to prohibit products from being imported from that system elsewhere, which is, incidentally, increasingly becoming the norm in many non-EU countries.
- The European Commission currently has the platform to defend the EU animal welfare model, by negotiating the inclusion of animal welfare standards into a new World Trade Organisation agreement, the negotiations on which are currently taking place within the Doha Development Round Agenda. However, in the face of opposition from the majority of non-EU countries, the subject does not even get raised at negotiating meetings.
- The concern of the EU industry is that the increasing costs of production, combined with further reductions in import tariffs, are likely to seriously undermine the efforts of the industry in further raising standards of animal welfare. While I believe that companies marketing shell eggs can utilise to their advantage their proximity to the marketplace, this will not be the case in the fast-growing egg product market (dried egg in particular), which is where the EU industry is under greatest threat. Here, price remains the most important purchasing factor and unless food manufacturers are able to achieve a price premium in the finished product for utilising non-cage eggs, inevitably they will seek to source low-cost eggs produced in conventional cages outside the EU.
- These double-standards are likely to result in the export of a significant
proportion of the egg industry to non-EU countries, where there is generally no animal welfare legislation in place. This is confirmed by various economic studies carried out by the egg industry, animal welfare groups, and the European Commission. Surely this cannot be allowed to happen by default? I urge politicians and policy-makers to act now and find an acceptable compromise.
- This leads me on to my final point. While it is commonsense, yet often overlooked, it is important to try and achieve agreement between interested parties prior to legislation being proposed (or during the consultative process). It is often the lack of trust between those with apparent opposing views that can prevent compromise being achieved, which could be taken to government thereby mitigating what may be considered to be extreme proposals.
RECOMMENDATIONS
- A trade association must be non-party political. It must be proactive and positive. It must always seek to anticipate future issues and act accordingly. It must handle crisis management issues professionally and forcefully. This will generate respect from those it is seeking to influence.
- Whilst a trade association's principal purpose is to represent the interests of its members in discussions with policy-makers and regulators (looking forward), it is important to keep its members up to date with issues as they progress (reporting back). There is nothing more frustrating than looking behind and seeing no one there!
- Ensure there are effective lines of communication, in particular an efficient up-to-date electronic database of members which can be used to pass on information and solicit a response almost immediately. Utilise the available technology - email and the internet.
- A trade association's membership is absolutely vital when there is a need to respond on specific issues, e.g. letter writing to government in support of a key lobbying issue. Members must therefore be "sensitised", but care must be taken not to ask for their help too often, otherwise it risks a limited response on the vital issues.
- Ensure that the trade organisation has an attractive website which is kept up-to-date, thereby allowing opinion-formers easy access to research industry concerns. Similarly, the availability of promotional material, either on the internet or in print, adds to the professional image of an association.
- Consider the production of and circulation to opinion-formers of standard briefing papers, e.g. "This is what the industry does for animal welfare, etc". This enables the industry's case to be promoted, and acts to balance opposing views.
- Invariably trade associations will not be as well resourced as some pressure groups. This means that they must closely watch legislative developments and seek to influence policy-makers at the earliest opportunity. One very effective means of achieving this is to encourage legislators/policy-makers and opinion-formers to visit facilities to see first-hand how the industry operates.
- Policy-makers/legislators should be encouraged to concentrate on animal welfare "outputs" (achieving the aim), rather than on welfare "inputs" (defined as prescriptive standards).
- Industry should conduct research to provide credible scientific data in support of its aims, especially if it is unhappy with the direction it is being given. Ideally this should be independent.
- Consider establishing Scientific Advisory Committees (SAC). These can provide the necessary degree of independence from industry, thereby adding credibility. The SACs should encompass a diversity of stakeholders.
- Effective lobbying is a skill requiring a large amount of time input and great patience. The trade association should prepare its case, be clear and concise in what its objectives are. It should consider the position of others. It should get to know th right people and build up long-term relationships with legislators/policy-makers. It should be a (constructive) nuisance.
- As a greater number of politicians will be urban-based in future, ensure that they too are lobbied.
- Consider organising special events for politicians and opinion-formers, either as one-offs, or ideally annual, that can focus the trade association's lobbying activities, e.g. an omelette lunch.
- Besides lobbying government, a trade association should also seek to influence other interested parties to explain and promote a particular position. This would enable better understanding of the industry position and, where possible, enable a compromise to be reached. Government would then be offered a compromise position rather than two opposing positions, which should remove the need for swingeing legislation.
- Ensure that the lobbying arm of a trade association is adequately resourced. As previous Scholars have reported, "lobbying is an investment, not a cost". This is truer today than it has ever been.
- Where possible, and recognising the necessity for compromise, the intensive livestock industries should work together on specific issues. This adds clout.
The recommendations above equally apply to trade associations operating at UK and EU level.
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A full copy of Mark's Report may be obtained from the Nuffield Director.






