Official Report: Minutes of Evidence

The Chairperson (Ms Ferguson): I welcome Bronagh Mallon and Helen Thompson, pesticides policy officers, Department of Agriculture, Environment and Rural Affairs; Philip Kennedy, head of food safety policy and delivery, Food Standards Agency (FSA); and Mark McGregor, trade and Windsor framework branch, Department for the Economy, who regularly attends the Committee. Feel free to present when you are ready.

Ms Bronagh Mallon (Department of Agriculture, Environment and Rural Affairs): Good morning. Thank you for the opportunity to speak to the Committee today. Helen Thompson and I represent pesticides policy, which sits in the environmental farming branch of DAERA. We are here to speak to the proposal for a regulation amending regulations (EC) 999/2001, (EC) 1829/2003, (EC) 1831/2003, (EC) 852/2004, (EC) 853/2004, (EC) 396/2005; (EC) 1099/2009, (EC) 1107/2009, (EU) 528/2012 and (EU) 2017/625 as regards the simplification and strengthening of food and feed safety requirements.

The proposal seeks to update and streamline elements of the regulatory framework underpinning several regulations within DAERA's remit. Our assessment of impact covers those aspects of it for which DAERA is the responsible competent authority in Northern Ireland, including regulation (EU) 2017/625 on official controls, covering plant health, sanitary and phytosanitary (SPS) measures and animal feed; Council regulation (EC) 1099/2009 on the protection of animals at the time of killing; regulation (EC) 999/2001 on transmissible spongiform encephalopathies; regulation (EC) 1107/2009 concerning rules for approving, authorising and controlling plant protection products; and regulation (EC) 396/2005 setting the maximum residue levels (MRLs) of pesticides permitted in or on food and feed of plant and animal origin sold in the EU.

Given the practicalities that would be involved in having officials covering all areas of the proposal attend the Committee, we are here to provide further information and to answer questions specifically on regulation (EC) 1107/2009 and regulation (EC) 396/2005. Officials' current assessment of the other regulations within DAERA's remit is that applying or not applying the proposed amendments is unlikely to have a significant effect on the everyday life of communities in Northern Ireland. However, any specific questions concerning those areas can be followed up by the relevant DAERA officials after the meeting.

Under the current framework, EU pesticides regulation is primarily governed by regulation (EC) 1107/2009, which allows to be marketed or used only plant protection products that are effective and which pose no unacceptable risks to human health, animals or the environment.

All plant protection products undergo a two-step authorisation procedure. First, the EU approves active substances, and, after that, member states authorise commercial forms of plant protection products containing the approved active substance.

Regulation 396/2005 sets maximum residue limits for pesticides in food and feed, based on the European Food Safety Authority (EFSA) risk assessments and applies equally to EU-produced and imported food. DAERA is the competent and enforcing authority for both regulations, with the Health and Safety Executive (HSE) in GB delivering key functions on DAERA's behalf.

I move now to the proposed EU amendments. They form part of a wider EU simplification package that is aimed at reducing the administrative burden while maintaining safety standards. Key changes include removing mandatory 10- to 15-year periodic renewals for most active substances. That will, potentially, allow unlimited approvals, except for higher-risk substances. Reassessment would shift to a Commission-led, trigger-based model when new evidence emerges, alongside longer transitional and grace periods. That represents a significant move away from automatic reviews.

While biocontrols and biopesticides are already regulated, biocontrol products, such as microorganisms, pheromones and plant extracts, currently face similar and lengthy approval processes to those of chemical pesticides. The proposal would promote their use through clearer definitions, accelerated and provisional approvals and a more favourable regulatory pathway supporting integrated pest management.

I move now to proposed changes regarding science, data and residues. The legal requirement to use up-to-date science remains, but longer approval periods and procedural simplifications could reduce automatic scrutiny. Expanded data protection and longer grace periods will provide industry with certainty but prolong the market presence of substances. Science on maximum residue levels remains unchanged, but the procedures would be simplified and import controls strengthened.

I move now to implications for Northern Ireland. The Department's assessment is that the proposal is unlikely to have a direct or immediate impact on everyday life. However, indirect impacts for Northern Ireland plant protection users would arise from faster access to biocontrol and alternative products and reduced regulatory disruption, which would help to avoid yield losses, emergency derogation costs and compliance uncertainty rather than lowering fees or product prices.

