William Allen, Policy Manager, The International Meat Trade Association
“Ensuring sustainability policies are thoroughly considered, analysed for knock-on effects, and include adequate preparation time for businesses may seem at odds with the current urgency of action, but it is arguably more important than ever”
As we approach the 5-year countdown to 2030 – which is a deadline set by many countries and organisations to meet certain environmental targets – there is an increasing sense of urgency about translating rhetoric into tangible progress. Ensuring sustainability policies are thoroughly considered, analysed for knock-on effects, and include adequate preparation time for businesses may seem at odds with the current urgency of action, but it is arguably more important than ever. Implementing policies which are rushed and do not achieve their stated aims (or do so at huge societal cost elsewhere) will take even more valuable time and resources to resolve than ensuring policies are well-designed in the first place.
The EUDR is the archetype of this approach – an overemphasis on its (laudable) goals at the expense of the actual compliance process resulted in chaos and a last-minute 12-month delay to implementation. The lack of consultation and codesign with industry, supplier countries and even the EU member states who were tasked with enforcing the regulation left a vacuum of information, concerns lodged at the WTO and resulted in the delay announced by European President Ursula von der Leyen. There is always criticism of involvement of meat related organisations in this policymaking but the reality is that if you don’t have supply chains involved in the conversation, you cannot ensure that the resulting policy is as effective as it can be in its policy objectives.
The agricultural commodities which the EUDR focused on are generally foodstuffs. Food supply chains are often not vertically integrated and involve multiple actors (each with their own key role and expertise) producing, purchasing, processing and selling before the food arrives with the end consumer. Each food supply chain is also unique and must be considered in relation to the policy – for livestock products, all parts of the animal are valued and utilized for some purpose and various stages of disassembly and reassembly can take place before a final product is created for onwards distribution.
Beef mince for example can be derived from multiple cattle, so aggregating geolocation data from all of the farms where the different cattle were born, grazed and finished is a more complex task than one might originally think. An SME producer, whose animals ultimately end up in products ranging from food to pharmaceuticals to clothing, could be a situation where they are obliged to provide various data metrics in multiple different formats for all of the different destination countries and product-specific regulations where their products end up.
While robust traceability systems exist for food safety reasons, there is a challenge to ensuring that a completely different set of data & metrics can be transmitted through the supply chain. The direction of travel to include sustainability data (from carbon footprints to deforestation & biodiversity impacts, and beyond) goes beyond a straightforward repurposing of existing supply chain traceability and will involve the creation of entirely new data & compliance systems, which need time and consideration to implement, and cannot be conjured up overnight. IMTA strongly supports the transition to more sustainable supply chains but there is a need for policymakers to ensure that:
- We avoid creating a fragmented regulatory environment which would create obstacles to trade
- There is an understanding of how all parts of the food supply chain work in practice going back to the supplying countries and a realistic appreciation of what is feasible to deliver in the short, medium & long-term. Sometimes consultation with industry is limited to supermarkets, who are the most visible part of the supply chain, but this is an oversimplified understanding of how food reaches consumers and is a barrier to designing sustainability policies in the most effective way; particularly when policy compliance (such as EUDR) falls at the point of import.
- Clear information and guidance which is understandable and accessible for all sizes of company is provided well ahead of any implemented requirements
- Unintended consequences – such as impacts on food security, consumer prices or potential conflict with other sustainability concepts like food waste – are considered
In the race to meet environmental targets, there is a real risk that we end up with nations or regions working in silos, with no internationally agreed standards and a revival of protectionism under a new guise. Such a scenario would create logistical nightmares and barriers for global trade; which relies on transparency, predictability & non-discrimination. Two-way trade for meat contributes to sustainability by ensuring carcass balance* – allowing consumer preferences for certain cuts to be met without requiring large increases in domestic production and ensuring that all parts of the animal are utilised.
As noted in the recent G20 Agricultural Declaration, trade “plays a crucial role in…building sustainable and resilient food systems, including by facilitating the movement of food from surplus to deficit regions, thereby improving food availability, promoting access, and helping to stabilize prices…International trade measures linked to environmental sustainability objectives must be rooted in international cooperation, based on science and compatible with the rules of the World Trade Organization (WTO)”. We hope that policymakers work closer with industry to help find solutions that are evidence-based, feasible to implement, and that crucially will best achieve what they ultimately set out to do.