Written Evidence submitted by The Chemical Industries Association(CIA)(SH0052)



This submission is from the UK Chemical Industries Association (CIA).


The Chemical Industries Association (CIA)

CIA is the trade association representing and advising chemical and pharmaceutical businesses across the UK. A significant contributor to the UK economy (£17 billion of Gross Value Added on a turnover of £55.5billion), the chemical industry is at the heart of UK manufacturing, with chemistry and chemicals helping to ensure clean water, food, clean energy, and other essentials to everyday life.


The Chemical Industries Association (CIA) welcomes the opportunity to submit comments on soil health for the UK. Comments provided have been collated from our UK CIA Chemical Industry membership. There are, however, also closely aligned with comments made in Europe from CEFIC to the open public consultation on the new soil strategy submitted in March 2022 to the EU Soil Health Law consultation).


UK Parliament Call for Evidence – Introduction and Invitation for Submissions:

The health of soil in the UK – soils ability to function as a vital living ecosystem that sustains plants, animals, and humans – faces challenges from contamination, nutrient loss, erosion and compaction. The impact of this is likely to be significant through accelerating climate change, increasing the chance of flooding, reducing the productivity of farms and losing an important ecosystem for bacteria, fungi and invertebrates. The inquiry will look at why soil health continues to be a problem and consider how the UK Government can accelerate soil restoration in England. The Committee invites submissions on the following:


Q1. How can the Government measure progress towards its goal of making all soils sustainably managed by 2030? What are the challenges in gathering data to measure soil health how can these barriers be overcome?

CIA Response:

UK CIA would like to share few key considerations with regard to the UK Governments goal of making soils sustainably managed by 2030:

Sustainable use and protection of the soil environmental quality is a priority for the chemical industry. The UK Chemical Industries Association (CIA) welcomes the initiative to examine soil health in the UK, as it recognises soil as a valuable natural resource, and the need to maintain its highest quality.


The new proposal should ensure coherence between national legislation, the new UK Environment Act 2021 and remaining EU legislations in force (e.g.) the initiatives stemming from the EU Green Deal. It should be limited to precautionary aspects and focus on avoiding overlapping objectives. For example, for industrial production sites there are already soil monitoring requirements in the Industrial Emissions Directive (Art 16) and a clear demarcation would be needed in any new soil proposals. UK CIA also believes that stakeholder participation should be ensured throughout the process of developing any new soil proposals (e.g. through discussions in expert group meetings).

In the EU’s ‘Open Public Consultation on the New Soil Strategy for Soil’ – our sister organisation in Europe (Cefic.org) confirmed the proposed set of criteria under the Mission on Soil health and food (the following eight indicators) was appropriate to assess current soil status and to track changes:


1. Presence of soil pollutants, excess nutrients and salts

2. Soil organic carbon stock

3. Soil structure including soil bulk density and absence of soil sealing and erosion

4. Soil biodiversity

5. Soil nutrients and acidity (pH)

6. Vegetation cover

7. Landscape heterogeneity

8. Forest cover


Whilst UK specific metrics against which the Government can measure progress on making all soils sustainably managed, alignment with metrics being developed under the EU Soil Health Law proposals could be considered. Barriers would be overly complex systems to collect or measure the soil health data with potential inconsistency in application between environments such as Urban (influenced by anthropogenic inputs and industry), Rural (dominated by agricultural/ forestry inputs) and ‘wild’ (limited anthropogenic inputs).


Q2. Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?

CIA Response:

The chemical industry is committed to reducing its environmental impacts and has shown support to European and UK initiatives. Our industry takes its responsibility seriously by building on operational excellence standards to protect people and environment, for instance through Responsible Care®. The UK was one of the first adopters of Responsible Care®, some 30 years ago, and CIA has been integral to its implementation in the UK.

What is always desired is regulation that is integrated and easy to follow, with as few ‘systems’ to use for recording/inputting data as possible. With regard to soil health, regulation is followed though (as non-exhaustive examples) material management plans (MMP’s), documented approval processes for soil recycling and quality control would be good to formalise (e.g. Claire Home (claire.co.uk) )


Q3. Will the standards under Environmental Land Management schemes have sufficient ambition and flexibility to restore soils across different types of agricultural land? What are the threats and opportunities for soil health as ELMs are introduced?

CIA Response:

UK CIA understands that the Environmental Land Management schemes (Sustainable Farming Incentive, Local Nature Recovery, and Landscape Recovery) focus on Agricultural use of land. We do not comment in general on other sectors. If proposals for schemes to manage Industrial land were developed – we could provide comment.


Q4. What changes do we need to see in the wider food and agriculture sector to encourage better soil management and how can the Government support this transition?

CIA Response:

Individual members of the UK CIA may have views on agri-chemicals etc. – however, we have interpreted the comment as directly requesting information on the ‘Farming’ industry – and so again we prefer not to comment in general on other sectors.


Q5. What does UK Government need to do to tackle other stressors on soil health such as soil contamination?

CIA Response:

With the UK outside the EU, UK proposals considering the various types of national soil, their properties and functionalities, the UK national perspective should be used to address the issues of pollution/degradation. Remediation measures of contaminated sites are currently addressed in targeted national legislation; it is the responsibility of the National Competent Authorities to determine the identification procedure for contaminated land and set priorities.


We recommend that any Soil Health proposals adopt a risk-based and sustainable model for contaminated land assessment and management. The European Union are also consulting on soil Health and the NICOLE/Common Forum joint statement (2013) provides helpful principles that might form the basis for a regulatory model here in the UK, and in the EU.

A risk-based approach consistent with how the land is used, inclusive of various types of intervention on soil with effects on physical and biological soil health, should apply to soil investigation and remediation measures. Such a risk-based approach would identify when there is a real risk to human health and the environment, taking into account the land use and would help to identify the appropriate and proportionate measures to prevent harm. This is of key importance to set the right priorities in an economically feasible way.



February 2023