Licensee Policy briefing October 2022
The recent changes to Defra’s ministerial teams alongside promised reviews of future frameworks, have raised many questions for organic farmers.
The Soil Association have so far worked extensively with Government to promote organic’s interest and reward for organic farmers through the development of Environmental Land Management Schemes. This includes gaining support for organic farming practices within Sustainable Farming incentive and Local Nature Recovery Options and the creation of a new Organic Standard to be launched in 2024.
We have had recent approval for a Test and Trial, which is designed to allow the organic sector to benchmark organic farming practice against all of the SFI standards and we are part of a range of lobbying and stakeholder groups to promote the needs of the organic sector.
As we enter a new period of change, Adrian Steele, Soil Association Organic Sector Development Advisor and co–chair of the English Organic Forum explains our understanding of the changes at Defra and what it means for the organic industry.
The new Secretary of State for Defra, Ranil Jayawardena, has been settling into his post. He has established very quickly his key messaging, which can be condensed into three words; Trade. Growth. De-regulation. This is entirely consistent with the Chancellor’s vision for Agriculture as set out in his Growth Plan;
"Farmers do essential work in producing high quality food for consumption at home and for export. However, agricultural productivity growth has been weak for many years and this needs to change to support the rural economy. The government will rapidly review frameworks for regulation, innovation, and investment that impact farmers and land managers in England. This will ensure government and industry are working together to strengthen UK food security, and maximise the long-term productivity, resilience, competitiveness, and environmental stewardship of the British countryside. The government will set out plans later this autumn."
The Ministerial team, which now includes Mark Spencer, Trudy Harrison, and Scott Mann, is conducting this review of the frameworks, and that review includes the Agricultural Transition Plan (ATP), and the Environmental Land Management Scheme (ELMs). There has been some speculation that this review could result in major changes to ELMs, but thankfully this has been quelled by the Secretary of State, and by Defra civil servants.
Environmental groups and other interested parties including the Soil Association are concerned that the government’s direction of travel could include a watering down of environmental protection, and have mounted a strong defence of the principle of Public Payments for Public goods.
We don’t know what will come of the review, but Liz Truss has indicated that farmers will need help to keep food price rises under control though it is very unclear how this would work in practice. An important area to watch is whether the deregulation drive and the review of all retained EU legislation lowers UK environmental and animal welfare standards, and whether that is linked to the opening up of the UK market to imports produced to lower standards via trade deals.
What does this mean for the Organic Sector?
Ranil Jayawardena has come to Defra via first the Treasury and then the Department for International Trade (DIT). His background is in banking, rather than farming. We have had meetings with him whilst he was at DIT, and he was very supportive of the organic sector, recognising the integrity of organic food and the certification process. He indicated that the sector had the potential to export effectively, and represent the high values embedded in the government’s vision for ‘Global Britain.’ He is interested in the role that ensuring equivalence of organic standards plays in international trade, and whether it would be an advantage to accentuate the Britishness of UK exports through labelling.
There is an awareness within Defra that the UK organic sector is smaller in terms of market share than all comparable Western European nations bar the Republic of Ireland. However, there is still a refusal to set targets for organic market growth. Instead, the question being asked is what regulations act as a barrier to growth, and whether they can be removed.
The Government intends to proceed with the Retained EU Law (Revocation and Reform) Bill, as part of the ‘Brexit Dividend’ concept. It is unclear exactly how this will be implemented but will prove to be a massive undertaking. Defra alone will be responsible for analysing, processing, adapting, and reissuing 570 pieces of legislation, with a deadline of the end of 2023. Only time will tell as to whether this can be achieved.
The current Organic Regulations are effectively ‘cut and pasted’ from the EU legislation. We have had strong indications from Defra that they will be reviewed and adapted over the next year. Encouragingly, Defra is creating a Four Nations Working Group, and an Organic Experts Group to help it keep the devolved nations and the organic sector on board, as well as working with the other Certification Bodies through the UK Organic Certifiers Group.
It is likely that the government will continue to push forward with legislation enabling the roll out of Novel Breeding Techniques (which include gene-editing) as part of its de-regulating drive.
We haven’t seen plans to ensure the continuation of financial support for Organic Conversion and Maintenance after the legacy EU Agri-environment schemes are closed to entry from January 2025. George Eustice had indicated that such support would be forthcoming as a part of the ATP, as recognition of the environmental benefits that are delivered through organic land management. Defra have been light on details to date, and we are continuing to push for clarity.
Whilst the SFI and LNR are claimed to be on course for full roll out in 2024, there are still unanswered questions about what Defra’s targets are, and how they will be delivered through these two schemes. This is in stark contrast to the EU Farm to Fork Strategy, which has clear targets including for organic farming to make up 25% of the land area by 2030, and the Scottish Government who aim to double organic land production by 2026 Outgoing Defra Ministers rejected a land area target for Certified Organic production, and we expect this position to be maintained, despite much lobbying. However, we do know that support for organic farming practices will be embedded within the SFI standards and LNR options.
The standards for soils were developed very quickly, with the idea that the basic payment income would be offset with a compensatory payment for basic sound soil management. We have ensured that organic farmers would be eligible for the standards, but have heard from some Licensees that they have been prevented from entering some of their land parcels into the SFI standards - those parcels that were subject to legacy EU Agri environment scheme funding. We will be taking this up with Defra in early October.
SFI Standards in development
Although we and others have continually challenged Defra about the structure of these schemes, we are still being presented with a series of practice based (eg Nutrient Management), and asset based (eg Hedgerows) Standards. We have always advocated that Defra should take a whole farm approach to environmental delivery, and that organic farming provides an excellent model of how a holistic approach will have additional benefits for animal welfare.
As a result, Defra committed to creating an Organic standard, which will be due to launch in 2024. We have not yet seen a draft of this Standard, so are awaiting clarification on whether it will include whole farm provisions related to organic conversion. We have had approval for a Test and Trial, which is designed to allow the organic sector to benchmark organic farming practice against all of the SFI standards as they are developed, to ensure that Defra takes them into account, and reward them consistently for the public goods that they generate.
We also have the opportunity to press the case for good agroecological practice being rewarded, through three other official stakeholder engagement vehicles; Practitioner Working Groups, Stakeholder Working Groups, and the Future Farming Programme Forum. Defra is also engaging with a small number of organic farms that are in the National Pilot.
Defra has committed to 22 Pilot project proposals for LR in 2022 and is intending to ‘pilot’ 500 LNR proposals in 2023. We would very much like to licensees who are accepted into these pilots. Whilst we know that the LR is intended for large scale (minimum 500 hectare) and ambitious change, we are still seeking clarity on LNR. There was a presumption that LNR would be broadly comparable to EU legacy agri-environment schemes, but we do not know for sure. It is possible that this scheme may come under pressure from the new ministerial review of the ATP and move closer to the SFI in form.
Finally, the English Organic Forum had been working with Defra to identify areas where the government and the organic sector can work together. This resulted in the development of a draft EOAP. It was well received by Defra, and the outgoing Ministerial team and it is hoped that we will continue to develop the plan with the new Ministerial team. Soil Association Certification is committed to promoting the needs of the organic sector in these changing times and we will keep licensees updated on progress going forward.