Internet consultation on new regulations

From slow start to new standard

New rules, the business world is not waiting for them. Yet they keep coming, especially in the Netherlands. Civil society organisations and the government often work together to move consumers and businesses in the right direction. In itself, there is nothing wrong with this. But there is sometimes a problem with the implementation of new regulations. For example, insufficient account is taken of certain parties, administrative burdens, conflicting situations or obstacles to innovation. But internet consultation by the meat sector hardly ever takes place. A missed opportunity!

Due to the corona crisis, many supermarkets and butchers are turning double sales. The meat industry remains busy with deliveries. In the meantime, home owners are making massive use of the Internet. Online food ordering got off to a slow start in recent years, but in a short time it has become the new norm.  

Internet and new regulations

Traditionally, we are used to branch organisations mediating for better rules. But when the product boards were abolished, this task was transferred to the employers' organisations. However, the budgets they have for this cannot be compared to those of the product boards. And you notice that. This is one of the reasons why there is currently internet consultation for new regulations. Already since 2009, but unfortunately it is still hardly used. In 2016, a study was carried out into who generally responds to an internet consultation. In general, these are highly educated older men (55+) and interest groups or action groups. Per regulation there are usually about 2 to 4 responses. Responses are public on www.internetconsultatie.nl.

In the meat sector, oddly enough, companies never react, while they are better placed than trade associations to judge whether a new regulation is feasible or not. Who will take the lead?

Internet consultation difficult?

Not at all! You go to www.internetconsultatie.nl and you will immediately get an overview of all the new rules. You can also search with "meat" or "animal". This will give you an overview of all relevant open and closed consultations. Any reactions can also be viewed. These range from very detailed to (usually) short and to the point. For each new rule, you can download a short overview of how the rule is described, together with the motivation. Simple and clear.

Open consultations on new regulations in the meat sector

There are currently two consultations in progress for the meat sector. One from the Ministry of Agriculture, Nature and Food Quality (LNV) is about a ban on the trade in and slaughter of high-pregnancy pigs and cattle, and one from the Ministry of Health, Welfare and Sport (VWS) is about a new approach to product improvement.

The ban on the trade in high-pregnancy pigs and cattle is in itself a good decision, because nobody wants to slaughter pregnant animals. But if we look at the implementation, it is said that this only concerns cattle farmers. But that is actually not true, because the slaughterhouse has to check this by means of a declaration that the animal is not in the last third of its pregnancy. This is often not visible on the outside. And if, for example, there is no declaration and it turns out during slaughter that there is an almost full-term foetus present. Who is responsible then? And how do you measure whether the foetus has been carried more than 77 days (pig) or 185 days (beef)? Because that is prohibited. For the sake of convenience, it is assumed that the farmer must always know. But if, for example, the animals are walking outside in groups, you cannot always check this. In addition, this rule conflicts with the transport regulation. In it there is a ban on transporting animals with more than 90% gestation. So they are allowed to transport animals in their last third of gestation up to 90% to the slaughterhouse, but the slaughterhouse may not receive them. Shouldn't the transporter then also check a declaration from the farmer? The aim of the legislation is good, but its implementation is ramshackle and difficult to enforce (NVWA). This consultation runs from 5 March to 16 April 2020. No one has responded yet (at the time of writing).

At the end of 2020, the former Agreement on the Improvement of Product Composition (AIP), which was signed by many parties, expires, but strangely not by the meat sector. A new approach will follow at the end of 2020. The new agreement contains new low standards for the salt and saturated fat content of, among others, meat preparations and meat products. These levels must be lowered step by step. The RIVM has calculated three levels from national databases: rearguard, middle and leaders. For example, the sodium content of meat preparations is classified as 760 - 530 - 360 mg/100g and for processed meat products as 920 - 823 - 720 mg/100g, respectively. The saturated fat of meat preparations is 8 - 5 - 3 g/100g and of processed meat products 10 - 9 - 7 g/100g.

To motivate companies, the government wants to use incentives such as "naming" (frontrunners) and the food choice logo Nutri-Score. Two consumers have responded so far: "We have the Commodities Act in our country. This should be regulated in it." And "Good idea. You can't miss a shot." Industry has not yet responded. The internet consultation runs from 24 March to 5 May 2020.

Internet consultation of new regulations, like online food ordering, is slow to get off the ground. But, sooner or later, it will become the new norm. #Let your voice be heard!

Yvon Bemelman