We need a trade policy that aligns food imports with environmental goals

This post is by Nandi Mkhize, programme officer and researcher in international trade and Brexit at ClientEarth and Anna Sands, trade policy specialist at WWF.

The UK is developing its new trade policy, amid fierce debate within the country and with trading partners about how it will enshrine environmental standards into law.

Simply maintaining the country’s existing environmental policies won’t be enough. The UK needs to design a trade policy that is aligned with its forward looking environmental objectives, set out within the Environment Bill, the 25 year environment plan and the Agriculture Act. New trade rules must also square with the country’s commitment to net zero greenhouse gas emissions by 2050.

As challenges to this overhaul abound, food standards have been a central issue, featuring prominently in trade talks with the US and EU. Some argue that the UK’s new trade rules will flood the market with low quality imports, while opponents are concerned that strict rules will be unhelpfully protectionist.

To find a constructive way forward, a briefing written by David Baldock and published by the Institute for European Environmental Policy for ClientEarth and WWF, outlines how a new trade policy framework can help align food import standards with UK environmental objectives.

The briefing goes through the main issues in the debate, the distinctions between standards for domestic food production and those that apply to imports, as well as how these distinctions offer some possible solutions.

The issue: aligning food import standards with environmental goals
In this debate, there are two extremes. On one end, there is a risk that mass liberalisation will result in the UK market becoming flooded with food produced to lower standards, pressuring UK producers to lower theirs to compete. This could lead to devastating environmental impacts on soil health, wildlife habitats, emissions and levels of air pollution.

At the other end, by requiring imports to meet all our domestic environmental standards, we could be viewed as protectionist, or even misinterpreted as wanting to block trade with developing countries.

What is needed is a framework that:

• protects all existing British environmental standards;
• filters the food we import based on its environmental footprint, and;
• facilitates trade in line with our environmental objectives.

This is not about picking which of our existing standards to maintain, they must all be maintained. Rather, we need to work out which rules for domestic food production ought to apply to imported food.

Domestic standards vs import standards
There are important distinctions between domestic standards and import standards in the UK. There are also differences between product standards, which apply to the final product, and production standards, which apply to the method of production.  

The table below explains the difference between these standards, giving examples already applicable in the UK.

	Product standards	Production standards
Domestic standards	Apply to products for sale and produced in the UK (eg maximum pesticide residue levels in food)	Apply to domestic means of production (eg maximum levels of fertiliser use)
Import standards	Apply to imported products for sale in the UK (eg permissible inorganic fertilisers and pesticides)	Apply to means of production of imported goods (eg organically produced food)

Domestic production standards refer to how a particular product or good is produced in the UK.  For example, this might relate to the management of soil, water and wildlife on UK farms.

Domestic product standards, on the other hand, apply to the actual finished product, not the process of making or growing it. An example of this is illegal dye in spices. These standards usually apply to both domestically produced and imported goods.

The UK has clear rules for domestic production standards and domestic product standards. But it has very few production standards for imports. This matters because putting in place restrictions on the production method of imported goods is likely to be an important weapon in tackling global environmental problems.

However, a blanket requirement for every food import to adhere to all UK domestic production standards is not the solution. It would be unhelpful to have the same regulations over water extraction and irrigation in countries with different water resources, for example. 

Given the different farming and environmental conditions, forms of production and approaches to achieving environmental policy goals across the world, there needs to be a flexible approach.

A sensible and modern approach to import standards
David Baldock proposes three criteria to help determine which domestic production standards are most important for import rules.

The first is environmental significance: if a standard applicable to agriculture is important to deliver a key environmental outcome, eg clean water, then it would fall into this category. This is to ensure that overall provisions in trade agreements do not undermine environmental objectives in the UK.

The second criterion is the level of influence on agricultural practice. Measures that have a substantive bearing agricultural production and producers are likely to be critical here.

The third criterion is the impact on production costs. This aims to capture the link between an environmental standard and specific traded commodities, and address the potential impact on competitiveness.

Applying these, the rules that emerge as most important for trade policy relate to pesticides, fertilisers, ammonia, wildlife, permitting potential harmful activities and environmental impact assessment. 

This approach should not be used as a form of protectionism, nor as a way to undermine developing countries’ ability to sell to the UK. Instead, it should be seen as a way to allow for engagement and sensible flexibility, so that trade can continue without compromising the environment being protected.

If the UK continues to develop its own environmental domestic production standards, to adhere to policy goals without developing aligned import standards, this will leave a large imbalance and create conflict between trading and environmental objectives.

But, if the UK integrates this flexible approach into its trade policy, it will pave the way for food imports that meet the country’s environmental objectives.