AHDB submission to assurance review

[Grass And Grain]

I see AHDB have published their submission.

AHDB written submission to Farm Assurance Review commissioners | AHDB

AHDB’s submission to the commissioners leading the 2024 independent farm assurance review

ahdb.org.uk

 

[Grass And Grain]

Some salient points, and probably somewhat different to what AHDB might have said 3+ years back. Better than previous thinking. They've identified some issues, shortcomings, where improvements could be made, how the current system struggles to provide us a price premium, etc.

Slight criticism is there's not really enough in there about the assurance provided by our competent/statutory authorities, the ones who ensure our food producers/processors are providing safe food. Maybe AHDB could look at this, and give an opinion if this system provides a reasonable level of food safety. And then look at how necessary/useful private assurance schemes are in compare to this.

^^^that would seem to me, to be the starting point when looking at food assurance. They seem to have skipped this important bit, and jumped straight into assessing private food assurance schemes. e.g. there's an awful lot of lamb, beef, maize, grain, feed and other produce which is presented to the marketplace and consumer without the Red Tractor, QMS, FAWL, etc stamps of approval.

If I look at the highest premium retailers of meat for example, farm shops, butchers, delicatessens, restaurants, etc..... there's very little use of the Red Tractor logo/license, however they pretty much all proudly display their competent authority Food Hygiene Rating, and consumers trust this. So why suggest anything different for on-farm food checks? Or at least, if anyone thought butchers shops need to be RT assured to give assurance, then why haven't they highlighted this (it's the point of sale). They haven't said anything about it because we all know the consumer trusts the 1-5 Food Hygiene Rating on the shop window green sticker.

^^^Just think AHDB are missing a trick here, and should be shouting about and promoting our good/high legislative standards, and using that as a marketing tool for our produce (unless they think there's anything wrong with it, in which case they ought to say if they think there's a food safety issue). Paid for assurance schemes shouldn't be thought of as the default requirement, and I think AHDB have slightly fallen into that trap.

So I think AHDB are maybe about 75% there, but just need to extend their thinking a little bit, particularly for the issue of grain assurance as there's a free solution starring them in the face, and it'll help get a more level playing field with grain imports, and should work fine for meat, dairy, etc.

Not bad. Improved. Definitely a change in language. Room to take it a bit further.

 

[MrNoo]

Not at all convinced, I wondered at first if I was actually reading the same reply. Just waffle and not really addressing the core issues, certainly in the cereal sector. Lets just remind ourselves that they are co owners of Red Tractor. My view is that it's a limp wristed weak response but to be expected.

 

[Grass And Grain]

Not at all convinced, I wondered at first if I was actually reading the same reply. Just waffle and not really addressing the core issues, certainly in the cereal sector. Lets just remind ourselves that they are co owners of Red Tractor. My view is that it's a limp wristed weak response but to be expected.

For cereals it will come down to, will they actually do anything about it? They ought to be telling AIC and Flour Millers that they're pulling support for RT cereals as it's not necessary.

They need to show their teeth.

 

[Drillman]

AHDB could have gone a lot further, however there is no way that red tractor can achieve even a small percentage of what they have said.

Or in simple terms a few more nails in the rt coffin but with an undersized hammer!

 

[texelburger]

A few pertinent points but,by jove,what a plethora of pure waffle.
The Dairy section is interestsing when they say RT is necessary for market access. Conversely this means it denies access unless you are RT creating market restriction,something that never happened before RT was born.The same argument applies in the grain trade where non assured UK grain has no access to Mills whereas non assured,non traceable imports do.AHDB levy payers that aren't assured do not receive the support that their levy money deserves.
It's a start but nothing more.

 

[Grass And Grain]

I'm

A few pertinent points but,by jove,what a plethora of pure waffle.
The Dairy section is interestsing when they say RT is necessary for market access. Conversely this means it denies access unless you are RT creating market restriction,something that never happened before RT was born.The same argument applies in the grain trade where non assured UK grain has no access to Mills whereas non assured,non traceable imports do.AHDB levy payers that aren't assured do not receive the support that their levy money deserves.
It's a start but nothing more.

The whole submission has sort of presumed assurance is good/necessary, gives market access, etc. And as you say, it's just as reasonable to say the assurance industry has blocked market access (unless you pay the protection racket) for good British produce, yet allows non-assured imports. It's the assurance industry themselves who have done this (e.g. AIC feed mill assurance UFAS specifically does this).

Thing is, for cereals, what are AHDB going to do now? Leave it to the assurance review? Obviously they're going to wait for assurance review to publish their findings and recommendations, but then someone needs to action them.

 

[Grass And Grain]

I note the cereals section says:-

"The difference between our farm assurance versus trade assurance that dominates global markets is clearly an issue that needs addressing."

