Food Safety: Implications for the ACP

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31 March 2010

Executive brief: Update, April 2010

1 Background and key issues

Food safety has been a feature of EU policy for many decades. Since the mid 1990s, however, in response to major food crises, EU food safety policy has been more vigorously defined and implemented. This has included: the application of the precautionary principle under the 2002 general food law; the harmonisation of regulations across the EU; the introduction of ‘traceability’ systems within food chains; the implementation of a comprehensive package of regulations on hygiene; and the establishment of a comprehensive food and feed control regulation. This last regulation may prove to have the greatest impact in ACP countries, as it places the responsibility for the control and verification of compliance with EU standards upon the governments of the exporting countries. This de facto bestows on public authorities a central role in the export of ACP food and agricultural products to EU markets.

More recently the line between EU food safety and EU food quality policy has become blurred. For example, while rules relating to animal transport and animal slaughtering practices may have food safety dimensions, they also have strong elements of ‘quality’ differentiation, designed to yield price premiums to producers that meet certain standards. This is even more the case for any regulations dealing with animal welfare labelling, where the explicit aim is to allow consumers to make more informed choices in their purchase decisions, with this yielding, it is hoped, significant price premiums for products meeting high animal welfare standards.

The emergence of private voluntary standards is seen as an important issue in ACP countries, since it has a direct bearing on the functioning of the supply chain and the distribution of revenue along the supply chain. In the EU there is an emerging debate about the extent to which private voluntary standards (PVS) should be regulated, and the need for harmonisation both between public and private standards, and between various private standards, in order to reduce costs of compliance and verification. The European Commission, for its part, has supported calls for greater coordination of private labelling schemes, but is reluctant to play an interventionist role in this area, preferring to play a facilitating or coordinating role.

Given the importance of agriculture in most ACP countries and the importance of the EU as a destination for agricultural exports, the implications of the EU’s stricter food safety control regime cannot be overestimated. All food and agricultural products must comply with EU food safety standards before they can be placed for sale on the EU market. This compliance needs to be demonstrably verified, since the EU importer has a legal responsibility for ensuring the safety of food placed for sale on the EU market, and can be fined heavily for a failure to comply with this responsibility.

In this context, both the private sector and national policy makers in ACP countries need to understand the different trade policy issues arising from the EU’s new food safety policy and to develop appropriate policy responses to address these issues. This is particularly the case given that the financial aspects of food safety compliance can be commercially significant. The investments required to ensure compliance can also affect the distribution of power along supply chains to the disadvantage of primary producers. The food safety compliance requirements can constrain the possibilities for the structural development of certain sub-sectors, making it harder to move up the value chain in response to the process of preference erosion that is under way. Then can also adversely impact on the development of regional trade in food and agricultural products, as the quest for recognition of ‘equivalency’ with EU standards in one country closes off its domestic markets to regional suppliers (this is a particular problem in, for example, the dairy sector). They can also periodically lead to the disruption of trade with the EU because of shortcomings in national control systems. Ultimately it may even lead to the de facto closure of the EU market to exports of food and agricultural products, either because of a failure to meet EU standards or because the costs of compliance have come to exceed the profits secured from the export trade.

Stricter EU food safety standards can even have important implications for government finance, as national food safety control systems need to be established and maintained to meet EU requirements. While the EC is extending assistance in this area, both through dedicated programmes (e.g. the Europe-ACP Liaison Committee [COLEACP] pesticides initiative programme [PIP] and the €30 million pan-ACP food safety compliance initiative) and through a multiplicity of initiatives implemented at the national level, overall the level of resources currently available is unlikely to be sufficient, given the scale of the challenge faced.

In getting to grips with food safety issues, five distinct areas need to be addressed: the setting of standards; technical compliance; the financial costs of compliance; and, finally, the financial costs of verification and control systems and the nature of transitional arrangements. However, these challenges also need to be seen in the light of broader considerations linked to product differentiation on quality grounds. Against this background six specific areas of policy response can be identified:

• establishing an effective dialogue on the application of standards;
• assisting enterprises with the upgrading process to meet EU standards;
• meeting information needs related to standards compliance and facilitating technical assistance in attaining compliance;
• supporting the establishment and upgrading of effective national food safety control capacity in ACP countries, via the establishment of a dedicated food safety control financing facility;
• establishing systems for the financing of recurrent costs of national food safety control authorities;
• greater use of temporary derogations.

