Select Committee on Agriculture Second Report



The regulatory system

41. The harmonisation of the regulatory system for organic production throughout the European Union began ten years ago with the introduction of Council Regulation 2092/91 on organic production of agricultural products and indications thereto on agricultural products and foodstuffs. Coming into force in 1992, the Regulation set out rules for the production, processing, labelling and marketing of organic crop products.[96] The latest amendment to the Regulation (Council Regulation 1804/1999) brings livestock within its scope with effect from August 2000, thus closing a major gap in the EU's organic legislative framework. The standards prescribed by the Regulation are the minimum which must be met; where the Regulation is silent, the "competent authority" in an individual Member State (the establishment of which is provided for by the Regulation) may set its own standards. In addition, the competent authority is required to approve private sector certification bodies, which in turn may impose on their members standards higher than those in the Regulation. Products produced in accordance with the standards and inspection processes set out in the Regulation in any Member State may be imported into any other. In addition, imports from countries whose standards and inspection systems have been recognised as equivalent to those applying within the EU (Argentina, Australia, Hungary, Israel, Switzerland and the Czech Republic) are treated as if they were produced within a Member State, whilst produce from other third countries must be authorised by the competent authority in the importing Member State and the importer must be registered with an organic inspection body.[97]

42. In the UK, the competent authority is the United Kingdom Register of Organic Food Standards (UKROFS). UKROFS predates Regulation 2092/91, having been established in 1987, and has seen its role change over time, first with the introduction of the main Regulation and more recently with the agreement of the livestock regulations, which has removed from it the necessity to set its own standards in this area. The focus of UKROFS is now "on ensuring that organic certifying bodies correctly interpret and implement [the Community] legislation rather than actually setting standards".[98] UKROFS currently recognises eight inspection bodies as running certification systems in compliance with the Regulation: Organic Farmers and Growers Ltd (known by the designation on labels of UK 2), Scottish Organic Producers Association (UK 3), Organic Food Federation (UK 4), Soil Association Certification Ltd (UK 5), Bio-Dynamic Agricultural Association (UK 6), Irish Organic Farmers and Growers Association (UK 7) , Food Certification (Scotland) Ltd (for organic salmon; no UK number allocated) and Organic Trust Limited (UK 9). The designation of UK 1 is reserved for operators who are directly certified by UKROFS itself because they wish to work only to the basic EU standards (accounting for just 15 enterprises at the present time).[99] The private inspection or sector bodies are responsible for ensuring that those registering with them are acting in accordance with the prescribed standards of that body, whilst UKROFS is responsible for ensuring that the private sector bodies are competent and fulfilling their certification and inspection procedures to the required level.

43. A number of issues were raised with us during the course of this inquiry as to the nature of the regulatory system for standards and certification, both as applied in the UK and on a more general EU-wide level. On certification, comments focussed mainly on the number of certification bodies and the comparison between organic certification schemes and farm assurance. In this section of the Report, we therefore deal with these issues first. However, we recognise that both concerns are closely linked to questions about standards, particularly the difference between standards adopted by the various sector bodies in the UK and in other Member States and elsewhere, so we discuss this question, followed by an examination of the advantages and disadvantages of a single international standard. Finally, we look briefly at the role of UKROFS.

The number of certification bodies

44. As we have seen, including UKROFS itself, there are currently nine certification bodies in the UK, each entitled to use its own logo on organic produce. The certification bodies are responsible for inspecting those producers, processors and importers licensed by them to ensure that correct standards and procedures are being followed. There can be no doubt that the certification bodies have so far done an impressive job in regulating the industry and in promoting both organic products and the organic philosophy. The Soil Association pointed out that the certification bodies "provide a highly cost efficient mechanism for control of this sector which would otherwise have to be undertaken by MAFF or its designated agents at much greater cost."[100] MAFF recognises this role in the form of an annual grant which is currently under review.[101] The number of such bodies results from the history of the movement, with the dominant player, the Soil Association, operating to more stringent standards than its counterparts who offer their members the basic UKROFS standards, and the Bio-Dynamic Agricultural Association at the pure end of the organic spectrum, relying as it does upon very natural methods

of farming, with small scale production and an affinity with the Steiner philosophical approach.[102]

