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Sustain Brexit Consultation responses

Trade with Australia, response to Department for International Trade, 2018

We would firmly expect the UK Government to honour and respect the concerns of the British public in relation to food standards – safety, quality, workers’ pay and conditions, environmental protection, animal welfare and sustainable farm livelihoods, as well as fair dealing with food producers at home and abroad.

What would you want the UK government to achieve through a free trade agreement (or related trade talks) with the Australia, and why? Please supply your answer and any supporting evidence below

Sustain is the UK alliance for better food and farming and a registered charity, number 1018643. We represent around 100 not-for-profit national organisations and work with hundreds more at local level – local authorities, public health groups and community organisations.

The Sustain alliance advocates food and agriculture policies and practices that enhance the health and welfare of people and animals, improve the working and living environment, enrich society and culture and promote equity. The alliance is independent from the agri-food industry, and does not take funding from for-profit food or farming companies.

It is funded from grants (from charitable foundations and government, local authorities or related sources), membership subscriptions and sales of publications. Since the EU Referendum in June 2016, Sustain has been active in convening alliance members and others to discuss the implications of the UK’s decision to leave the European Union, and to work together to achieve the best possible outcome for the country’s food, farming and fishing, especially in relation to environmental and health concerns.

The Brexit debate has generated a lot of comment about how in the race to secure international trade deals, the UK may come under severe pressure to compromise our food, farming and fishing standards – a damaging race to the bottom. Sustain is not anti-trade and is interested in seeing the UK agree new trade deals that promote a beneficial race to the top. This is especially important given the necessity for food trade policies to support consistent and effective action on pressing global priorities such as climate change, biodiversity loss, the state of fish stocks and marine ecosystems, antimicrobial resistance, food poisoning, food fraud, obesity and diabetes, and measures to improve pay, fair trading and working conditions – especially in the food supply chain. We are confident that a high proportion of UK consumers and voters agree with us.

In April 2018 an IPPR poll found that, when asked whether the UK should lower food safety standards to secure a trade deal with the US or retain current standards, only 8% of the public thought the UK should lower food safety standards, with 82% preferring to keep standards as they are. This is backed up by research recently undertaken by the consumer organisation Which? looking at food safety and more broadly at quality standards and methods of production.

We would therefore firmly expect the UK Government to honour and respect the concerns of the British public in relation to food standards – safety, quality, workers’ pay and conditions, environmental protection, animal welfare and sustainable farm livelihoods, as well as fair dealing with food producers at home and abroad. We want to be sure that trade deals affecting food standards are agreed only if we can guarantee that people in the UK can enjoy a supply of food that is:

The British public expects their food to be safe. International trade deals must not undermine this. The UK has lots of national priorities on things like reducing antibiotic use in medicine and farming, reducing food poisoning, promoting healthier children’s food and baby food, and reducing diet-related conditions such as obesity and diabetes. We expect trade deals to help achieve these, not undermine them.



We want trade deals to enable the prioritisation of the production, availability, affordability and promotion of healthy food, and not to make sugary, calorie-laden food and soft drinks cheaper, more accessible or more heavily promoted.


High quality

Everyone needs to know what they are eating and where it comes from, so we would like any new trade deal to protect country of origin labelling. We also want to be free to support producers of higher quality, traditional goods, especially those with protected geographical status, such UK as Melton Mowbray pies or Cornish sardines.

We want the UK to remain free to promote and protect accreditation schemes and kitemarks and not allow fake or copy-cat goods with lower ethical values. As consumers are increasingly seeking out higher welfare and quality goods, these labels incentivise producers to take part in ethical and sustainability schemes, which is desirable.


Respectful of UK consumer and health priorities

We want trade deals that ensure our food is, for example:

  • Produced from healthy animals naturally healthy and resistant to disease; not with the overuse of the antibiotics that we so badly need for human medicine. UK trade deals must therefore, without fail, help and not hinder the realisation of international commitments such as the United Nations WHO/FAO One Health AMR strategy, to which the UK is a signatory.
  • Processed in ways that are safe and meet UK consumer expectations. This must not favour ‘end of pipe’ chemical treatments for pathogens, and must favour production methods that build inherent hygiene and animal welfare, and be inherently less prone to infection and contamination. Signatories to the trade deals must also be required to monitor and transparently report on food poisoning rates and sources of contamination, and be able to be held accountable for any incidents that may arise as a result of food trade.
  • Produced in full consideration of the special needs of babies and children, not made with excessive salt and sugar, questionable additives or low-quality bulking ingredients, and with full respect for the UK’s current approach to limiting contamination.
  • Promoted and advertised in a way that prioritises healthy diets, upholding the UK’s bans and controls of promotion of High Fat, Sugar and Salt (HFSS) foods, especially in advertising or marketing communications targeted at children under the age of 16; also respecting the UK’s robust scientific standards for health and medical claims associated with food.
  • For environmental protection and wildlife, produced without chemicals and pesticides currently banned in the UK and across the EU. And for our health, made in a way that respects limits to the amount of permissible chemical and pesticide residues in food.
  • Labelled in a consistent way that UK consumers can recognise and understand, with standard ingredient and nutrition information, details of where the food comes from, allergen declarations and front-of-pack traffic-light colour-coded nutrition information. The UK must not be constrained by the terms of a trade deal from introducing mandatory warning labels for certain types of food, should these be considered necessary in future.
  • Overseen by a consumer protection system that can monitor progress, identify and address problems, and give consumers the rights of information, complaint, refund and redress.