In conclusion, the changes retain formal safety and scientific standards whilst moving towards more flexible and efficiency-driven mechanisms for review and oversight. The anticipated benefits include faster innovation, particularly for biocontrol, and the boosting of long-term competitiveness by cutting administrative burdens.

Mr Phillip Kennedy (Food Standards Agency NI): Thank you, Chair and members, for the opportunity to brief the Committee on the matter. I am the Food Standards Agency's head of food safety policy and delivery. I am here to answer your questions on areas in the FSA's remit: genetically modified microorganisms (GMM) in food and feed; the authorisation of feed additives; notification to the EU of national hygiene legislation; and the accreditation of laboratories.

The FSA is a science- and evidence-led organisation. Our priority is to ensure that Northern Ireland consumers benefit from robust public health protection. All the changes in the FSA's remit that would be introduced by this proposal are technical in nature and tightly focused on the simplification and clarification of existing law. There are no new requirements and no changes to the level of protection for consumers.

For genetically modified microorganisms, the proposed amendment would provide explicit confirmation that food and feed fermentation products that are obtained using genetically modified microorganisms as processing aids, are excluded from the definition of "Produced from GMO". That is a legal clarification in keeping with the FSA's long-standing view on the use of GMM and does not change any wider policy. There are several proposals for procedural changes to the authorisation of feed additives. They include making the majority of feed additive authorisations valid for an unlimited time, rather than the current period of 10 years, in line with the position in Great Britain. Authorisations could still be suspended at any time if there is a change to safety conditions, and certain groups of higher-risk additives would remain subject to the 10-year renewal requirement. There is a proposed administrative change to simplify how national authorities notify the EU of domestic adjustments to hygiene requirements. Finally, the proposed regulation would create the possibility for less rigid accreditation requirements for specialist laboratories, which are responsible for maintaining standards for the routine testing of food and feed, reducing administrative burden. We communicated the proposed changes in the FSA's Northern Ireland industry stakeholder bulletin, which reaches over 5,000 subscribers, and have engaged directly with labs and feed stakeholders. No concerns were raised.

FSA officials will continue to monitor the proposals as they move through the EU process, and continue to engage in four-nation discussions with our colleagues in Food Standards Scotland, and work with DEFRA, DAERA and the Department for the Economy.

Thank you for sharing questions ahead of the session. I am happy to go through the responses relevant to the FSA.

The Chairperson (Ms Ferguson): Yes, please.

Mr Kennedy: Question 1 asked:

The European Commission estimates that the total cost saving for businesses across the EU due to the feed additive proposals would be €22·1 million, with a further €5 million in savings for national and EU Administrations. There would be proportionate direct and indirect savings for Northern Ireland businesses and public authorities.

The majority of Northern Ireland feed production capacity is focused on finished compound feeds. The FSA is not aware of any feed additive producers in Northern Ireland. It is aware of two pre-mixture producers in Northern Ireland that would be expected to benefit from the changes to labelling requirements, which would reduce the amount of text that must be printed and translated, reducing costs and simplifying logistics.

The European Commission states that the legal clarification on genetically modified microorganisms would reduce expenditure by businesses and competent authorities linked to unnecessary product withdrawals due to a lack of clarity on the legislative position. The clarification reflects the FSA's long-standing understanding on the use of GMMs.

The European Commission states that each hygiene notification under current requirements induces staff costs equivalent to three weeks of staff time in the notifying country, and the proposals could reduce that by 25% to 50%. Northern Ireland public authorities would benefit from that saving if any notifications were made in future.

The European Commission has assessed that the estimated total cost saving for national and EU Administrations due to the laboratory accreditation proposals would be €602·2 million, and there would be proportionate savings for Northern Ireland public authorities and laboratories.

Question 2 asked:

No negative impacts are foreseen. These are procedural changes and technical clarifications, which maintain consumer protection.

Question 3 asked:

The proposals in the FSA's remit do not place any new regulatory or administrative obligations on businesses or public authorities in Northern Ireland.

Question 4 asked:

The FSA has a network of five EU-based national reference laboratories encompassing 14 specific areas, and two Northern Ireland-based official laboratories. Responses were received from all those labs. Northern Ireland-based official laboratories broadly welcomed the recognition of operational constraints, the need for flexibility and the aim to reduce administrative burden. The proposals would give the European Commission the ability to introduce legislation setting out future derogations from current laboratory designation requirements in more detail. Therefore, it is difficult for laboratories to determine how much benefit might be gained.

