CONSULTATION ON 'PUTTING CONSUMERS FIRST: The Food Standards Agency draft strategic plan 2005-2010' Response by the Royal Society for the ...

CONSULTATION ON ‘PUTTING CONSUMERS FIRST: The Food
      Standards Agency draft strategic plan 2005-2010’

       Response by the Royal Society for the Protection of Birds
                             June 2004

The RSPB is Europe’s largest wildlife charity with over one million members. We
manage one of the largest conservation estates in the UK, covering more than 100,000
hectares. Sixty of our reserves are farmed, covering more than 20,000 hectares, with
around 170 tenant farmers, and 200 employees. We protect and enhance habitats such
as lowland farmland, heather moorland, lowland heath, wet grassland, estuaries and
reedbeds, and our reserves help to protect 63 of the 77 most rare or threatened breeding
birds in the UK.

The RSPB’s vision is for sustainable systems of farming that produce adequate supplies of safe,
healthy food; protect the natural resources of soil, air and water that farming depends on; help to
protect and enhance wildlife and habitats; provide jobs in rural areas and contribute to a diverse
rural economy.

Introduction

The RSPB is involved in food and consumer issues as part of our work on agriculture
and the conservation of farmland birds. Our activities include consumer education and
the development of wildlife-friendly foods, independently and in partnership with a
range of companies and organisations. Currently, for example, we are working with
Asda and Banks Cargill on the Safeguarding the Arable Farmed Environment (SAFE)
project, and have developed an RSPB bird-friendly organic rice produced by our partner
organisation in Spain and marketed by Suma Wholefoods. We also work with like-
minded organisations around the world, through BirdLife International, promoting
sustainable food and farming. This is critical given the global nature of the food chain.

The aim of this work is to reverse the decline in farmland birds. Our members share this
aim and many wish to know what they can do in their own lives to help wild birds –
making wildlife-friendly buying decisions is one more way to do this. Our own market
research confirmed this desire, but identified the lack of knowledge consumers have
about production methods as a major barrier. Wildlife and environmentally friendly
choices can only be made if consumers are fully informed about the environmental
impacts of their food and can make an educated choice.

The RSPB believes that consumers should be given information about the environmental
impact of products in a clear and accessible way. This should include information about
production methods as well as provenance details and ‘food miles’, allowing consumers
to choose to purchase local foods and foods that are not responsible for excessive
greenhouse gas emissions.

We therefore support the FSA’s commitment to better inform and educate consumers
and hope to see the expertise that the agency has developed over the last five years to be
applied to the full scope of concerns expressed by consumers.

We welcome the opportunity to respond to this consultation. This response is arranged
according to the questions posed in the invite to consultation and is restricted to our
areas of expertise.

The RSPB recommends that:

•   In response to consumer demand, the Choice priority area identified in the draft
    strategy includes the aim to make it easier for consumers to select
    environmentally friendly foods.

•   The guiding principles presented in the draft Strategic Plan are expanded to
    include specific reference to the environment and built upon to provide the FSA
    with a sustainable development action plan that includes action points and
    targets.

•   This plan includes a pledge to make environmentally friendly eating an easier
    option and encourage consumers to choose environmentally friendly food
    products.

Q1 We think that our priority areas for the next five years should be Food Safety,
Eating for Health and Choice. Do you agree?

The RSPB agrees that these three areas should be the FSA’s priority for the next five
years, but asks that Choice is significantly expanded to cater for the growing number of
consumers looking to purchase wildlife and environmentally friendly food products.

Consumers are increasingly concerned about the impacts their food makes on the
environment and wildlife, and are demanding food with positive environmental
credentials. Evidence for this can be found in the small but growing market for food
with environmental credentials and in market research. Organic foods now account for
2% of UK food sales and, with annual sales worth over £1bn, their market share is
continuing to grow. Organic farming has been shown to deliver benefits for the
environment and wildlife. As well as the organic label there are a number of emerging
environmental schemes and brands, such as the LEAF Marque (supported by Waitrose
and Marks & Spencer), White and Wild milk (sold through Sainsbury’s), and
Conservation Grade (used by Jordan’s). All have been well received by the public and,
following on from their success and in response to the recent reform of the Common
Agriculture Policy, a host of similar schemes are expected.