An additional area of concern that has emerged in some ACP regions, notably West Africa, has been the emergence of an export trade in fruit and vegetables from Europe that do not comply with EU market standards. Since these products have no commercial value in the EU, their sale price tends to be such as to periodically undermine local fruit and vegetable markets. In other sectors this trade has in some instances given rise to food safety concerns in Africa. This is requiring targeted assistance in building food safety compliance capacities in Africa, not only for the export trade but also for food products placed on local markets.

2 Latest developments

2.1 Food safety and trade relations

A working paper, ‘European food safety regulation and the developing countries’, was published in 2009 by the Danish Institute for International Studies (DIIS). This analysis sought to identify the legal measures under the EU food safety policy that ‘cause the most problems for developing [country] exporters’, with a view to identifying possible solutions. It highlighted the fact that food safety requirements have been identified as ‘one of the foremost issues affecting exports of agricultural and food products from developing countries’, with shortcomings in compliance estimated to cost African exporters alone over US$1 billion per annum in lost exports. The paper maintains that the basic structure of the EU approach to food safety ‘do[es] not take into account the consequences of the food safety regime which go beyond the Community’s borders’. Specifically, EU standards do not take into account the different conditions of production and certification existing in developing countries.

There are concerns that EU food safety standards and sanitary and phytosanitary (SPS) regulations can be used as a form of trade protection in an era of tariff liberalisation and price instability. This is a particular concern for small developing countries, since the nature of food safety investments, with basic overhead costs often very high regardless of the volume of production involved, means they fall particularly heavily on countries with limited export volumes. In addition, for small-scale exporters, problems with individual consignments can have commercial implications industry-wide. In this context the costs of compliance with food safety and SPS regulations can come to constitute an insurmountable barrier to new entrants. This, it is argued, periodically gives rise to barriers to exports which on purely food safety grounds are not justified.

The DIIS working paper proposes three specific sets of measures ‘to make the barriers more easily surmountable’:

• ‘strongly increased harmonisation of the industrialised countries’ food safety standards’;
• comprehensive reviews of each new proposal’s ‘likely consequences … on developing countries’, including a review of possible ‘alternative measures’ that would reduce negative impact on developing countries;
• ‘continued (and preferably increased) provision of technical assistance to the developing countries to enable them to comply with the food safety standards’.

2.2 Completion of the pesticide review

On 12 March 2009, the EC announced the completion of its pesticide review. Of approximately 1,000 substances available before 1993, ‘about 250 have passed the harmonised EU safety assessment. All reviewed pesticides have undergone a detailed risk evaluation with respect to their effects on humans and on the environment.’ The EC has now created a consolidated list of approved substances that member states may authorise for use in plant protection products. Only 70 substances failed the review process and were removed from the market. The remaining 680 products were ‘either not submitted, or were incomplete or were withdrawn by the industry’.

On 24 September 2009, after much controversy and debate, the EU Council adopted the new regulation on plant protection products. The EC commissioner for health claimed that the new regulation would ‘establish the most modern and protective system for the health of consumers worldwide’. However, concerns continue to be expressed over the impact of the new regulation on global agricultural productivity. The UK Crop Protection Agency has argued that the new regulations, which are no longer based on an assessment of the risk to health from absorption of plant protection products, but rather on ‘hazard-based cut-off criteria’ (i.e. the intrinsic chemical properties of the pesticide), could result in ‘some 15 to 20% of currently approved crop-protection products’ being lost to farmers. According to press reports, ‘experts have warned that the new rules will reduce crop yields and quality, and increase the cost of food to consumers’. The Crop Protection Agency’s chief executive, Dominic Dyer, has argued that the new EU rules are ‘at odds with the urgent demands placed on modern, productive agriculture’.

Against the background of these concerns, the UK government has launched a £13 million programme of support to research and development (R&D) for crop-protection products. The aim of the programme is to ‘help meet new and existing EU regulations on pesticide approval and use’ by helping growers ‘[to] respond to the dual challenges of increasing the productivity of crops while reducing the environmental impact of crop protection’. This initiative has been welcomed by UK horticulture producers, given that ‘the funds will mostly be allocated to applied R&D’.

