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Rural Directorate
Animal Health and Welfare Division
Livestock Traceability Policy

T: 0131-244 -6404
E: Livestock.ID@scotland.gsi.gov.uk




CONSULTATION ON IMPLEMENTATION PROPOSALS FOR EU REQUIREMENTS
REGARDING ELECTRONIC IDENTIFICATION (EID) OF SHEEP AND INDIVIDUAL
RECORDING OF SHEEP AND GOATS

I am writing to invite your comments on implementation options for EID of sheep and
individual recording of sheep and goats arising from EU Regulations that will come
into force on 01 January 2010.

The consultation period will start on 07 September and close on 02 November 2009.

EU Parliament and Council Regulation (EC) No 21/2004 (the regulation) establishes
a system for the identification and tracing of ovine and caprine animals. The
Regulation was approved by the UK Government as far back as 2003 with the 1st
phase (double tagging) introduced in Scotland in January 2008. The second phase
introduces the recording of individual animals by means of electronic identification
from 01 January 2010.

This consultation is not seeking your views on the principle of EID which has already
been established by EU law and has to be implemented in terms of the Scotland Act
1998. As you will be aware the Scottish Government has all along expressed grave
reservations about the current proposals for EID but there has not been enough
support from other EU Member States or from the European Commission for a
voluntary scheme. However, working in partnership with industry, in what has been
an uphill struggle, we have come a long way in the last two years.

We have won significant flexibilities in the Regulation to help our sheep farmers. We
previously secured concessions for phasing in the individual recording requirements
from 2010 which will significantly reduce the burden on our industry. As recently as
14 July we secured further concessions from the Commission which will allow
markets and abattoirs to act as Critical Control Points (CCP’s) to electronically scan
animals. This will significantly reduce the cost to farmers for EID implementation.

Should the Scottish Government or its industry fail to implement and comply with the
Commission Regulation it would leave us open to infraction procedures and heavy
fines that could total millions of pounds in disallowance and loss of Single Farm
Payment for industry. It is therefore important that we find workable solutions.




                                          1
What is being consulted on?

There are a number of significant decisions to be made regarding
implementation, including consideration of the following options:

   •   The slaughter derogation – the Regulation allows lambs to be identified with a
       single (non electronic) identifier if they are intended for UK slaughter before
       reaching 12 months of age.
   •   Replacement tagging – the Regulation provides flexibility in how Member
       States allow lost or illegible identifiers to be replaced. It is a Scottish decision
       to adopt rules that suits the industry and maintains traceability.
   •   Critical Control Points (CCP’s) – the Regulations allows the use of third
       parties to record individual animal identities on behalf of keepers. It is a
       Scottish decision to make use of this provision.
   •   Database – the Regulations allow farm registers and movements documents
       to be dispensed with if a central database contains all the information required
       in these documents. It is a Scottish decision to make use of these provisions.

What is not being consulted on?

    • EID only after leaving the holding of birth – Scotland and the rest of the UK
      sent proposals to the EU Commission that sought to allow breeding ewes that
      stay on the holding of birth to be exempt from compulsory electronic
      identification until they move off the holding.        Unfortunately the EU
      Commission and the Council of Minsters were not able consider this option
      and therefore all animals must be identified within 6 months in intensive
      conditions and 9 months in extensive conditions. We will, however, continue
      to raise concerns with the European Commission on this issue at every
      opportunity.

Responding to this consultation paper

We are inviting written responses to this consultation paper by 02 November 2009.

Please send your response to:

Livestock.ID@scotland.gsi.gov.uk or

Livestock Identification – Sheep and Goat Consultation
Rm 347 Pentland House
47 Robb’s Loan
Edinburgh
EH14 1TY

If you have any queries please contact David McLean on 0131 244 6404.

We would be grateful if you could clearly indicate in your response which questions
or parts of the consultation paper you are responding to as this will aid our analysis
of the responses received.



                                            2
This consultation, and all other Scottish Government consultation exercises, can be
viewed online on the consultation web pages of the Scottish Government website at
http://www.scotland.gov.uk/consultations. You can telephone Freephone 0800 77
1234 to find out where your nearest public internet access point is.


The Scottish Government now has an email alert system for consultations
(SEconsult: http://www.scotland.gov.uk/consultations/seconsult.aspx). This system
allows stakeholder individuals and organisations to register and receive a weekly
email containing details of all new consultations (including web links). SEconsult
complements, but in no way replaces, SE distribution lists, and is designed to allow
stakeholders to keep up to date with all SE consultation activity, and therefore be
alerted at the earliest opportunity to those of most interest. We would encourage you
to register.


Handling your response

We need to know how you wish your response to be handled and, in particular,
whether you are happy for your response to be made public. Please complete and
return the Respondent Information Form which forms part of the consultation
attached to this letter as this will ensure that we treat your response appropriately. If
you ask for your response not to be published we will regard it as confidential, and
we will treat it accordingly.


All respondents should be aware that the Scottish Government are subject to the
provisions of the Freedom of Information (Scotland) Act 2002 and would therefore
have to consider any request made to it under the Act for information relating to
responses made to this consultation exercise.


Next steps in the process

Where respondents have given permission for their response to be made public (see
the attached Respondent Information Form), these will be made available to the
public in the Scottish Government Library or placed on the Scottish Government
consultation web pages. We will check all responses where agreement to publish
has been given for any potentially defamatory material before logging them in the
library or placing them on the website. You can make arrangements to view
responses by contacting the SE Library on 0131 244 4552. Responses can be
copied and sent to you, but a charge may be made for this service.

What happens next?

Following the consultation closing date, all responses will be analysed and
considered along with any other available evidence to help us reach a decision on
how the EU identification and recording regulations could be introduced in Scotland.
We aim to issue a report on this consultation process as soon as possible and this
will include indications of the changes to be made to the legislation.


                                           3
Comments and complaints

If you have any comments about how this consultation exercise has been conducted,
please send them to:

Name: Derek Wilson
Address: Rm 350 Pentland House, 47 Robb’s Loan, Edinburgh EH14 1TY
E-mail: Derek.Wilson2@scotland.gsi.gov.uk

I look forward to any comments you may have


Yours Sincerely


Nick Ambrose


Dr Nick Ambrose
Head of Animal Health – Disease Prevention
Rural Directorate
Scottish Government


04 September 2009




                                       4
RESPONDENT INFORMATION FORM: Proposed amendments of the sheep and
goat identification and tracing regulations.

Please complete the details below and return it with your response. This will help
ensure we handle your response appropriately. Thank you for your help.

Name:
Postal Address:


1. Are you responding: (please tick one box)

(a) as an individual go to Q2a/b and then Q4
(b) on behalf of a group/organisation go to Q3 and then Q4

INDIVIDUALS

2a. Do you agree to your response being made available to the public (in Scottish
Government library and/or on the Scottish Government website)?

Yes (go to 2b below)
No, not at all We will treat your response as confidential

2b. Where confidentiality is not requested, we will make your response available
to the public on the following basis (please tick one of the following boxes)

Yes, make my response, name and address all available
Yes, make my response available, but not my name or address
Yes, make my response and name available, but not my address


ON BEHALF OF GROUPS OR ORGANISATIONS:

3 The name and address of your organisation will be made available to the public (in
the Scottish Government library and/or on the Scottish Government website). Are
you also content for your response to be made available?

Yes
No We will treat your response as confidential

SHARING RESPONSES/FUTURE ENGAGEMENT

 We will share your response internally with other Scottish Government policy teams
who may be addressing the issues you discuss. They may wish to contact you again
in the future, but we require your permission to do so. Are you content for the
Scottish Government to contact you again in the future in relation to this consultation
response?

Yes                                           No



                                          5
THE SCOTTISH GOVERNMENT CONSULTATION PROCESS

Consultation is an essential and important aspect of Scottish Government working
methods.
Given the wide-ranging areas of work of the Scottish Government, there are many
varied types of consultation. However, in general, Scottish Government consultation
exercises aim to provide opportunities for all those who wish to express their
opinions on a proposed area of work to do so in ways which will inform and enhance
that work.

The Scottish Government encourages consultation that is thorough, effective and
appropriate to the issue under consideration and the nature of the target audience.
Consultation exercises take account of a wide range of factors, and no two exercises
are likely to be the same.

Typically Scottish Government consultations involve a written paper inviting answers
to specific questions or more general views about the material presented. Written
papers are distributed to organisations and individuals with an interest in the issue,
and they are also placed on the Scottish Government web site enabling a wider
audience to access the paper and submit their responses. Consultation exercises
may also involve seeking views in a number of different ways, such as through public
meetings, focus groups or questionnaire exercises. Copies of all the written
responses received to a consultation exercise (except those where the individual or
organisation requested confidentiality) are placed in the Scottish Government library
at Saughton House, Edinburgh (K Spur, Saughton House, Broomhouse Drive,
Edinburgh, EH11 3XD, telephone 0131 244 4565).

All Scottish Government consultation papers and related publications (eg, analysis of
response reports) can be accessed at: Scottish Government consultations
(http://www.scotland.gov.uk/consultations)

The views and suggestions detailed in consultation responses are analysed and
used as part of the decision making process, along with a range of other available
information and evidence. Depending on the nature of the consultation exercise the
responses received may:

• indicate the need for policy development or review;
• inform the development of a particular policy;
• help decisions to be made between alternative policy proposals;
• be used to finalise legislation before it is implemented.

Final decisions on the issues under consideration will also take account of a range of
other factors, including other available information and research evidence.


While details of particular circumstances described in a response to a
consultation exercise may usefully inform the policy process, consultation
exercises cannot address individual concerns and comments, which should
be directed to the relevant public body.



                                          6
    CONSULTATION ON IMPLEMENTATION
    PROPOSALS FOR EU REQUIREMENTS
  REGARDING ELECTRONIC IDENTIFICATION
(EID) OF SHEEP AND INDIVIDUAL RECORDING
           OF SHEEP AND GOATS


           07 September to 02 November




                                         1
CONSULTATION ON IMPLEMENTATION PROPOSALS FOR EU
REQUIREMENTS REGARDING ELECTRONIC IDENTIFICATION
(EID) OF SHEEP AND INDIVIDUAL RECORDING OF SHEEP
AND GOATS
EC 21/2004 establishing a system for the identification and registration of
ovine and caprine animals.

Summary

The objective of the Regulation is to improve the effectiveness of the
identification and tracing system for sheep and goats by introducing individual
traceability. The Foot and Mouth outbreak in 2001 identified inadequacies in
the EU sheep and goat identification and tracing arrangements laid down in
Council Directive 92/102/EEC so in 2003 new rules were agreed to phase in
improvements to EU identification and traceability arrangements.

The first phase required double tagging from 2005. In Scotland those rules
were deferred until 18 January 2008 following an initial derogation that
maintained batch recording. The second phase is to move to individual animal
traceability. This requires the introduction of individual animal recording
through electronic identification and the date when this must be introduced is
01 January 2010 as set by the EU Council of Ministers.

The Regulation applies equally to all 27 Member States in that all are required
to introduce individual recording. Some countries can opt not to use electronic
identifiers, but given the UK has the largest sheep population in Europe,
Scottish Ministers are legally obliged to implement individual recording and
EID.

What is being consulted on?

There are a number of significant decisions to be made regarding
implementation including:

   •   The slaughter derogation – the Regulation allows lambs to be identified
       with a single (non electronic) identifier if they are intended for UK
       slaughter before reaching 12 months of age.
   •   Replacement tagging – the Regulation provides flexibility in how
       Member States allow lost or illegible identifiers to be replaced. It is a
       Scottish decision to adopt rules that suits the industry and maintains
       traceability.
   •   Critical Control Points (CCP’s) – the Regulations allows the use of third
       parties to record individual animal identities on behalf of keepers. It is
       a Scottish decision to make use of this provision.
   •   Database – the Regulations allow the non use of ‘on’ farm registers
       and movement documents if the central database contains all the
       information required in these documents. It is a Scottish decision to
       make use of these provisions.


                                                                               2
What is not being consulted on?

      • EID only after leaving the holding of birth – Scotland and the rest of the
        UK sent proposals to the EU Commission that sought to allow breeding
        ewes that stay on the holding of birth to be exempt from compulsory
        electronic identification until they move off the holding. Unfortunately
        the EU Commission and the Council of Minsters were not able consider
        this option and therefore all animals must be identified within 6 months
        in intensive conditions and 9 months in extensive conditions.

A summary of current systems can be found at Annex A.


Options for implementation in Scotland

The final phase of the new EU rules governing the identification of sheep and
goats will be implemented in Scotland on 01 January 2010 through a
combination of the Regulation itself and new domestic legislation
(provisionally entitled - The Sheep and Goat (Records, Identification and
Movement)(Scotland) Order 2010).

