A low throughput abattoir (under 1,000 LSUs) does not have full time OV presence and so the majority of the OV hours will be covered by a 90% discount. Once the throughput has exceeded 1,000 LSUs the abattoir is required to have full time OV presence [2] and so their costs increase considerably, though the hours may still be eligible for discount in either the 75% or 26% discount range, depending on how many OV hours they use in total. These discounts represent a considerable amount of money.
Below are some examples:
A medium sized abattoir processing 90 cows, 500 pigs and 500 sheep per week reported to us they currently pay £7,246 per month, this would increase to £12,167 per month if the full cost was applied.
A small abattoir processing 1k LSUs per annum reported they currently pay £446 per month and removing the discount would mean an increase to £2,268 per month (408% increase).
Examples of the impact of removing the discounts for a further three typical medium-sized abattoirs (provided by AIMS):
- £5,159.17 would rise to £10,163.10 (97% inc.) per month
- £3,127.50 would rise to £7,417.60 (137% inc.) per month
- £2,143.41 would rise to £5,766.00 (169% inc.) per month
If the full costs increase further next year, as FSA have indicated, it is expected that the percentage increase would be closer to 200-300% for medium abattoirs if the discount was removed.
Example of the impact of removing the discount on FSA charges for a small to medium mixed species abattoir (December 2023 – August 2024):
With discount: £51,059.96
Without discount: £94,085.21
Of the discount the abattoir says:
“The discount the FSA offers allows us to remain competitive with our pricing, removing this would inevitably mean we would need to pass part of the cost onto farmers to able to withstand it, which in turn would be another devastating blow for British Farmers”
A very low throughput abattoir reported paying only £60 per month. This would rise to £600 or more without the discount. They felt such a rise would lead them to close their abattoir, stating it feels like the final nail in the coffin when considered alongside other rising costs such as energy and animal by-product collection.
Additional points to make:
- The complexity of the current charging system is such that it is difficult for abattoir operators to work out whether they have been charged correctly, and it is not uncommon for invoices to be incorrect.
- Being based on a time recording system means there is little incentive for the FSA or their contractor to deliver services more efficiently.
- Key stakeholders have maintained that the current charging system does not comply with the official Control Regulations because non-chargeable items are included in the charges; the correct consultation and approvals did not take place, and the impact on non-discrimination and equal treatment was not adequately addressed.
- We recommend a wider review of the charging system, rather than a narrow focus on the discount, and suggest the FSA instead consults on moving away from the time-based charging system and instead adopting a throughput-based (headage) approach. Such an approach would align with other European countries which use a headage system and do not charge for other official controls.
- Alongside this review, we believe a review of the current inspection system is also needed. There have been long-standing concerns about delivery of veterinary controls, as well as the recruitment and retention of vets. The majority of small abattoirs which have closed in recent years have cited issues with the vet as a reason for closing. With shortages in vets, combined with a need to cut costs, it would be beneficial to review the role of the OV and consider how remote inspection (whereby vets perform the ante-mortem inspection via video) could be applied which would then enable post-mortem inspection to be carried out by Meat Hygiene Inspectors with significant cost savings.
- There is a lack of joined up thinking, given that £4m has just recently been invested in supporting the Smaller Abattoir Sector, this financial help will be undone by an increase in FSA charges.
Consultation questions and suggested points to include:
Q1. Name
Q2. Email address
Q3. If you are responding on behalf of an organisation or company, please give brief details about it.
Q4. Where is the business or organisation you are responding on behalf of based?
Q5. Please tell us about the benefits of offering a discount on charges for official controls and other official activities for:
a) Consumers
b) FBOs in the meat sector who are charged for OC and OOA
c) Retailers, primary producers (e.g. livestock farmers) and other FBOs in the supply chain
d) OVs, MHIs and other officials involved in the delivery of OC and their enforcement
e) Wider society, the food system and others who may benefit
The discount levels the playing field and allows small abattoirs to survive under the current charging system which is based on OV attendance rather than throughput. When Ministers gave FSA permission to use a time-based charging system, they stipulated that abattoirs should not pay more than the headage rates in the official control regulations.