45. The multiplicity of certification bodies has not caused a problem in the past but we found general agreement that it could become a hindrance to the development of the organic sector. UKROFS was the only dissenter from the view that the different organisations - "the plethora of organic accreditation agencies", as one witness described it[103] - could be confusing for customers, who could be led to question just how organic was organic, and indeed for farmers trying to choose between them.[104] This situation has worsened with the growth of the organic market, both in its extension to include consumers who have no in-depth knowledge of the issues involved, and in the pressures it places on the certifiers. We heard of at least two cases where importers or processors had become frustrated by the delay in gaining approval from one certification body and had turned to another instead.[105] This causes difficulties throughout the chain right up to the customer who may be used to purchasing products with a particular logo, and we were warned that the situation was likely to get worse as "more bodies are trying to muscle in or come in to take advantage of the business opportunities".[106] In short, the structures applying to a "cottage industry" might not be so acceptable in a mass market.

46. In some countries, a solution to this problem has been found in authorising a single certification body; for example, in Denmark and Holland.[107] In Ireland, all organic enterprises are certified by the competent authority directly. By contrast, in Germany the sector is even more fragmented. It is clear that it is much more efficient to have larger organisations which can absorb the sudden increase in demand for certification (and operate a single database, rather than eight separate ones[108]) and that it would be much simpler for the farmer, food industry and the consumer, if there were fewer bodies. In the past, this would have been extremely difficult to achieve because of the different standards operated by the various bodies in the livestock sector, but the introduction of the EU regulation on livestock with a common minimum standard has brought the standards imposed by the bodies into greater alignment. The certification bodies to whom we spoke were themselves in favour of "fewer certifiers working more closely together"[109] or even "coalescing certification bodies into a neutral UK-Organic-Certification-Limited type body"[110], always with the proviso that within this arrangement there would be room for opting to operate to higher standards and to differentiate foodstuffs produced in this way. There was little support for bringing the certification and inspection of organic enterprises under direct UKROFS control and in any case, we see no need for such a step. We recognise that the EU regulation obliges UKROFS to register any new body which meets the requirements and that it would not be possible to prevent the formation of a new certification body. The multiplicity of bodies with their different standards and symbols is a significant weakness and we believe that the certification bodies should be encouraged by the Government in their efforts at closer co-operation, which may lead ultimately to mergers.

Organic certification and farm assurance schemes

47. Another area in which we believe that there is room for consolidation and simplification is the cross-over between organic certification and farm assurance schemes which are also proliferating in the UK. We recognise that organic standards and schemes "represent some of the first and best developed farm assurance schemes".[111] However, the expansion of other schemes in conventional farming, and in particular, the efforts made to rationalise these schemes to encourage consumer awareness and trust and to reduce the burden of both time and money on farmers, has led to questions over whether there is a need for the two systems to operate in such isolation. There are clear advantages for both sectors if inspectors were authorised to verify both organic and conventional schemes. For farmers, particularly those in conversion, it would remove the need for duplicate inspections; for the administrators of the scheme it could reduce costs; and for the organic sector as a whole it would meet the objections of those who point out that while farm assurance schemes have independent verifiers, the organic certification bodies both set the rules and carry out the inspections.[112]

48. We were encouraged to hear that moves are taking place to take matters forward in this way. The MLC wrote of discussions "on adding bolt-on modules to existing implementation protocols",[113] whilst the Soil Association was looking to a future ideal of "a one-stop shop for farmers and one symbol that the consumer is going to have to take notice of".[114] We recognise that much work would need to be done on the standards for any joint scheme: at the moment, the two sectors have different priorities and cover different issues, as well as having different standards where their coverage converges. It should, however, be possible to work towards the adoption of core values, perhaps even including the environmental objectives proposed by conservation groups.[115] This might be achieved by setting a quality standard along the lines of ISO 2000 which could be met by different but equivalent production methods. In the short term, it may be necessary to concentrate on closer co-operation and inspections, both on farm and beyond the farm gate. Given the goodwill expressed to us by the Soil Association, we believe there is potential to bring the two sides together to great benefit. We recommend that MAFF facilitate discussions between the farm assurance schemes and the organic certification sector with a view to ensuring agreement on common core values and inspection protocols and with the goal of a single inspection process and shared symbols.