The provisions of the Regulation are directly applicable in UK law but
domestic legislation is required to define offences, penalties and any options
(derogations) available in the Regulation that we propose to apply, plus some
additional provisions needed for implementation.

An analysis of the costs is included in the accompanying regulatory impact
assessment setting out our estimates of the costs of implementation.

The paragraphs below describe how the changes to the existing rules might
be implemented; these will take effect from 01 January 2010. The specific
questions (which follow) are those on which we welcome your views.
References to the Regulation have been included. Your responses will help
Scottish Ministers shape the Scottish legislation.

New Provisions

Identification of sheep

All lambs born after 01 January 2010 must be identified with two identifiers,
one of which must be electronic 1

The Regulation has not changed the timescale of when sheep must first be
identified, it remains either within 6 months of birth - if intensively farmed;
within 9 months of birth - if extensively farmed; or before any movement off
the holding of birth occurs whichever is the sooner.


1
    Article 4.2 Commission Regulation 21/2004


                                                                                3
A single non-electronic slaughter batch tag (“a slaughter tag”) might be
applied instead of two identifiers to animals that will be slaughtered before
reaching 12 months of age 2 . This is commonly described as the slaughter
derogation, the options for which are discussed in detail below.

The Regulation provides for all identification identifiers to be approved but
extends the range of those currently available for use by the keeper 3 . It
provides for the use of eartags, tattoos, pastern tags, electronic eartags,
electronic boluses, electronic pastern tags and injectable transponders. The
use of electronic pastern tags and injectable transponders is optional when
animals are not involved in intra-community trade.

We are proposing to authorise the use of all methods of identification provided
for with the exception of injectable transponders. We propose not to authorise
the use of injectable transponders because there are public health concerns
surrounding their use, particularly associated with the risk of migration from
the injection site. We will review the use of injectable transponders and their
potential application, as more information becomes available.

We are also proposing that where a tattoo is used to identify an animal it
should not be used in conjunction with a bolus. This is because it would not be
possible to include a visual identifier on a tattoo to indicate that a bolus had
been applied.



Question 1. Do you agree with the Scottish Government options on the
types of identification to be used?

If not, please explain why.



Slaughter Derogation

The Regulations allow for the provision of a slaughter tag in place of two
means of identification for animals that are intended to be slaughtered within
12 months of age. The minimum requirement for the slaughter tag is that it
contains the flock/herd mark of the holding of birth.

There are various options surrounding the ‘slaughter’ derogation. These are:

NO SLAUGHTER DEROGATION – requires that all lambs born on or after 01
January 2010, with no exceptions, would require two means of identification
(one of which is electronic) and would need to be individually recorded (100%
of all lambs).


2
    Article 4.3 Council Regulation 21/2004
3
    Annex A1 Council Regulation 21/2004


                                                                               4
A RESTRICTED SLAUGHTER DEROGATION – requires finished lambs
moving direct to slaughter or via a market to slaughter to be identified with a
single slaughter tag (approx 35% of all lambs). Under this option, finished
lambs would continue to be recorded in movement documents and in holding
registers on a batch basis. All other lambs would require two means of
identification (one of which is electronic) and would need to be individually
recorded.

A FULL SLAUGHTER DEROGATION - requires only those lambs that are to
be kept beyond the age of 12 months to be identified with two means of
identification (one of which is electronic). Breeding sheep and hoggets over
12 months of age would have to be individually recorded on a movement
document and in the holding register. All lambs that are intended for
slaughter within 12 months of age could be identified with a single slaughter
tag and be recorded on a batch basis (approx 70% of all lambs).

AN ‘ELECTRONIC’ SLAUGHTER TAG DEROGATION – this would allow for
the ‘slaughter tag’ to be a single electronic tag and applied to all animals to be
slaughtered before the age of 12 months. By doing so this would alleviate the
problem of recording ‘batch within a batch’ where mixed animals are moved
(see below in points to consider). There are two options within this electronic
slaughter tag derogation –

   1. The slaughter tag may contain only batch information – the six digit
      flock/herd mark. Or

   2. The slaughter tag may contain a full unique 12 digit identity code – the
      six digit flock/herd mark plus a unique 6 digit identity.

The difference of a batch or individual number on an electronic slaughter tag
affects the recording requirements and whether or not the animal can be
upgraded breeding status if it reaches for 12 months of age.

The Commission have stated that in order for animals to be upgraded to
breeding animal/older than 12 months animals have to be completely
traceable and in order to satisfy this requirement animals must be individually
recorded when them move between holdings.

As both the batch and an individual numbered electronic slaughter tag will
contain a unique number in the electronic chip, an animal can be recorded
individually regardless on what is printed on the outside of the tag (batch or
full unique number).

If the electronic slaughter tag contained a full 12 digit unique number of the
outside of the tag then they need to be individually recorded in holding
registers and movement documents and therefore the animals could be
upgraded at any point, regardless of the holding they are on when they reach
12 months of age.




                                                                                5
If the electronic slaughter tag contained only the batch details on the outside
then these animals can be upgraded off their holding of birth without the need
to individually record if they move direct to another holding. If the animal
moves through a market then the animal can still be upgraded on a
subsequent holding as long as the animals are individually recorded prior to
departure from the HoB or through critical control point (CCP’s) (see section
on movement documents for more information on CCP’s).


Points to consider

On the face of it, a full derogation appears the obvious choice because it
would be the least costly cash option for producers (see cost analysis within
the accompanying Regulatory Impact Assessment). It also reduces the
individual recording burden for many keepers.

However, as farmers, auctioneers and abattoir staff will have to record lambs
in holding registers and on movement documents by the numbers from each
original flock (batch within batch) this would be almost impossible without EID.

The Regulation requires the sender of the lambs to record how many lambs
within the batch have the same holding of birth identity. The issue becomes
more complicated when batches of sheep originate from more than one
holding of birth. These ‘mixed batches’ are typically found in movements
between store-lamb finishers and markets and from markets to slaughter. For
those businesses affected, having to record the numbers of lambs with the
same holding of birth identity would significantly increase costs due to
handling and recording burdens.

Further Ewe lambs originally intended for slaughter with a single tag could not
be upgraded to full EID and be retained for breeding unless the change to
electronic identification is made on their holding of birth.

A restricted derogation attempts to resolve the same practical record
keeping issues but by limiting the sale of single identified finished lambs direct
to an abattoir or through a dedicated slaughter section of market. The aim is
to ensure that finished lambs on a single batch tag are only presented for
immediate slaughter and that mixed batches of store lambs have full EID.
This will avoid the record keeping difficulties associated with mixed batches of
store lambs for sheep keepers, livestock markets and abattoirs.

Not having a Slaughter Derogation would remove all the complications of
running two distinct systems and would therefore be the most straightforward
system to operate. .It would also provide for all animals to be individually
receded which would therefore provide for the option of full individual tracing
for Food Chain Information (FCI) – see accompanying RIA for flock
management benefits). It would, however, be the most expensive option as a
result of electronically identifying all animals as well as increasing the
recording burdens on Industry as a result of recording individual animal
details.


                                                                                6
An Electronic Slaughter Tag Derogation would look to remove most of the
complications are as it would enable holding of birth details to be read
electronically, instead of manually. It would, however, increase costs to
producers who choose to apply these non-official electronic tags because they
are more expensive than conventional tags used in finished lambs. There is
also the extra complication surrounding the upgrading of these animals if they
reach 12 months of age.

Scottish Ministers do not have a preferred option. We do, however, recognise
that a balance has to be reached between traceability requirements and the
ease of use throughout the production chain and cost to industry. We are
therefore minded to provide for all of the slaughter tag options and allow
Industry to determine the best option for them based on their
operations/practices.


Question 2. Do you agree that the Scottish Government should provide
for all the slaughter tag options?

Question 3. Do you have a preferred slaughter tag derogation option?

Question 4. If you favour an electronic slaughter tag, do you prefer a
batch or individual numbered eartag?




Reserved colours for Electronic Identification

It has been suggested that reserving colours for electronic identifiers (and
specific match up tags) would be beneficial for manufacturers, farmers and
enforcement bodies alike. This would ensure consistency across the sector,
allow animals to be easily and quickly identified, and further reduce the time
taken to process sheep, particularly in high throughput premises
(markets/abattoirs).

The Scottish Government, in line with requirements of the other GB
administrations, therefore propose that the colour yellow is reserved solely for
the use of electronic eartags (either full eartags or the slaughter EID tag). The
match up eartag can be any other colour apart from red or black (see below).

Because a bolus cannot be seen by the eye, there is a risk that a receiving
keeper of an animal fitted with a bolus might assume that a visual identifier
has been lost and attempt to apply a new set of identifiers. This would cause
problems, particularly where the result is that an animal has two electronic
identifiers (tag and bolus) bearing different numbers.




                                                                               7
The Scottish Government therefore suggest that where a bolus is used for
electronic identification purposes the match up identifier should be black with
distinguishable letters and numbers.

Finally the Scottish Government propose that any replacement eartags should
be red in colour, in line with current practise.


Question 5. Do you agree that the Scottish Government should reserve
the colours to be used for electronic identifiers and match up tags?




Identification of goats

The rules for the identification of goats will not change. Goats will continue to
be required to be identified with two non-electronic identifiers, but keepers
may fit electronic identifiers if they wish. The slaughter derogation is currently
used for goats and we do not propose to alter the existing requirements (an
individual number can be included). Very few goats are sold via markets and
therefore the practical record keeping issues that exist for sheep do not apply
to goats.



Question 6. Do you agree that Scottish Government maintains the
current rules for goats and the use of the slaughter derogation remains
unaltered for goats?



Replacement Rules for Identification (sheep and goats)


Where a means of identification becomes lost or illegible, the Regulation
provides for either an identical numbered replacement or different numbered
replacements to be fitted, provided traceability is not compromised 4 .

The current system of replacements is considered overly complex for keepers,
particularly because different replacement rules apply to different age groups
of animals. The complexity has resulted in lower levels of compliance than we
would have hoped for and has led to unwelcome financial penalties for some
keepers.

We therefore propose to simplify the replacement rules and allow keepers the
choice of


4
    Article 4.6 Council Regulation 21/2004


                                                                                8
   •   Using identical numbered replacements; or
   •   Different numbered replacements, with cross referencing; or
   •   Keepers to choose if they wish to EID older sheep, those born before
       31st December 2009

Identical numbered replacements are being catered for to allow breeders to
retain an animal’s unique lifetime identity; there will be no cross reference
required for these types of replacements.

EID is being allowed for older sheep because some keepers may find it easier
to manage the individual recording requirements from December 2011.

The main method of replacement is expected to be the application of different
numbered identifiers, cross-referenced to the original number because this will
reduce the costs compared to like for like replacements.

The system proposed for the application of different numbered replacements
would require the keeper to remove the surviving tag, to apply two new
identifiers and to cross-reference in the replacement section of the holding
register.

When different numbered replacement identifiers are applied they must be red
in colour.


Like for like replacements if metal tag, bolus or tattoo originally used

The provision to remove a surviving plastic tag to facilitate the application of a
new set of replacement identifiers will be permitted. Concerns have been
raised about the removal of metal tags, Veterinary advice is that this would
cause pain to the animal. We are therefore proposing that metal tags cannot
be removed from an animal unless there are welfare reasons for doing so.
Where a surviving tag is a metal tag, keepers will need to apply an identically
numbered replacement.

Similarly where a bolus or a tattoo has been used to identify an animal, it
would be impractical to cut out the surviving identifier. It will be necessary
therefore to apply identical replacements in these circumstances.


Question 7. Do you agree Scottish Government should implement the
simplified replacement rules?

If not please explain why and what you would propose instead.




                                                                                9
Authorised and approved EID equipment

Guidelines and procedures for the implementation of electronic identification
have been adopted (Article 9 and Commission Decision 968/2006). These set
out minimum standards but also provide for additional tests in accordance
with the Technical Guidelines of the Joint Research Centre. In Scotland we
propose to require all electronic identifiers and electronic reading equipment
to conform to both the minimum standards and to the additional tests provided
for in the Technical Guidelines.


Question 8. Do you agree that we should only authorise the use of
electronic identifiers and reading equipment, which conform to both the
minimum requirements and to the Technical Guidelines?



Holding Registers

There is no change to the register recording requirements for animals born
before 01 January 2010.

For animals born after 01 January 2010 and which are not subject to the
slaughter derogation, the following additional information must be recorded 5 :

     •   The individual number of the animal;
     •   The year of birth and the date the animal was identified;
     •   The month and year of death;
     •   The breed and (if known) genotype.

