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Sustain Brexit Consultation responses

Trade transparency: response to the International Trade Committee, 2018

Sustain believes trade can bring many benefits. However, as a food and farming alliance, we want to be sure that such trade deals are beneficial to our health, food safety, animal welfare, food producers and the environment.

Written evidence submitted by Sustain (UTP0004)

About Sustain: Sustain is the UK alliance for better food and farming. We represent around 100 not-for-profit national organisations and many more at local level. 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. 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. See:

In parallel, we also support the inquiry submissions of the Trade Justice Movement and Global Justice Now, sister networks with whom we work.

Executive summary

Sustain believes trade can bring many benefits. However, as a food and farming alliance, we want to be sure that such trade deals are beneficial to our health, food safety, animal welfare, food producers and the environment. Hence:

A. Given the potential impact of trade deals on health, food safety, animal welfare, food producers and the environment, we are calling for complete trade transparency.

B. We are concerned about the clear signs from United States negotiators that we will have to accept lower standard, lower welfare food in exchange for trade. Meat grown with hormones, chlorine dips and profligate antibiotics are worrying examples.

C. Farmers’ representatives and unions (and even a former UK ambassador to the US) have warned of the threat to domestic industry if British farmers are forced to compete against cheap food imports.

D. We fear poorly negotiated trade deals that allow in cheap food imports will reduce our farmers’ income, lower workers’ wages and accelerate closure of small farms.

E. Our research shows massive drops in staffing and resources in the UK agencies charged with our food safety – we and they are concerned that future trade deals will add further pressure.

F. Sustain has been arguing since the EU Referendum result in 2016 that we must not compromise our food standards in exchange for trade. Recent polling by the IPPR showed that 82% of the UK’s general public agree with this sentiment – results confirmed by recent research by Which? – the UK’s biggest consumer association. 

G. We are concerned that the current trade discussions that will eventually lead to full trade talks, including those relating to food standards, are being conducted in secrecy by the Department of International Trade who release only selected information.

H. Even though those discussions are already underway, there are still no formal mechanisms in place to consult civil society and no indications about how Parliament will have their say.

I.  Trade deals must deliver on achieving international objectives to which the UK has already signed up.


Given the implications for our food system and associated health, safety, wellbeing, animal welfare and environmental concerns, we are calling for complete trade transparency.

We want impact assessments published in advance; comprehensive, proactive consultation with civil society, parliamentarians and affected groups in order to set mandates for negotiators in advance and for parliamentarians to have sufficient time to debate and vote on prospective trade deals.

Responses to ITC’s UK Trade Policy Transparency and Scrutiny consultation questions

Which documents pertaining to trade policy and negotiations should the Government make publicly available – and which should remain confidential?

