Orla Delargy, Head of Public Affairs, Sustain
IATP submits evidence on trade bill to the House of Lords
IATP teamed up with Sustain, the alliance for better food and farming in the United Kingdom, to submit evidence on the trade negotiations between the U.K. and the United States to the House of Lords International Agreements Sub-Committee Inquiry. We co-authored the comments to show that civil society in both countries have a shared interest in ensuring that any trade deal that is struck is in the interests of people and the planet and doesn’t undermine quality food and sustainable agriculture. The Lords’ inquiry is timely and important. Despite the pandemic, the trade talks have proceeded quickly. Negotiators from the two countries met virtually for a fourth round of talks in September, with U.K. trade secretary Liz Truss claiming significant progress; the next round is planned for later in October. Meanwhile, the U.K. hasn’t finalized its post-Brexit laws setting out the overarching framework for conducting trade negotiations nor for agricultural policy generally. The Trade Bill is still wending its way through Parliament while separately, amendments to the Agriculture Bill to maintain current food and farming standards are still under consideration.
In our submission, IATP and Sustain raised many concerns. The kind of trade deal that is likely to emerge from these fast-paced talks poses significant risks to U.K. food and farming practices. At the same time, the deal would limit opportunities to improve U.S. food and environmental standards and begin moving away from our over-industrialized agricultural system.
The U.K.’s negotiating objectives for the trade agreement state that the government will not compromise “on our high environmental protection, animal welfare and food standards” and acknowledge “UK product sensitivities, in particular for UK agriculture.” However, to date the U.K. government has refused to enshrine food standards in legislation, effectively ensuring they remain a bargaining chip. This contrasts with the specificity of the U.S. negotiating objectives and repeated statements by U.S. Trade Representative Robert Lighthizer, Trump administration officials and members of Congress from both parties objecting to U.K. food standards as “protectionism” — and making plain that the U.S. will act against any food standards that U.S. commodity exports cannot meet. Some key issues IATP and Sustain identify:
The U.S. allows between 70 and 80 pesticides that are banned in the U.K. and also allows higher levels of residues on food. A U.S.-U.K. trade deal could permit the sale of U.S. imports with higher pesticide residue levels than currently allowed, or with residues of banned pesticides. It could lead to the U.K. reauthorizing active substances which have been banned due to concern over their negative impact on human health or the natural environment. In addition, it could put in place measures which restrict the U.K. from introducing more protective standards in the future. This is also a concern from the U.S. perspective; a trade deal could lock in current weak standards and stymie efforts to reform our pesticide laws.
The U.K. slaughtering industry will face pressures to meet the “efficiency” of the U.S. meatpacking industry, with workers experiencing increased risk of injury and illness as a result. Meatpacking is one of the most dangerous jobs in the U.S. The situation is only getting worse as the Trump administration turns over inspections to the industry itself, excessive line speeds lead to high injury rates and multiple environmental and safety violations go unchecked due to weak enforcement. Spraying poultry carcasses with peracetic acid to sanitize the end product has been linked to workers’ respiratory problems, complicating the response to COVID-19, which has hit the U.S. meatpacking industry hard, killing least 200 meatpacking workers to date. The faster processing lines also directly cause contamination as plastic and metal parts break off and fall into food in processing plants, leading to a major increase in recalls.
The U.K. (through EU regulations) has detailed species-specific legislation on pigs, hens, broiler chickens and calves to protect their welfare on farm and at slaughter. U.S. animal welfare regulations are weak; there is no federal legislation governing the welfare of animals while they are on the farm. There are federal provisions on slaughter, but this legislation does not cover poultry. U.S. legislation is also much less protective on the transport of live animals; for example, EU rules allow a maximum of 12 hours transport time for live chickens, but in the U.S., the limit is 28 hours. The U.K. has banned barren battery cages for egg laying hens since 2012 and sow stalls since 1999. While these systems have been prohibited in some U.S. states, there is no federal ban and a majority of states lack such protections. The U.S. has no mandatory labeling related to animal welfare concerns and doesn’t regulate the veracity of voluntary disclosures.
