Written evidence submitted by The Horticultural Trades Association (HTA)
1. Broad-brush Opportunities and Challenges:
Summary:
1.1 An exciting Brexit opportunity for the ornamental and landscape horticulture sector is the creation of new way to support the management of the UK countryside and our natural environment, based on providing public environmental benefit. This sector, which is also referred to as ‘the garden industry’, delivers huge environmental resilience and a financial support system to replace CAP and based on these values would greatly benefit our sector. Green infrastructure, including street trees, parks, gardens, green walls and green rooves, alleviates flooding, cleans the air and water, mitigates against extreme temperatures and reduces energy use in buildings. Alongside the garden industries in other countries, the UK industry is transforming itself from the perception of providing just aesthetic and recreational benefit, to delivering significant environmental, health, wellbeing and societal benefits.
1.2 Import substitution is another big opportunity presented by Brexit. We currently import approximately £300 million per year, and yet the UK has one of the best climates in the world for growing a broad range of plants (AHDB Project CPM 001
https://horticulture.ahdb.org.uk/project/quantifying-opportunities-ornamentals-growers-import-substitution-and-export). With a collaborative government-industry effort, we could expand our nursery sector to almost entirely meet domestic demand. The current biosecurity threat of potentially devastating plant pests and diseases makes this opportunity all the more important. There are various reasons for the imports, including the efficiency of continental suppliers as a result of their governments’ investment; the range of stock available through one continental supplier; the confidence UK buyers have in continental suppliers able to deliver complex orders quickly and efficiently; price; lack of stability in the UK market leading to reluctance to invest in home production. The industry is making very significant efforts to improve biosecurity standards and it can do more to nurture better relations between suppliers and customers. However, nurseries need confidence in their market, particularly for trees and longer lead-time woody crops, as well financial incentives to give businesses the confidence to invest. The success of the UK film industry shows that simple incentive schemes like 25% rebate on expenditure can create a significant boost and bring in good returns over the long term to UK plc. Please see the Import Substitution for Oak Report by the HTA, 2017: https://hta.org.uk/government/campaign-listing/oak-report.html
1.3 Exports: there is a limited amount of physical product exported in the ornamental and landscape horticulture sector. Seeds manufacturers are one example where there is scope to increase product export but this subsector has expressed concerns about the rising costs of regulation, in particular plant health fees to assess and approve every single batch. The recently proposed rise in plant health fees could seriously disrupt export plans for this sector and deter any future exporting. (Please see annex: Letter from Mr Fothergill’s Seeds, 24 October 2017, for more detailed evidence on this). The current system is slow and inefficient and there is concern that this could get worse. The UK does export design, consultancy and education expertise, but we do not know the quantity or potential of this. The iconic Singapore Gardens by The Bay was designed by British landscape architects, for example.
1.4 A challenge the sector faces is in securing funding for strategic Research and Development. Ornamental and landscape horticulture traditionally gets eclipsed by its bigger brother agriculture and the edibles sector, and so the number of horticulture research institutions carrying out work in our sector has dwindled dramatically. Government support in innovation specifically for our sector would make a massive difference. The industry would like to develop many new environmental and health benefitting plant products such as ‘super street trees’ which absorb ten times the amount of air pollutants and don’t need hugely expensive pruning and management. We could also develop green roof substrates which absorb twenty times the amount of storm surge water from torrential downpours. In 2013 the HTA proved that climbing plants act as external air conditioners against buildings, keeping them cool in summer and insulated in winter. However, we need more strategic research to translate this knowledge into real domestic and commercial landscape products to provide these benefits to the whole UK. For more information, please see our 5-year strategy: http://www.hip.org.uk/assets/uploads/publication/HIP_R&D_Strategy_2015_Summary_web.pdf. This strategy was part Defra-funded alongside industry.
1.5 There is a skills challenge for the sector, primarily in changing perceptions in the young to see this sector as an attractive highly-skilled career choice. This is in common with the challenge faced by land-based industries. A match-funding pot could be very helpful to help the land-based industries create a more joined-up approach to strategic careers promotion. Currently it is fragmented, with individual sectors contributing relatively small amounts and not accomplishing their aims.