Good for people (including farmers, farm workers and food producers)

International trade deals must ensure that our food comes from farmers and food workers who have been paid and treated fairly in line with International Labour Organisation conventions, and with opportunities for people to make progress and earn more over time, in an enforceable way.

International trade deals must not enable the food and farming industries to compete on a ‘race to the bottom’ in terms of worker pay and conditions, must not put our domestic food producers’ livelihoods at risk, and must not put pressure on UK employers to reduce pay and undermine safe and decent working conditions.


Good for the planet

The UK Government must ensure, via its trade deals, that our food is produced in a way that is environmentally friendly and meets national priorities for conservation and enhancement of nature, as well as national and international targets for reducing greenhouse gas emissions. It should not be produced using excessive chemicals and damaging techniques that harm pollinators such as bees, soil, air quality and clean water, as well as precious and irreplaceable wildlife and ecosystems at home and abroad.

Trade deals must help protect our seas, coasts and marine life. We must be able to prioritise a sustainable approach to fishing, fishery management, marine protection areas and marine ecosystem regeneration, as well as sustainable fish buying in the public and private sectors, in line with the UN’s official guidelines for responsible fishing.

Trade deals must not undermine the efforts of UK farmers and fishers and UK farming and fisheries policy to protect and enhance the natural environment and must not force our UK farmers and fishers to lower their standards in order to compete. Nor should trade deals undermine the UK’s ability to provide payments to farmers in return for environmental and social outcomes; and the UK’s ability to regulate the supply chain to achieve greater fairness and combat unfair trading practices; both as set out in Defra’s draft new UK Agriculture Bill.

Trade deals must not threaten our rules on buying sustainable fish for our schools, hospitals and armed forces – we want these enhanced and to see this encouraged and promoted more in the public and private sectors. The UK is still in the process of rolling out mandatory sustainability standards for the food served in Central Government, HMP prisons, the armed forces and NHS hospitals, as well as in many schools throughout the UK – trade deals must not undermine our ability and freedom to set and expect robust standards. This will include complete exclusion of some stocks and species, promotion of sustainably certified or scientifically assessed fish, and support for fisheries with questionable sustainability status to be put into fishery improvement programmes.


Good for animals

The UK Government must ensure that when it signs new trade deals, any meat, dairy or other livestock products we import comes from animals that have been treated well and transported and killed as humanely as possible, to at least UK animal welfare standards.


Public service procurement contracts

Trade deals must not in any way undermine the ability of our public institutions – such as schools, hospitals, prisons, central government and the armed forces – to buy well produced, healthy, fair and sustainable food. We must remain free to use our public sector food contracts to favour producers who abide by high standards that can demonstrably provide public benefits.


What concerns, if any, do you have about a free trade agreement (or related trade talks) with Australia, and why? Please supply your answer and any supporting evidence below

Sustain and our members are deeply concerned that in the race to secure international trade deals, the UK may come under severe pressure to compromise our food standards – and standards of production in farming and fishing – generating a regrettable and damaging race to the bottom.



Farmers’ representatives and unions have warned of the threat to domestic industry if British farmers are forced to compete against a ‘flood of imports’ from abroad.

There is growing concern that in scenarios in which UK farming is expected to compete on price with countries like Australia that may have different or lower standards, UK farming may become unprofitable – some of it already is.

Post-Brexit scenario-modelling by the UK’s Agricultural and Horticultural Development Board suggests that in some possible scenarios, many UK farmers risk seeing their incomes halve after Brexit. Some commentators foresee the end of smaller and family farming, unless explicitly supported.

