Agricultural Industries Confederation                                                                                    DEF0005

Written evidence submitted by the Agricultural Industries Confederation (AIC)

About the AIC

The Agricultural Industries Confederation (AIC) is the agri-supply industry’s leading trade association with over 230 Members in the agri-supply trade and represents £9 billion turnover at farmgate. AIC represents several sectors within the agri-supply industry including: Animal Feed; Crop Protection and Agronomy; Fertilisers; Grain and Oilseed and Seed.

For the purposes of this inquiry, AIC members source and supply soy and palm products in feedstuffs, that are used by all parts of the UK livestock sector as feed.

Background information on soy in the UK

Soya, usually as soyabean meal, is used in animal feeds because of its unique characteristics in its amino acid profile, protein concentration, nutrient density, digestibility and palatability to livestock. Given these characteristics, soya complements other feeds such as cereal grains. It also ensures less nitrogen being excreted in the manure from animals. It is therefore an essential part of livestock feed. The majority of imported soya comes from Argentina, Brazil, United States, Canada, and Paraguay.

Livestock feed is made up of cereals, pulses, oilseeds and their co-products which are non-edible for humans, products from the food industry (bread, pasta etc), grass and silage feed additives such as minerals, trace elements and vitamins. None of these alone provide the same amino acid profile, nutrient density or digestibility to animals as soya, which is why they are used in combination in rations.

There is considerable research taking place into novel proteins, such as insects, algae and single cell proteins. These sectors are in their infancy and significant investment is required to scale up and develop a catalyst to these technologies.

Consultation Questions

The effectiveness of UK efforts to reduce global deforestation

1. In what ways and to what extent are UK value chains (in the form of public procurement, goods, services, or the private sector) contributing to global deforestation?

UK supplied soy profile

The animal feed sector has taken significant steps in order to address the risk (legal or illegal) of deforestation in origin countries. UK Soy supply data, collated by AIC, shows that 70% of imported soya into the UK comes from sources carrying no deforestation risk (illegal or legal). This means it is covered by zero deforestation standards set by soya scheme owners or covered by ASM (Amazon Soy Moratorium) contracts, or grown in territories with no deforestation risk (such as USA and Canada).

The remaining 30% has had no sourcing scheme requested, however research shows that the majority (27%) is considered low risk of any deforestation using the FEFAC methodology. The FEFAC methodology is a risk calculator developed by FEFAC in conjunction with CIARA, ABIOVE and CAPRO and weights the risks as follows: Brazil (Cerrado) – 50% (SCF considers the contribution of soy in deforestation to be significantly lower than the FEFAC estimate), Argentina (Gran Chaco) – 3%, Paraguay – 16%. This leaves 3% that carries a risk of deforestation.

Existing initiatives to address deforestation in soya and palm oil supply chains

AIC Services, as a member of the Roundtable on Sustainable Palm Oil (RSPO), have developed a Palm Oil Credit Scheme (APOCS) to purchase RSPO Credits on behalf of AIC members and thus encourage and support development of sustainable production and supply chains. By purchasing RSPO Credits, a business directly supports those palm growers who have changed growing practices to meet all of the RSPO Principles and Criteria to produce certified sustainable palm oil products.

The Feed Material Assurance Scheme (FEMAS) standard has a Responsible Sourcing Module which is successfully benchmarked to the FEFAC Soy Sourcing Guidelines. AIC are involved with the development of the guidelines as members of the FEFAC Soy Sourcing Guidelines Development Group.

Existing ‘book and claim’ or mass balance models are offered by soy supply schemes which are benchmarked under FEFAC soy sourcing guidelines. This means there is a documented system for demonstrating that soy purchased is compliant with the scheme claims.

Certified soya is available to the market, through a range of systems such as ‘credit’ schemes or ‘chain of custody’ standards that follow the physical supply. In addition to this, The European Feed Manufacturers' Federation (FEFAC) formed a coalition of members in 2014 to develop the FEFAC Soy Sourcing Guidelines. These consist of social and environmental criteria and recommendations for good agricultural practices for soya cultivation. There are now 18 benchmarked schemes compliant with FEFAC guidelines. Certified schemes do attract additional costs, and these costs will fall to the supply chain to be able to absorb them. 

2. How effectively is the Government monitoring the UK’s contribution to global deforestation and its progress in tackling the issue? And what progress has been made by Government to develop an indicator on overseas environmental impacts of UK consumption of key commodities?

In the UK, the Roundtable on Sustainable Soya was established in 2018 to provide the UK industry with an open forum to work together towards a secure, resilient, supply of deforestation free sustainable soya to the UK. The UK Roundtable now comprises over 30 members, including major supermarkets, processors, farming organisations, feed businesses, foodservice businesses and soya traders. This has been a very effective mechanism of addressing sustainable soya, initiated by Government, which it should be commended for.

It must be stated that given the complex nature of imports of commodity goods to the UK, the Government must work in partnership with key trading partners. In the case of palm, soy and maize, imports are mixed with product from other regions and then transhipped via the EU to the UK, itself moved into smaller vessels. The European Union is itself seeking to implement its own measures to mitigate against deforestation, and given its overall market size, will be entirely influential to the UK’s market. The AIC believes that whilst the Government must be free to pursue its own approach to deforestation, it cannot look at it in isolation. Working alongside the EU’s incoming proposals will ensure consistency across the supply chain and best outcomes for producers in origin countries and consumers in the UK. Failure to do so could mean the UK has to directly source materials from origin countries, significantly adding to their cost.