Animals born after 01 January 2010, which are identified in accordance with
slaughter derogation, would continue to be recorded on a batch basis. In
these situations, however, the holding register must record the number of
animals with the same holding of birth identity within the batch – ‘batch within
a batch’.

The Scottish Government propose to continue with the 36 hr period for
recording details in the holding registers, with the holding registers being
either paper or computer based.

The Regulations provide that where a competent authority central database
exists and contains all the information required of a holding register, then
there is no need to maintain on farm registers.

If the Scottish Government was to make use of this provision then as well as
notifying all movements to sheep and goats to the database (SAMU), all
births, deaths and details of replacement identifiers would have to be notified
to the database, within set timescales.
5
    Annex B2 Council Regulation 21/2004


                                                                             10
The current Scottish legislation requires records to be retained for 3 years.
This provision does not entirely reflect the requirement of the Regulation 6 .
We therefore have to amend the implementing provisions to reflect the EU
Regulations and require the register to be retained for 3 years from the day
when an animal referred to in the register dies or leaves the holding.



Question 9. Do you think that the Scottish Government should make
use of the provision to use a central database for the purposes of the
holding registers, thus removing the need to have on farm registers?

Question 10.       If a centralised individual database is to be
established, what do you think is appropriate timescales for reporting
births, deaths and details of replacement identifiers?


Movement Documents

The additional information that will be required on the movement document is
the individual identification number of each animal 7 . This requirement applies
to all animals regardless of when they were born but will be phased in as
follows:

     •   For lambs/kids born after 01 January 2010, the provisions will apply
         from 1 January 2011; and

     •   For sheep and goats born before 01 January 2010, the provisions will
         apply from 31 December 2011, except that animals moving direct or via
         market to slaughter will never need their individual numbers recorded.


Sheep and goats movements are currently required to be notified to the
central database within 3 days. There are no proposals to change this
deadline.

Following representation of the Scottish and UK Governments the
Commission have amended the Regulations to permit the use of Critical
Control Points (CCP’s) to act as third parties. This means that CCP’s can
record the individual identities of animals on behalf of the receiver/consigner,
therefore removing recording burdens for sheep farmers.              CCP’s are
permitted subject to the following conditions -

     •   Animals are not transported in the same means of transport, unless the
         batches of animals are physically separated from each other,


6
    Article 5.3 Council Regulation 21/2004
7
    Annex C.2 Council Regulation 21/2004


                                                                             11
   •   The individual identification code of each animal is recorded within the
       relevant herd registers within 48 hrs; and
   •   The information relating to the movement is provided to the competent
       authority database within 48 hours
   •   All CCP’s are approved by the Competent Authority



Question 11. Do you agree that the Scottish Government should make
use of the provisions to allow Critical Control Points (CCP’s)?



The Regulations also provide that where a competent authority central
database exists and contains all the information required on a movement
document (apart from the keepers signature) then there is no need to have
paper based movement documents travelling with animals.

Question 12. Do you think that the Scottish Government should make
use of this provision and therefore look to remove paper based
movement documents?


Central Database


The Regulation provides for a batch-recording database and this has been in
place in Scotland since 2001, through the Scottish Animal Movement System
(SAMS). There is no requirement for the database to be enhanced to record
individual information however as mentioned above there are derogations
available regarding the need to maintain a holding register or to complete
movement documents if a database exists which records individual
information. Responses to questions 8 and 11 will determine whether or not
the Scottish Government should pursue a centralised individual animal
database.


Contingency arrangements (subject to ongoing EC discussions)


There will be occasions i.e. power or equipment failure, when it is not possible
for high volume premises including markets and abattoirs to read and record
individual animal details. These situations will be exceptional but when they
occur could disrupt trade. The volumes and throughput of stock would mean
that individual recording would not be a viable option to meet the regulatory
requirements given the available labour resource.

In these exceptional circumstances, for markets and abattoirs only, we are
proposing that they will not be required to individually record animals. Local
Authorities have enforcement responsibility in markets and abattoirs and we


                                                                             12
are proposing that markets and abattoirs agree with their local authority and
Animal Health a contingency plan that could be invoked.

Scottish Government will be working closely with Local Authorities, Animal
Health and industry to draw up guidelines for contingency plans, which will
include obligations to carry spare reading equipment, equipment maintenance
contracts to ensure minimum downtime, recording requirements and follow up
action required etc.


Question 13. Do you agree that contingency arrangements should be
put in place at markets and abattoirs to ensure that normal trading
practices are not disrupted in the event of power or equipment failure?




Penalties

A person committing an offence under the proposed regulations will be
subject to prosecution, which would result in imprisonment or a fine not
exceeding the statutory maximum.

The domestic rules are cross compliant and breaches of the rules could be
subject to Single Farm Payment penalties.

Enforcement

It is proposed that the Local Authorities will continue in their current
enforcement role. The Scottish Government Rural Payments and Inspection
Directorate (SGRPID) will continue to carry out statutory on farm inspections
to confirm compliance with the rules.

Training

The Regulation requires that training is made available 8 . The Scottish
Government proposes to make any training considered necessary available,
building upon information and evidence gained from the Scottish research
pilot.

Please add any further comments you may have on the implementation
options of the EU regulations.



Animal Health – Disease Prevention
Rural Directorate
Scottish Government

8
    Article 11(2) Council Regulation 21/2004


                                                                          13
Annex A - Summary of the current (double tagging) sheep and goat
identification regime in Scotland

The current rules 9 have been in force since 18 January 2008. They
implement the double identification and batch recording requirements-which
are effective until 01 January 2010, at which time they will be revoked.

The main provisions contained within the current legislation are:

    • All sheep and goats must be identified with two official means of
      identification bearing the same identical number within 6 months of birth
      (intensively reared stock) or 9 months of birth (extensively reared stock)
      and in any case before the stock leave the holding on which it was born.
    • The only exception from the need to apply a double means of
      identification is for those animals, which are intended for domestic
      slaughter within 12 months of birth which may be identified using a single
      slaughter tag.
    • Lost or damaged tags must be replaced within 28 days of the loss or
      damage being detected. The lost or damaged tag must be replaced with
      an identical tag, or (if the animal is on its birth holding) another UK tag or
      (if the animal is not on its birth holding) a red R tag. Whenever a
      replacement tag is applied (of whatever type), a record of the replacement
      should be made in the replacement section of the holding register and
      where appropriate a cross reference made between the old and new tag.
    • All movements onto and off a holding must be recorded in the holding
      register on a batch basis within 36 hours of the movement taking place.
      For movements off the holding keepers have a choice between making a
      record in the register or retaining a copy of the movement document. The
      register must also include replacement information and keeper details as
      required by the Regulation.
    • All movements between holdings (except between holdings within 5 miles
      of the keeper’s main holding where the animals remain under the care
      and control of the keeper) must be accompanied by a movement
      document and must contain the batch information of the animals being
      moved. The receiving keeper must forward a copy of the movement
      document to the SAMS within 3 days of receipt of animals onto the
      holding.
    • All movements are recorded on a central database, the Scottish Animal
      Movement System (SAMS) operated by the Scottish Governments Rural
      Payments and Inspectorate Directorate.
    • Inventory returns must be submitted centrally on an annual basis as at 1
      January.



    LITP


9
    Sheep and Goat (Identification and Traceability)(Scotland) Regulations 2006, as amended



                                                                                              14
                 REGULATORY IMPACT ASSESSMENT (RIA) FOR
              SCOTLAND ON THE IMPLEMENTATION OF ELECTRONIC
                IDENTIFICATION (EID) OF SHEEP AND INDIVIDUAL
               RECORDING OF SHEEP AND GOATS UNDER COUNCIL
                          REGULATION (EC) 21/2004




Version:           1.0
Issue Date:        September 2009
Table of Contents


Section   Title                                       Page
   1      The Council Regulation                        3
   2      Purpose and Intended Effect                   3
   3      Options for Implementing the Regulations      4
   4      Benefits                                      8
   5      Costs                                        11
   6      Small/Micro Firms Impact Test                26
   7      Legal Aid Impact Assessment                  26
   8      Test run of Business Forms                   26
   9      Competition Assessment                       27
  10      Enforcement, Sanctions and Monitoring        27
  11      Monitoring and Review                        27
  12      Consultation – who                           28
  13      Summary and Recommendations                  28
  14      Regulatory Quality Declaration               30
  15      Data used in EID RIA                         31




                                                     Page 2 of 31
1.        The Council Regulation

1.1    Council Regulation (EC) 21/2004 (“the Regulation”) establishes a system for
the identification and registration of ovine and caprine animals and amending
Regulation (EC) No 1782/2003 and Directives 92/102/EEC and 64/432/EEC. The
Regulation applies throughout the United Kingdom. This RIA only applies to the
introduction of individual recording and electronic identification (EID) in Scotland.

2         Purpose and Intended Effect
2.1       The objective

2.1.1 This RIA will assess the potential impact upon the livestock industry,
Government, and other stakeholders of the regulatory introduction of electronic
identification (EID) of sheep and individual recording of sheep and goats on 01
January 2010.

2.1.2. The introduction of individual recording and electronic identification is
intended to improve the system of identification and traceability of sheep and goats,
giving rise to disease control benefits that include reduced outbreak costs, and fewer
infected premises and animals culled. The rules of the system will be linked to the
payments of EU subsidies.

2.2       Background

2.2.1 Following the 2001 Foot and Mouth Disease (FMD) outbreak the EU
Commission decided on the need to improve traceability of sheep and goats in order
to control future disease outbreaks better. This led to the adoption of the Council
Regulation (EC) No 21/2004.

2.2.2 The first phase required double tagging from 2005. In Scotland those rules
were deferred until 18 January 2008 following an initial derogation that maintained
batch recording. The second phase is to move to individual animal traceability. This
requires the introduction of individual animal recording through electronic
identification and the date when this must be introduced is 01 January 2010 as set
by the EU Council of Ministers.

2.2.3 Since the introduction date was agreed, concessions have been agreed by
the EU Commission’s Standing Committee on the Food Chain and Animal Health
(SCoFCAH) that provides for a phased in approach to individual recording with the
use of 3rd parties to record the information as follows:

      •   No animals have to be individually recorded on a movement document until
          01 January 2011.
      •   No animals born before 01 January 2010 have to be individually recorded on
          a movement documents until 01 January 2012.
      •   No animal born before 01 January 2010 and moving to slaughter (directly or
          via a market) will have to be individually recorded at all.



                                                                           Page 3 of 31
      •   Animals born after 01 January 2010 will require to be individually recorded in
          farm registers.
      •   Animals born after 01 January 2010 require two means of identification one
          must be electronic) – although a slaughter derogation exists for animals
          intended to be slaughtered within 12 months of age.


2.3       Rationale for Intervention

2.3.1 EU Regulation 21/2004 is directly applicable to all Member States. If the
Scottish Government fails to enforce this Regulation there is a high risk that the
European Commission would commence infraction procedures against Scotland and
the UK. The Regulation is also considered for the purpose of cross-compliance and
therefore keepers that fail to comply with the Regulation could have some or all of
their Single Farm Payment withheld under disallowance procedures.

2.3.2 The ability to identify and trace livestock movements is an important part of
the Scottish Governments capability in controlling animal’s disease. By setting
nationalised standards and procedures, rather that leaving traceability to individuals,
quicker and more efficient traceability should be recognised leading to better disease
outbreak management and eradication. This is the basis of the case for compulsory
animal identification.

3         Options for implementing the Regulation
3.1    The implementation options are different for sheep and goats.           The
Regulations provide for compulsory EID in Member States which have over 600,000
sheep and over 160,000 goats. As the UK has over 600,000 sheep we must provide
for compulsory EID for sheep but do not have provide this for goats as we have less
than 160,000. Both sheep and goats are, however, subject to individual recording.


3.2       Sheep

3.2.1 All sheep born or identified after 01 January 2010 must be identified by two
identifiers, one of which must be electronic. The exception to this rule is in case of
animals intended for slaughter within 12 months of age, where a single non
electronic slaughter batch tag may be applied. This is known as the slaughter
derogation.


Option 1 – Do nothing

3.2.2 In this scenario, Scotland would continue to rely on the current system of
identification; that is, double identification of sheep and goats (two eartags or one
eartag and a tattoo, with manual recording of details in holding registers and on
movement documents at batch level. A slaughter derogation will allow keepers to
identify animals that are below the age of twelve months, and intended for slaughter,
with a single eartag.



