Select Committee on Agriculture Appendices to the Minutes of Evidence


Memorandum submitted by the Crop Protection Association (F 14)


  1.1  The Crop Protection Association (formerly the British Agrochemicals Association) is the United Kingdom trade body representing those companies engaged in the manufacture, formulation and distribution of crop protection products for agriculture, forestry, horticulture, gardening, industrial, amenity and Local Authority uses. The Association's members account for more than 95 per cent of sales in the UK crop protection market at manufacturer level and approximately 80 per cent of the market at distributor level.

  1.2  The Association is an active member of the European Crop Protection Association that represents the industry within the European Union and the Global Crop Protection Federation that has a similar role world-wide.

  1.3  As the voice of the crop protection industry within Great Britain, the Association's aims and objectives are in line with the Government's policy of optimising the use of crop protection chemicals for the effective control of pests whilst protecting food, human health and the environment.

  1.4  The crop protection sector is a dynamic part of the UK chemicals industry and has close connections with the pharmaceuticals and fine chemicals sectors. Member companies had total sales in 1998 of £480 million and significantly contributed to foreign earnings with export sales of £1,096 million. Member companies employ a total of 8,000 staff. The crop protection sector is innovative and has always been at the forefront of technical developments. It maintains a close and vibrant relationship with Universities and other research institutes both in the UK and abroad.


  2.1  Organic farming has been described as, "an approach to agriculture where the aim is to create integrated, humane, environmentally and economically sustainable agricultural production systems with maximum reliance placed on locally or farmed derived renewable resources and the management of self regulating ecological and biological processes and interactions in order to provide acceptable levels of crops, livestock and human nutrition, protection from pests and diseases, and an appropriate return to the human and other resources applied. Reliance on external inputs whether chemical or organic is reduced as far as possible."

  Contrary to the popular layman definition, organic farming is not simply farming without the use of pesticide and fertilisers.

  2.2  Organic production and marketing is a growing reality all over the world. Within the EU, likely demand for organic products far exceed supply even though the amount of land farmed organically across the region has grown by about a third since 1995. Within the UK, organic farming made a noticeable expansion in the mid 1990's and has continued to increase at a rate of about 25 per cent per anum since then. This expansion of organic production may be attributed to a broad range of factors.

  2.3  Over the past 15 years the organic movement has promoted its philosophy and its products with enthusiasm and with great commitment. To create its niche in the market, it attacked pesticides, fertilisers and conventional farming with varying levels of misinformation. So far it has made relatively minor inroads into conventional farming but it has got much coverage in the media, is being actively promoted by the major supermarkets and is gaining increasing political influence, especially since the onset of the BSE scare. Gardeners, too, have progressively adopted organic methods.

  2.4  Organic "evangelists" often state that their way of farming is the only one which produces safe food, looks after the environment properly and is ultimately sustainable. The public accept these statements at face value but most agriculturists know they are flawed. They have a growing fear that the organic farming agenda has the potential to mislead agricultural policy-making in the European Union and in Britain to the detriment of conventional farming.

  2.5  Many of the claims that organic produce is healthier, tastes better or is better for the environment are based on personal views or "feelings". Contrary to the claims of the Soil Association little scientific or objective evidence exists to support these claims. Organic farming principles may well have positive effects on people, the environment and livestock but such benefits are almost impossible to quantify. In many cases, the philosophy is not yet matched by current knowledge.


  3.1  The levels of organic premia vary between commodities, which may be a reflection of the balance between supply and demand for the product. Cereals and vegetables are typically marketed at 50-60 per cent premium over the conventional equivalents.

  3.2  Consumer demand for organic products continues to rise. This drive towards consuming more and more organic foods is largely in response to concerns about the safety of conventionally produced foods. The number of high profile food scares over recent years has caused many consumers to lose confidence in the food supply chain. Their search for alternatives has led many consumers to turn to organic foods, which they perceive to be safer and healthier. Active campaigns from the food media have established concerns amongst consumers that influence their demand for organic produce. These include; concerns about genetic modification technology, pesticide residues in food products, use of antibiotics and general animal welfare issues. Environment issues are of increasing importance and some consumers are now choosing to purchase organic foods as a way registering their positive support.

  3.3  Much of this trend is connected with media interest and a strong marketing initiative by elements of the organic movement. Virtually all of the public concerns about GMOs have been antagonised by speculative comments from the organic movement that appear to have little foundation in scientific reality.