Based on currently available information, laboratories welcomed simplified accreditation requirements, particularly to improve responsiveness during emergencies and supply shortages, and to enable testing outside strict accreditation scopes, with appropriate quality controls remaining to ensure the validity of results. That could deliver increased testing availability and resilience.

Question 5 asked:

The FSA will continue to engage with stakeholders through our regular engagement with our network of laboratories, our animal feed and meat stakeholder fora, and the Northern Ireland food industry liaison group. The FSA continues to provide updates in the Northern Ireland food industry stakeholder bulletin, which reaches over 5,000 subscribers. The FSA is also working alongside DAERA and the Department for the Economy to seek stakeholders' views.

Mr Mark McGregor (Department for the Economy): Thank you for the invitation to provide evidence. My remarks on behalf of the Department for the Economy will be brief, as only one of the 10 measures falls within DFE's remit, which is the measure concerning biocidal products regulation (BPR). It is a bit different from what I usually attend to give evidence on, in that the biocidal products regulation is a devolved matter, which falls to the Department for the Economy. However, we rely heavily on the subject matter expertise and technical and scientific support from the Health and Safety Executive (HSE) of Great Britain and our partner body, the Health and Safety Executive for Northern Ireland, holds the competent authority role in relation to biocidal products.

I turn briefly to the proposed changes as a result of the amendments. The proposal aims to free up regulatory capacity to complete the EU biocidal review programme. That has been ongoing since 2012, when the BPR came in. The intent is to update the EU biocidal review programme by removing routine, time-limited renewals for most active substances. Approvals would, in general, no longer automatically expire, except for some substances in higher hazard classes, with there being exclusionary criteria and candidates for substitution. In certain cases that are already in renewal or where a renewal application is not submitted in time, the European Commission would retain powers to impose time limits, where justified, and initiate reviews where evidence indicates that approval conditions may no longer be met.

A related procedural change simplifies how European Union authorisation decisions are published, moving away from a full publication in all languages in the Official Journal of the European Union, which is a lengthy process, to information being published via the European Chemicals Agency's (ECHA) systems. The ECHA is based in Helsinki and is seen as the key source of information in those matters.

I will briefly touch on the impact for Northern Ireland. DFE's assessment, supported by our Health and Safety Executive of Great Britain colleagues, is that any practical impact on Northern Ireland businesses and consumers is likely to be very limited. The expectation is that, with fewer renewal applications being required, there will be a resultant reduction in compliance and administrative costs for the businesses affected, so the potential impact is a reduction in administrative and compliance costs for businesses. No impact has been identified for consumers.

Unfortunately, as of just before the meeting, we had still not received input from the Health and Safety Executive of Great Britain on the questions that the Committee sent in advance. The answers to some of those questions rely on its specialist knowledge. We are following up with it to emphasise the importance of getting the return through in a timely manner and in a written format, so that I can submit that to the Committee after the meeting. I am able to touch on some of the questions in a general way, but more detail is required from the subject matter experts.

The first question asked:

That question will have to be addressed by the Health and Safety Executive of Great Britain. There are some quite difficult procedures involved in trying to extract that information because businesses do not record trade and trade volumes on the basis of a regulatory regime that might come into place through the EU. You will be aware things such as standard industrial classification (SIC) codes and commodity codes, which identify business activity. We are asking HSE GB to look at that data to see whether it can extract any information. Such information will, inevitably, be caveated, because there is not alignment between the regulations and how businesses report. When I get further information from the Health and Safety Executive of Great Britain, I will forward that on to you.

It is same situation when it comes to the second question:

Generally, it is a reduction in the administrative burden. It is putting a pause in a renewal programme that has been ongoing, so there is not an additional burden. However, there is some work to be done in understanding what that means for manufacturers in some of the areas that may be at the higher end of the hazard risks. That is another area where I am pressing HSE GB's experts to give a clearer answer that would benefit the Committee.

The third question is:

It will not do so because there will be a reduction on the administrative burden on businesses, and the change does not relate to any activities or functions that are carried out by public authorities. There is a change to how ECHA, as an agency of the EU, operates. The Departments, the competent authority, the market surveillance authority and the enforcers do not see any increased demands on us from that. When we look at the consumer aspect of it, the changes in relation to business are regulatory and administrative matters, so, generally, there are not going to be any consumer impacts here.