In April 2009 COLEACP undertook a first assessment of the likely impact of the new EU pesticide regulation on ACP suppliers. The report noted the shift to ‘hazard-based cut-off criteria’. This is seen as a significant policy shift, as it raises the bar for the level of tolerance of pesticide residues. The assessment made a distinction between short-term and longer impacts of the new regulations. It argued that although ‘several pesticides currently used on export crops may be withdrawn in Europe, the new regulation is not likely to have a major impact in ACP countries in the short term’, since ‘substances will remain authorised until they come up for review when their annex I listing expires’. Even at this point, however, derogations can be sought to allow time to develop alternatives. It notes that where a pesticide is no longer authorised for use in the EU, ‘continued use on ACP export crops will still be possible provided that the product is registered locally, and EU minimum residue levels (MRLs) and Import Tolerances are complied with’.

However, the report did note that in the longer term the use of some less expensive substances may need to be phased out, with ‘consequent increases in production costs’. This, it is maintained, could have a particular impact on the smallholder sector. The report further noted that certain elements of the regulation remain unclear, and these clarifications could impact on ACP exporters, for example regarding the actual thresholds established for tolerance of substances found in imported products that have been scheduled for withdrawal. In this context it should be noted that in its first annual review of pesticide residues in food, using tests conducted in 2007, the European Food Safety Agency (EFSA) found that ‘MRLs are more often exceeded in samples imported from third countries than in EU products (2.31% of surveillance samples with EU origin and 6.84% ... from third countries)’. This suggests that scrutiny of imports may be stepped up in the coming period, given the higher incidence of risk associated with imported products.

2.3 The impact of private voluntary standards

Private voluntary standards need to be seen in the light of the legal responsibility of importers for the safety of food they place for sale on the EU market and the increasing market fragmentation in EU food markets, with strong demand growth in the quality-conscious ‘luxury purchase’ component of the market, and stagnant demand growth in the price-sensitive ‘necessity purchase’ component of the market. In the latter context, private voluntary standards form part of a wider process of ‘product differentiation’ designed to ‘protect and gain market share when competing in national and regional markets’. As a consequence these private standards are often ‘higher and more demanding than the minimum standards enforced by governments’ and the international standard-setting bodies.

While stricter private voluntary standards ‘can create an incentive for producers to invest in modernising their production processes and output’ and can help exporters ‘maintain and improve their market access’, it can pose problems particularly for smaller producers, whether considered nationally or in terms of the production system. While some ACP producers in some sectors have successfully risen to this challenge (e.g. certain Namibian beef product exporters and certain Kenyan vegetable product exporters), others struggle to meet these standards in a cost effective way, which leads over time to these producers falling out of the supply chain. Indeed it has been suggested that it ‘development strategies postulated on smallholder production of high-value agricultural products for export’ may be unrealistic in the absence of targeted and sustained support.

Concerns have also been expressed that the rise of private voluntary standards is actually undermining the functioning of the international system for establishing food-safety and health standards (such as the Codex Alimentarius), marginalising ACP countries from discussions and debates which have an increasingly important bearing on their food and agricultural exports to the EU. After all, why should producers seek to meet international standards, when these are insufficient to secure access to the most commercially attractive components of the EU market?

In the course of 2009, a number of reports were published assessing the commercial impact of food safety standards. The CUTS Centre for International Trade, Economics and Environment (CUTS-CITEE) published a report looking specifically at the impact of private voluntary standards on trade with developing countries. This report argued that despite the theoretical benefits of international standards in the food sector, ‘stringent food safety standards, imposed over and above CODEX standards and inter-country difference of standards in importing developed countries, are now impeding the export performance of developing countries’. This is linked both to internal financial, technical and infrastructural constraints in developing countries, and to the precise modalities for implementing, monitoring and verifying compliance applied by importers. External constraints on compliance identified include an absence of ‘timely dissemination of requisite information’ on new standards in developed country markets and the emergence of a tendency towards the use of some of these standards as trade barriers.

The CUTS-CITEE study argued that private voluntary standards place particularly onerous requirements on poor producers. Significantly, the study argued that where ‘private standards become industry norms’ and where ‘a small number of food retailers account for a high proportion of food sales’, then ‘the choice of whether or not to comply with a voluntary standard becomes a choice between compliance and exit from the market’. This, it is argued, raises the question: who carries the financial burden of compliance with private standards, some of which are only loosely based on scientific grounds? In this context, the CUTS analysis highlighted the importance of ensuring that ‘regulatory barriers are not misused to achieve protectionist objectives’, and the need for financial and technical assistance with compliance attainment and verification.