                                                                             Page 4 of 31
3.2.3 This is not an option for Scotland as it would result in us knowingly under
implementing EU Regulations which would leave us open to infractions procedures
that could cost millions of pounds. If the Scottish Government do not implement the
EID regulation and do not instruct farmers to adhere to the Regulations and of their
cross compliance obligations, which stand regardless of domestic EID
implementation, we could suffer disallowance of approx £11.5 million initially, which
could quickly rise to 100% of SFP paid to sheep farmers in Scotland. This could be
well in the region of several hundred million pounds. In addition the Scottish
Government could lose our paying agency status resulting in no agricultural
payments being allowed in Scotland.

3.2.4 Sheep farmers who choose not to comply could lose 15% - 50% of their SFP
at the start. Continued non-compliance by farmers would result in 100% loss of their
SFP.


Option 2 – Full EID implementation

3.2.5 Identify all newborn sheep, from 01 January 2010, with an EID device and
one other means of identification. From 01 January 2010, all animals born after this
date will be required to be individually identified in farm holding registers and then on
movement documents by 01 January 2011. The only exemption from reporting
individual IDs in holding registers and on movement documents will be where older
non-electronically identified animals are moved directly to slaughter (or to slaughter
by way of a market) from the holding on which they stand.

3.2.6 Although this would be the easiest option to implement as all animals would
be identified under the one option it would also be by far the most expensive option.
This would be due to a result of all animals requiring two means of identification, one
of which would electronic, and be individually recorded. The cost and practicality of
this option therefore makes this option very difficult to implement.

Option 3 – Restricted Slaughter Derogation

3.2.7 Identify all newborn breeding sheep and goats, from 01 January 2010, with an
EID device and one other means of identification. From 01 January 2010, all
breeding animals born after this date will be required to be individually identified in
farm holding registers and then on movement documents by 01 January 2011.
Where older, non-electronically identified animals are moved directly to slaughter (or
to slaughter by way of a market) from the holding on which they stand, there will be
an exemption from the need to report individual IDs in holding registers and on
movement documents.

3.2.8 However, for animals under the age of 12 months and moving direct to
slaughter (or via a market) only a single non electronic slaughter batch tag need be
applied containing the flock mark of the holding of birth. Only the flock mark of
animals identified under the slaughter derogation will be required to be recorded in
farm holding registers and on movement documents.




                                                                             Page 5 of 31
Option 4 – Full Slaughter Derogation

3.2.9 Identify all newborn breeding sheep and goats, from 01 January 2010, with an
EID device and one other means of identification. From 01 January 2010, all
breeding animals born after this date will be required to be individually identified in
farm holding registers and then on movement documents by 01 January 2011.
Where older, non-electronically identified animals are moved directly to slaughter (or
to slaughter by way of a market) from the holding on which they stand, there will be
an exemption from the need to report individual IDs in holding registers and on
movement documents.

3.2.10        However, for animals intended for slaughter before the age of 12
months only a single non electronic slaughter batch tag need be applied containing
the flock mark of the holding of birth. Only the flock mark of animals identified under
the slaughter derogation will be required to be recorded in farm holding registers and
on movement documents. However, where a batch contains animals bearing
several different flockmarks, the movement document will be required to contain a
count of the numbers of sheep within the batch bearing each flockmark (batch within
a batch).

3.2.11        This option provides for the least amount of animals requiring an
electronic identifier (approx 70% would not require them – see section 5.5.1)
however the requirement to record ‘batch within a batch’ information, particularly in
places of high throughput (such as markets and abattoirs) would be almost
impossible to carry out unless the animals could be electronically read and recorded.
Therefore this option would be very difficult for high throughput premises to operate.
(Batch within a batch is where animals in a mixed batch that have the same flock
numbers needs to identified to identify the holdings the animals where born on. This
would have to be done by manual checks unless the animals are electronically
identified).

Option 5 – Electronic Slaughter Tag Derogation

3.2.12         In order to alleviate the problem of ‘batch within a batch’ (see option 4)
an alternative exists that would allow animals intended for slaughter under the age of
12 months to be identified by a single electronic tag. As mentioned in the main
consultation document the electronic slaughter tag may contain only a flock mark or
a full 12 digit unique number and the difference will effect the ‘upgrading’ of these
animals if they reach 12 months of age. This RIA assumes that the full 12 digit will be
used. By use of electronic slaughter tags mixed batched animals could be recorded
electronically removing the need to manually record this information.

3.2.13         This option would continue to provide for the use of the slaughter
derogation to its fullest extent, but by allowing the use of an electronic slaughter tag
it would alleviate the problem of ‘batch within a batch recording’.

3.3    Goats

3.3.1 The rules for the identification of goats will not change, but goats will have to
be individually recorded in holding registers and movement documents. Goats will


                                                                             Page 6 of 31
require to be identified by two non electronic identifiers but keepers may fit electronic
ones if they wish. As with sheep we can choose to apply the slaughter derogation or
not.

Option 1 – Continue with existing system and introduce individual recording

3.3.1 Only goats which are to be kept beyond the age of 12 months would be
double identified with a matching pair of identifiers. These animals would need to be
individually recorded on movement documents and holding registers. All animals
intended for slaughter with 12 months of age would be identified by the slaughter
derogation – identified with a slaughter tag and recorded on a batch basis.

Option 2 - No slaughter derogation and introduce individual recording

3.3.2 All goats, with no exception, would be double identified. This would mean that
all animals would need to be individually read and recorded.

3.4    Critical Control Points (CCP’s)

3.4.1 Following representations by the Scottish and UK Governments the
Commission have amended the Regulations to permit the use of Critical Control
Points (CCP’s) to act as third parties. This means that CCP’s can record the
individual identities of animals on behalf of the receiver/consigner, rather than
farmers having to individually record animal identities as they leave the holding and
therefore markets and abattoirs appear to be well suited to acting as CCP’s. This
therefore avoids the need for many keepers to purchase recording equipment and
transfers the individual recording requirement to the approved reading facility. All
movement of animals outwith CCP’s would still require to be individually recorded by
the consigning and receiving keepers.

Option 1 – Allow the use of CCP’s

3.4.2 This allows for third parties (for example markets and abattoirs) to be
approved CCP and record the individual identities of animals and pass this
information to the consigning and receiving keepers, therefore fulfilling the
requirements of the holding registers and movement documents. In order for CCP’s
to act effectively and in particular those of high throughput volumes, animals may
require to be electronically identified (full EID or slaughter EID tag).

Option 2 – Do not allow the use of CCP’s

3.4.3 This would mean that all animals would have to be individually read and
recorded at individual holding level before the animals departed. This would require
most farms in Scotland to purchase electronic reading equipment. Holdings with few
numbers of animals could operate on a manual basis, but it would be a management
decision on the best way to individually record the animals identities.




                                                                             Page 7 of 31
3.5   Central Database

3.5.1 The Regulation also provides derogations from the requirement to maintain
farm records and complete movement documents where a central database
containing individual information is operational. A national database containing
individual animal information is not, however, an EU obligation and therefore any
costs to carry out these functions would be over and above the EU requirements. As
such only high level estimates are given to costs associated with these derogations.
If this is an option the Scottish Government and its industry wishes to pursue then
further cost analysis will be carried out.

4.    Benefits
4.1.1 Cost-benefit analysis (CBA) offers a framework within which information may
be assembled on the economic gains and losses associated with a course of action
(in this case the implementation of EU Regulations and the attempt to combat
disease control and ensure public health).

4.1.2 In the case of sheep EID and individual recording of sheep and goats in
Scotland, it is unfortunate that some information on costs and benefits remains
incomplete. This is mainly due to the absence of an individual animal database that
could be interrogated to provide detailed animal movement patterns. None the less
costs and benefits have been derived from known sources, including evidence
gathered from the Scottish electronic research pilot and from Industry stakeholders.

Benefits

4.2.1 The potential benefits of EID and individual recording falls into three main
categories; disease control, consumer confidence; and flock management. This is in
addition to the benefit of the Scottish Government and Industry in complying with EU
regulations and therefore avoiding disallowance and infraction procedures as
mentioned earlier.

Disease Control

4.2.2 The outbreak of FMD in 2001 was the principle driver towards the introduction
of the EU Regulation. In this context the benefits of EID and individual recording
depends not only to its contribution to reduction the duration of the outbreak but also
on the frequency and intensity of outbreaks.

4.2.3 In the absence of any formal epidemiological modelling of EID’s efficacy at
reducing the duration of an FMD outbreak it is not possible to state categorically the
impact on FMD costs. However for illustrative purposes it is possible to consider
how EID and individual recording could impact on the costs. In the 2007 FMD
outbreak it is estimated that the costs to the Scottish Industry was around £36.5
million if which nearly three quarters was attributed to withholding costs arising from
the movement ban. If EID and individual recording were highly effective (and
therefore fully implemented) it is possible that, in the extreme, all of these costs
might be avoided through reducing the duration of the outbreak and facilitating
earlier relaxation of movement restrictions. Equally, a proportion of the market


                                                                            Page 8 of 31
losses arising from the export ban might be avoided, although some losses cannot
be avoided since the legal minimum period of an export ban would still be observed.

4.2.4 It can therefore be assumed that up to around £30 million of costs might be
avoided of a disease outbreak of the 2007 magnitude if a fully effective EID system
was in place. However if such an outbreak occurs only once every 10 years then
expected annual benefit is only £3 million. If EID is less than effective then the gains
would be smaller.

Consumer Confidence

4.3.1 Livestock traceability systems originally arose in response to consumer
concerns over BSE in the cattle sector. However, for the sheep sector, given the
absence of any high profile food safety risk, it is not clear exactly why consumer
confidence would be expected to be affected by the introduction of individual
traceability for sheep. Moreover, whilst it is true that evidence on consumer
preferences suggests that systems of quality assurance and origin labelling do have
some value, individual traceability per se does not feature in this. That is,
consumers are generally either unaware of or uninterested in the mechanics of how
quality assurance and origin labelling operate and are unlikely to pay a price
premium for individual traceability if they perceive no advantage from it.

4.3.2 An alternative view of this is that requirements for individual traceability might
become a requirement for continued access to export markets.                     Indeed,
notwithstanding uncertainty over the status of such moves under the WTO, countries
such as Australia and New Zealand are pushing individual traceability partly as a
response to expectations that the EU and other trading partners may adopt such a
stance. However, given the relatively low volumes of Scottish sheep exported
beyond the EU, the relevance of the market access argument is rather limited.

Flock management

4.4.1 In principle, EID offers the technical potential to improve flock management by
linking ewes to lambs and permitting the collation of information on, for example,
daily liveweight gains and final carcass weight and grade. Such a management
system could deliver productivity improvements, provided that additional investments
were also made to on-farm information systems and at abattoirs for passing
information back along the supply chain – therefore linked to Food Chain Information
(FCI).

4.4.2 For example, enterprise costing reported by Quality Meat Scotland (QMS) for
the top, middle and third of sheep flocks suggest that differences in both technical
and marketing performance generate a difference in gross margin per ewe of around
£12 between the top and average performers and £25 between the top and bottom
performers. Simplistically, this implies that better flock management and marketing
could add £37m to the aggregate gross margin of the sector, although a more
sophisticated analysis of the distribution of current performance and variation in
management constraints lowers this to perhaps £20m (Pareto Consulting - CBA of
Scottish Electronic Research Pilot 2009).



                                                                            Page 9 of 31
4.4.3 However, the existence and persistence of variation in performance across
farms is not new and has been the target of repeated efforts to raise management
standards. When the Forward Strategy for Scottish Agriculture was launched in
2001, it was estimated that around only 10% of all farms were engaged in some form
of benchmarking. Since then, various efforts have been made to extend the uptake,
such as the provision of on-line information, the formation of monitor farms and the
availability of funding under Land Management Contracts. Yet, taking the latter as
an example, only around 13.5% of farms with sheep also enrolled in the
benchmarking option (Pareto Consulting - CBA of Scottish Electronic Research Pilot
2009). Whilst this may not be truly representative of the sector, it does reveal that
even when funding is available for relatively simple benchmarking activities, uptake
by the industry remains low. This suggests that the likely usage of EID for flock
management will be extremely limited and hence any performance gains attributable
to it minimal.


Benefit of options identified in the paper

Identification

4.5.1 Pursuing option 1 for sheep identification could result in infraction procedures
and disallowance. The possible fines associated to these procedures to the Scottish
Government and industry significantly outweigh the costs associated with
implementation and therefore this option would provide no real benefits. The benefit
of option 2 is that it provides for a one system fits all and therefore makes it the
simplest of systems to introduce. However as previously stated this is the most
expensive option.