Setting standards

49. The problem of confusion for consumers and others is greater where different certification bodies operate to different standards. As we have seen, the basic standards are those set out in the EU Regulation which apply across Europe with some flexibility to allow for local conditions. UKROFS told us that the regime prescribed in the Regulation "was based largely on practices which were in place at the time the standard was drawn up throughout Europe", making it "an embodiment of traditional practice more than anything else".[116] To this extent, there is some justification in the complaint that the standards have no proven scientific basis. UKROFS itself is able to add to the basic regulations in setting standards for the UK as a whole, although it is legally obliged to register anyone who conforms to the EC regulation, and beyond that, the certification bodies are free to establish their own regimes. Increasingly, it seems that the certification bodies are taking on more of the work of standard setting. The Soil Association has a committee system to develop standards and is adamant that it should retain the ability to set its own standards for organic production in order to allow them "to evolve, as the organic market develops, as advances in technology emerge and as our understanding increases".[117] The other certification bodies, with the exception of the Bio-Dynamic Association, tend to follow the UKROFS standards and act merely as certifiers and inspectors.

50. Two issues were repeatedly raised in evidence to us about standards for organic production. The first was that the standards themselves were non-scientific, arbitrary and illogical.[118] Various examples were given, including the grazing of non-organic stock in cider orchards (where the grazing limit of 120 days is divided between the number of organic orchards on a holding; ie. with two, it is 60 days and with three, 40), allowable inputs in horticulture (where the active ingredients are the same in chemical and organic treatments, but the latter are applied in less easily regulated amounts) and the withdrawal periods for antibiotics in livestock, which are double the safety margin already built into the UK regulatory system for conventional agriculture.[119] There was also a feeling that the standards were moving away from practical experience towards ideology.[120] To some extent, the Soil Association did not contest the charge that its standards lacked scientific rigour. The Director explained that the development criteria included "evidence-based and non-evidence-based elements", the latter being "gut feeling, intuition, ethical considerations, and consumer attitudes".[121] This raises questions about the need to establish a scientific basis for organic agriculture to which we return later in this Report.

51. The second issue raised was the charge that the UK certification bodies were "gold-plating" the regulations, with the result that the standards required of UK producers were higher than those elsewhere in Europe or third countries.[122] For instance, conversion periods are longer and certain pesticides may be used elsewhere but not in the UK.[123] This has obvious implications for competitiveness in that producers will have higher costs and, it is claimed, may discourage companies from investing in the UK.[124] Closely linked to the perception that the UK was over-implementing the regulation is the belief that products from other countries may not be reaching the basic standards at all, because of inadequate supervision of imports.[125] Several witnesses were concerned that this could lead to loss of consumer confidence and a decline in the market for organic products.[126] It is difficult to address this concern when the different standards used in producing "organic" products make meaningful international comparisons hard to achieve.

