1 / 10

TACKLING REGULATORY CREEP Some observations from food regulation Michael Hunt

TACKLING REGULATORY CREEP Some observations from food regulation Michael Hunt Food & Drink Federation. Regulatory Creep? Different things to different people. FDF’s concerns fairly well covered by BRTF definition:

deason
Télécharger la présentation

TACKLING REGULATORY CREEP Some observations from food regulation Michael Hunt

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. TACKLING REGULATORY CREEP Some observations from food regulation Michael Hunt Food & Drink Federation

  2. Regulatory Creep? • Different things to different people. • FDF’s concerns fairly well covered by BRTF definition: • “The process by which regulation is developed or enforced in a less than transparent way and not in accordance with the Principles of Good Regulation.” • Most UK food law from Brussels. • Sound principles become victims of politics and targets • So welcome implementation of Commission’s Better Regulation Action Plan.

  3. Better Regulation • Not so much deregulation as good regulation • So “better regulation” is the aim • Clear • Practicable • Enforceable • Not just regulations but • Regulatory system and • Activity of regulators

  4. Recommendation 2 Stakeholder involvement on what constitutes compliance Consequence of not providing measurable compliance criteria in technical legislation Example: EU GM legislation Goal: consumer information and choice Flaw: not based on detectability of GM material Result: unenforceable, fraudsters’ charter

  5. Recommendation 4 • Purpose and legal status of guidance • Involvement of the regulated and enforcers • Not “enforcing” against guidance • Good examples of best practice guidance: • - QUID • - allergen labelling

  6. Section 6.4 • Adopting a more co-operative approach • “Naming and Shaming” • Guidelines • “We do not believe that it is appropriate to name and • shame in relation to guidelines. • There is no right of appeal …. The damage is done” • Surveillance

  7. Section 6.4 • Adopting a more co-operative approach • Stakeholder forums – need substance not show • Food safety / consumer information - objective/subjective - evidence base • Recommendation 6 • Industry/government forums • “Consider at an early stage compliance issues associated with emerging regulatory proposals…” • Govt. response: FIPER anticipated – what will it achieve in practice?

  8. Recommendation 8 • Checks & balances in regulators’ founding • statutes • Food Standards Act 1999 • (2) “ ….to protect public health from the risks which may • arise in connection with the consumption of food … and • otherwise to protect the interests of consumers in relation to • food.” • Food safety • Diet & health proposals – burden from regulator’s activity

  9. Recommendation 8 Checks & balances in regulators’ founding statutes • Government response: “…need for regulators to assess carefully the impact of any new actions on the overall regulatory burden that they impose.” • Imminent FSA consultation on its approach to regulatory decision-making • Burden from regulator, not just burden of regulation

  10. “Make It Simple Make It Better” Thank you BRTF! Valuable input to review of EU food labelling legislation

More Related