 4.5.2 Option 3 and 4 both offer significant savings to industry because of the
possibility of the use of a slaughter tag. Option 4 however, introduces the issue of
dealing with mixed batches, which would appear to make the option impossible to
operate whilst option 3 would only be useful to those who move animals direct from
the holding of births to an abattoir. Option 5 provides the benefit of allowing all
animals intended for slaughter to be identified by a single means of identification,
would cater for mixed batches and the problem of recording ‘batch within a batch’
and allows for slaughter animals to be upgraded to full identity status if they reach 12
months of age. The downside to this option is that animals moving direct to
slaughter from the holding of birth (and therefore not causing any mixed batch
problems) would require an electronic tag that is significantly more expensive that a
plastic tag.

 4.5.3 The benefits of option one with regards to goats is that it allows for current
system to remain in place with only the addition if the extra information required in
movement documents and holding registers. Option two for goats would provide a
benefit of operating only one system, rather than allowing a two tier system
(breeding animals and those intended for slaughter under 12 months).




                                                                           Page 10 of 31
Critical Control Points

4.6.1 Option one provides significant benefits’ over option two by allowing the use
of third parties to read and record individual animal identities. This means that all
farmers who move animals through a CCP (primarily expected to be markets and
abattoirs) will not have to buy electronic reading equipment and spend time and
labour costs associated with using the equipment. There are no easily recognised
benefits associated with option two. If farmers wish to read and record individual
animals at their premises then they can do so as they wish, irrespective of the use of
CCP’s.

Central Database

4.7.1 As mentioned previously a central database that records the individual identity
of animals is not a requirement under the European Regulation and therefore the
creation on such a database could be seen as over implementation of the
Regulation. However, if such a database does exist it does open up the options of
removing farm records and movement documents if the required information is held
centrally. This would lead to a paperless system with less on farm recording
burdens for famers and industry bodies whilst looking to provide quicker and
accurate data to the competent authority.

4.7.2 As such it would appear sensible that a central database should be a desired
outcome for the Scottish Government and Industry, although perhaps be addressed
in the long term with phased in approach being adopted. In the immediate future the
derogations available could be made to those who wish to voluntary adopt the
requirements – focussing on either only the derogation associated with movement
document or on movement documents and the holding register.

Goats

4.8     The costs associated with option 1 and 2 are very similar (see section 5.14 –
5.17) although option one is slightly cheaper and maintains the current identification
system for goats. Given that most, if not all, goats will be recorded on an individual
basis then the Scottish Government see no reason to change the current rules on
identification and therefore believes the slaughter derogation (option 1) should
continue to be an option for goat keepers.

5       Costs

5.1     Sheep Identification

5.1.1 - number of animals:

•     There are around 7.1 million sheep in Scotland.
•     This includes approx 3.7 million lambs, of which approx 70% (2.6 million) are
      intended for slaughter before the age of 12 months
•     Of the 2.6 million slaughter lambs 50% of the animals are estimated to go direct
      to slaughter and 50% are slaughtered after being on at least two holdings.



                                                                          Page 11 of 31
•     The remaining 30% of the lamb crop (1.1 million) are retained beyond the 12
     months, mainly as breeding animals.
•    Of the 1.1 million breeding animals approximately 50% (550,000) will be kept on
     the holding of birth, with the other half moving to a different location.

5.1.2 Costs of means of identification will vary between different manufactures and
the type of device used. This RIA therefore assumes that the average cost
purchasing two means of identification is £1 per animal (based on one conventional
eartag (approx £0.15), and one electronic tag (approx £0.85p)).

5.1.3 Previous studies have shown that it takes around 92.4 seconds to apply a
conventional and EID tag to a single animal. This falls broadly in line with results
from the Scottish Electronic research pilot which indicates that it can take two people
one minute to indentify an animal. This RIA therefore assumes that it take on
average one person 100 seconds to identify an animal with the two means of
identification (36 animals per hour). Similarly previous studies have shown it takes
on average 33 seconds to apply a single tag (109 animals per hour).

5.1.4 Labour costs associated across the livestock sector are averaged at £7.97 per
person per hour (figures from Scottish Government Economists on costing of Land
Management Options 2009).


Option one – Do nothing.

5.2.1 The costs associated to this option can be linked to those produced in the RIA
for Scotland on the implementation of double tagging for ovine and caprine animals
under Council Regulation (EC) 21/2004 that was produced in December 2007.
Since that document was produced several factors have changed that slightly alter
figure given at this point – i) the ration of animals slaughtered under 12 months of
age or not has changed for 60:40 to 70:30. The labour costs have also slightly
decreased and the costs of eartags have reduced.

5.2.2 Under this option 70% of all newborn lambs would require a single batch tag
with the remaining 30% requiring two eartags. The cost of purchasing identification
therefore estimated to cost £720,000 (2.6 million lambs X £0.15 + 1.1 million lambs X
£0.30).

5.2.3 Using a labour rate of £7.97, the labour cost associated with identifying all
new born lambs under this option is estimated to be £278,510 (70% of all lambs/ 109
(number of animals single tagged per hour) X £7.97 + 30% of all lambs/55 (number
of animals double tagged in per hour) X £7.97).

5.2.4 Replacement tags are estimated to be 5% of the flock. It is assumed that the
vast majority of keepers would not replace a lost identifier with an identical identifier
and would instead replace with new identifiers. On this basis costs for replacement
tags for animals born after 01 January 2010 is estimated to be £36,000 (5% of 2.6
million X £0.15 + 5% of 1.1 million X £0.30).




                                                                            Page 12 of 31
5.2.5 The total cost for identifying animals under this option is there estimated to be
£1,105,510

Option two – Full EID implementation

5.3.1 Under this option 2 all newborn lambs would have to be identified with two
means of identification, one which must be electronic. The cost of purchasing the
means of identification is therefore estimated to be £3,700,000 (3.7 million lambs x
£1).

5.3.2 Using the labour rate of £7.97 per hour, the labour costs associated with
identifying the 3.7 million lambs is therefore estimated to be £819,139 (3.7 million
lambs / 36 (animals identified per hour) x £7.97).

5.3.3 Replacement tags are estimated to be 5% of the flock. It is assumed that the
vast majority of keepers would not replace a lost identifier with an identical identifier
and would instead replace with new identifiers. On this basis costs for replacement
tags for animals born after 01 January 2010 is therefore estimated to be £185,000
(5% of 3.7 million lambs x £1.00).

5.3.4 The total cost of identifying animals under option two is therefore estimated to
be £4,704,139

5.3.5 The total additional cost of identifying animals as a result of option two is
therefore estimated to be £3,598,629

Option 3 - Restricted slaughter derogation

5.4.1 Under this option all lambs not sent direct to slaughter would have to be
identified with two means of identification, one of which must be electronic. Animals
that are sent direct to slaughter would only require a single plastic eartag. Therefore
the costs of purchasing means of identification under this option is estimated to be
£2,599,250 (direct to slaughter 35% of 3,700,000 x £0.15 = £194,250 + not direct to
slaughter 65% of 3,700,000 x £1= £2,405,000).

5.4.2 Using the labour rate of £7.97 per hour, the labour costs associated with
identifying the 3.7 million lambs under this option is estimated to be £627,129 (direct
to slaughter 35% of 3,700,000 / 109 (animals identified per hour) X £7.97 = £94,689
+ not direct to slaughter 65% of 3,700,000 / 36 (animals identified per hour) x £7.97
= £532,440).

5.4.3 Replacement tags are estimated to be 5% of the flock. It is assumed that the
vast majority of keepers would not replace a lost identifier with an identical identifier
and would instead replace with new identifiers. On this basis costs for replacement
tags for animals born after 01 January 2010 under this option is estimated to be
£129,962 (5% of 35% of all lambs (direct to slaughter) x £0.15 = £9,712 + 5% of 65%
of all lambs (not direct to slaughter) x £1 = £120,250).

5.4.4 The total cost of identifying animals under option three is therefore estimated
to be £3,261,652


                                                                            Page 13 of 31
5.4.5 The total additional cost of identifying animals as a result of option three is
therefore estimated to be £2,156,142


Option 4 – Full slaughter derogation

5.5.1 Under this option all lambs intended for slaughter within 12 months of age
only require a single plastic tag. All other animals would have to be identified with
two means of identification, one which must be electronic. Therefore the costs of
purchasing means of identification under this option is estimated to be £1,498,500
(intended for slaughter 70% of all lambs x £0.15 = £388,500 + not intended for
slaughter 30% of all lambs x £1 = £1,110,000).

5.5.2 Using the labour rate of £7.97 per hour, the labour costs associated with
identifying the 3.7 million lambs under this option is estimated to be £435,121
(intended for slaughter 70% of all lambs / 109 (animals identified per hour) x £7.97 =
£189,379) + not intended for slaughter 30% of all lambs / 36 (animals identified per
hour) x £7.97 = £245,742).

5.5.3 Replacement tags are estimated to be 5% of the flock. It is assumed that the
vast majority of keepers would not replace a lost identifier with an identical identifier
and would instead replace with new identifiers. On this basis costs for replacement
tags for animals born after 01 January 2010 under this option is estimated to be
£74,925 (5% of 70% of all lambs intended for slaughter x £0.15 = £19,425 + 5% of
30% of all lambs not intended for slaughter) x £1 = £74,925).

5.5.4 The total cost of identifying animals under option four is therefore estimated to
be £2,008,546

5.5.5 The total additional cost of identifying animals as a result of option four is
therefore estimated to be £903,036

Option 5 – Electronic slaughter tag derogation

5.6.1 Under this option all lambs intended for slaughter within 12 months of age
could be identified by a single electronic tag. All other animals would have to be
identified with two means of identification, one which must be electronic. Therefore
the costs of purchasing means of identification under this option is estimated to be
£3,311,500 (intended for slaughter 70% of all lambs x £0.85 = £2,201,500 + not
intended for slaughter 30% of all lambs x £1 = £1,110,000).

5.6.2 Using the labour rate of £7.97 per hour, the labour costs associated with
identifying the 3.7 million lambs under this option is estimated to be £435,121
(intended for slaughter 70% of all lambs / 109 (animals identified per hour) x £7.97 =
£189,379) + not intended for slaughter 30% of all lambs / 36 (animals identified per
hour) x £7.97 = £245,742).

5.6.3 Replacement tags are estimated to be 5% of the flock. It is assumed that the
vast majority of keepers would not replace a lost identifier with an identical identifier


                                                                            Page 14 of 31
and would instead replace with new identifiers. On this basis costs for replacement
tags for animals born after 01 January 2010 under this option is estimated to be
£165,575 (5% of 70% of all lambs intended for slaughter x £0.85 = £110,075 + 5% of
30% of all lambs not intended for slaughter) x £1 = £74,925).

5.6.4 The total cost of identifying animals under option five is therefore estimated to
be £3,922,196

5.6.5 The total additional cost of identifying animals as a result of this option is
therefore estimated to be £2,816.686

Table one – summary costs for identification

Options    Cost        of Labour          Replacement       Total        Total
           purchasing     costs           costs             costs        additional
           id                                                            cost
Option 1      £720,000     £278,510             £36,000     £1,105,510        £0
Option 2     £3,700,000    £819,139            £185,000     £4,704,139    £3,598,629
Option 3     £2,599,250    £627,129            £129,962     £3,261,652    £2,156,142
Option 4     £1498,500     £435,121            £74,925      £2,008,546     £903,036
Option 5     £3,311,500    £435,121            £165,575     £3,922,196    £2,816,686


5.7   Movement Documents and Critical Control Points

5.7.1 Information from the Scottish Animal Movement System (SAMS – the current
competent authority database) shows that there are approximately 320,000 batch
movements covering over 7,500,000 animals. This equates to 23.5 animals per
batch.

5.7.2 In line with 5.1.1 (percentage split of the national flock) this RIA assumes that
of the 320,000 batch movements, 51% will be animals from the new lamb crop, and
49% from the older population.

5.7.3 Information for the Scottish Animal Movement System (SAMS) and those from
EPIC which were used to underpin the Scudamore review of FMD 2007 suggest that
30% of all moves are moves from farm to farm, 40% are moves from farms to
markets (and then on a farm or abattoir) and 30% of moves are from farm to abattoir.

5.7.4 Labour costs associated across the livestock sector are averaged at £7.97 per
person per hour (figures from Scottish Government Economists on costing of Land
Management Options 2009).

5.7.5 Results from the Scottish Government electronic research pilot shows that it
takes on average around 6 seconds per animal for on farm hand held EID reading,
whilst faxed panel readers takes around 3 seconds. Manual reading and recording
by comparison takes around 2 minutes per sheep.

5.7.6 Results from the Scottish Government electronic research pilot shows that it
takes around 5 minutes to upload data captured by a hand held device, regardless of


                                                                           Page 15 of 31
the number of animals. Timing is automatic by fixed panel readers. Manual
recording onto paper documents (and holding registers) takes around 2 minutes per
animal.