  1. We believe the government should make as much as possible public in order to facilitate public debate about future trade deals and build consumer confidence that health, food safety, animal welfare and environment are dealt with properly. There is a lot at stake.
  2. Over the coming years, the UK is likely to seek new trade deals with a number of non-EU countries. Sustain believes trade can bring many benefits. However, as a healthy and sustainable food, farming and fishing alliance, we want to be sure that such trade deals are agreed only if we can guarantee that people in the UK can enjoy a supply of food that is safe, affordable and good for our health, animal welfare, food producers at home and abroad, and the environment – including protecting precious natural resources and reducing the emissions that cause climate change. We also want to be sure that farmers at home and abroad can make a decent living, and for British farmers to be able to produce food and manage our countryside in a way that respects our needs and the needs of future generations.
  3. 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, farming, animal welfare and environmental standards. Senior US trade officials have already repeatedly warned the UK that they intend to negotiate hard on this point, rejecting legitimate EU and UK concerns about food standards as ‘non-tariff barriers to trade’ and warning against protecting our farming industry with tariffs[1].
  4. Farmers’ representatives and unions (and even a former UK ambassador to the US[2]) have warned of the threat to domestic industry if British farmers are forced to compete against cheap food imports.
  5. There is growing concern that in scenarios in which UK farming is expected to compete on price with countries operating to 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[3] 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,[4] [5] unless explicitly protected or otherwise supported. Such considerations have implications for national security, farming livelihoods, rural economies, environmental protection and good management of our countryside and natural resources. UK policy on trade in food will need to be balanced with legitimate consideration of national and domestic food security and social and environmental impact, including rural economies.
  6. Food standards in the UK – quality, integrity, safety and traceability – are already under severe pressure[6] 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[7]  for the food industry and standards bodies.
  7. Sustain has been arguing since the EU Referendum result that we must not compromise our food standards in exchange for trade. Recent polling by the IPPR showed that 82% of the UK’s general public agree with this sentiment[8] – results confirmed by recent research by Which? – the UK’s biggest consumer association.[9] 
  8. Although the Department for International Trade is refusing to release full details on all the working groups it has set up with non-EU countries, we know from their Secretary of State, Liam Fox that they are keen to do a quick deal with Australia, New Zealand and the United States[10]. They have also set up trade working groups with the Gulf Co-operation Council, Israel, India, China, Norway, Turkey and South Korea.[11]
  9. Chlorine-dipped chicken[12] from the United States has become emblematic of people’s concerns about future trade deals with countries whose standards differ from our own, but is only the tip of the iceberg. A wide coalition of stakeholders have already written to Liam Fox and Brexit Secretary David Davis to express concerns about food standards issues including (but not limited to) matters such as overuse of antibiotics in farming, irradiated meat, the prevalence of high fructose corn syrup in US processed foods and food labelling.[13]
  10. There are also concerns relating to evidence that free trade agreements such as NAFTA have been associated with a significant increase in diet-related diseases associated with increased consumption of cheap imports of highly processed food and sugary drinks.[14]
  11. At the time of writing, we are 9 months away from the UK Secretary of State for Trade having the legal powers to sign and ratify trade deals. Recent reports on EU/UK trade discussions suggest that Liam Fox will have less than three months between conclusion of withdrawal negotiations at an EU summit in December and Brexit Day, March 29, 2019, to negotiate continuation of Britain’s current free trade agreements.[15]
  12. Yet there is still no mechanism for civil society or parliamentarians to set a mandate for UK trade negotiators, scrutinise negotiations, undertake scientific reviews on food safety or sustainability or indeed to have any say on the proposed deal. Not only that, but the DIT is refusing to answer even simple questions from parliamentarians about the meetings of trade working groups – for example, when they take place and who attended.[16]
  13. Who will decide what we are prepared to sacrifice in food and farming standards in exchange for the US accepting British steel, for example? Who will be in the room negotiating and who will they call for advice when the negotiations touch on sensitive food and farming issues, especially those – such as farm antibiotics – that require a level of specialist technical expertise?
  14. If we are allowed to know who these people are, we would tell them that under the terms of any trade deals we expect our food, farming and fishing standards to guarantee provision of a reliable and affordable supply of food. These are not barriers to trade, nor are they protectionist – they are healthy, fair and sustainable ground rules for the benefit of everyone. We want food that is: 
  1. Trade deals must deliver on national priorities for food and be open to public debate, scientific review and parliamentary scrutiny and consent, fully including and respecting the devolved administrations.
  2. Trade deals must deliver on achieving objectives to which the UK has already signed up, and these must take precedence, such as the Paris Climate Change Agreement, International Labour Organisation conventions, UN Sustainable Development Goals and the WHO’s One Health approach to good governance of antibiotics.
  3. It is for all of the above reasons that we calling on Government to publish as much as it can about trade negotiations.

What level of access should Parliament and the devolved administrations and legislatures have to trade policy documents, including trade negotiation texts?

  1. We believe there should be a transparent process for scoping potential trade agreements before starting negotiations, as is currently done in the EU. This should involve impact assessments looking at social (including public health; education), economic, human rights, environmental, labour and gender impacts both in the UK and in developing countries.
  2. Given how long trade deals can take to negotiate, and how they will have an impact on all of us, we believe these should be conducted by a body independent of any government.  The findings should be published in an accessible, non-technical, language and format so as to be readily understood by a general audience. These findings must be taken into account in a decision whether to go ahead and how the trade negotiations should be shaped.
  3. We would like to see UK parliamentarians (for example members of a trade scrutiny committee) and devolved administrations and legislatures having full access. They are our elected representatives and should have oversight over what is being negotiated. We believe that better outcomes can be achieved with regular contact between parliamentarians and UK trade negotiators, and with openness about developments.
  4. The current Secretary of State for International Trade conceded in an interview with the BBC Radio 4 Today programme on the 7 November 2017 that negotiators on the EU/US TTIP deal did a lot of work only to find out too late that the public wouldn’t accept it. In that interview he said we would need to understand the public’s parameters early on and that we needed a consultation mechanism that was “wider and more generous than any other country has at the present time”. Sustain agrees with him on this point.

How should the Government consult business and civil society groups on trade policy matters, including prospective and on-going trade negotiations?

