Defra's labelling plans will add cost and complexity, but fail to deliver transparency - NPA 

The NPA has told Defra that its plans to introduce new labels ranking pork products by method of production (MOP) will add cost and complexity to the supply chain, while failing to deliver on their objectives.

In a letter accompanying the NPA’s response to Defra’s consultation on improving food labelling, chairman Rob Mutimer tells the Department it would be ‘foolhardy’ to proceed with the MOP proposals.

• You can view the letter amd see the NPA's full consultation response in the Members' Area. 

The two-pronged consultation, launched in March, seeks views on changes to country-of-origin labelling (COOL), alongside the more controversial MOP plans.

The NPA is broadly supportive of the COOL proposals, which include increased visibility of origin labelling and new rules around the use of flags on labels.

But the plans to introduce MOP labels on pork, chicken and eggs have been met with forceful opposition from across the supply chain, both back in 2021 when the proposals were first presented, and again more recently.

Despite this, Defra is again proposing plans for a five-tier mandatory label, covering domestic and imported products.

The draft standards set out how for pigs, free range and outdoor bred-pork would be categorised in the highest tiers, with tier 3 encompassing ‘enhanced indoor’, followed by ‘standard’ indoor, representing ‘baseline UK welfare regulations’. The lowest tier would be ‘unclassified, non-UK standard’ for product which does not meet the UK’s legal baseline.

Many concerns

Mr Mutimer highlighted the NPA’s ‘many significant concerns’ over the proposals, which the association had previously outlined in its response to Defra’s 2021 call for evidence on the subject.

“We are therefore very disappointed to see the concept and detail included proposed yet again, with no evidence of reflection on the responses submitted by NPA or the wider pork supply chain,” he said.

The NPA’s primary objection is that method of production is not an indicator of good or poor welfare. It is widely accepted that good animal husbandry and management procedures have a far greater impact on the welfare of pigs than the system in which they are raised.

“Any measure of animal welfare on food packaging should be scientifically accurate and representative and, therefore, based on outcomes and not inputs,” Mr Mutimer said. “Indeed, the consultation itself, acknowledges that welfare outcomes are a better measure of welfare, but that due to the complexity this would entail it is not being considered.”

He said the five-tier approach would ‘denigrate’ ‘standard’ production, that is Red Tractor Farm Assurance, to the second to lowest tier, despite these standards going beyond the legislated minimum for animal welfare.

“Enacting these proposals would undermine domestic production by damaging the trust that consumers place in British pork and in Red Tractor,” he said.

Complexity

The complex nature of pig production in the UK means it would be near impossible to accurately identify one system to cover the whole life of many pigs. For example, pigs can be born and then reared outside for around half their lives and spend the remainder of their lives inside. It would, therefore, be misleading to consumers to apply a lower welfare tier in this case.

The NPA response points out that clear labelling for pork products already exists. “These proposals would only serve to confuse consumers, rather than delivering the accurate and meaningful information some require, while not providing them with any more information than is currently available,” Mr Mutimer added. 

It also highlights the ‘significant’ cost and complexity of implementing the rules, particularly as individual pork cuts are often downgraded and traded between processors. “This does not appear to be well-understood by Defra, and a number of assumptions have been made throughout the proposals in relation to pricing structure and willingness from retailers to engage in and enforce method of production labelling,” Mr Mutimer said.  

Summing up, he concluded: “We believe the MOP proposals will add cost, extra burdens and complexity throughout the supply chain, while completely failing in their aim of enlightening consumers about animal welfare and driving improvements on farm. We believe it would be foolhardy to press ahead with this policy.”