5.7.7 EID reading and recording equipment will vary in specification and cost but
figures of £600 for hand help equipment and £10,000 for fixed panels at markets and
£5,000 at abattoirs are indicative of the equipment available and therefore used for
the purpose of this RIA. This RIA uses the figure of 20 markets in Scotland and 30
abattoirs.

5.7.8 There are approx 15,000 sheep holdings and keepers in Scotland (Scottish
Government data). Of these approximately 50% have flock sizes of less than 100
animals (Scottish Government Economic Report on Scottish Agriculture 2009
edition). Results from the Scottish Government Electronic research pilot suggests
that EID reading equipment would not be required for flocks of less than 100
animals.


Option 1 – Allow the use of CCP’s

5.8.1 Installation of fixed panel readers at CCP’s is estimated to cost £350,000 (20
markets X £10,000 + 30 abattoirs X £5,000).

5.8.2 All 320,000 batch movements require an accompanying movement document.
Approximately 70% of batches (224,000) go through markets and abattoirs –
possible critical control points. Reading and recording of animals at CCP’s would be
automatic and therefore there would be negligible costs in doing so (on the
assumption that animals do not require to be re-read). Therefore a nil cost is used
for this RIA.

5.8.3 96,000 batch moves may not go through a CCP’s (i.e. farm to farm moves)
Using the same proportionate figure as paragraph 5.8.2 (70-30% split) this could
equate to 4,500 holdings (30% of all keepers). In line with point 5.7.8 it can be
assumed that 50% of these holdings (2250) will require EID reading equipment at
some point and therefore the cost of for reading equipment on farm is estimated to
be would be £1,350,000 (2250 holdings x £600).

5.8.4 On assumption that all animals will require to be individually identified (i.e. no
slaughter derogation) then labour costs for reading and recording the 96,000 batch
movements by use of hand held equipment is estimated to be £346,535 based on
50% of the batches being recorded by EID equipment and 50% manual (48,000
batches x 23.5 animals / 600 x £7.97) + 48000 / 12 batches per hour x £7.97 =
£46,863 + 48,000 batches X 23.5 animals / 30 x £7.97 = £299.672).

5.8.4 Therefore the total additional costs associated with the reading and recording
movement documents with the use CCP’s is estimated to be £2,046,535




                                                                           Page 16 of 31
Option 2 – do not use CCP’s

5.9.1 It is assumed that high throughput premises (i.e. markets and abattoirs) will
require EID reading equipment to fulfil their regulatory requirements, regardless if
CCP’s are used or not. Therefore equipment costs for markets and abattoirs are
estimated to be £350,000 in line with point 5.8.1.

5.9.2 On the basis that 50% of all holdings will require EID reading equipment at
some point the costs for reading equipment on farm is estimated to be £4,500,000
(7500 holdings X £600 reading equipment).

5.9.3     On the assumption that all animals will require to be individually identified
(i.e. no slaughter derogation) then labour costs for reading and recording 160,000
batch movements (50% of the total batch movements) by use of hand held
equipment is estimated to be £156,211 (160,000 batches x 23.5 animals) / 600 x
£7.97) + (160,000 /12 batches per hour) x £7.97).

5.9.4 Following on from point 5.9.3 it can be assumed that 50% of all batch
movements will require to be manually recorded. The labour costs associated with
manually reading and recording is therefore estimated to be £998,906 (160,000
batches x 23.5 animals) / 30 x £7.97)

Therefore the total additional costs associated reading and recording movement
documents with no use of CCP’s is estimated to be £6,005,117


Table 2 - Summary of costs associated with the use and non use of CCP’s

Options      Cost of reading On          farm On        farm Total costs
             equipments     at reading        reading    and
             possible CCP’s    equipment cost recording
                                              costs
Option 1         £350,000        £1,350,000      £346,535    £2, 046,535
Option 2         £350,000        £4,500,000     £1,155,117    £6,005,117


5.10   Holding Registers

5.10.1 As mentioned in the main consultation there is no change to the recording
requirements for animals born before 31 December 2010. For those that are born
after this date then the following information is required; individual identity of animal;
the year of birth and date the animal was identified, the month and year of death;
and the breed and genotype (if known). If any animal is identified under the
slaughter derogation at the batch level then information would be recorded at a batch
level.

5.10.2 It is assumed that births will be entered in runs of consecutive numbers and
therefore there will be minimal time and effort required to record this information (i.e.
entry need only say 50 animals (numbers 1-50) born in 2010, identified on 01 March
2010. Therefore no cost is associated to this activity.


                                                                             Page 17 of 31
5.10.3 Animals that die on farm prior to being identified (i.e. any animal still on the
holding of birth that has not been identified within 9 months) will not require their
death details to be recorded.

5.10.4 On farm deaths for identified animals is approximately 5% of the flock (2-3%
found on lowland farms and 5-7% of upland farms – therefore 5% is average. From
Scottish Electronic Research Pilot information) In line with point 5.7.6 it takes 2 mins
per animals to manually read and record an animal. The costs therefore associated
with completing the holding register with death details is £49,148 (2% of all lambs /
30 animals per hour x £7.97).

5.10.5 The requirement to record individual animal’s movements onto a holding
register will be in line with the requirement of the movement documents as outlined
in sections 5.7 to 5.9. However, as the information in movement documents can be
used for the purpose of the holding registers then no extra costs will be associated to
populate the holding register.

5.10.6 Therefore the costs associated with the extra requirements of the holding
register will be £49,148.

5.11 Central Database

5.11.1 There are no new provisions for a central database to hold individual animal
information under the Regulations, however, benefits could be realised if one exists.
Costs below are therefore kept in general terms, with more detailed work being
required if an individual database is deemed appropriate.

5.11.2 If a central database is required it will incur both start up costs and running
costs. In the absence of working examples elsewhere to draw upon, the magnitude
of such costs is difficult to gauge. However assessments in Spain and the
Netherlands suggest running costs in the order of £0.1 per sheep and £0.8 per ewe
which equates to around £0.7m to £2.5 in Scotland, with £1.6m as an average.

5.11.3 Within this estimate, the treatment of incomplete data could be an important
cost component – reconciliation. If an error rate of 2.5% was witnessed on an
individual animal identity this would equate to 92,500 reconciliations. If these
reconciliations could be achieved automatically then the costs would be minimal.
However if, as with reconciliations associated with the British Cattle Movement
Service (BCMS), labour input was required then costs would increase. Using the
approximate figure of £5 per reconciliation as witnessed by the BCMS then costs
would be £462,500

5.11.4 The total initial costs therefore associated with an individual database would
cost in the region of £2,062,500 (discussions on funding of any such database would
be required before any commitment).

5.11.5 The Scottish Government believes that should the full intended slaughter
derogation be introduced as the only system then it would not make sense to have a
centralised individual database given that 70% of the animals would not be


                                                                           Page 18 of 31
individually indentified. A centralised database, however, could be utilised for any of
the other options.

5.12 Analysis of the Impacts of the EID regulation on Farm businesses using
farm accounts survey (FAS) data
5.12.1 The additional costs associated with the different options for the
implementation of the European EID regulation in Scotland are calculated above
and this analysis takes these figures and applies them at a farm business level (on a
cost per animal basis). This allows for the relative impacts on different farm types to
be examined, using FAS data to estimate the expected changes to farm business
costs and therefore net profitability. The analysis allows for indicative profitability and
farm business cost figures to be estimated by farm type.
5.12.2 The analysis considers each of the four options for implementation in turn (it
assumes that the impact of option one – do nothing is zero). It also looks at the
marginal effect of the decisions around critical control points, by examining all four
options under the assumption that critical control points are approved as part of the
EID implementation, and then examining the most and least costly options (full EID
implementation and implementation with the full slaughter derogation) under the
assumption that critical control points (CCP’s) would not be used.
5.12.3 The final element of the analysis is that the FAS dataset allows the
examination of the increased costs due to EID on the top 25% of the most profitable
farms, as well as the bottom 25%, which can show how more and less profitable
businesses would be affected. However, some caution should be taken here, as the
sample size of the farm accounts survey means that for certain farm types any
results split by profitability quartile would be based on restricted sample sizes which
limits the extent to which the results can be applied to the whole of Scottish
agriculture. To this end all that can be said is that it is likely that the most profitable
farms would face smaller costs than the least profitable farms, which in general are
less able to control their input costs.
5.12.4 The following results tables show firstly, the average cost increase, secondly,
the cost increase as a percentage of the total farm business costs, and finally the
cost increase as a percentage of the total profits. Unless it is stated otherwise, the
results are calculated for each option, assuming that critical control points are
allowed. It should be noted that the cost shown is an average cost, and so there is
likely to be some variation in the actual costs that are faced by producers.
Table 3 – Average cost increase per farm for policy options (with CCPs)
                                           Option 3 -    Option 4 -   Option 5 -
                        Option 2 - Full    Restricted    Full         Electronic
 Average cost           EID                slaughter     Slaughter    slaughter tag
 increase per farm      implementation derogation derogation derogation
 Specialist cereals                  £65           £48           £33             £56
 General Cropping                    £54           £40           £27             £46
 Dairy                               £67           £49           £34             £57
 LFA Specialist Sheep               £714          £527          £364            £612
 LFA Specialist Beef                £269          £198          £137            £230
 LFA Cattle and
 sheep                              £867          £639          £441            £744
 Lowground Cattle                   £315          £232          £160            £270


                                                                              Page 19 of 31
 and Sheep
 Mixed                              £225         £166          £115             £193
 All Farm types                     £326         £240          £166             £279


5.12.5 In terms of the absolute increase in average costs per farm, the farm types
that are most affected by this regulation are LFA specialist sheep and LFA cattle and
sheep farms. The exact increase in costs is determined by the option. As has been
shown previously, full EID implementation (option 2) is the most costly option for
industry, and the types of farm that will be affected the most are those which keep
sheep, and have low profitability. Under this option LFA cattle & sheep farmers
would see an increase in their business costs of about £867 on average, whilst the
average LFA specialist sheep would see an increase of around £714. Lowground
Cattle and sheep farmers would only see an increase of £315 on average and the
increase in costs across all farm types would be £326 on average under this option.
5.12.6 The option which would have the smallest effect on industry is the full
slaughter derogation (option 4); this would meant that an average LFA cattle &
sheep farm would experience a £441 increase in costs, whilst the average LFA
specialist sheep producer would see an increase of around £364 on average. The
average farm under all farm types would experience an increase of £166 under this
option.
5.12.7 The estimates of additional costs incurred as a result of the regulation are
more useful when set in the context of the business costs prior to the regulation.
Table 4 shows the costs as a percentage of total farm business costs for 2008.
Table 4 – Additional costs as a percentage of total farm business costs
                                           Option 3 -     Option 4 -   Option 5 -
 Cost transferred as     Option 2 - Full   Restricted     Full         Electronic
 % of average total      EID               slaughter      Slaughter    slaughter tag
 farm business costs     implementation derogation derogation derogation
 Specialist cereals                0.05%         0.04%         0.03%           0.05%
 General Cropping                  0.03%         0.02%         0.02%           0.03%
 Dairy                             0.03%         0.02%         0.02%           0.03%
 LFA Specialist Sheep              1.75%         1.29%         0.89%           1.50%
 LFA Specialist Beef               0.32%         0.23%         0.16%           0.27%
 LFA Cattle and
 sheep                             0.90%         0.66%         0.46%           0.77%
 Lowground Cattle
 and Sheep                         0.36%         0.27%         0.18%           0.31%
 Mixed                             0.19%         0.14%         0.10%           0.16%
 All Farm types                    0.29%         0.22%         0.15%           0.25%


5.12.8 Once again, table 4 shows that the largest impact on producers would be
under full implementation, and the smallest impact would be under the full slaughter
derogation, however the results also show that LFA specialist sheep would be the
worst hit (as a proportion of their total farm business costs) under any option, with
the average producer facing between a 1.75% and 0.89% increase in its total farm
business costs. LFA cattle and sheep would be the next worst hit, whilst LFA beef



