FDF Response to DEFRA/DECC Review of balance of Competences: Environment and Climate Change

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August 2013

Like any manufacturing sector, food and drink has both direct and indirect impacts on the environment. Many of these impacts occur at local level only. But others extend beyond national boundaries to EU or international level - the most obvious example being that of greenhouse gas emissions. Some, such as water, can be both local or international, depending on where and how raw materials are sourced.

This presents an extremely complex set of challenges in terms of regulation. Generally speaking the guiding principle should be one of subsidiarity, consistent with the potential for the impact in question to have wider ranging consequences. The interpretation of this principle will, however, vary according to the geographical location of the Member State concerned.

The key issue is therefore the extent to which it is necessary to harmonise legislation at EU level in order to provide a level playing field for companies competing both within the Single Market and more globally. There is no simple answer to this. Even within a harmonised system, it is important to maintain a degree of flexibility to respond to particular local circumstances.

This balance can really only be assessed on a case by case basis. And, for the reasons already given, a UK perspective will not necessarily be shared by a majority of EU Member States, which gives rise to a slightly different set of issues in respect of decision making. The ability to derogate is fundamental to this, subject to safeguards against distortion of competition and other unintended consequences.

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