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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:

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TACKLING REGULATORY CREEP Some observations from food regulation Michael Hunt

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  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

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