                                                                         Page 20 of 31
and lowground cattle and sheep farms would both be affected more than the
average over all farm types.
5.12.9 As the results above show, some farms will be hit proportionally more than
others, and this would lead to relatively small increases in costs causing significant
percentage increases in farm business costs. The following results table shows how
these increased costs affect overall net profit.
Table 5 – Additional costs as a percentage of farm net profit
                                             Option 3 -    Option 4 -    Option 5 -
                           Option 2 - Full   Restricted    Full          Electronic
 Cost transferred as %     EID               slaughter     Slaughter     slaughter tag
 of net profit             implementation derogation derogation          derogation
 Specialist cereals                  0.10%        0.07%         0.05%           0.08%
 General Cropping                    0.08%        0.06%         0.04%           0.06%
 Dairy                               0.08%        0.06%         0.04%           0.07%
 LFA Specialist Sheep                3.96%        2.92%         2.01%           3.39%
 LFA Specialist Beef                 1.02%        0.75%         0.52%           0.87%
 LFA Cattle and sheep                3.17%        2.33%         1.61%           2.71%
 Lowground Cattle and
 Sheep                               1.06%        0.78%         0.54%           0.91%
 Mixed                               0.60%        0.44%         0.30%           0.51%
 All Farm types                      0.76%        0.56%         0.39%           0.65%


5.12.10       The above table shows the size of the average additional costs relative
to the net profit of the average business. It shows that under full EID implementation
the additional costs to an average LFA sheep farm would be equal to 3.96% of net
profit, and 3.17% of the average net profit for LFA cattle and sheep farms. LFA
specialist beef and lowground cattle and sheep both see increases in their farm
business costs equivalent to over 1% of their net profit, and the average farm over all
farm types would see an increase equal to 0.76% of its net profits.
5.12.11        These increases would fall depending on the different options, and
under the cheapest, where a full slaughter derogation is imposed (option 4) then the
LFA specialist sheep farm would see an increase in costs equal to just over 2% of
net profit, with LFA Cattle and sheep seeing an increase of 1.61% of net profits. On
average across all farm types, farms would see an increase in costs equivalent to
0.39% of net profit.
5.12.12       These results show that under every option, farms that are LFA
specialist sheep have the largest increase in costs as a proportion of their total farm
business costs and net profits, but LFA cattle and sheep farms are likely to see the
largest absolute increase in costs.
5.12.13         The previous results were estimated under the assumption that critical
control points would be adopted, the following now considers the changes that would
occur if critical control points were not adopted as part of the policy.
5.12.14       The non-adoption of critical control points would increase the costs of
the implementation of the EID regulation quite considerably. By comparing the
figures of the impacts on farm business costs both with and without critical control
points, the marginal effect that this decision has on farm businesses can be shown.



                                                                          Page 21 of 31
Table 4 below shows the average cost increase under option 2 and option 4, the
other options will have costs somewhere in between these two extremes.
Table 6 – Average increase in farm business costs by farm type
                            Option 2- Full   Option 4 - Full
                            EID              Slaughter
 Average cost increase      implementation derogation
 per farm                   without CCPs     without CCPs
 Specialist cereals                    £134               £102
 General Cropping                      £111                 £85
 Dairy                                 £138               £105
 LFA Specialist Sheep                £1,477             £1,127
 LFA Specialist Beef                   £556               £424
 LFA Cattle and sheep                £1,793             £1,368
 Lowground Cattle and
 Sheep                                 £651               £496
 Mixed                                 £466               £356
 All Farm types                        £673               £514


5.12.15       Table 6 shows that without critical control points under option 2 the
average LFA cattle and sheep producer would see an extra £926 added to his costs,
and the average LFA specialist sheep farm would be £763 worse off relative to
option 2 where CCPs were implemented as part of the regulation. Under option 4
this increase is slightly lower, but still high; LFA Cattle and sheep farms would face
an extra £728 on average on top of the costs of option 4 without CCPs, and the
average LFA specialist sheep farm would also see £600 in additional costs because
of the non adoption of CCPs under this option. Table 5 shows these costs in the
context of total farm business costs by farm type.
Table 7 – Average increase in farm business costs by farm type
                            Option 2- Full   Option 4 - Full
 Cost transferred as % of   EID              Slaughter
 average total farm         implementation derogation
 business costs             without CCPs     without CCPs
 Specialist cereals                  0.11%               0.09%
 General Cropping                    0.07%               0.05%
 Dairy                               0.07%               0.05%
 LFA Specialist Sheep                3.61%               2.76%
 LFA Specialist Beef                 0.66%               0.50%
 LFA Cattle and sheep                1.85%               1.41%
 Lowground Cattle and
 Sheep                               0.75%               0.57%
 Mixed                               0.39%               0.30%
 All Farm types                      0.61%               0.46%


5.12.16      Table 7 illustrates the increase in costs as a result of the non adoption
of CCPs, as a proportion of total farm business costs the cost under these options is
much higher than under the same options where CCPs are implemented. Under
option 2 LFA sheep farmers see an average additional cost from the regulation of


                                                                          Page 22 of 31
3.61% of total farm business costs, compared with 1.75% in the case where CCPs
were to be allowed. Under option 4 without CCPs the average cost increase for LFA
sheep farmers would be equal to 2.76% of total farm business costs, but with CCPs
it would be only 0.89%.


Table 8 – Cost transferred as a percentage of net profit
                             Option 2- Full   Option 4 - Full
                             EID              Slaughter
 Cost transferred as % of    implementation derogation
 net profit                  without CCPs     without CCPs
 Specialist cereals                   0.20%               0.16%
 General Cropping                     0.16%               0.12%
 Dairy                                0.17%               0.13%
 LFA Specialist Sheep                 8.18%               6.24%
 LFA Specialist Beef                  2.11%               1.61%
 LFA Cattle and sheep                 6.55%               4.99%
 Lowground Cattle and
 Sheep                                2.18%               1.67%
 Mixed                                1.24%               0.94%
 All Farm types                       1.57%               1.20%


5.12.17       Table 8 shows these costs as a percentage of net profit, and the
figures are striking in their size comparative to those where CCPs are implemented.
The average LFA specialist sheep farm would face a cost equal to 8.18% of its net
profit under option 2 with no CCPs, and the average LFA cattle and sheep farm
would see costs equal to 6.55% of net profit also. This compared to a respective
3.96% and 3.17% of net profit under option with CCPs allowed.
5.12.18       Under option 4 the costs are still large as a proportion of the farm’s net
profits. The average LFA specialist sheep farm would face a cost equal to 6.24% of
net profit, and LFA cattle and sheep farms would see a cost on average just under
5% of net profits. This can be compared to the scenario where CCPs are
implemented, LFA sheep would see costs in that case of only 2.01% on average,
and LFA cattle and sheep only 1.61% on average.
5.12.19      It is clear that the critical control points account for the majority of the
costs under these two options, comparing them to the same EID implementation
option shows that by adopting critical control points the impact on farm business
costs is more than halved, although even with CCPs the impact is still significant.
5.12.20         The impact on the profitability of farms has been shown to be variable
depending on the option for implementation that is used. The negative effect on
profitability that this regulation entails might mean that some farms may see reduced
profitability. The following table shows the increase in the percentage of farms with
negative net profits as a result of the implementation of this policy.




                                                                            Page 23 of 31
Table 9 – Increase in farms with negative net profitability
                              Increase in the total number of
Policy implementation         farms (all farm types) with
option                        negative net profit
Option 1                                    0.00%
Option 2                                    0.90%
Option 3                                    0.68%
Option 4                                    0.68%
Option 5                                    0.90%
Option 2 without CCPs                       1.35%
Option 4 without CCPs                       0.90%


5.12.21        The above table shows that although there will be some increase in
farms operating with negative net profits as a result of the regulation, especially if
Critical control points are not adopted, any increase is likely to be small.

5.13   Goats

5.13.1 There are around 661 holdings with goats and kids in Scotland which keep
4,182 animals (Scottish Government Economic Report on Scottish Agriculture 2009).
As there are less than 160000 goats in the UK there is no need to compulsory EID
the new herd, but there is the requirement to individually record the animals in
holding registers and movement documents.

5.13.2 It is estimated that approximately 1900 kids are born each year and a similar
number of deaths to maintain a stable population. Of the kids it is estimated that
almost all male kids (98%) and 60% of females will be slaughtered in the first year
i.e. approximately 1500 kids, leaving about 400 for breeding purposes.

5.13.3 This RIA uses the same figure for identifying goats and sheep with
conventional tags as £0.15 per tag (£0.30 for two).

5.13.4 This RIA assumes that it takes a similar time to identify a goat and a sheep
and therefore uses the figure of 33 seconds to apply a single tag (109 animals per
hour) and 66 seconds to apply two conventional tags (54 animals per hour).

5.13.5 This RIA assumes that it takes a similar time to manually read and record an
individual goat and sheep and therefore uses the figure of 2 minutes per animals (30
animals per hour).

5.13.6 On the basic assumption that there are 3 animals per holding, this RIA
assumes that individual animal identities would always be recorded on movement
documents and holding registers.




                                                                          Page 24 of 31
Option 1

Identification

5.14.1 Under this option the identification costs are estimated to be will be £345
((1500 x £0.15 = £225) + (400 x £0.30 = £120) = £345.

5.14.2 Using a replacement rate of 5%, and on the basis that a non identical means
of identification would be fitted, costs are estimated to be £17 (5% of 1500 x £0.15
+ 5% of 400 x £0.30)

5.14.3 Labour rates associated with identification is estimated to be £169 (1500 /109
x £7.97) + 400 / 54 x £7.97).

5.14.3 Therefore the total cost for identifying goats under this option is estimated to
be £724

5.14.4 There are no additional costs associated with identifying animals under this
option from the current rules.

Individual Recording

5.14.4 400 animals will require to be recorded on an individual level, but it is
assumed all 1900 would be. Therefore the costs associated with individual recording
of all goats be manual means is estimated to be an additional £504 (1900 individual
animals at 30 per hour x £7.97 labour = £504).

5.14.5 Therefore the total cost of option one is estimated to be £1228.

5.14.6 The total additional costs associated with identifying animals under this option
are estimated to be £504.


Option 2

5.15.1 This option would see all goats double identified (no slaughter derogation)
and individually recorded.

Identification

5.15.2 Under this option the identification costs is estimated to be will be £570 (1900
x £0.30). This is an additional £225.

5.15.3 Using a replacement rate of 5%, and on the basis that non identical means of
identification would be used replacement costs are estimated to be £29 (5% of 1900
x £0.30). This is an additional £12.

5.15.4. Labour rates associated with identification would be £280 (1900 / 54 x
£7.97). This is an additional £111.



                                                                           Page 25 of 31
5.15.5 Therefore the total cost for identifying goats under this option is £879.


Individual Recording

5.15.6 1900 animals will be recorded on an individual level and therefore the costs
associated with individual recording of all goats by manual means would be £504
(1900 individual animals at 30 per hour x £7.97 labour = £504).

5.15.7 Therefore the total cost of option two would be £1383.

5.15.8 The total additional costs associated to this option is therefore estimated to be
£852


6      Small/Micro Firms impact Test

6.1    Almost all of the sheep and goat farms in Scotland are small businesses, as
are most of the markets and abattoirs. The Regulation is directly applicable to all of
these and the cost of complying with the Regulation is significant and various
according to the type and scale of business. The Scottish Government has worked
closely with Industry and the EU Commission in order to indentify the best solution
for implementation and to where burdens could be possibly reduced.

6.2 The cost of compliance will be greater for those businesses that trade a lot of
animals and have many movements on and off their holdings. Therefore markets,
abattoirs and finishers will be disproportionately affected. Breeders, where the
majority of animals are born on their holding will be least affected, but this is
dependant on whether or not a slaughter derogation is adopted, and what type.
Headage costs should be broadly similar for all size of units although those with less
than 100 animals may not require purchasing on farm reading equipment.


7      Legal Aid Impact Assessment

7.1   This proposal does not create new criminal sanctions or civil penalties and is
not expected to have any implications on an individual’s right to access legal aid.

8      Test run of Business Forms

8.1     No business forms will be involved with the implementation of the proposed
legislation.

9      Competition Assessment

9.1   The Regulation is directly applicable in all Member States. It aim is to
improve on existing requirements with regards to the identification and traceability of
sheep and goats. Given that this Regulation is taken into account for cross



                                                                            Page 26 of 31
compliance for payment under CAP, it is crucial that Scottish farmers are able to
comply with the chosen routes for implementation, otherwise they face disallowance.

9.2    The office of Fair Trading (OFT) Competition Filter was carried out using the
following questions:

1) Directly limit the number of suppliers?
2) Indirectly limit the range of suppliers?
3) Limit the ability of suppliers to compete?
4) Reduce the supplier’s incentive to compete vigorously?

The answer to questions 1, 2 and 4 is negative. However for question 3 the effect
the Regulation will have on supplier’s ability to compete may depend upon how the
Regulation is implemented and the size and nature of the business concerned.

9.3    Where competition could be distorted is if the full or restricted slaughter
derogations are adopted. This may encourage keepers, who are able to finish their
lambs, to move animals directly to slaughter. However the impact on this is thought
to be low as the majority of upland producers would not be able to do so and
therefore they may have no option but to electronically identify animals if markets
demand this.     Cross border competition would also be affected if Scottish
implementation is different to English and Welsh implementation.