A more detailed survey carried out within the framework of the COLEACP PIP initiative has also been carried out, with its accompanying report published in May 2009. This focused on the impact of changing buyer requirements on the supply chain for fruit and vegetables, and looked exclusively at companies already receiving technical assistance with standards compliance under the PIP initiative. While the survey noted ‘an appreciable growth’ in aggregate exports between 2000 and 2006 through distinct supply chains serving different national EU markets, it also noted that firms found private voluntary standards ‘difficult or very difficult to meet’. However these difficulties varied, according to the supply chain being served. The anglophone supply chain linking suppliers in Kenya, Zambia, Uganda and Ghana with supermarkets in the UK, Germany, Netherlands and Switzerland generated more problems of compliance than the francophone supply chains that linked producers in Madagascar, Mali, Burkina Faso, Benin, Senegal and Côte d’Ivoire to wholesalers, catering companies and others in France, Italy and Switzerland.

The survey found ‘distinct differences … between companies supplying these value chains in terms of the demands and pressures they face from buyers, as well in the adaptations they make in order to meet them’. In terms of the anglophone supply chain, over the longer term some companies reported reduced profits due to the lack of a price premium and increased costs of maintaining certification. Of particular concern was that the survey noted that some 20% of companies involved with smallholder out-growers reported that some smallholder growers ‘had chosen not to renew their certificate despite the fact that they had the infrastructure, procedures and knowledge in place’. Significantly, these companies where out-growers were not renewing their certification were concentrated in countries where compliance with standards has been established for some years and where the full impact of recurrent costs was known (e.g. Kenya).

Despite these trends, overall the survey concluded that earlier fears of a generalised exodus of smallholder out-growers from export value chains in response to stricter food standards had not yet been realised. The volume of products sourced from out-growers from 2000 to 2007 had changed little. Yet there were marked differences between countries, with evidence emerging in Kenya that ‘very small-scale out-growers are being excluded from high-value retail supply chains due to the demands of PVS’. The report concluded on a cautionary note, arguing that while ‘the future trends for sourcing from small-scale growers are unclear … there is a risk that the pattern seen in Kenya will be repeated elsewhere as demands of PVS become more widespread and tightly enforced’.

Against this background the PIP report argued for:

• ‘continued technical assistance both from national and international agencies’;
• ‘improved routes of engagement with those who set and implement the PVS, as well as mechanisms to adjust them, in order that they can be better adapted to local circumstances’;
• ‘improved dialogue … with EU buyers in order to ensure that their policies create and enhance opportunities to trade’;
• ‘the fairer apportioning of costs along the supply chain’;
• a more proactive approach from developing countries in achieving compliance and defining how this is to be achieved.

A number of these recommendations would appear to have a bearing on EU policy discussions over the functioning of food supply chains. It is envisaged that in the course of 2010 these discussions and deliberations will give rise to recommendations, which will then feed in to proposals for the 2013 round of CAP reform. This would appear to be area of EU policy where a clear development dimension could usefully be added while policies are still under development, particularly as regards the functioning of fruit and vegetable supply chains: according to the PIP survey, ‘fresh fruit and vegetables sourced from Africa … [are] not high risk when compared to [fresh fruit and vegetables] from other sources’. On this basis the survey questioned ‘the proportionality of some EU retailer policies which, assuming higher risk, … apply more stringent controls on developing country suppliers’. Clearly some form of guidelines dealing with the proportionality of PVS control systems in the light of actual risks faced would appear to be warranted.

EU agricultural product quality policy and private voluntary standards

As part of the consultations on EU agricultural products quality policy launched in October 2008, the impact of Food Quality Certification Schemes (FQCS) was reviewed. The review, published in early 2009, found that private standards dealing with food quality certification were more flexible and responsive to new demands and trends, and could create value for producers, particularly where efficiently managed, with costs kept to a minimum. However the danger of too many such private quality schemes was highlighted, as this could confuse consumers and multiply costs. It was felt that clear EU guidelines could contribute to a more coherent development of private quality standards, although some contributors to the consultation felt that this could equally well be achieved through greater private sector-led coordination.

The review highlighted the fact that private quality standards can lead to additional costs, while non-adherence can effectively exclude products from the market. Ensuring that producers gain real value is therefore seen as vitally important. Against this background, suggestions for reducing the cost burden of private quality schemes included the introduction of mutual recognition, group certification, combining the audits required under different schemes, and financial assistance with the establishment of private quality schemes.

