Increasing understanding and best
16. In order to produce a definitive answer to the
question of whether UK farmers are particularly disadvantaged
in the implementation of IACS it would be necessary to spend a
considerable amount of time in each of the Member States. We have
not been able to conduct such an inquiry. Nevertheless, we believe
that Mr Curry was correct to conclude that "enforcement and
the fear of disallowance led every Member State to apply the regulations
as rigorously as possible", with the result that "All
farmers in every Member State believe that their government are
over-zealous in implementing European rules".
Like the IACS Working Group, we do not believe that "a more
detailed study would have led to substantially different conclusions".
However, we do firmly believe that greater knowledge of practices
in other Member States would be valuable in two ways. First, it
would allow checks to be made on allegations or vague suppositions
that certain Member States are not playing by the rules, thus
providing hard evidence that competition was fair or alternatively
that measures should be taken to ensure such fairness and reassuring
those who feel over-burdened by the demands of the system. Second,
it would allow the identification and dissemination of best practice
throughout the EU.
17. Faith in the reliability of the information gathered
would depend largely on which body took on responsibility for
this task. Although there are existing fora for the exchange of
ideas between national officials,
we believe that the European Commission could play a much greater
role in this area. Mr Slade accepted that the Commission did have
a role as regards best practice, and he indicated that following
audit visits, letters were sent to Member States, "containing
not only observations, criticisms, recognition of good points
and encouragement, but also recommendations as to how matters
can be improved."
He also stressed that his service "sees it as an obligation
to ensure that there is fair and equal treatment to the Member
States, to the farmers across the EU."
Nevertheless, he believed that its duty to provide Member States
under investigation with a fair hearing would make it difficult
for the Commission to share the information it gathered on how
States operate IACS.
We appreciate the sensitivity of this matter but the Commission's
central position in the implementation of IACS and its checking
and monitoring procedures make it the only body which can publish
reliable information on all Member States. We recommend that
the UK Government, through the Council of Ministers, press the
Commission for the publication of regular, up to date reports
on the implementation of IACS in individual Member States. We
further recommend that the Commission be required to highlight
instances of best practice in such reports and to encourage the
adoption of such practices throughout the Union, while realising
that the central administrative role is a national matter.