The fourth question is

Again, I want full detail from the Health and Safety Executive of Great Britain to explain that. The impact is anticipated to be minimal. Great Britain has, essentially, a mirror regulation, a GB/UK biocidal products regulation, which is, in essence, almost identical to the EU process. It is going through the same process about grandfathering in old registrations and the burden that that is creating in the system. Great Britain is looking at that, and I think that its approach is slightly different. Therefore, there may be some frictions around the transfer of information between the two systems. I do not know how deep and impactful that is likely to be, so I will provide you with more information on that from HSE GB when it replies to us.

The next two questions were for DAERA and the FSA. The seventh and final question was:

Colleagues in DAERA and the FSA have given some comment on how they have been engaging with some directly impacted stakeholders. At the Department for the Economy, the route that we have used is via our arm's-length body Invest NI. It has a website called NI Business Info. We availed ourselves of that to put up a short article that we described as a call for comment. It has been turned around too quickly and at great pace, with not a lot of detail, so we cannot refer to it as a consultation. It is an opportunity for businesses to give us any comments, observations or concerns that they may have. That is open and live on the NI Business Info website at the minute. It was publicised through the Invest NI weekly bulletin, which has an audience of over 10,000 people in the business and academic sphere. To date, we have not got any responses from that call for comment. It is open for another two weeks. If we were to receive anything, we would make sure that we forward that on to you for your consideration. I am happy to take any further questions.

The Chairperson (Ms Ferguson): Thanks, Mark. Before I let members in, if concerns were raised, Mark, how would you feed those in?

Mr McGregor: We meet the Windsor framework side of the Department for Business and Trade (DBT) quite regularly, and we also meet the Windsor framework task force on the chemicals side. Chemicals is a devolved matter and sits with my team. We have a coordinator for that, and they engage with the subject matter experts in HSE GB in that instance. We would also need to engage with DBT if an issue were raised and with the Windsor framework task force to escalate it. It would not be something that we could resolve, but we could escalate any concerns that were raised via that mechanism.

The Chairperson (Ms Ferguson): It is disappointing that the Health and Safety Executive of GB was not able to respond to you so that we could have further clarity and detail. Thank you for giving some presentation. What is that relationship like? Will this be a one-off in a sense?

Mr McGregor: It should be. Our relationship with the Health and Safety Executive of Great Britain has been extremely strong since exit started. It has supported us in a comprehensive manner. This is a one-off situation. I do not expect it to be repeated.

The Chairperson (Ms Ferguson): One final question from me: data has been an issue, and how we can get the granular detail for people or businesses that are impacted on here in the North in comparison with GB has been raised before. Do you have any thoughts on how the data is held and how you can get localised data?

Mr McGregor: There are methods, and we have done it before. Previously, when we gave evidence to the Committee, we asked our analytical services colleagues to have a look at it, because they are specialists. We asked the specialists in HSE GB to look at it this time. Economists and the like can look at those SIC codes and try to cross-reference them with commodity codes and then try to work out what the GB versus Northern Ireland percentage of trade is; whether it is a company that covers all four Administrations or an all-islands company. It is a difficult piece of work to do, and we have done it previously. Of necessity, it has to be caveated, because we are trying to put out information that is not matching up. There is no way of recording how many biocidal product movements there have been. Some of the SIC codes would be on pesticides and chemicals or whatever. Therefore, we can work with it, but the figures will never be entirely accurate.

The Chairperson (Ms Ferguson): Thank you, Mark.

Mr Brooks: Thank you for your presentation so far. Notwithstanding our own general disapproval of and objection to businesses here being subjected to EU regulation laws, something that concerns me about some of the things that come before us, including this, is the flexibility that the EU gives itself to decide on and change things, as it would be natural for anybody to do, I guess. In the FSA's responses, it has made a virtue of the ability to look at future derogations. Derogations with the EU are usually fairly hard won.

What does digital labelling empower the EU to do in the future? How does that interact with us as regards its making any significant change? Would that have to come before us by way of regulations being laid in Brussels or is the EU able to do that without the formal laying of regulations or making laws in Brussels? Will we have notification of that? Will we be able to feed into that or could it change quite quickly and we would have to just react?