Submissions to the consultation process from third countries highlighted the need to ensure that the elaboration of EU quality standards did not give rise to discrimination against third-country producers, and emphasised the need for mutual recognition of food quality certification schemes and the ongoing debate over geographic indications (GIs). In addition, the need for support to developing countries in the form of financial and technical assistance helping them to comply with private certification schemes was thought necessary.

In the Commission’s communication of 28 May 2009 on agricultural product quality policy, it was argued that ‘private certification schemes can act as catalysts for developing country access to the EU market’ by acting as ‘an incentive for the modernisation of developing countries’ export supply chains’ and by improving the quality of goods placed for sale on the domestic market. Equally, it was acknowledged that ‘private scheme requirements can be difficult to meet for some producers in certain developing countries’, and in this context it was argued that ‘in the light of compliance costs, international donor assistance plays an important role in securing participation of small and medium-sized businesses and smallholder farmers in developing countries’. Overall, however, the position was adopted that the EC ‘does not support legislation for private and national certification schemes at this stage’, although it did recognise a need for the development of ‘good practice’ guidelines for private certification schemes, in order to reduce consumer confusion, and red tape for farmers.

2.4 EU support for food safety initiatives

In 2009, a number of training programmes took place in Africa linked to the ‘Better Training for Safer Food’ initiative. While this programme, launched in 2006, had been primarily focused on the staff of ‘competent authorities’ of EU member states, in 2009 it was extended to include a distinct ‘Better Training for Safer Food in Africa’ component. This Africa-focused initiative was launched in April 2009 at the African Union headquarters in Addis Ababa, under the auspices of the Health and Consumer Affairs Directorate-General of the European Commission, and is set to run for two years. The overall aim of the programme is ‘to keep participants up to date with Community law in these areas’ and to promote ‘more harmonised and efficient controls’. Specific objectives include:

• extending support to strengthening human capacity through training of trainers, in particular for veterinary and laboratory services;
• helping to improve national and regional legal frameworks towards harmonised systems;
• strengthening the capacity of small and medium enterprises to enhance their access to local, regional and EU markets;
• strengthening the capacity of the African Union on SPS issues.

Additional priorities include: sharing information and policy advice; strengthening official feed and food control systems; and the modernisation and rehabilitation of testing and certification laboratories.

Some €10 million is to be spent over the next three years in seven programme areas. The four to be implemented through the World Organisation for Animal Health (OIE), at a cost of €5.4 million, include:

• the conducting of an evaluation of the performance of veterinary services in 15 countries and the conducting of a gap analysis of the needs and priorities of each of these veterinary services departments, with follow-up evaluations and accompanying measures envisaged in some 40 countries;
• support for improvement of the national and/or regional legal framework relating to animal health and food safety in 15 countries;
• support for the strengthening of laboratory capacities through fostering twinning arrangements between laboratories in Africa and OIE reference laboratories;
• support for strengthening the capacity of national delegates to the OIE, chief veterinary officers and national focal points in all African countries in relation to international sanitary standards.

The two programmes to be implemented through Agriconsulting Europe, at a cost of €3.9m, include:

• training of trainers in five EPA regions;
• strengthening the capacity of small and medium enterprises (SMEs) via targeted and sustained missions and ad hoc assistance, largely involving the secondment of experts to address shortcomings identified by the EC Food and Veterinary Office (FVO) in national food safety control systems.

A programme to be implemented through AETS consortium at a cost of €0.22m involves:

• intensive training for officials from the African Union Commission and regional economic communities on food safety issues.

The development of direct cooperation links between African governments and the EC departments responsible for specific policy areas potentially offers an opportunity for improving the targeting and quality of EC assistance. However, with many elements of the programme being sub-contracted out to international organisations and consultancy companies, it is important that these programmes nevertheless encourage the establishment of direct links for the exchange of information and technical advice between EU and African food safety authorities beyond the lifetime of the two-year programme.

3 Implications for the ACP

3.1 Food safety and trade relations

From an ACP perspective, when considering the impact of food safety controls on trade in food and agricultural products, it is important to distinguish between the challenges faced in complying with EU standards and the challenges faced in verifying compliance with EU standards. Specific policy responses are needed in each of these areas. The ‘GLOBALGAP’ decision to recognise the equivalence of ‘KENYAGAP’ standards is an example that should be followed in other areas of standard setting, since this ensures that EU standards are respected in ways consistent with local realities. Such practice keeps the focus on the achievement of the underlying policy objective, and not on the modalities through which it is achieved.