  3.4  The increasing profile of organics in the media, supermarkets and other consumer-focused events has helped too to raise awareness and thus influence demand. Also, most importantly, a gradual decrease in retail price premia either deliberately set by retailers or as a result of increases in available volumes, have meant that more main stream consumers are able to afford to purchase organic products.

  3.5  Overall, the future development of organic production and consumers demand seems set to continue to rise. Speculation about the final market share that the organic sector will capture is not easy but some estimates suggest that it is unlikely to rise above 12 per cent of total consumption. It is evident that organic production will remain a minority part of the market for the foreseeable future. An important constraint on the development of the sector is the difficulty of ensuring efficient marketing that meets consumers' expectations. Consumers are very demanding both in terms of the range and presentation of food products and of year round availability. It is unlikely that the majority of UK consumers will wish to support the aims of the organic movement by purchasing produce at high premia. The core support for organic production remains within the urban middle ranking socio-economic groupings.


  4.1  In the UK the United Kingdom Register of Organic Food Standards (UKROFS) is the body that has been appointed by UK agricultural ministers to carry out the function of organic certification. UKROFS also licence and supervise private organic certification organisations that carry out farm inspections and certifications.

  4.2  There are seven approved organic certification bodies operating in the UK. They all operate privately but are all subject to inspections to ensure that their systems and the standard of their inspections conform to the EC Regulation.

  4.3  Organic Certification organisations have played a very important role in the development of the organic sector. They have been very effective in defining standards for production, processing and direct marketing. In addition, they have helped to raise consumers' awareness and confidence in organic foods and in so doing contributed to the overall development of the market.

  4.4  Our Association is concerned that although the UKROFS licensed certification organisations are basically similar in their interpretation and implementation of the UKROFS standards there is still a significant variation. We would prefer to see a single UK organic standard being implemented by all the certification bodies. Also, we feel that all the bodies should adopt the UKROFS standard, which is the UK interpretation of the EU Regulation.

  4.5  Variations occur in standards between EU member states, and this causes producers and consumers great concerns. We believe that many of the imported products, even those from approved third countries, are not produced to the same rigorous standards that apply in the UK.


  5.1  Farm Assurance has been developed by conventional farming to provide a system to ensure that customers and final consumers have confidence in British farm products. Farm assurance schemes were set up in each sector, in response to consumers' concerns about specific issues related to the safety of UK farm products. This is following a number of high profile food safety cases (eg BSE and Salmonella in eggs), that have had the effect of diminishing consumers' confidence in the integrity of producers' on-farm activities.

  5.2  Farm assurance schemes require conventional producers to demonstrate that products are produced, handled, stored and delivered in a manner that complies with all legal and voluntary codes of good practice. The standards are established by industry-wide representative groups in each commodity sector and cover issues related to food safety, product traceability, pesticide residue in produce, use of antibiotics, storage, transportation, animal welfare as well as a response to environmental concerns.

  5.3  Though the schemes are designed and implemented by industry groups in each sector, they operate as totally voluntary schemes and producers therefore make their own decisions about whether or not to join. The number of producers that are registered with the various schemes however, is relatively high because many retailers and customers have tended to make scheme membership a condition of supply.

  5.4  Our Association has had a strong role in such schemes and believes that they have done much to increase confidence in UK food produced by conventional farming techniques.

  5.5  Although farm assurance schemes and those for organic production have similar objectives to achieve high food safety standards, product traceability, high animal welfare, and response to environmental concerns there is one important difference. This is that farm assurance schemes have independent verifiers to check producers' compliance with scheme standards whereas organic farms are not inspected by independent bodies. We believe that this system is not entirely fair to the consumer and creates a wrong impression of the standards between the two systems of production. We would support an independent verification body such as CHECKMATE that operates for many of the conventional Assurance schemes.


  6.1  Organic farming increasingly being accepted by producers and policy makers as a viable form of production and the uptake in conversion has increased dramatically over recent years. Growth of the sector has been estimated at 20 per cent increase per annum since 1996.

  6.2  The increase in organic production has partly been achieved as a result of the EU application of policies to support organic conversion and farming as part of the agri-environment programme, EC Regulation 2078/92. This Regulation was implemented in 1993 and provided the financial basis on which to support conversion. Other EU policy measures have supported organic farmers.

  6.3  In 1998 a second programme of assistance to organic farmers was introduced in the UK. It was called the Organic Farming Scheme (OFS) and offered grants of up to £450/ha, ie twice that paid under the previous scheme. Consequently, there was a rapid increase in the uptake of the grant with the resulting expansion of the UK organic supply base. Unfortunately, after only four months of operation, the scheme ran out of funds and was closed for a review and consultation with the organic sector. The objective of the MAFF review is to identify a more effective means of administering the limited financial resources available to support conversion. We understand that the scheme is expected to be reopened in April 2001.