UK farm policy is in the process of transformation. The draft UK Agriculture Bill currently before parliament signals the intention of Government to prioritise environmental protection, encourage farming to play its role in mitigating and adapting to climate change, to direct public payments to achieve environmental outcomes, and to regulate the supply chain so that farmers are treated more fairly. Such welcome moves must be enhanced and not undermined by trade deals.



Trade deals must not inadvertently support the overuse of antibiotics in farming – either in the UK, through British farmers being forced to compete with food produced to lower standards; or overseas – antibiotic-resistant superbugs know no boundaries, hence the UK’s official support for the United Nations WHO/FAO One Health AMR strategy. The systems of farming that use much higher levels of antibiotics are generally more intensive, cramming thousands of animals into small spaces, resulting in disease and faecal contamination that require higher levels of veterinary intervention, including antibiotics. UK trade deals must not support antibiotic-dependent intensive livestock systems, as these now pose unacceptable risks to human health and the global economy.

We have found evidence of Australia being criticised for their lack of transparency in the use of antibiotics. There is also no national system to monitor how much antibiotics are given to farmed animals and no law that requires farmers to notify the detection of superbugs that are resistant to antibiotics. Figures on antibiotic use are only reported on a voluntary basis by pharmaceutical companies.

Our colleagues at the Alliance to Save Our Antibiotics have unearthed Australian government evidence of veterinary antibiotic sales up to 2010. Using the data in this report, and using data on the population of farm animals in Australia, they calculated that the use of antibiotics in poultry is more than 20 times higher than in the UK, and use per animal in pigs is over twice as high as in the UK.

On a more positive note, Australia does prohibit the use of fluoroquinolones in farm animals, which are still permitted for use in the EU and are classified as high-priority critically important antibiotics in human medicine by the WHO.

The EU is set to vote (possibly as early as 25th October 2018) on a proposed ban on using antibiotics for preventative group treatments in farming. However this will not come into force until the UK is likely to have exited the EU. The UK government recently confirmed they supported the European Commission’s aims in restricting the prophylactic use of antibiotics but fell short of saying they would implement the same all out ban on preventative group use. We need to see the UK to implement the proposed ban in full and also continue to find further ways to reduce the overuse of antibiotics in farming. We need the UK decisively to rule out encouragement of excessive antibiotic use via trade deals.



If the UK signs a new trade deal with Australia, the UK is likely to need a robust and transparent process for authorising the use of Genetically Modified Organisms (GMOs); effective measures to prevent GM contamination from any imported produce and an effective liability regime for those affected by GM contamination. We would also point out that genetic resources and genetic diversity are both key public goods, held in common not by private interests. Genetic resources should not be controlled through patenting – and this should be dealt with in trade discussions.

Currently the UK government recognises UK consumer objection to eating GMOs, and insists that foods containing them be clearly labelled. Whatever their view on the pros and cons, consumers from across the spectrum of attitudes to this technology insist that they want to know what they are eating. This right and preference should not be jeopardised by trade deals. Furthermore, currently most foods produced in the UK are likely to continue to adhere to stricter EU regulations to retain those markets, so relaxing our rules on authorisations and labelling could offer a competitive advantage to imports over many home-produced products, and also lead to additional burdens of proof on those who currently legitimately claim ‘GM free’. 

Finally, the devolved nations’ divergent policy on GM in food and farming must be respected and legislation developed that will allow it to be fully implemented.


Food standards

Under EU rules, UK consumers are currently protected from questionable food production methods like chlorine-dipped chicken, hormone-grown beef and routine or excessive use of food irradiation. We don’t want to be forced to accept these due to a trade deal, without healthy democratic debate and accountable decision-making, in relation to the implications of such treatments for food production methods, hygiene, disease control in humans, plants and animals, and animal welfare.

Currently, there are only two food products in Australia’s top ten export list: beef and wheat. Hormone growth promoters  are widely used in Australian cattle farming. They accelerate weight gain and have been utilised in Australia for more than 30 years. About 40 per cent of Australian cattle are treated with hormone growth promoters adding an estimated $210 million to the value of the Australian beef industry.

As members of the EU, the UK has long rejected hormone-treated beef, arguing that at least one of the growth hormones used is carcinogenic. Australian producer organisations dispute the science. Consequently, reports have emerged that the Australian beef industry representatives are already pushing for the UK to drop our objection to hormone-treated beef when the UK leaves the EU. UK consumers have made their objections to hormone beef quite clear. In a Which? survey conducted earlier in 2018,  80% said they were not at all or not very comfortable with growth hormones in beef production. We urge UK trade negotiators to reject any attempts to pressurise the UK to accept hormone-treated beef.

