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8 February 2019

Rt Hon Michael Gove MP

Secretary of State
Department for Environment, Food and Rural Affairs
2 Marsham Street
London SW1P 4DF

Dear Secretary of State

As representatives of a very broad swathe of the UK’s farming and food &
drink supply-chain, we are writing to you today on a matter of great urgency
and of deep concern to our members.

In fewer than 50 days, the UK will leave the European Union. The legal
default is that we will do so irrespective of whether or not we have signed a
withdrawal agreement and, at present, that no-deal Brexit looks ever more
the likeliest outcome.

Businesses throughout the UK food chain – and their trade associations - are
now totally focused on working to mitigate the catastrophic impact of a no-
deal Brexit. Large amounts of time, money, people and effort are being
diverted to that end.

At this moment of potential crisis for our industry, it cannot be ‘business as

usual’ within government. Neither we nor our members have the physical
resources nor organisational bandwidth to engage with and properly respond
to non-Brexit related policy consultations or initiatives at this time.
Government has recruited many extra staff; we cannot.

We very strongly urge you therefore to require of your Cabinet colleagues

that a range of current and planned consultations that will impact food and
drink, some of which are expected shortly, are firmly and clearly placed on
“pause” until this uncertainty is over. A list of the relevant consultations of
which we are aware is given in the appendix to this letter.

If government seeks to press ahead with these consultations it will be seen

by some as a sign of bad faith and many organisations may decline to

We are grateful for your assistance with this issue.

Ian Wright CBE Paul Rooke Andrew Pollard
Chief Executive Head of Policy President
Food and Drink Agricultural Industries Association of Bakery
Federation Confederation Ingredient Manufacturers

Pete Robertson David Camp Chris Stemman

President Chief Executive Director
Association of Cereal Association of Labour British Coffee Association
Food Manufacturers Providers

Walter Anzer John Hyman Jack Ward

Director General Chief Executive Chief Executive
British Food Importers British Frozen Food British Growers
and Distributors Federation Association

Nick Allen Richard Griffiths Declan O’Brien

Chief Executive Officer Chief Executive Director General
British Meat Processors British Poultry British Specialist Nutrition
Association Association Association

Nick Bennett Judith Bryans Gordon Polson

Chairman Chief Executive Director
Council for Responsible Dairy UK Federation of Bakers
Nutrition UK

James Bielby Nigel Jenny David Thomson

Chief Executive Chief Executive Chief Executive Officer
Federation of Wholesale Fresh Produce Food and Drink
Distributors Consortium Federation Scotland

Andy Richardson Graham Keen Liz Murphy

Chairman Executive Director Chief Executive Officer
Food and Drink Wales Health Food International Meat Trade
Industry Board Manufacturers’ Association

Bob Price Terry Jones Michael Bell

Director and Policy Director General Executive Director
Advisor National Farmers’ Union Northern Ireland Food and
National Association of Drink Association
Cider Manufacturers
Dick Searle Andrew Curtis Andrew Kuyk CBE
Chief Executive Director General Director General
Packaging Federation Potato Processors’ Provision Trade
Association Federation

James Withers Simon Cripps James Smith

Chief Executive Executive Chairman Chairman
Scotland Food and Seasoning and Spice UK Flavour Association
Drink Association

Kate Nicholls Dr. Sharon Hall

Chief Executive Officer Chief Executive
UK Hospitality UK Tea & Infusions


Food and drink-related policy consultations that we are expecting:

• A Deposit Return Scheme for England & Wales (with links to Scotland
and NI possibly)

• A consistent national recycling collection service

• An overhaul of the current Producer Responsibility programme, the

Packaging Recovery Note (PRN) system

• Proposals for a tax on plastic items with less than 30% recycled

• Proposals to further restrict the advertising of HFSS foods and drink

Farmers also have a particular concern about extending the mandate under
‘Making Tax Digital’ at this time.

Defra consultations, where consultation timetable should be paused:

• Consultation on Protecting and Enhancing England’s Trees and

Woodlands (consultation closes 28/02/2019)

• Fitness Check of the Water Framework Directive and the Floods Directive
(consultation closes 04/03/2019)

• Improving our management of water in the environment (consultation

closes 12/03/2019)

Expected consultations that should be delayed:

• National Action Plan on the sustainable use of pesticides

• Clean Air Strategy - urea fertiliser use

• Consulting on a chemicals strategy

• Setting targets for the 25 Year Environment