"We believe that any incremental adjustments to the current assurance structures will fail to reset divisive perceptions which have become entrenched."

 

[texelburger]

We believe that any incremental adjustments to the current assurance structures will fail to reset divisive perceptions which have become

This is,of course,clearly incorrect. A test ,similar to imports, will clearly level the playing field and reduce divisive perceptions.

 

[Grass And Grain]

This is,of course,clearly incorrect. A test ,similar to imports, will clearly level the playing field and reduce divisive perceptions.

I presumed what they were meaning was, that farmers wouldn't accept it if RT fiddle around the edges and make small changes to their scheme, take out a rule, then take out another, etc. etc.

i.e. they're saying it wouldn't address the issue, it needs a complete overhaul and fundamental change. Start from a completely blank piece of paper.

My personal opinion is that, given imports haven't any farm level assurance, they could be from ANY country, and only get the occasional lab test ....

...our legislative standards and checks are more than sufficiently robust and provide better or equivalent assurance than the imports. AHDB should liaise with mills and crushers, tell them AHDB are withdrawing support for RT (for straightforward base market access) and get them to accept our UK grain.

If mills want RT grain, then they should still accept standard UK grain, but offer a price premium for the RT assured. (Although danger of that is they create massive price gap between the two, and hence effectively won't buy non-assured, so I'm far from certain about this). (Maybe we set the RT premium at say £2/t, then the farmer has a real choice).

 

[Grass And Grain]

Would need a solution for RED renewable energy directive, but all the other countries seem to manage (and they haven't got RT or equivalent farm level assurance schemes).

 

[slackjawedyokel]

We’ve got to hope that the second review comes to some very blunt and unambiguous conclusions.

I can certainly see RT simply trying to ‘style it out’; on the one hand loudly saying “We’re changing, we’re changing”, while in reality very little changes.

Clearly it needs wholesale change, not simply playing around at the edges!

 

[Tarw Coch]

If mills want RT grain, then they should still accept standard UK grain, but offer a price premium for the RT assured. (Although danger of that is they create massive price gap between the two, and hence effectively won't buy non-assured, so I'm far from certain about this). (Maybe we set the RT premium at say £2/t, then the farmer has a real choice).

Surely there would be no reasonable excuse to pay less for non RT grain than imported grain

 

[robbie]

Having read the ahdb response I think it does make some very valid points but I'm very disappointed with the soft wooly manner in which it's been written. This is there one big opportunity to shand up to assurance on behalf of all levy payers and stamp on it hard but instead we have a statement which h falls short of that by a long way.

I suppose it's to be expected really, because as I've said before all these organisations are far to hand in glove with each other and all part of the same merry go round.
Keep everything smooth and cosy because they know thier next seat on the gravy tain could well be with one of the other organisations so don't want to upset anyone.

 

[Grass And Grain]

Surely there would be no reasonable excuse to pay less for non RT grain than imported grain

Good point. TBH, given imports aren't farm-assured, and vast majority of mills use imports, this pretty much negates any need for RT to exist at all (for cereals).

 

[Grass And Grain]

Having read the ahdb response I think it does make some very valid points but I'm very disappointed with the soft wooly manner in which it's been written. This is there one big opportunity to shand up to assurance on behalf of all levy payers and stamp on it hard but instead we have a statement which h falls short of that by a long way.

I suppose it's to be expected really, because as I've said before all these organisations are far to hand in glove with each other and all part of the same merry go round.
Keep everything smooth and cosy because they know thier next seat on the gravy tain could well be with one of the other organisations so don't want to upset anyone.

I suppose for things like meat sector, there's the reputation thing and competitor products like Borda Bia which demonstrate carbon accounting. That said, AHDB themselves are piloting studies to demonstrate our carbon emissions, and what is wrong with out laws and government inspections to demonstrate food safety.

If AHDB think we need a commercial independent assurance check over and above the legislative checks, then they must think our legislative checks are lacking. That means they think non-assured food isn't sufficiently safe to eat. That means AHDB are putting down and underselling our goods (and we've paid levy to AHDB for them to come out with this!).

Before AHDB back the need/cost of assurance from schemes such as the paid for Red Tractor, they need to come out and say if they think our food laws are lacking in any way. They need to say if the legislative system isn't good enough. If they can't say that, then it puts a question mark over private assurance schemes for the purposes of food safety and also environmental assurance and welfare (because we have EA inspections, pesticide compliance inspections, APHA, vet attestations, etc).

Edit. The GFC got binned off because farmers rejected it. No farmer members of an assurance scheme means no assurance scheme. If an assurance scheme isn't to our benefit and we don't get remunerated accordingly, then farmers and their representatives have the collective power to walk.