  1. We believe the Government should conduct thorough impact assessments, as outlined above. There should then be a thorough consultation process, during which business, public agencies and standards enforcement bodies, civil society and others could contribute their views and help set mandates for negotiators.
  2. Mechanisms should be created whereby interested parties can scrutinise negotiations, and scientific experts on areas such as food safety, food security and sustainability can flag risks. This would not be tying the hands of our UK trade negotiators; the process of setting mandates and scrutinising trade deals is already undertaken in other countries such as the United States, why should we expect any less?
  3. As well as inviting submissions, the relevant body should actively approach and encourage submissions from a wide range of groups, particularly those likely to be strongly affected by the potential deal. The outcome of the consultation must help shape trade negotiations.
  4. From Sustain’s perspective, we are not encouraged by feedback from food system stakeholders about the level of Brexit-related consultation to date. Many have expressed strong frustration at the lack of consultation, and the apparent lack of understanding by senior policy-makers about the profound implications of the various future trade scenarios for food, farming and fishing. A major fear has been that “consultation is skewed towards big industry” and we would be concerned if this continued on in the government’s approach to trade negotiations. A very large proportion of the UK’s food and food-related industries are SMEs, employing 3.9m people.
  5. The possibility of future trade deals being agreed without parliamentary or public scrutiny, and without social or environmental impact assessments, adds to a general sense of anxiety about the future for the UK’s high food standards. It is notable that the EU requires a sustainability assessment (social, economic, environment) for trade deals. So should the UK.

What role should Parliament and devolved administrations and legislatures have in drafting and/or approving the UK's negotiating mandate for trade negotiations?

  1. We are concerned that the UK’s Department for International Trade has apparently already established 14 working groups with non EU countries to discuss trade but refuses to divulge even basic details about their meetings. To the best of our knowledge, the devolved administrations are yet to have been consulted on these discussions. The DIT has been at pains to say these are not formal trade discussions, and yet they must surely be at least paving the way. As yet, there has been no public consultation.
  2. Sustain believes that Parliament’s consent should be secured for the trade negotiations to begin, including on setting the objectives, principles and boundaries of the negotiations. There should be a remit for the devolved administrations to input into the mandate process.
  3. With particular regard to the food system, several of the specialist stakeholder organisations that we have consulted with have expressed dismay at the lack of public and political understanding that food and farming are devolved matters, and the lack of attention to these issues in relation to current food standards and import/export arrangements; let alone to the implications for new or revised trade deals. As one senior academic expressed at a consultative event, “The impression is of extreme fluidity: lots of different options, contradictory statements and opinions coming from government, and nothing is clear.”
  4. Special concern is expressed by colleagues from both sides of the border in Ireland that the terms of various legislation and agreements may undermine the terms of the Belfast Good Friday Agreement. This requires agreement of both Northern Irish and Republic of Ireland participants on certain matters. Such concerns do not yet appear to have been addressed adequately by the Government.
  5. Trade agreements also look set to highlight many different potential divides between approaches in the four nations of the UK, especially with regards food and farming.

What procedures should be in place for the UK Parliament and devolved administrations/legislatures to scrutinise trade agreements as they are being negotiated?

  1. We believe that transparency should be the norm during trade negotiations, and mandates, negotiating texts and informing materials made public unless there is a specific and convincing reason not to.
  2. In particular the UK should release the text of its proposals ahead of each negotiating round, and any texts agreed between the parties should be released after each negotiating round. This is becoming normal practice by other governments and reflects the trend for increasing transparency in EU and WTO negotiations, as well as common practice in other areas of international negotiations such as on climate change.
  3. Whilst not a specialist in parliamentary procedure, Sustain backs calls for a scrutiny body, such as an independent parliamentary committee to be established. It should have access to all documents and be fully involved in providing guidance and scrutinising any trade negotiations and listening to public concerns. Devolved administrations should be fully involved. Civil society should also have a robust mechanism for being involved and consulted throughout, with the freedom for such groups to comment and have evidence heard during the negotiation process.

What powers should Parliament and the devolved administrations and legislatures have over the ratification and implementing legislation of UK trade agreements?

  1. We believe Parliament should have an automatic debate and vote on a UK trade deal before it is implemented. The EU Parliament and US Congress are both ensured a vote on trade agreements – why should the UK Parliament and British people expect any less?

June 2018









[9] Which? (May 2018) Consumer Insight: Brexit and Food: (see pages 25 onwards for responses relating to Brexit)








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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