http://www.womens-institute.co.uk/camp-defra1.shtml?hilite=DEFRA

The Right Hon. Mrs Margaret Beckett, MP,
Secretary of State,
Department of the Environment, Food and Rural Affairs,
Nobel House
Smith Square
London
SW1P 3JR

22nd November 2002

Dear Secretary of State,

EU Regulation and the Survival of the UK Meat Industry

We write to express our great concern regarding the future of the UK meat processing industry (abattoirs and cutting plants), arising from the potential impact of two items of EU legislation. These will have a severe effect on all sectors, but will effectively bankrupt the small and medium-sized enterprises. We refer to:

EU Working Document SANCO/1420/2002 Proposal for Official Feed and Food Controls and 1774/2002 Animal By-Products Regulation.

PROPOSAL FOR OFFICIAL FEED AND FOOD CONTROLS. This proposes full recovery from the industry of all meat inspection costs. In the UK it would include the cost of MHS and BSE measures. If costs are applied as at present through a Standard Charge, charges for all plants will increase very substantially. Large plants would be disadvantaged since they would be less competitive than imports from other EU countries, which do not have the same level of costs as the Meat Hygiene Service. Smaller plants would cease to be financially viable.
If full cost recovery were applied on a plant-by-plant basis, for large meat plants this would mean a probable increase in cost from £2-£3 per livestock unit to £10 per livestock unit. For smaller plants the increase would rise from £3 to up to £100 per livestock unit. These costs are clearly unsustainable and plants would close.
We entirely support DEFRA and the Food Standards Agency's position backing the status quo.
We urge DEFRA to confirm that it will maintain this position in negotiations with the Commission to keep the existing status quo in charging for meat inspection and to keep charges at a proportionate level.

ANIMAL BY-PRODUCTS REGULATION. According to the timetable, this will be introduced in April 2003. It will require all abattoirs to collect and store blood for later disposal by costly means not currently employed in the UK. Some large abattoirs already collect and dispose of blood through renderers but a third of other abattoirs do not and the by-product is disposed of with the approval of the water companies via the sewage system or to land. Smaller abattoirs will have to invest in refrigerated storage tanks, where blood will await collection, probably on a weekly basis. There will be considerable additional expense. There may be planning issues. It is doubtful whether the UK has sufficient appropriate capacity at present to dispose of additional blood. Certainly it does not exist on a regional basis. Disposal will mean substantially increased long-distance lorry journeys, creating additional emissions, hazards and possible nuisance where none existed before. We would welcome information on the scientific basis for regarding blood and existing methods of disposal as a health hazard.
We urge DEFRA to confirm that it will request a permanent derogation for smaller abattoirs and a transition implementation period for all abattoirs.

If the new regulations are implemented as they stand and within the time-scale envisaged, the large abattoirs will become less competitive and the small and medium-sized enterprises will close.

The impact will extend far beyond the meat industry. We are attaching a memorandum. This details the far-reaching effects abattoir closure will have on very varied spheres of interest, such as DEFRA's rural and regeneration strategy, many of the Curry Report's recommendations, the Countryside Agency's initiatives, the livestock industry, animal welfare, direct and local marketing, consumer choice, the rural economy, the environment and policies designed to reconnect the consumer with farming and the countryside.

The very varied organisations we represent are all concerned about the widespread consequences this legislation will have on your Department's interests - the environment, food and rural affairs, including farming and animal welfare. This letter will demonstrate to you the breadth and depth of our anxiety about these EU measures. We hope your officials will likewise continue to be concerned about their potential disastrous impact and we intend this letter to provide them with additional support in the imminent EU negotiations on this legislation.

Yours sincerely,

(see attached list of signatories)