  6.4  Now that organic production has established itself as a viable method of fulfilling a niche market we believe that the Government must carefully consider what level of intervention it wishes to introduce. High levels of support could distort the market, cause over supply and result in new entrants leaving the sector once prices for organic and conventional produce equilibrate. The question is whether Government should exert this type of influence that it does not seek in some other agricultural sectors. Farmers are opportunities and will seek new markets if these are financially viable either due to Government support or true market returns.


  7.1  We would stress that if farmers are unable to make an adequate return on capital—both working and fixed capital—then they will be most unlikely to continue farming organically. The most common barrier to entry into the market is fear of oversupply.

  7.2  We believe that a balance must be struck between conventional and organic farming. Interference with market forces by distorting the requirement for organic produce could affect UK agriculture as a whole and may also affect individual farming businesses.

  7.3  In the majority of cases organic produce is more expensive than conventional produce. For this reason the market will be limited to a minority of the UK market who believe the often-erroneous claims about organic produce.

  7.4  There is bound to be some element of retail premium for most organic products and this is often attributed to a payment for the perceived benefits of organic production. Similar benefits are attached to the majority of UK farmers who produce using Integrated Farming Management (IFM) techniques. We believe that consumers are often misled into believing that they are providing significant and tangible support to environmental systems rather than supporting the deeply held philosophical beliefs of a small sector of the farming community.

  7.5  The Government clearly needs to be aware of the demand profiles and determine whether the UK is prepared to invest in home production or continue our dependence on imports for this niche market. For either option we need to ensure that the standards of organic production and/or processing are equivalent to those expected of conventional producers and processors. We must not have dual standards and thus unmatchable competition.

  7.6  General figures indicate that up to 70 per cent of all organic foods sold in the UK is imported. The Soil Association's Food and Farming Report 1999, suggests that for the fruits and vegetables sector, as much as 80 per cent is imported, and for cereals the amount is 70 per cent.


  8.1  Contrary to public beliefs, a range of crop protection and other materials is permitted within organic farming systems. Although limited in number some of these materials are applied to organic crops on a number of occasions each season. Organic growers make much use of physical, mechanical and cultural methods of controlling weeds, diseases and pests of their crops. However, conventional farmers also use these techniques as part of an Integrated Crop Management (ICM) systems. Such systems are, to a greater or lesser extent, used by the majority of conventional farmers.

  8.2  The Control of Pesticides Regulations (COPR 1986) implement Part III of the Food and Environment Protection Act (FEPA 1985) and this applies to all pesticides in the UK. The Plant Protection Products Regulations (PPPR 1995) were made under the European Communities Act 1992 to implement Council Directive 91/414/EEC concerning the placing of plant protection products on the market. Other regulations contain provisions to allow a control and enforcement regime to be applied to plant protection products and thus to give consistent controls on the use of crop protection products. There are also a number of voluntary and statutory codes of practice, which control the supply, storage and use of crop protection chemicals in the UK.

  8.3  The "organic" pesticides are subject to the same influences of Directive 91/414EEC as conventional crop protection products. However, the majority of the "organic" materials are "old" having entered the market many years ago. Materials such as copper sulphate and sulphur will be reviewed under the existing EU programme but this is unlikely to occur for the next few years. In the case of copper sulphate, little information is available concerning the direct and indirect ecological effects of the material or of the residue levels routinely found on organic produce.

  8.4  It is our view that all crop protection materials used within organic farming systems must be subjected to the same rigours of the registration process as "conventional" products. We must stress that our member companies also sell and develop materials for the biological control and organic markets. However, the size of the organic market and the cost of submission to the regulatory process severely limits the numbers of the new products coming forward.


  Currently, there are no commercial GM crops grown in the UK. A number of farm-scale trials are being undertaken at sites throughout the country. Information derived from these trials will be extremely important in providing scientific evidence to understand the potential environmental issues.

  The Soil Association has said that it is firmly opposed to the development of GM technology as a matter of principle. On this basis they would appear to have pre-judged the evidence from the field scale evaluations.

  Discussions between the Government, the farming industry and others has led to the production of the SCIMAC Code of Practice which set standards for further investigations into this new technology. The main issue for organic farming appears to be the separation distances between GM crops and organic crops. Organic farmers argue that the risk of cross-pollination from GM crops could undermine the organic status of the crops in question. They are using this argument to press for the extension of separation distances to six miles. This approach seems quite inconsistent with the current approach to addressing the risk of cross-pollination from conventional crops, where a degree of tolerance (5 per cent?) is addepted industry practice. There should be a consistent approach according to the standards already established by UKROFS.