2. Regulations
Summary:
2.1 Plant protection products, pesticides and herbicides: The ornamental and landscape sector is a heavy user of glyphosate, particularly in the management of amenity landscapes including parks, gardens and urban areas. The sector uses neonicotinoids to control vine weevil in container-grown crops, but this is limited to just three types of neonicotinoid and they are only applied under strict conditions. The sector’s neonicotinoid use accounts for less than 0.1% of total UK use. The sector would like to see the UK government take a risk-based approach to these products, based on peer-reviewed scientific evidence. There is concern that the current green lobby which takes the approach that all chemicals are bad, will have such strong influence over policy makers that we will end up with very few ways to treat pests and diseases. This could lead to resistance in pests and diseases which would ultimately threaten our landscapes and countryside.
2.2 Plant Health: For plant health it would make sense to have at least equivalence with continental systems and good information and intelligence sharing. Plant pests and diseases don’t respect national borders. The UK has one of the best plant health regimes and the industry is pleased that we had a strong and successful influence over the new EU Plant Health policy, strengthening and extending existing systems such as plant passporting and the need to include all plants for planting. The industry is making great efforts to improve biosecurity by creating a Plant Health Assurance Scheme. This has potential to become a standard by which recognised trade is benchmarked. The sector sees the need for the UK to be recognised as an equivalent third country by the EU so that we avoid the requirement of phytosanitary certificates for every single plant trade.
2.3 Plant Variety Rights: The ornamental and landscape horticulture sector is very concerned about potential rising costs for separate UK registration for new plant varieties. The current Withdrawal Bill aims to give varieties protected rights mirroring the EU system and then a 3-4 year transition for new applications for the new UK rights. For new applications there will be a new UK system which will work alongside the EU system with separate UK applications. This will require close cooperation with the EU on aspects such as DUS (Distinct, Uniform and Stable) testing and recognising names of new varieties.
How achievable this system is going to be is not clear yet. The potential administration costs of a new system are a significant concern for the sector, and there is a danger that this will act as a discouragement to exports and UK innovation in plant breeding. The negotiations with the EU will make this situation clearer.
2.4 Water availability regulation is a major concern in our sector because water for food and container-grown ornamental plants is not classed as an essential use, therefore any restrictions will impact on our sector immediately without any exemptions. In hot, dry weather a container-grown plant can survive only 24 hours without watering. The horticulture industry as a whole needs water for food and ornamentals crops to be adopted as an essential need so businesses can have confidence in this vital resource.
3. Labour and skills
Summary:
Alongside agriculture and the wider horticulture industry, the ornamental and landscape horticulture sector relies on seasonal labour availability for crop production at certain times of the year. Depending on the crop this could be at several different times of the year. The HTA is starting to receive reports of recruitment issues from nurseries. Due to a variety of reasons, there is currently a more limited pool of seasonal labour resource, and agencies are prioritising bigger industries and businesses over SME’s. Most HTA member nurseries are SMEs. The sector would like to see a replacement scheme for SAWS implemented if this continues.
Along with other industries, the ornamental and landscape horticulture sector would like to create a strong UK skills pipeline but this will take time and government support. Along with other land-based careers, horticulture has suffered from a poor perception as a career choice. The industry has joined up to create Grow Careers (www.growcareers.info) as an information portal but a wider joined-up and match-funded approach needs to be taken by government to help industry in wider meaningful careers promotion. For example, there is a need for better data on the labour trends at national, regional and local levels, as well as skills analysis for the sector as a whole. There used to be a sector skills council which carried out data collection an analysis, as Defra used to do with more depth for ornamentals production, but this is no longer carried out. Without good data it is very difficult to address recruitment issues, skills issues and the long-term creation of a UK skills pipeline for horticulture and land-based industries.
Background
The HTA is the leading trade body for the garden industry representing growers, retailers, landscapers and manufacturers. Currently, the ornamental and landscape horticulture is estimated to be worth £13 billion. This includes plant production, retail, landscaping, garden tourism, tree surgery, garden and landscape management. Ornamental plant production is worth £400 million approx., and the market for garden products is worth £5 billion. Almost half the UK population actively garden (Taking Part Survey – Sport England https://public.tableau.com/profile/taking.part.survey#!/vizhome/MostFrequentResponses-ChildhoodActivitiesFreeTimeetc_/Dashboard.)
There are more than 300,000 people employed in this sector and we are seen as world leaders in many different ways including design, management, shows, and education.