9.4  Higher costs of production as a result of the Regulation may result in some
changes to the number of holdings. However, it should not lead to significant
changes in the structure of competition within the market.

9.5     Markets and abattoirs will be affected by the Regulation, irrespective of the
means of identification, as they will have to change their practices and or
infrastructure to incorporate individual recording. The scale of the business will
determine how they do this, but the introduction of EID is not thought to be a barrier
to competition.


10    Enforcement, Sanctions and Monitoring

10.1 The Regulation will be enforced by domestic legislation, which in Scotland will
replace The Sheep and Goats (Identification and Traceability) (Scotland)
Regulations 2006, as amended.

10.2 Local Authorities enforce the current legislation on farm, transport and in
markets.     The Meat Hygiene Service enforces in abattoirs.            The Scottish
Government carries out official on farm inspections. It is proposed that responsibility
for enforcing the new legislation will remain as is.

11    Monitoring and Review

11.1 Feedback will be provided by the Scottish Industry and by the enforcement
bodies involved.



                                                                          Page 27 of 31
12      Consultation

Within Government

12.1 Colleagues within the Scottish Government and other UK administration have
been and will continue to be involved with the implementation of this Regulation.

Public Consultation

12.2 The main industry bodies will be invited to provide their views on the various
options. Every effort will be made to ensure that the final package of measures is
practical and workable for the Scottish industry.

12.3 This RIA provides estimates on the basis of the best information available and
will now be issued for formal consultation. Should the results of the consultation
exercise indicate that changes to the RIA are required a further RIA will be submitted
to the Committees for consideration.

13      Summary and Recommendations

13.1    Summary of all additional costs (in £millions)

Note – option refers to the means of identification (i.e. option 2 is full EID). The
reference to A and B relates to the use of CCP’s, A including the use of CCP’s, B
not. For example Option 2A refers to full EID with the use of CCP’s, Option 2B
refers to full EID without the use of CCP’s


             Option   Option   Option   Option    Option    Option   Option   Option     Option
             1        2A       2B       3A        3B        4A       4B       5A         5B
             (Do      (Full    (Full    (Restri   (Restri   (Full    (Full    (Electr    (Electr
             nothin   EID)     EID)     cted      cted      slaugh   slaugh   onic       onic
             g                          slaugh    slaugh    ter)     ter)     slaugh     slaugh
                                        ter)      ter)                        ter)       ter)
Means of     £0       £3.6     £3.6     £2.2      £2.2      £0.9     £0.9     £2.8       £2.8
Id.
Holding      £0       £0.005   £0.005   £0.005    £0.005    £0.005   £0.005   £0.005     £0.005
Register
Use     of            £2                £2                  £2                £2
CCP’s
Non use                        £6.0               £6.0               £6.0                £6.0
of CCP’s

Total        £0       £5.6     £9.6     £4.2      £8.2      £2.9     £6.9     £4.8       £8.8
costs

Database     £0       £2.0     £2.0     £2.0      £2.0      No       No       £2.0       £2.0
cost                                                        data     data
                                                            base     base




                                                                                   Page 28 of 31
13.2   Benefits are as outlined in section 4.

13.3 The Regulation requires all Member States to introduce individual animal
recording and compulsory EID for populations over a certain number. Various
concessions and derogations have been achieved from the Commission over the
years which mean there are various options available to each Member State on how
to introduce the Regulation. The main options centre on the means of identification
to be used, an in particular what type of, if any, slaughter derogation should be used.
The Regulations also permit the use of 3rd parties to act as critical control point which
can significantly reduce the cost and administrative burden on much of the Industry.
Finally the Regulations also permit the use of an individually animal central database
which, if in place, can remove some of the paper based burdens at the individual
farm level.

13.4 There are various options available on the way to identify animals. Option
one, whilst considerably the cheapest option on account of not having to purchase
electronic identification and reading equipment or record individual numbers, is ruled
out due to the huge risk of infraction and disallowance. Option two provides for full
EID of the national flock and would be the most expensive option, however this
would be the simplest system to operate as all animals would be identified the same
way. Option 3 and 4 allows for the use of slaughter derogations, with the full
slaughter derogation (option 4) being the cheapest option. However the issue of
mixed batches further down this line makes this option very difficult, if not impossible
for large throughput premises (i.e. market and abattoirs) to operate. Option 3 does
however remove some of the issue of mixed batch recording by limiting the slaughter
derogation to only animals that move direct to slaughter, however this option could
somewhat limit options available to this animal later in life. Option 5 looks to address
the issue of mixed batch within a batch by introducing an electronic slaughter tag.
This means that the full intended slaughter derogation could be introduced in a way
that is acceptable for large throughput operators.


13.5 Each option will impact differently on the various Industry sectors and the
Scottish Government therefore wishes to implement the Regulations in the most
flexible manner possible to cater for individual business needs. As such the Scottish
Government does not have a preferred option for identifying animals and proposes
to cater for all the options within the domestic provision and allow Industry and
businesses to determine their best option.

13.6 With regards to the option of the use of CCP’s the Scottish Government
recommends that we make use of this provision in the Regulation and introduce
them in Scotland – option 1. Cost analysis shows that the use of CCP’s could
reduce the cost associated with individual recording from over £6 million to £2
million, representing huge cost savings to the Industry. In addition to this CCP’s will
dramatically reduce the on farm burdens of gathering and recording animals by
reading them at the CCP. Although the Scottish Government recommends the use
of CCP’s anyone who did not want to utilise a third party could carry out individual
recording requirements should they wish.



                                                                            Page 29 of 31
13.7 It would appear to be sensible that the Scottish Government and its Industry
work towards a centralised individual animal database as this would not only assist
with animal disease control, it would reduce the administrative burdens on those who
wish to operate electronic systems. The Scottish Government therefore proposes
that, in conjunction with the Scottish Electronic Research Pilot, the Scottish
Government and Industry should scope the option of introducing such a database.
Further costs and details can be looked at as part any such scoping exercise.

13.8 The Scottish Government therefore proposes to allow all the various options
for identifying animals, permits the use of CCP’s and works with Industry on scoping
a centralised individual database.


14    Regulatory Quality Declaration

I have read the RIA and I are satisfied that the costs and benefits are accurately
captured and that the recommendations are the best one in these circumstances.


Signed:




Richard Lochhead
Cabinet Secretary for Rural Affairs and the Environment
04 September 2009




                                                                        Page 30 of 31
Data used in EID regulatory impact assessment

Numbers of livestock

•        7,100,000 sheep in Scotland(1)
•        3,700,000 lambs (1)
•        3,400,00 breeding and other sheep (1)
•        2,600,000 lambs intended for slaughter (2)
•        1,500,000 lambs retained for breeding (2)
•        5% tag loss rate (3)
•        5% on farm death rate (2-3% lowland farms, 5-7% upland farms),
1
  Figures from Economic Report on Scottish Agriculture
2
  Estimates from Industry
3
  Tag manufacturer estimates
4 Figures from the Scottish Electronic Research Pilot

Prices

Livestock Labour                         £7.97 per hour 1
Single eartags                           £0.15 each 2
Double eartags                           £0.30 per pair 2
Replacement eartags (non identical)      £0.15 each 2
EID eartag                               £0.85 each 2
EID Hand held reader                     £600 each2
Market fixed panel                       £10,000 each2
Abattoir fixed panel                     £5,000 each2
1
    Scottish Government Economists on costing Land Management Contracts 2009
2
    Figures from market research

Timings

•        6 seconds per animal to read with hand held
•        3 seconds per animals to read with fixed panel
•        120 seconds per animal to manually read and record
•        5 min to upload electronic batch
•        100 seconds to identify an animals with two means of id (one EID tag, one
         conventional tag)
•        33 seconds to apply a single tag

(all timings from the Scottish Electronic Research Pilot).




                                                                          Page 31 of 31
                                                     abcdefghijklmnopqrstu
Rural Directorate
Animal Health and Welfare Division
Livestock Traceability Policy

T: 0131-244 -6404
E: Livestock.ID@scotland.gsi.gov.uk




CONSULTATION ON IMPLEMENTATION PROPOSALS FOR EU REQUIREMENTS
REGARDING ELECTRONIC IDENTIFICATION (EID) OF SHEEP AND INDIVIDUAL
RECORDING OF SHEEP AND GOATS

List of Consultees

Organisation
Aberdeen & Northern Marts
Aberdeen City Council
Aberdeenshire Council
Action of Churches Together in Scotland
Advocates for Animals
ALIDMA
Andrew Moran & Son Ltd.
Angus Council
Animal Health Office
Animal Health Trust
Argyll and Bute Council
Association of Show and Agricultural Organisations
Blackface Sheep Breeders Association
Blairdrummond Safari Park
Bluefaced Leicester Sheep Breeders Association
Border Leicester Sheep Breeders Association
Border Livestock Exchange Ltd
Border Union Agricultural Society
British Goat Society
British Institute of Agricultural Consultants
British Society of Animal Science
British Veterinary Association (Scotland)
Caithness Livestock Breeders
Caledonian Marts (Stirling) Ltd
CBI Scotland
Cheviot Sheep Society
Church of Scotland Offices
City of Edinburgh Council
Clackmannanshire Council
Comhairle nan Eilean Siar
Compassion in World Farming
COSLA
Craig Wilson Ltd.


                                        1
Crofters Commission
Cumberland & Dumfriesshire Farmers
Dingwall & Highland Marts Ltd
Dumfries and Galloway Council
Dundee City Council
East Ayrshire Council
East Dunbartonshire Council
East Lothian Council
East of Scotland Farmers Ltd
East Renfrewshire Council
Evangelical Alliance
Falkirk Council
Farm Animal Welfare Council
Farming & Wildlife Advisory Group
Federation of Small Businesses
Federation of Wholesale Distributors
Fife Council
Food Standards Agency
Forestry Commission Scotland
Glasgow City Council
Harbro Ltd
Harrison & Hetherington Limited
Health and Safety Executive
Highland Council
Highlands & Islands Enterprise
Institute of Auctioneers & Appraisers in Scotland
Inverclyde Council
John Milne
John Swan Ltd.
L S Smellie & Sons Ltd.
Lawrie & Symington Ltd.
Livestock Marketing (Borders) Ltd.
Macaulay Land Use Research Institute
Meat Hygiene Service
Midlothian Council
Minister for Environment
Moray Council
National Fallen Stock Company
National Farmers Union Scotland
National Federation of City Farms
National Livestock Traders & Producers Association
National Sheep Association (Scotland)
North Ayrshire Council
North Country Cheviot Sheep Society
North Lanarkshire Council
Orkney Auction Mart Ltd.
Orkney Islands Council
Perth and Kinross Council
Quality Meat Scotland
Rare Breeds Survival Trust


                                        2
Renfrewshire Council
Reston Auction Mart Co. Ltd.
Road Haulage Association
Rowatt Research Institute
Royal (Dick) School of Veterinary Studies
Royal College of Veterinary Surgeons
Royal Environmental Health Institute of Scotland
Royal Highland & Agricultural Society of Scotland
Royal Northern Agricultural Society
Royal Zoological Society of Scotland
Rural Affairs and Environment Committee
Scotbeef
Scottish Agricultural College
Scottish Agricultural Organisation Society Ltd
Scottish Association of Meat Wholesalers
Scottish Association of Young Farmers' Clubs
Scottish Borders Council
Scottish Centre for Inspection & Env Health
Scottish Churches Parliamentary Office
Scottish Conservative Central Office
Scottish Consumer Council
Scottish Crofting Federation
Scottish Enterprise
Scottish Federation of Meat Traders Association
Scottish Green Party
Scottish Inter Faith Council
Scottish Labour Party
Scottish Liberal Democrats
Scottish National Party
Scottish Parliament
Scottish Rural Property & Business Association Limited
Scottish Wildlife Trust
Sheep Veterinary Society
Shetland Flock Book Trust
Shetland Island Council
Shetland Livestock Marketing Group
Small Farms Association
South Ayrshire Council
South Lanarkshire Council
SSPCA
Stirling Council
Sutherland Agricultural Society
Tenant Farmers Association of Scotland
The Independent Farming Group
The Scottish Chamber of Commerce
The Scottish Food Trade Association (GCFT)
The Women's National Commission
Thomson Roddick & Medcalf Ltd.
UK Agricultural Supply Trade Association
United Auctions Ltd.


                                        3
Wallets Marts Castle Douglas Ltd.
West Dunbartonshire Council
West Lothian Council
Women’s Food and Farming Union




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