Food standards in the UK – quality, integrity, safety and traceability – are already under severe pressure as a result of the paucity of resources for essential services such as testing, inspection and border checks. Changes to trade, movement of goods, potential border arrangements and our food standards being portrayed as ‘non-tariff barriers to trade’ are causing exceptional concerns and uncertainties  for the food industry and standards bodies.


Food poisoning

We note that the food poisoning pathogen campylobacter remains an issue in Australia (as it does in the UK) and that there has been a sharp increase in incidents of salmonellosis over the last 20 years, including 15 deaths. This is a foodborne illness caused by infection with Salmonella bacteria. In the UK we have managed to reduce the risk of salmonella poisoning radically and the most recent epidemiological lab data from Public Health England shows no deaths in England and Wales from salmonella between 2005 and 2015. Salmonella food poisoning is most commonly caused by consumption of contaminated food of animal origin, such as beef, poultry, milk, fish or eggs.

Trade deals must not expose us to increased risk of food poisoning – and even increased deaths – from pathogens like salmonella and campylobacter. The UK food and farming industries and government agencies have been working hard to tackle contamination from these and other dangerous bacteria and also foodborne viruses. Trade deals must not undermine this progress. We ask our trade negotiators to investigate this further, and transparently to take into account food safety considerations when exploring food trade deals, particularly in relation to livestock products.


Animal welfare

We are concerned that UK producers might be forced to lower their animal welfare standards in order to compete with livestock products produced to lower standards. Conversely, we are concerned on behalf of animals that the lowest standards in either country (Australia or UK) should not prevail and set the new low bar for trade and common practice. Principles of high animal welfare must be championed throughout. Information and labelling for livestock products must be reliable and transparent about 'use by' and slaughter dates, country of origin, methods of production and (a future possibility) environmental or climate change impact. There should be no future constraint on the UK being able to set such requirements for domestic and imported produce, when sold in the UK.

The UK continues to permit export of live animals for slaughter and breeding, which many consider to raise concerning animal welfare issues. However, the public mood has turned against live export for slaughter over recent decades, the volume of live exports has declined to tens or hundreds of thousands of animals, depending on species, and the UK Government is consulting on the possibility of imposing an all-out ban on the export of live animals for slaughter. Meanwhile, Australia continues to export around 1.8m sheep a year for slaughter, mostly to Qatar, Kuwait and Turkey. In April this year, they were faced with a global scandal when a video made by a whistleblower provided evidence of more than 2,400 sheep dying from heat stress en route to the Middle East. The Australian government has faced a lot of opposition, but no doubt reluctant to lose the $250m of annual exports, launched a website in July 2018 to defend the practice.  Trade policy needs to support the highest animal welfare and the preferences of UK consumers for high welfare meat that comes from animals that have been treated well at all stages of production and slaughter. This does not include long-distance live export of animals for slaughter.


Is there anything else you would want to say about the UK’s future trading relationship with Australia? Please supply your answer and any supporting evidence below

Sustain’s focus and expertise is on food, farming and fishing. We have also been working with others to campaign for transparency in UK trade negotiations, in recognition that this general principle would be beneficial across a very wide range of social, environmental, food, fishing, farming, health and other concerns. We want the Government’s trade team to be required to:

  • Undertake impact assessments (including on issues such as environment, labour, farm livelihoods and public health), that are comprehensive, researched independently and published in advance;
  • undertake proactive consultation with civil society, scientific specialists, parliamentarians and affected groups in order to set mandates for negotiators in advance;
  • give parliamentarians sufficient time and powers to debate and vote on prospective trade deals.

Parliament should have a legal right to scrutinise and debate impact assessments before having a vote on a negotiating mandate. The assessments should also be revisited periodically to a) take account of the negotiated text b) assess whether projected gains and risks have materialised. Parliamentarians could also choose to insert a review clause into the deal related to the impact assessment in order to enable termination.

Negotiations should be fully transparent with the negotiating mandate published (as it is in the US), negotiating proposals and texts for each round published and requirement to update parliament on progress.

Final deals must be subject to parliamentary debate and affirmative vote before being ratified or implemented in any form.

Finally, Sustain and its alliance members are very concerned about the potential for future trade deals to generate costly Investor-State Dispute Settlements. We would like to see them excluded  from any deal as they are the mechanism that could be used to undermine UK producers and to challenge environmental and food standards and protections.

Brexit: We stand at a cross-roads. When the UK leaves the European Union, will our leaders uphold good standards for our food, farming, fishing and trade deals? And will they agree a sensible deal with the EU? We need to make sure that they do!

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Sustain advocates food and agriculture policies and practices that enhance the health and welfare of people and animals, improve the working and living environment, promote equity and enrich society and culture.

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