February 2018
Annex: Letter from Mr. Fothergill’s Seeds concerning impact of fees on export
24th October 2017
To Whom It May Concern,
We, Mr. Fothergills Seeds Ltd., are writing to provide our feedback on the proposed changes to fees for statutory plant health services provided by the Animal and Plant Health Agency in England and Wales. We have elected not to provide our feedback directly through the questionnaire attached to the consultation document as we find the line of questioning in the document obscures the real-world implications of the suggested changes. We believe this letter will better represent the facts of how our business will be affected by the proposed changes and better illustrate the reality we face if these proposed fees are brought into effect.
As a medium-sized commercial business operating in the horticultural industry we rely on the Export Certification Services provided by the Animal and Plant Health Agency (APHA) to deliver our Export sales strategy. Our £3.5m annual Export turnover can only be achieved with the support of APHA, which in recent years has been increasingly lacking and more expensive. The further increased fees proposed in this consultation are poised to seriously disrupt our Export sales, which will have a significant impact on the business as a whole.
Our general range of products for export currently constitutes almost 1,500 pictorial packet seed products with around 1,000 unique seed varieties and is constantly growing in order to meet customers’ expectations of choice and novelty. To ship any of these products to any country outside the EU we must have them sampled and a “visual health check, weed and orobanche search” must be performed. In his latest visit our inspector sampled approx. 50 varieties in approx. 2.5 hours. At this rate having our entire range sampled will take 50 billable hours, currently costing £13,048.00 in total. The proposed fees would increase this cost to £45,512.59. Due to the number of different products we are offering, adding a fee per sample causes a drastic increase in cost and furthermore, sampling so many different products takes a disproportionate amount of time when compared to bulk seed businesses or growers.
Alongside this general export range, we offer bespoke products to distribution partners in Canada, Russia and Australia. All of these countries have very specific entry requirements for seeds and plant products, often including the requirement for the type of testing referred to as “specialist bespoke tests” in the consultation – i.e. PCR and ELISA tests. We recently made a shipment of 1,910 pictorial packets of tomato seed to Australia, constituting 9,550 actual seeds. To meet the import requirements of Australia a total of 23,000 seeds from the same lot were put through PCR testing, one sample of 20,000 and one of 3,000. We paid only for the sampling, not for the testing. Under the proposed charges this testing would cost us £3,284.08 on top of the increased sampling fees. This shipment constituted a turnover of £915; paying the proposed prices for this testing on top of having to buy in the extra seed to be tested is simply not viable. As the Australian authorities are in the process of increasing their biosecurity restrictions we will likely be facing the requirement for more testing. We are already facing the inability to supply goods to a market where we currently hold a very significant market share and further restricting our options by moving this testing beyond our means puts our business in a precarious position.
These “specialist bespoke tests” are also a requirement in many of the 12 other countries we trade with outside the EU. For a recent order from a long-term customer in Japan, 60 lines out of 280 on their order would require such testing. Last season we supplied an order to Armenia where 30 lines out of 123 on the order would require this type of test. Typically, these orders are for a few hundred packets per variety. Buying enough seeds for the sample size required for this testing is already a risky proposition, due to the nature of our trade. Expanding and increasing our sales to cover these risks becomes impossible in the face of thousands of pounds of fees per line for the necessary tests.
It is worth noting that our knowledge of these testing requirements and our understanding of how these proposals will affect us comes from the business’s own investigation and analysis of importation requirements in the markets we operate in. The “Export Advice” being offered by APHA, which often stands as a barrier between us and the phytosanitary certification we require, has become slow, inefficient and non-committal in recent years. This poor service has already led to a loss for the company, as in the aforementioned shipment to Japan we had to remove products from the order when we could not get an answer to our questions from APHA. The suggestion that we will be charged for using this service needs far deeper consideration than is offered in this consultation.
I hope that this letter illustrates the manner in which our business will be affected by the proposed changes to fees for statutory plant health services provided by APHA and how the business relies on these services to succeed. The case studies above show how the proposals disproportionately affect our business due to the nature of our trade. Smaller shipments of hundreds of different seed varieties will face substantially higher fees than larger shipments of a few varieties. It is discouraging to be faced with a blanket charging scheme that offers no understanding of the different types of business that are using these services and with no flexibility that could allow our business to take advantage of markets that offer great potential for us. To take advantage of these opportunities and continue to compete in the markets we are already excelling in, we need APHA (and DEFRA by extension) to support us with efficient, affordable and effective services that enable our business.
Yours Faithfully,