 

[Jackov Altraids]

I'll just remind everyone of this;

When the NFU submitted its response to the Red Tractor 2021 Standards Review it called for a fresh approach and set out 8 key principles to guide the standards body to improve its offer to scheme members.
The NFU’s 8 key principles for developing food assurance standards are:

1	Continue to retain trust and support growth in the domestic market for British food.
2	Provide an assurance platform for growth in the export market for British food and ensure high value exports have robust assurance supporting traceability claims.
3	Retain its leading position on cost effective assurance and protect members from inspection and regulatory duplication. Any additional costs associated with implementing new standards should be supported with a clear and simple cost benefit analysis or business case.
4	Be empowered to challenge duplicity within the marketplace and not facilitate the hypocrisy of buyers’ sourcing policies which undermines domestic standards.
5	Seek to add value through segmentation and market differentiation where there is a need to deliver different value propositions to different markets, without inflating the core standard and eroding value to scheme members.
6	Provide marketing choice for buyers. Scheme options, or bolt-ons, could provide competition for cost-effective or a more practicable alternative for brands and scheme members alike.
7	Provide a viable but discretionary alternative to new or increasing regulatory burdens and it should deliver efficient solutions in areas that are susceptible to regulatory burdens.
8	Explore the opportunities for inspections to be driven by outcomes and data, and where possible reduce the burden of inspection and add value back to farmers.

Despite what they say, it has been the NFU and AHDB that have continually facilitated RT's monopolisation of assurance, the attempt to make it as compulsory as possible and be a puppet of the supermarkets.

 

[SilliamWhale]

There is a lot of waffle in it.

I note the cereals section says:-

"The difference between our farm assurance versus trade assurance that dominates global markets is clearly an issue that needs addressing."

"We believe that any incremental adjustments to the current assurance structures will fail to reset divisive perceptions which have become entrenched."

They set it up!

Farmers are funding them to own RT and now funding them to discover what we've been saying all along.

 

[SilliamWhale]

Would need a solution for RED renewable energy directive, but all the other countries seem to manage (and they haven't got RT or equivalent farm level assurance schemes).

Easy to do. Farmers can fill a declaration in.

What is so special about RT that gives RED compliance?

 

[Grass And Grain]

I'll just remind everyone of this;

When the NFU submitted its response to the Red Tractor 2021 Standards Review it called for a fresh approach and set out 8 key principles to guide the standards body to improve its offer to scheme members.
The NFU’s 8 key principles for developing food assurance standards are:

1	Continue to retain trust and support growth in the domestic market for British food.
2	Provide an assurance platform for growth in the export market for British food and ensure high value exports have robust assurance supporting traceability claims.
3	Retain its leading position on cost effective assurance and protect members from inspection and regulatory duplication. Any additional costs associated with implementing new standards should be supported with a clear and simple cost benefit analysis or business case.
4	Be empowered to challenge duplicity within the marketplace and not facilitate the hypocrisy of buyers’ sourcing policies which undermines domestic standards.
5	Seek to add value through segmentation and market differentiation where there is a need to deliver different value propositions to different markets, without inflating the core standard and eroding value to scheme members.
6	Provide marketing choice for buyers. Scheme options, or bolt-ons, could provide competition for cost-effective or a more practicable alternative for brands and scheme members alike.
7	Provide a viable but discretionary alternative to new or increasing regulatory burdens and it should deliver efficient solutions in areas that are susceptible to regulatory burdens.
8	Explore the opportunities for inspections to be driven by outcomes and data, and where possible reduce the burden of inspection and add value back to farmers.

Despite what they say, it has been the NFU and AHDB that have continually facilitated RT's monopolisation of assurance, the attempt to make it as compulsory as possible and be a puppet of the supermarkets.

NFU seemingly not wanted any competition for RT. Partly why we're in the mess we ar

There is a lot of waffle in it.


They set it up!

Farmers are funding them to own RT and now funding them to discover what we've been saying all along.

It's taken us to spell it out to them. How did they not realise their RT scheme was an extra barrier to market access for their levy payers.

It's like trying to turn the direction of a rather stubborn oil tanker.

Particularly for the cereals sector, I think AHDB have cost us all a fortune with RT, and it wasn't necessary at all. It was AHDB and NFU policy.

There's 20,000 assured UK grain farmers.

@£350 for the average inspection, that's £7million per annum.

@ a very conservative £1,000/farm compliance cost, that's £20 million/annum (it's probably nearer £3,000+).

This has been going on for about 20 years, and AHDB have not only backed it, but have been instrumental in the ownership of RT and the direction of travel. They did this in the full knowledge that no other country in the world had farm based grain assurance schemes, and that's pretty much still the case today.

It hasn't given us better market access. It hasn't stopped imports flooding our markets and pressurising our prices. It hasn't improved our export marketing. What has it done apart from cost us £20 million/annum?