Robert Newbery (NFU Chief Poultry Adviser), Mark Williams (BEIC Chief Executive) and Peter Bradnock (BPC Chief Executive) sent a letter to Richard Macdonald (CO Defra, Red Tape Review Secretariat) on 3 November. The introduction of the letter is as follows:

On behalf of the NFU Poultry Board, the British Egg Industry Council, and the British Poultry Council, please find below our combined comments and suggestions for ways in which Defra can reduce the burden of 'Red Tape' in the poultry industry.

This document highlights areas where red tape and bureaucracy are impacting on the competitiveness of the poultry sector. Issues are highlighted below, and brief suggestions for solutions are given.

Red tape frustrations mainly arise from legislation and its implementation. Most legislation affecting the poultry and eggs sectors originate in Brussels. We think that UK MPs need more powers to scrutinise and raise any alarm on proposals for upcoming EU legislation at an earlier stage. The Danish Parliament example, where MPs sit down to question ministers every Friday on the agendas of the forthcoming weeks EU meetings, might usefully be examined.

Before any EU or UK proposals are progressed the appropriate competent authority must be required to carry out a proper regulatory impact assessment.

When proposals in the EU are negotiated, UK must ensure that its negotiators are those with the best level of knowledge of the subject and have sufficient negotiating experience to advance the UK interest.

In terms of implementation, certain general principles should apply. UK food business operators should not be subjected to any more onerous regulatory or other requirements than are provided for in the EU legislation. Similarly, UK should not be denied access to any derogations or provisions which are available to food business operators in other member states.

Where government activities are charged for, the company or site being charged should be able to reduce or avoid the charge by compliance with the requirements. There should be a mechanism in place to either reduce inspection frequency by demonstrating reduced risk, such as membership of a recognised assurance scheme, or to replace official inspections with those already undertaken by the private sector assurance schemes.

A further principle should be that the government department or agency should not be given a statutory charging monopoly, but the service is able to be provided by alternative providers with competing charges.

Charges should only be levied for a specific service provided and not simply as a tax to make up for shortfalls in departmental funding allocations.

A further point of principle should be that, as a result of industry’s efforts in achieving the objectives of legislation, e.g. the risk of salmonellosis in poultry flocks, the burden of legislation is reduced.

All activities performed by the public sector in implementing legislation or the provision of other services need to be regularly assessed to determine the activity is a legal imperative, whether it is still needed, and whether it can be provide by another more efficient provider, or by the industry itself under its own cost. In this respect there may be an ongoing need for a body such as this Red Tape Review group to examine new legislation from this perspective.

Further Reading

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You can view the complete letter by clicking here.