52. It is true that within the EU standards do vary, as the regulation permits derogations and can be adapted to meet local conditions such as climate and soil type.[127] It is, however, not the case that the UK is generally applying a more rigorous regime than that in other countries. Dr Lampkin thought "the UK is in the middle position" since "in some respects other countries have higher standards and in some respects we have higher standards".[128] He named Denmark as a country with particularly high standards.[129] Dr Lampkin also dismissed suggestions that the standards were policed less well in other EU states than in the UK, arguing that "most countries now have pretty good systems in place to ensure the EU regulations are interpreted effectively and there is a fairly consistent approach across the European Union".[130] The Minister supported this view with the argument that countries such as Sweden, Austria, Holland and Denmark were "very proud of the way they apply" standards on organic production.[131] He also emphasised the role of the European Commission in checking that the regulations were correctly implemented.[132] There is a committee set up under article 14 of the regulation for this purpose. We believe that it would be of great benefit if more information were gathered and made publically available on what was happening in other Member States. UKROFS agreed that "it would be helpful if UKROFS more proactively sought information about the implementation of standards in other Member States" but insisted that it lacked the money to do so.[133] We recommend that the Government ensure that the European Commission reports regularly on the implementation of the regulation and actively encourage the European Parliament to monitor this implementation. The Government should produce a "Non Paper" for distribution at the Agriculture Council to further this end. We further recommend that MAFF be pro-active in drafting EU regulations and ensuring their scientific validity before they are written into law. MAFF should also, either directly or through UKROFS or the FSA, seek to monitor the effect of regulations to ensure that other public policy objectives are not compromised.

53. With regard to imports from third country suppliers, there is even less general knowledge and information available about the standards applied in production. Although we have heard evidence from companies who have gone to great lengths to guarantee the integrity of their supplies - for example, Sainsbury's organic pineapples and Yeo Valley Organic Company's arrangements with the Soil Association to check fruit from South America[134] - doubts and suspicions are still strong among UK producers.[135] The Soil Association agreed that the mechanisms for establishing equivalence of standards and certification procedures in third countries were "not very thorough".[136] This is clearly a matter of some concern, particularly as it is generally impossible to detect differences between products produced organically and those produced conventionally through tests carried out by trading standards officers. Unless these discrepancies are removed, there is a real danger that confidence in organic food may be damaged.

A single organic standard

54. The obvious solution to the difference in standards applied by the various bodies in the UK as well as in the rest of Europe and the world would be a single international standard to which all countries would be expected to adhere in order for products to be labelled organic. This has the advantage of simplicity, at least as a concept. It would end consumer confusion and reduce what the Provision Trade Federation described as "tensions between national producers and importers, each claiming that they are suffering a competitive disadvantage because they have to meet stricter standards."[137] There is also a standard ready to be adopted in the form of that developed by IFOAM (the International Federation of Organic Agricultural Movements). Fifteen major international certifiers including the Soil Association are currently accredited to the IFOAM Basic Standard[138] and three of our witnesses strongly supported its adoption.[139] The most cogent argument was that IFOAM met the criteria of a single standard: "it is a clear standard, it is understood by everybody and it is policed and audited to make sure it is followed through".[140] A further consideration was IFOAM's independence.[141] An alternative would be adopting the EC standards worldwide, perhaps redesignating them as obligatory standards rather than minimum ones.[142]

55. The battle between the proponents of high IFOAM standards and lower EU ones is not the only issue which would have to be decided in adopting a single standard within the UK, EU or the world marketplace. There is also the need for flexibility in that whatever standard were agreed, it would have to allow for adaptation to different geographical and climatic conditions if it were not to be seen as a unfair barrier to the development of the market. For example, requirements set down for livestock production in Denmark might not be suitable for farming in the Highlands of Scotland. A single standard would also have to allow for amendment and adaptation as more became known about organic farming or new products or techniques were developed. This might be difficult if it required agreement by many different interest groups. It must also be recognised that higher or alternative standards are a marketing tool. There will always be groups of producers willing to strive for higher and more demanding standards if this differentiates their products and guarantees them a market. We note too that with a single standard, the certification bodies would lose their responsibility for standard-setting, leaving them as mere checkers of compliance with the IFOAM or EU rules.[143] The Soil Association supported the IFOAM accreditation programme as one "designed to create a level playing field of standards and certification competence globally"[144] but believed that the loss of its own standards development function would "solve the problem of consumer confusion but it would also stifle the ability of the organic standards [bodies] to be involved."[145]