Mr Kennedy: Article 16 would be amended to clarify that the feed business operator responsible for first placing the feed additive on the market or the premixture of additives is responsible for the labelling. That aligns with the requirements in regulation 767/2009 on placing on the market and use of feed. It would also be amended to permit digital labelling for certain non-safety-related information. Currently, the labels must be attached to the packaging or the container. The proposal allows for some non-safety information, such as the name and address of the person responsible, approval number of establishment and the batch details, to be provided digitally.

Mr Brooks: If the EU were to change any of those requirements or want to add to or take away anything from that in future, would that process bring it before us again? Would this Committee or our Departments have sight of that going forward?

Mr Kennedy: We would monitor that and give you sight on it, if necessary. At the minute, we do not see any —.

Mr Brooks: We would have limited, if not zero, ability to influence at that point, I imagine.

Mr Kennedy: Yes.

Mr Brooks: Yes. I am just establishing that danger so that we are aware of it, particularly because the understanding is that the UK Government do not intend to go down that line. We quite often hear when things come before us that the UK Government intend to follow that two years down the line without any guarantee. In this case, they do not intend to go down that line. What is the rationale for that? I see that the UK Government also say that there could be enforcement challenges because of that.

Mr Kennedy: I will go back to the enforcement challenges, because it is an interesting question. In relation to feed additives, there is a reference to enforcement challenges. It reflects the practical operation of a dual labelling system: digital and written. Under that approach, the feed business operator has the option to provide certain non-safety-critical information digitally, while all essential safety information must be contained in a physical label.

Digital labelling for feed additives is optional rather than mandatory, and, as such, the impact on enforcement officials is expected to be limited and gradual. Where feed business operators choose to use digital labelling, it may introduce a minor additional step during the inspections, as enforcement officers may need to adjust inspection practices. However, that is expected to be minor, as digital information provided by feed operators must be readily accessible to the competent authorities on the label.

That probably answers the second part of your question. The first part was about whether we perceive that there will be any impacts from the difference between GB and Northern Ireland. Is that correct?

Mr Brooks: Yes.

Mr Kennedy: To be honest, I have confidence in the regulation in that the feed business supplier will have to provide exactly the same detail only in a different format, and we can access it that way, but we will monitor it.

Mr Brooks: GB businesses are already unable to move ruminant dry gelatine without full certification. How can we be confident that we will not see the competitiveness of businesses being impacted on again?

Mr Kennedy: I will have to come back to you on the issue of ruminant dry gelatine without certification. I would need to consult the subject matter expert.

Mr Brooks: Thanks very much.

Mr Martin: I have one question regarding the DAERA evidence. In question 5, you mention:

etc. The question was:

You said in your answer:

In the next paragraph, you said that it is:

What is the scale of Northern Ireland's agrochemical market? For clarity, is that businesses in Northern Ireland that make agrochemical supplies?

Ms Thompson: It is users.

Ms Mallon: Yes. It is regarding the use and size and significance of the Northern Ireland market.

Mr Martin: The people who buy those things.

Ms Mallon: Yes, it is the size of the market. Northern Ireland is considered by manufacturers and distributors to be a very small market. Subsequently, we are not considered a priority, as the sales here are not big enough for the companies to be overly concerned about. If something impacts on us, because sales here are significantly smaller than in the rest of the UK and Europe, we are not seen as a major place to buy in large bulk quantities of pesticides. We are just not a big market as a whole.

Ms Thompson: If a company wants to sell a product in a member state, it has to send in an application, which costs the company money. Therefore, when companies look at Northern Ireland, they will have to pay the full cost for product assessment and authorisation for the sale of a few thousand litres of a particular chemical, and they are saying that it is simply not viable and is no longer cost-effective for them. Even though the active is approved in Europe, we are seeing losses when it comes to the renewal of the product, because they are not prepared to spend the money on the small market in Northern Ireland. The likes of horticulture is suffering particularly badly because it is a very small market.

Mr Martin: In the context of your answer to question 5, what does an agrochemical do?

Ms Thompson: It is basically pesticides.

Mr Martin: My understanding, although it might be wrong, is that Northern Ireland is quite sizeable. If we look at the proportion of businesses in Northern Ireland, we see that agri-food is quite large. Am I wrong in saying that?