A number of major studies have confirmed this growing interest in environmentally
friendly food. The most recent was conducted by the Co-op1; which investigated
consumer attitudes to the ethics of the food industry. It revealed a significant demand
for information on the environmental impacts of food production. A clear majority
(70%) of the 29,500 sample felt that it was very important to support products grown in
ways that are not harmful to wildlife. Almost all (96%) felt that food labels should give
full information.

One of the key messages of the Curry Commission report on sustainable farming and
food was the need to reconnect the public with farmers. The report emphasised that
information is key to bridging this gap, and that it “must be provided in a meaningful
and honest way, which allows people to make real choices about the provenance,
nutritional content or production methods of their food”2

1
 The Co-operative Group (2004) Shopping with attitude. Manchester.
2
 Policy Commission on the Future of Farming and Food (2002) Farming and food: A sustainable future.
Quote from pp. 97.

The FSA already champions the provision of information on the provenance and
nutritional content of food, successfully facilitating consumer choice based on these
characteristics. We understand that there is further work to do on nutrition and applaud
the FSA’s recognition of this. We believe that the same must be done for the production
methods and the environmental impact of food, and that encouraging a greater
understanding of food and how it is produced would be complementary to efforts to
improve nutrition.

The RSPB therefore recommends that the FSA responds to these consumer signals and
resolves to help provide this information to the public. This is not only the logical
response to changing consumer demands, but it could also form a significant part of the
Agency’s sustainable development strategy, as described in the response to question 4.

Q4 The draft strategic plan contains an interim position on sustainability. What issues
should the Agency be tackling in this area?

We applaud the FSA’s commitment to integrate the Government’s principles of
sustainable development into the Agency’s policy and decision-making. We
recommend that the guiding principles presented in the draft Strategic Plan are built
upon to provide the FSA with a sustainable development action plan. This, like other
areas of FSA work, should include action points and targets.

The FSA have already made considerable progress in incorporating the social pillar of
sustainable development into their work, but we are deeply concerned about the
absence of any environmental dimension to the plan. Sustainable development,
according to the Government’s definition, should include the effective protection of the
environment.

An effective sustainable development plan should therefore include a policy response to
the Government Guiding Principle respecting environmental limits.

Modern methods of food production, designed to maximise yields through, among
other things, the increased use of chemical inputs, mechanisation, and specialisation, are
responsible for serious environmental degradation and biodiversity decline. This is
demonstrated by the almost universal decline in farmland bird species in the UK in
recent times. Between 1970 and 2000, for example, the tree sparrow declined by 95%, the
corn bunting by 88% and the yellowhammer by 53%. The Government’s Public Service
Agreement Indicator for farmland bird populations fell from 100 to 58.3 between 1970
and 2002 – the Government target is to reverse this decline by 2020. Agriculture, and the
food industry in general, contributes to a range of other environmental problems,
including water and air pollution. For example, almost a third of rivers in England and
Wales suffer from high nitrate pollution, while 40% are heavily enriched with

phosphorous3. High incidents of pollution are concentrated around the most intensive
areas of the country, and on average 70% of nitrates and 50% of phosphates in English
waters originate from agricultural land.

It is also important to note that policies designed to maximise food production, which
have severely impacted upon wildlife, have also contributed to public health problems.
The link between human health and environmental quality is made clear in
Government’s most recent annual report on sustainable development4. Investment in
the environment, by strengthening the environmental pillar of sustainable development,
will, therefore, not only benefit the environment and wildlife, but also human health.

The FSA should acknowledge the links between food production and environmental
damage, and, as the most important contribution the FSA could make to sustainable
development in the UK, pledge to:

    •   Make environmentally friendly eating an easier option;

    •   Encourage consumers to choose environmentally friendly food products.

This should be approached within the structure the FSA already has set-up, focusing on
consumers specifically using the FSA’s internet site and other communication mediums,
e.g. the Cooking Bus, as well as the rest of the food chain.

We recognise that the means by which food is produced is not in the FSA’s remit,
however, ensuring that people have the information and opportunities to make choices
about food is. This should include those consumers who wish to make their choices
based on environmental criteria.

The RSPB would welcome an opportunity for further discussions on making the
environment an element of the FSA’s draft strategic plan.

3
  Defra (2003) Strategic review of diffuse water pollution from agriculture. Discussion document. Defra,
London.
4
  Defra (2003) Achieving a better quality of life: Review of progress towards sustainable development.
Government annual report 2003. Defra, London.