It should be borne in mind, however, that innovations in this area need to be country specific, depending on the nature of the production system and the institutional framework in place. Overall, the emphasis should be on demonstrably ensuring compliance, not on how verification is achieved.

There appears to be considerable scope for cost savings in the sphere of compliance verification and certification through harmonisation and coordination. However initiatives by public authorities would appear to be needed in order to promote such coordination and harmonisation. Building on the suggestions of the study of the Danish Institute for International Studies, this could take the form of the establishment of a distinct development dimension to EU food-safety and SPS policies. This would seek to bring together existing EU policy initiatives in this area (e.g. the Better Food Safety in Africa and PIP initiatives) and link them to a strengthening of the policy dialogue. Such a policy dialogue would extend to new areas of EU policy that are currently under elaboration and which have a bearing on food safety, SPS, quality standards and supply chain issues. The aim of such an initiative would be to promote greater coherence between EU ‘aid for trade’ support initiatives in the area of food safety and these new emerging policy initiatives.

3.2 Getting to grips with the pesticide review

From an ACP perspective, while the short-term impact of the regulation is likely to be limited, close attention will need to be paid to the elaboration of aspects of the new EU pesticide regulation that are as yet unclear (e.g. the import tolerance limits), and clear strategies will need to be developed to minimise cost-increasing effects in the longer term. In addition, with the incidence of samples exceeding the MRLs three times higher for imported products than for products with an EU origin, intensified testing and compliance enforcement on imports of food and agricultural products can be expected in the coming period.

The question arises however of whether this would be justified for many ACP fruit and vegetables. Studies conducted under the PIP initiative have found that imports of fruit and vegetables from Africa show lower risks of pesticide contamination than imports from other sources. Against this background, it would appear important to ensure that arrangements for compliance enforcement take into account the actual risks associated with imports from individual ACP countries.

The types of initiative launched by the UK government to support research and development for crop-protection products could usefully be extended to ACP producers of horticultural products. This is particularly the case with regard to ‘applied research and development’. Regional horticulture associations in the ACP potentially have an important role to play in promoting such ‘applied research and development’ partnerships.

3.3 Getting to grips with private voluntary standards

The PIP survey found that while ‘traceability emerged as one of the most significant requirements requested by buyers in recent years …, surprisingly it was not generally considered as difficult to meet’. Most companies, with the benefit of external support, ‘have risen to the challenge by installing traceability systems’, illustrating ‘the capacity of ACP exporters to adapt and meet new technical requirements’. This highlights the importance of pump-priming public sector assistance to help ACP producers and exporters to meet private voluntary standards, and suggests a need to expand such support. Recent examples of cooperation between the German government and FAO in assisting west and central African farmers to meet EU standards, secure organic and other certification standards and build the capacity of producers in commercial negotiations, are a case in point.

As the PIP survey pointed out, in order to sustain smaller-scale producers in the supply chain, the formation of alliances with larger exporters or major importers is often required. Potentially there could be a role for public sector pump-priming support to foster the development of such relationships. The public sector role, however, may need to extend beyond such ‘aid for trade’ support and examine how private voluntary standards are developed and applied in practice in ACP countries, making sure that cost-increasing effects are kept to a minimum and that the specific needs of smallholder producers are accommodated. Certainly the elaboration of KENYAGAP standards to apply equivalent GLOBALGAP standards in a locally relevant manner would appear to warrant replication. However this is likely to require a deepening of the dialogue over the design and application of private voluntary standards, a process that is likely to need some level of public sector support. This issue could usefully be taken up in the context of the elaboration of specific proposals under the EU’s agricultural product quality policy, with a clear development dimension being added to this essentially domestically focused policy.

Equally there may well be a need to look at the impact that private voluntary standards have on the distribution of power along food supply chains. The issue of the functioning of supply chains is receiving increasing attention within the EU. There may well be a case for this initiative to be extended in the context of the implementation of the free-trade area agreements being concluded in the form of (I)EPAs, to include research into the functioning of major food supply chains, where private voluntary standards and other food-safety and SPS regulations are impacting on the distribution of commercial power along food supply chains.