Ms Thompson: No, but you have to remember that not every farmer will use pesticides to any great extent. You will find that the arable farmers are big users. The horticulture sector is small, but it is a big user. Grassland farmers are minimal users, generally. The number of users is seen as being very small compared with elsewhere.

We were in a better position when the chemical manufacturers could apply for UK-wide authorisation, because the whole of the UK is a bigger market. However, what we have found since the Windsor framework is that they cannot always do UK authorisations or applications, because the active substance is different, the MRLs are different or whatever. There is divergence there. We are losing as a result of that. That is the reality. We have heard directly from CropLife, which represents the chemical industry, that that is why the manufacturers are not supplying to Northern Ireland. It is based on cost.

Mr Martin: OK. Do you have any idea of the amount of those products that are bought in Northern Ireland?

Ms Thompson: No, that is not something that we have data on at this point.

Mr Martin: Does the Department for the Economy have any data on that?

Mr McGregor: Well, not immediately. [Laughter.]

Mr Martin: You are good, Mark, but you are not that good.

This is very new to me; it is not an area that I know a lot about. You mention:

My understanding — I may be wrong — is that a lot of farmers use those products in Northern Ireland. Given the fact that we have a large agri-food industry, I thought that it would have been larger than that.

My only other question is about DAERA's level of engagement with stakeholders on the issue. What level of stakeholder engagement have you had with the people who buy such things?

Ms Thompson: At the minute, very little. We speak to the UFU's pesticide policy official. She is aware of this. However, the problem at the minute is that we do not have enough detail. We do not know the full implications. We have a proposal here, but we do not quite know what the impact will be. A lot of it is administrative. It is more likely to affect the likes of the HSE, which is the national regulator for biocides for the whole of the UK. It will probably make its processes a little bit shorter etc. We have not done that, because we do not have the granular detail yet on what it is going to be.

Mr Martin: What did the UFU say about that following your engagement with it? What is its position on it?

Ms Mallon: It is really about raising awareness at the moment. We keep in regular contact with the UFU, and we make it aware of what is coming down the line. Like us, it cannot really comment at the moment, because it does not have enough detail to say how it will impact on it. It is very much a watch-and-see situation.

Ms Thompson: Yes. There is a positive, in that, if it reduces the administrative burden, we can get those products and actives on the market faster.

Mr Martin: That is DAERA's view. I just wonder —.

Ms Thompson: The big issue that farmers have at the minute is that GB can process the likes of new biocide products faster or get new products on the market faster. This may allow the EU to streamline its processes and get actives on the market quicker, aligning it more with GB.

Mr Martin: On the basis of your evidence, is it fair to say that the UFU does not have a position on that?

Ms Mallon: Not until it gets the detail. We are all looking at it together. We are monitoring the situation.

Mr Buckley: Thanks very much for the evidence this morning. This follows on distinctly from Peter's last comments. Obviously, my first big concern is the deeper divergence with GB. It has been presented as procedural and technical, but we know that it will affect almost every aspect of how products make their way through the food chain, and, therefore, it may have a bigger impact than has been perceived. When I look at the areas that are most exposed to the change, I see that they are the feed manufacturers, farmers and supply chains. There will be friction in the supply chain. Feed manufacturers probably have the highest level of exposure, particularly with the additive rules, labelling and definitions. Have I heard correctly that, in your engagement with them, they had no issue at all with the regulation?

Mr Kennedy: We have engaged with feed manufacturers. The regulation applies to feed additive manufacturers, and that is a difference in Northern Ireland. I would need to go back to the detail to check.

Mr Buckley: I am keen to ensure that there is a uniformity of view on that among the feed manufacturers so that we can ascertain the impact. I am also keen to better understand the trade flow of the source product to Northern Ireland and whether that has been impacted on.

You mentioned the UFU to Peter, and I heard that it has not given an opinion on the overall regulation because it is too early in the day. Are there any plans to re-engage with the UFU to help better inform the Committee before it takes a decision? We are taking a decision today on the inquiry. I do not know whether anyone has certainty about how it will or will not impact.

Ms Mallon: We enjoy a good working relationship with the UFU, and we correspond with it regularly. We have a good relationship with the UFU's pesticide officer. As with all new things, we maintain communication, and the intention is to further engage with the UFU as the details come forward.