  The Government has taken the pragmatic view that all GM crop-licensing decisions should be based on safety. Before refusing to allow a GM crop to be grown next to an organic farm, they will require evidence of a threat to human or environmental safety. There must be a clear distinction made between the recognition that pollen travels and an appreciation of the consequences of that occurrence.

  Aside from the lack of scientific evidence to support the claims of the organic movement there appears to be a more general issue at stake. Their aim seeks to create a liability for pollen drift that could find it's way into organic ingredients. This would turn the organic certification system into a content-based system rather than a process-based one. It would seem that if organic producers expect to sell a value-added product they must take responsibility for its production and marketing. Equally organic farmers need to recognise that other farmers choose to grow crops conventionally and, in the future, may also choose to grow GM crops. There has to be a sensible recognition that these different approaches to agricultural production are all equally valid and should b allowed to co-exist within reasonable and mutually acceptable bounds.


  10.1  Although the crop protection industry is not opposed to organic farming per se we believe that many of the claims from the organic movement must be treated with caution.

  10.2  We believe that if a large-scale extensification of crop production in UK is allowed to take place the nation will be less able to feed itself. The wide scale adoption of organic or very low input farming will severely and needlessly limit Britain's ability to feed itself from the land currently cultivated for crops. To sustain the present national yield of crops, large areas of currently uncultivated land (including set-aside) would have to be brought into crop production to compensate for:

    (a)  Yield reductions on each hectare averaging about 30 per cent;

    (b)  Fewer food crop opportunities in the rotation because of the need to grow fertility-building non-food crops, such as clover and field beans;

    (c )  More erratic harvests, with crop failures through pest and disease attack common;

    (d)  More frequent need for fallow crop-free to clean up fields where deep-rooted perennial weeds have taken over, such as couch grass, docks and creeping thistle.

  10.3  It is also clear that wildlife habitats would be under greater pressure. Over the past few years, conventionally managed farms have been able to concentrate production on land better suited for growing crops, allowing them to return less suitable parts of the farm to wildlife habitat and to adopt wildlife-friendly management of field margins.

  10.4  Severe restrictions on fertilisers and crop protection products will reverse these trends significantly. To maintain farm outputs, much more land will be needed leading to greater encroachment on wildlife-rich woodland, moorland, heaths and wetlands.

  10.5  We also believe that food safety will not necessarily be improved nor assured. Bacterial and fungal contamination has caused all proven outbreaks of food poisoning in the UK. This will not change; indeed, it may become worse as greater reliance is placed on the use of potentially infective animal manure's and human sewage. If these are not composted adequately there is a tangible risk from organisms such as E coli and related enteriformes.

  10.6  If organic farming is applied to a large proportion of UK production the present protection offered by chemical fungicides against potent fungal toxins, such as mycotoxins, will be lost.

  10.7  It is also clear that pollution control costs could increase. Environment Agency monitoring consistently shows that animal manures and silage effluents are the principle causes of agricultural pollution incidents. Again, increased reliance on farmyard manure could result in more incidents or more costly on-farm treatment methods. Heavy investment programmes by water service companies may be increasingly needed to avoid bacterial contamination of drinking water, another proven cause of outbreaks of illness.

  10.8  In summary, it is clear that organic production fulfils a niche market which is geographically and sociologically defined. It will never be able to replace conventional production whilst maintaining volumes of output. Care must be taken to ensure that organic production does not receive unfair treatment or financial incentives that will damage conventional farming systems or significantly distort the market place.

  10.9  Farming must remain profitable and productive. We believe that the key to maintaining a profitable, productive yet environmentally responsible agriculture is the practice of integrated Crop Management (ICM). This offers a common sense approach, which combines the tried and tested traditional methods with the sensitive and skilful use of modern technology in all activities on the farm. Farmers practising ICM are demonstrating that they can deliver profitable and productive agriculture using modern techniques and still retain a rich and diverse wildlife.

  10.10  Farmers must be able to retain all pest control options and not be constrained to certain restricted organic options. It should be noted that pest, disease and weed control is an essential part of ICM practices. Farmers must have the flexibility to choose from the widest range of control options so that they can best match an environmentally sensible solution to a particular problem.

  10.11  The crop protection industry is committed to promoting environmentally responsible use of our products within a conventional farming framework that makes use of all suitable techniques and systems.

11 June 2000

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