56. We agree with HRI that "There is an urgent need for a clear, defined understanding and pronouncement to producers, marketers and consumers of what constitutes 'organic produce', both to a realistic UK national standard, and for acceptance of organic food produced overseas and imported."[146] We believe that IFOAM accreditation has much to offer in gaining acceptance for the standards met by imports from third countries and that the Government should support its widespread adoption. However, on balance, we would not support the imposition of a single fixed standard upon the organic sector. The Soil Association told us of its plans to work with the other sector bodies in standards development,[147] which together with the new EC livestock regulations, should see a convergence of standards within the UK. Standards emerging from this new model would have to be endorsed by UKROFS, which would be responsible for ensuring that the standards were not so high as to undercut the competitiveness of the UK industry. The Government would also have a role in ensuring that the standard-setting procedure was properly resourced. The key to any standard - whether single or part of a whole range - is effective and uniform enforcement. Given the experience with the differential enforcement of EU rules, it is difficult to assume with confidence that a single international standard would, in practice, lead to a uniform quality of product. We recommend that the Government endorse the involvement of the certification bodies in setting standards, with UKROFS acting as a check and balance in the system, and that the Government provide sufficient funding to ensure the rigour of standard-setting procedures.

EU livestock standards

57. The new European rules for organic livestock production are a good example of the problems which may emerge when trying to set standards across the EU. The rules, adopted in August 1999 and coming into force in August 2000, allow temporary derogations in some areas as well as permitting Member States to apply stricter standards to their own producers. After consultation, UKROFS adopted the EU standards with only three significant variations. These are that the UK standards maintain the requirement that meat animals to be sold as organic (except chicks) must be born and bred on an organic unit, and not brought in as conventional and converted; maintain specific UK standards in respect of BSE; and provide a derogation shorter than permitted for poultry producers to meet the flock sizes and stocking densities prescribed and limit the producers able to benefit from the derogation.[148] Concerns brought to our attention over the livestock regulations focussed both on these differences and on the EU regulations as a whole.

58. To look first at the broader picture, we received many representations, particularly from scientists and vets, that the regulations might have a negative impact on animal health in their restrictions on the use of allopathic remedies and antibiotics. This could have a significant effect on the number of organic farmers in the UK because potential recruits might feel that they are unable to comply with the regulations.[149] Particular problems arise with the treatment of parasites and sheep scab.[150] Both the Scottish Agricultural College and the NFU believed that the rules did not allow sufficiently for differences in geography, climate and farming practices across Europe.[151] The British Cattle Veterinary Association and others also raised questions about the efficacy and safety of homeopathic medicines which are allowed under the regulations.[152] UKROFS offered assurance that these fears are misplaced and affirmed that "there is sufficient flexibility to allow the standards to be operated effectively under most UK conditions".[153] It believed that the provisions of the regulations were "sufficient in most cases to ensure the health and welfare of organic stock".[154] It is notable that their assurances were qualified in both cases. This is unsatisfactory.

59. Turning to the regulations as operated differently in the UK, there are concerns, particularly within the poultry industry, that the decision to restrict the derogation to five years will be harmful in terms of competitiveness.[155] On the other hand, animal welfare groups, such as the RSPCA and CIWF, argued that the regulations did not go far enough.[156] UKROFS assured us that it had considered the competitiveness implications of the derogation agreed but had "concluded that the balance of advantage lay in a derogation which ... would encourage the industry to move relatively quickly to the standard set out in the Regulation."[157] The difficulty is that imports from EU competitors which do not meet these standards are perfectly legal and leave UK producers with higher costs competing against products produced to lower standards.

60. Most witnesses agreed that the EU livestock regulations are "moving in the right direction"[158] and that welfare problems were potential rather than inevitable as a result. However, it is clear that the impact of the standards will have to be closely monitored. When asked about this, UKROFS could not respond further than to offer the assurance that it "will be putting in place arrangements to monitor the effect of the standards by means of close consultation with the industry".[159] We find this unsatisfactory and we are concerned by the lack of resources within UKROFS to conduct the necessary research into either animal welfare or the competitiveness impact of the regulations. We recommend that the Government ensure that the impact of the EU livestock regulations upon animal welfare and upon the competitiveness of the UK industry be monitored over the next decade with a view to recommending changes if necessary. We further recommend that UKROFS be charged to take into account the competitiveness implications of any proposed regulations and to publish the results of its analysis before agreeing on any changes to organic standards. One other lesson to be drawn from the development of the organic livestock rules is that organic farming is not necessarily synonymous with the highest animal welfare standards. We do not dispute that organic farmers want to adopt welfare-friendly production standards but it is clear that this is another area in which more research is needed.