Mr Buckley: OK. You also mentioned reducing the administrative burden. Whilst that might be the intention of the EU regulation across Europe, we know that, because of the particular situation in Northern Ireland and the potential for deeper divergence with GB, we could perhaps increase the administrative burden and put more friction on the supply chain. Has adequate thought been given to the supply chain issue for the products that are sourced in GB to access Northern Ireland's market and vice versa?

Ms Mallon: We have not considered that yet. No.

Mr Buckley: OK. Thank you.

Mr Brooks: I want to check your awareness, and you may not know. Is the AERA Committee aware that suppliers do not want to engage with Northern Ireland because of the disproportionate cost of doing so?

Ms Thompson: Not that I am aware of. The Minister has had a lot of queries from the UFU and others. That has been pretty much continuous since EU exit. We are waiting for another discussion on that.

Mr Brooks: We should probably write to the AERA Committee to inform them about the situation.

The Committee Clerk: When the Hansard of the session is available, we can forward it to the AERA Committee.

The Chairperson (Ms Ferguson): I have a final question to do with the issue of early engagement that has persisted and that we have raised with the EU, the Cabinet Office and the task force. What further information do you need? We want to ensure that our local farms and suppliers are engaged from the start and throughout the process. Before the final proposal, will you have any more meetings on the finer detail with the UFU? Will it be done through correspondence or telephone calls? I am conscious that you do not know the finer detail of the proposal and that there may be changes, but we are keen for there to be early and ongoing engagement. What other information are you waiting for before the final proposal, or are you just waiting for the final proposal?

Ms Mallon: It is hard to determine what further information we will get between now and then. We will monitor the situation as closely as we can. If we feel that something has come through that we should share with the UFU, we will engage with stakeholders, and that is always our intention.

Ms Thompson: The key people to engage with will be the manufacturers. The impact on farmers is indirect and is something that we cannot control. Ultimately, the provision of applications and product authorisations sits with the manufacturer. If they do not submit an application to HSE for authorisation, we do not get a product. We need to understand from them whether this will make things better for Northern Ireland. Will the cost come down enough for them to view Northern Ireland as a viable market again? That is the critical thing, more than the farmers, per se. The farmers are aware that they are losing products left, right and centre through EU decisions and commercial decisions. We would like to think that this will help, but we need to dive deeper with the manufacturers in order to see whether it will open the market.

The Chairperson (Ms Ferguson): Phillip outlined the extensive consultation that is happening currently. The Department for the Economy has had some engagement. You mentioned cross-departmental working, so how is that looking at the moment?

Ms Thompson: Sorry, with —?

The Chairperson (Ms Ferguson): With the Department for the Economy, the Food Standards Agency —?

Mr McGregor: The Department for the Economy issued a call for comment, which was linked directly all 10 measures. It noted that our Department, DAERA and the Food Standards Agency were involved in giving a brief synopsis of the overall package. Even though that is not a normal route through which DAERA and the FSA would consult, we did that for the whole package. There is an opportunity for businesses to feed into that.

Mr Kennedy: The Northern Ireland industry stakeholder bulletin goes out to feed manufacturers, consumers, other Departments and district councils in Northern Ireland. There are opportunities there to engage with meat industry and feed industry stakeholder fora and to consult.

The Chairperson (Ms Ferguson): That information goes to users.

Ms Thompson: Yes.

The Chairperson (Ms Ferguson): The farmers are saying such and such, but you need information from the manufacturers as to their feelings on what the impact would be. Will you engage separately with manufacturers, or are you going to use the information that is available through the Food Standards Agency and the Department for the Economy?

Ms Thompson: We are talking about chemical manufacturers, so it is about different chemicals. Biocides are different from plant protection products.

Ms Mallon: It is not necessarily the same people.

The Chairperson (Ms Ferguson): So you will engage separately with manufacturers?

Ms Thompson: Yes.

The Chairperson (Ms Ferguson): Do you have any plans or a schedule for that?

Ms Thompson: Yes. We will make contact first through CropLife, which is the main body —

Ms Mallon: — and expand it out from there.

Ms Thompson: — and get its feedback. It is pretty quick and honest with its feedback.

The Chairperson (Ms Ferguson): That is good, thank you.

There are no other questions. Thank you, Bronagh, Helen, Phillip and Mark, for your presentation this morning; it is much appreciated.