Regarding the question of how to prioritise a commodity’s impact based upon global deforestation and the UK’s role, AIC would want to be clear as to how Government would anticipate measuring this. For example, low risk/responsibly sourced commodities can come from high-risk geographies, and vice versa. An objective framework is required to ensure that all stakeholders can be clear on how these interrelated factors can be measured.

The Joint Nature Conservation Committee (JNCC) has produced a consumption indicator tool indicator and dashboard which assesses overseas impact of UK consumption of a wide range of commodities. This is a useful tool however, as indicated earlier, given that supply countries are given a risk-rating covering all territory in that country, it cannot account for those low risk/responsibly sourced commodities that come from so-called high-risk geographies.

3. How effective are the measures to improve due diligence and ban imported products of illegal deforestation in the Environment Act 2021? Do these measures target the right sectors? Given that they do not extend to all products of deforestation, are they adequate?

AIC would like to underline our view that we support the objective of preventing the import of commodities that have been produced on land that has been deforested illegally, and it is our view that there is a role in Government in helping to prevent this. Existing initiatives such as the UK Roundtables on Sustainable Soya and Palm Oil can not only help reaffirm this commitment, but also go over and beyond this baseline in considering how to progress to sourcing commodities that carry zero deforestation risk. Such challenges can only be met by a partnership between industry and Government.

It should be stated that the scope of due diligence is considerable. The legislation outlines extremely complex and detailed issues for each commodity, and the amount of work industry has already undertaken with DEFRA in order to meet its ambitions should not be understated. The legislation will need to be able to cover risk mitigation, supply chain enforcement, evidence reporting, embedded products, business turnover and threshold tests, de minimis tonnage tests and the role of the regulator. The Government appears to acknowledge that the weight of this legislation is not immediately possible for all the goods under scope, given that it has asked whether or not commodities should be phased in one by one as opposed to all commodities under scope.

The challenge now is to ensure that due diligence is well targeted, and can work with supply chains, farming businesses and retailers. The legislation must properly take account of imported products carrying ‘embedded’ soya (such as processed foods or imported meat) and ensure they are clearly under scope. Failure to consider this at all could lead UK farming businesses placed at a competitive disadvantage on food standards.

4. To what extent have the Global Resource Initiative (GRI) Taskforce’s recommendations on deforestation and land conversion been met by the Government?

Setting out a strategic pathway for the UK

The GRI recommended setting out an action plan, setting legally binding targets and establishing an independent advisory taskforce. AIC is of the view that the soy and palm Roundtables are successful advisory taskforces to Government. Due diligence proposals will present legally binding targets on illegal deforestation.

Driving market demand for sustainable commodities

GRI recommended due diligence proposals, Government and industry working together to deliver change, action on public procurement and action on dietary change. AIC is of the view that progress on delivering the first two recommendations has been made but we have seen little evidence of concrete progress on procurement and dietary change. We strongly believe that setting an example as far as procurement is concerned sends an important message to the whole supply chain.

Aligning collective global action to deliver at scale and pace

GRI recommended bold intergovernmental trade partnerships between producer and supplier countries, trade finance import guarantee schemes for sustainably produced commodities and using COP26 as a platform for a global call to action. AIC is aware of initiatives agreed at COP which go some way to delivering on the first and third recommendations.

Additional recommendations were made on establishing London as a global carbon trading centre and establishing public/private finance provision. We look forward to understanding how the Government seeks to take this forward.

Accelerating change, tracking progress

GRI recommended Government provide support to the development and scale up of innovative technologies that might help deliver the other GRI recommendations. There is activity in this space via the Agri-Tech innovation centres and in the regulatory arena with the Genetic Technology (Precision Breeding) Bill. AIC would strongly recommend continued Government inter-departmental collaboration to consider regulatory changes which will help deliver progress. An example would be to consider amendments to ‘TSE’ regulations to allow insect protein to be fed to pigs and poultry and to investigate the safety of new substrate streams fed to insects intended for use in animal feed.

GRI calls for the development of a monitoring, measurement and reporting framework to assess progress. To an extent, due diligence proposals will provide this framework. AIC has developed its own sustainability roadmap for member businesses, within which are plans for a self-assessment tool for members to monitor their progress and guidance on using metrics. AIC repeats the call for all parties, Government, industry and other stakeholders to continue to collaborate on metrics ensuring that there is consistency and transparency across the piece.

5. What role can sustainable certification and Government Buying Standards (GBS), have in tackling deforestation? How can the UK Government support the private sector to reduce its contribution to furthering deforestation?

The agricultural supply industry should certainly meet the challenges of deforestation. However, industry alone cannot enforce such changes. As stated by the Global Resource Initiative (GRI) in its Final Recommendations Report, Government procurement policy has a significant role to play in buying choices and influencing change.  As a result, products sourced by Government departments should align with this policy ambition, to show leadership on the issue.

A number of public commitments on food standards have been made by Government, which are very welcome, however it would seem incongruous if they are not extended to international firms selling into the UK. Any UK legislation should not impose cost burdens on UK producers and firms, if it is also not imposed on products exported to the UK with embedded forest risk commodities.

Finally, AIC would caution perverse incentives for the supply chain. The entire rationale of Government policy and due diligence is to ensure that countries with areas of rainforest engage in legal supply chains with western, buying nations such as the UK. The most effective way to achieve this is to ensure that UK businesses have the confidence to buy from developing countries and countries with existing forest areas, allowing the basis of trade to be raised to one of overall legality. This will meet the Government’s intention of being a leading nation on sustainable trade – and this can only be done by strengthening the supply chain from producer to consumer. What we must not do is put in place such a high-risk compliance system that drives UK businesses away from origin countries, and instead leave them to trade with only those nations that do not prioritise sustainability in sourcing goods.

August 2022