Food Safety and Chemical Washes
U.K. consumer concerns about chemical washes such as chlorine and peracetic acid are not merely a question of consumers’ distaste for these chemicals in their food. Rather, use of these chemicals reflects the inadequacies of the underlying food safety system in the U.S., which requires sanitizing meat with chemicals to make it safe. In contrast, U.K. and EU standards disallow anything but water washes, meaning maintaining and tracking safe practices throughout production and processing is a must. While U.S. agriculture and trade officials regard the effectiveness of post-slaughter chemical washes as science-based, independent research indicates that chlorine can make foodborne pathogens undetectable, rather than kill them. As discussed above, the high level of chemical use in U.S. meatpacking plants is also a worker safety issue.
Antibiotics and Other Drugs
Vast quantities of medically critical antibiotics are still used in farming — this can be a sign of cramped and dirty conditions that lead to disease. Overuse of antibiotics facilitates practices that are abusive to animals and undermines public health by fueling dangerous anti-microbial resistance and reducing the effectiveness of life-saving antibiotics. A recent report by the Alliance to Save our Antibiotics found that U.S. livestock received on average 5.4 times more antibiotics per animal in 2018 than their U.K. counterparts. These levels increase to 8 or 9 times more in U.S. cattle and include the routine preventative use of an antibiotic (virginiamycin) formerly classified as a growth promoter, all uses of which are prohibited in the U.K. Overuse of antibiotics, feeding livestock growth promotion drugs such as ractopamine and carbadox, and hormones in livestock feed is part and parcel of routine U.S. agribusiness. Any trade agreement the U.S. enters into will seek to normalize these practices and allow food produced in this way onto the U.K. market. The U.S. could use these trade rules to seek to roll back existing U.K. rules under the guise of reducing non-tariff barriers that “discriminate” against U.S. products and incorporate provisions to “harmonize” standards with less stringent U.S. rules to ease trade.
Consumer protections and the exercise of consumer choice are premised on high standards and effective labeling. A trade agreement between the U.K. and the U.S. risks both. The U.S. not only wants to lower standards, but also to limit labeling so that consumers won’t know what they are buying and eating. U.S. trade negotiators have taken a hard line against mandatory consumer labeling both before the WTO and in recent negotiations with Mexico and Canada. U.S. trade officials already have raised objections to the possibility that the U.K. might improve its food labeling laws following Brexit. Leaked memoranda documenting preliminary trade negotiations show U.S. officials objecting to “warning labels as harmful rather than as a step to public health” and “concerned that labeling food with high sugar content… is not particularly useful in changing consumer behaviour.”
Economic Implications for Farmers
A trade deal with the U.S. could force U.K. farmers to lower their standards to stay competitive, posing a significant economic threat and resulting in a race to the bottom for both food and environmental standards. If U.K. food standards slip, then British farmers will struggle to meet EU standards, thereby losing their primary export destination which currently accounts for 60% of U.K. agricultural exports. Equally concerning, British farmers could be undercut by imported crops grown more cheaply on a larger scale and to lower standards. From a U.S. perspective, expanding the U.K. market for the products of industrial agriculture does nothing to support high quality and organic farming, and undercuts U.S. domestic efforts to improve pesticide, animal welfare and antibiotic regulations to better protect public health and the environment.
The U.K. said in its negotiating objectives it wants to “futureproof the agreement in line with the Government’s ambition on climate.” This may be impossible, however, since U.S. trade negotiators are explicitly required by Congress under the trade promotion authority law to avoid any provisions addressing global warming or climate change. The recently negotiated New NAFTA, or U.S.-Mexico-Canada Agreement, reflects this requirement and continues a damaging climate legacy. Unfortunately, the U.S.-U.K. trade agreement is being negotiated pursuant to this same flawed climate directive.
The very fact of a trade agreement between the U.S. and U.K., which is designed to increase the shipping of goods across the Atlantic, will exacerbate greenhouse gas emissions. Provisions in the agreement could promote fossil fuel use and energy-intensive chemical, fertilizer and pesticide use in agriculture while limiting the authority of the U.K. government to regulate climate-harming practices. Intensive industrialized livestock and dairy practices are a major and growing source of climate-warming emissions. There is already evidence of growth of U.S.-style intensive farms in the U.K. One consequence of the U.K. leaving the EU and its Common Agricultural Policy is that the country has the opportunity to establish its own agricultural policies and farm support schemes. If the U.K. and U.S. agree to a low-standard trade deal, the U.S. will effectively further embed industrialized, climate-harming agriculture well into the future, while the U.K. will accelerate its adoption of those same destructive practices and miss out on an opportunity to chart a different, more sustainable future.
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