Processing standards

61. The EU livestock standards closed a significant gap in the European regulations for organic production but witnesses agreed that there remained much work to be done in the processing industry. At the moment, there are difficulties over the number of non-organic processing aids and additives allowed under the regulation.[160] There are also questions over the adequacy of the rules set down for complex processing, specifically where a plant makes both organic and conventional foods using a continuous process.[161] The experience of one organic sugar processor had led him to conclude that "the Commission and UKROFS have given processors an easier ride than farmers" by "adding to the list of approved processing aids and additives to help food manufacturers to get round their processing problems".[162]

62. These difficulties are likely to become more acute as more conventional manufacturers start to produce organic sidelines. Processing is clearly an area which will have to dealt with by the Commission in the same sort of comprehensive reform as in the livestock sector. However, MAFF had been given to understand that the Commission had "no immediate plans to draw up proposals in this area" and had too much work arising from the livestock standards to be able to take on any other matters.[163] In the absence of EU standards, it is possible to take independent initiatives, such as supermarkets working with suppliers to reformulate ingredients[164] or insisting on labelling to ensure that consumers are aware of the non-organic ingredients permitted in organic foodstuffs.[165] However, for the sake of consumer confidence, it is essential that the rules on processing are clarified and, given the boom in production of processed organic foods, the need is becoming ever more pressing. The Government should not allow the Commission to fall behind developments in this way. We recommend that the Government work in the Council of Ministers to present the Commission with a deadline by which to develop new standards for organic processing.

The role of UKROFS

63. At the very end of our inquiry MAFF announced that UKROFS was to undergo its quinquennial review. The first stage of the review, to be completed within six to seven months, will look at the effectiveness of the current arrangements for discharging the national competent authority functions prescribed by the EU organic farming regulations and the continuing need for the discretionary functions currently exercised by UKROFS, including standards setting, direct certification of producers and advice to Ministers.[166] We have heard several points raised about the conduct and role of UKROFS which should be brought to the attention of the inquiry.

64. In the first place, many witnesses complained about the delays experienced both in clearing imports and in registering organic farms.[167] In some cases, these had involved perishable products.[168] This situation held back the development of the market and caused huge frustration to both farmers and the food industry.[169] UKROFS defended itself by pointing out that delays were not always "a one-sided problem" but accepted that difficulties arose because of the lack of money available to it.[170] All witnesses agreed that UKROFS was under-resourced in terms of staff and funding, particularly in view of the rapid expansion of the organic market. The present Chairman admitted that when he took up his post he was "appalled at the level of resourcing and the pressure which was put both on the civil service secretariat and upon the board members of UKROFS by the sheer size of the workload".[171] This will have to be resolved. However, there was less universal sympathy expressed with the performance of UKROFS in general. One witness told us that UKROFS "just seems to be a body that is sitting there and doing not a lot at the moment"[172], whilst others complained about its "total lack of commercial thought".[173] Even the Soil Association argued that "the standard setting committee did not have the capacity or the expertise to do the job that needed to be done in the development of standards".[174]

65. It is evident that this is a particularly appropriate time to be examining the role and performance of UKROFS. Its work has been affected by the adoption of the EU livestock standards and is further threatened by the increasing pressure for it to become merely the rubber stamp of standards agreed by the certification bodies. On another front, the United Kingdom Accreditation Service (UKAS) is making bold moves to take over its accreditation role.[175] UKROFS put up no defence when asked why this should not be permitted.[176] These changes could leave UKROFS with only its role of inspecting imports, which could be done just as efficiently by a dedicated organisation outside the current structure. We recognise that many of the complaints we have heard about the certification procedures and standards are directed at the entire regulatory process run by UKROFS. We accept that at the moment UKROFS is not getting the support it needs from MAFF in terms of staff or funding. Nevertheless, we believe that there is scope for a complete reconsideration of its role. There is room for it to acquire a higher profile, as was hinted at by the current Chairman's intervention in the GM debate, and to perform a valuable role as the regulator between the certification bodies and the Government, but it is clearly not fulfilling that potential at the moment. We await the results of the review with great interest.

96  Ev. p. 132, para 11. Back

97  Ev. pp. 135-6, paras 33-5. Back

98  Ev. p. 122, para 3. Back

99  Ev. p. 124, annex B; Ev. p. 123, para 7. Back

100  Ev. p. 101, section 3.4. Back

101  IbidBack

102  Q 502; Ev. p. 181. Back

103  Ev. p. 186, para 21. Back

104  UKROFS Q 557; eg. Ev. p. 180, Ev. p. 18, para 13; Q 396.  Back

105  Ev. p. 208, paras 10-11; Ev. p. 78. Back

106  Q 502. Back

107  Q 502. Back

108  Q 502. Back

109  Q 504. Back

110  Q 502. Back

111  Ev. p. 19, para 16 Back

112  Ev. p. 171, para 5.5. Back

113  Ev. p. 236, para 28. Back

114  Q 503. Back

115  Ev. p. 227, para 4.4. Back

116  Q 564. Back

117  Ev. p 101, section 3.3. Back

118  Ev. p. 154. Back

119  Ev. pp. 182-3; Ev. p. 185, para 9; Q 87. Back

120  Ev. p. 95. Back

121  Q 519. Back

122  eg Ev. p. 210, section 3; Ev. p. 96. Back

123  Ev. p. 247; Ev. p. 169; Ev. pp. 187-8, paras 34-5. Back

124  Ev. p. 210, section 3. Back

125  eg Ev. p. 154. Back

126  Ev. p. 236, para 31; Ev. p. 152. Back

127  Ev. p. 51, section 5. Back

128  Q 151. Back

129  Q 151. Back

130  Q 151. Back

131  Q 697. Back

132  Q 697. Back

133  Q 555. Back

134  Ev. p. 75, para 5.10; Q 389. Back

135  Ev. p. 32. Back

136  Q 527. Back

137  Ev. p. 208, para 8. Back

138  Ev. p. 73, para 4.3. Back

139  Q 390; Q392; Q 442. Back

140  Q 442. Back

141  Q 443. Back

142  Ev. p. 208, para 9. Back

143  Q 390. Back

144  Q 527. Back

145  Q 513. Back

146  Ev. p. 185, para 15. Back

147  Ev. p. 101. Back

148  Ev. p. 123, para 11. Back

149  Q 64. Back

150  Q 79. Back

151  Ev. p. 11; Q 63; Q 237. Back

152  Ev. p. 192, para 6. Back

153  Ev. p. 252, para 1.5. Back

154  Ibid, para 1.6. Back

155  Ev. pp. 238-9. Back

156  Ev. p. 244; Ev. p. 246. Back

157  Ev. p. 252, para 3.1. Back

158  Q 89. Back

159  Ev. p. 253, para 4.1. Back

160  Ev. p. 156, para 10. Back

161  Ev. p. 156, para 8. Back

162  Ibid, para 14. Back

163  Ev. p. 151. Back

164  Ev. p. 74, para 4.7. Back

165  Q 521. Back

166  MAFF News Release 384/00, 1 November 2000. Back

167  e.g. Q 130. Back

168  IbidBack

169  Ev. p. 32; Ev. p. 78, section 5.5. Back

170  Q 586. Back

171  Q 547. Back

172  Q 397. Back

173  Ev. p. 95. Back

174  Q 510. Back

175  Ev. pp. 242-3. Back

176  Q 561. Back

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