The SFT-NCB survey of over 1,300 small abattoir users in 2022 found that small abattoirs were either important or essential to 88% of respondents’ businesses. Through enabling smaller abattoirs to keep operating, the discount directly contributes to the considerable benefits that small abattoirs provide. Below are some of the benefits listed by respondents to the survey:
- Supplying local, traceable meat to consumers.
- Supporting farmers and food businesses that rely on small abattoirs
- Boosting wider rural economy and providing jobs
- Reducing the distance animals travel to slaughter
- Reducing food miles
- Supporting the existence of rare and native breeds by providing a route to market and services tailored to their needs
- Supporting conservation grazing through routes to market for smaller herds and rare/native breeds
- Boosting food security and resilience through offering a diverse supply chain, alternative route to market and local meat
- Providing high quality and nutrient-dense meat
- Providing trust, confidence and a personal service for customers
- Offering better marketability and added value of meat
Depending on whether you are responding as a farmer, consumer or organisation, you can expand on and add to the above points and how they impact you.
Q6. Please tell us about any negative impacts of offering a discount on charges for official controls and other official activities on:
a) Consumers
b) FBOs in the meat sector who are charged for OC and OOA
c) Retailers, primary producers (e.g. livestock farmers) and other FBOs in the supply chain
d) OVs, MHIs and other officials involved in the delivery of OC and their enforcement
e) Wider society, the food system and others who may be subject to negative impacts
There are few negatives of offering a discount, however improvements could be made through a wider review of the charging system and role of the OV (see ‘Additional points’ section above).
Q7. Please tell us about the administrative burden of managing discounts on food business operators and official Veterinarians and Meat Hygiene Inspectors as well as any suggestions for simplifying administration.
The discount itself does not create a burden but the charging system is complex and FBOs report that invoices are frequently incorrect and it is difficult to work out the correct amount.
A move towards a throughput/headage-based approach would make charging more transparent and bring the UK into alignment with other European countries.
Q8. Please tell us about the impact of being unable to provide the discount and what could happen as a result for:
a) Consumers
b) FBOs in the meat sector who are charged for OC and OOA
c) Retailers, primary producers (e.g. livestock farmers) and other FBOs in the supply chain
d) Micro, small and medium sized enterprises and smaller premises that benefit the most from discounts and on the consumers they supply
e) OV’s, MHIs and other officials involved in the delivery of OC and their enforcement
f) Wider society, the food system and others who may be subject to negative impacts
Without the discount, many small abattoirs could cease operating which would be hugely detrimental to:
- The supply of local meat for consumers
- Farmers and food businesses that depend on small abattoir services
- The local rural economy that benefits from a supply of local meat
- Animal welfare as animals will be taken on longer journeys to slaughter
- The environment as food miles increase and conservation grazing becomes unviable
- Food security as food supply becomes more centralised and dependent on imports (particularly from countries where inspection costs are lower).
If they continue operating, abattoirs are likely to pass the cost on to their customers which will ultimately impact farmers, food businesses and the consumer.
Depending on whether you are responding as a farmer, consumer or organisation, you can expand on the above points and how they impact you.
Q9. Please tell us how the discount or other measures could help manage or reduce the impact of the increase in charges for official controls and other official activities in 2025/6 on those who will be affected.
The increase in charges for 2025/6 will already put an additional strain on small abattoirs. Maintaining and increasing the discount in line with the increase in charges is critical to mitigating the impact.
A review of the current inspection system is also needed. There have been long standing concerns about delivery of veterinary controls, as well as the recruitment and retention of vets. The majority of small abattoir closures in recent years have cited issues with the vet as a reason for closing. With shortages in vets, combined with a need to cut costs, it would be beneficial to review the role of the OV and consider how remote inspection technology might aid the OV in carrying out their role more efficiently, while opening up the possibility of some tasks, such as post-mortem inspection, being carried out by an MHI.
Q10. Please tell us about comparisons with discounting and charging for public sector services in other regulated sectors in the UK or in other countries. (Evidence given in this section need not be about the meat or food sectors.)
The discount system is unique to the UK while charge systems in other countries are unit based. FSA dairy hygiene inspections are charged a flat rate. Other sectors of the food industry, including high risk establishments and the wine industry for which FSA is responsible, are not charged for official controls, OOAs or enforcement.
For more information please contact:
Megan Perry, Head of Policy and Campaigns at the Sustainable Food Trust: megan@sustainablefoodtrust.org
NOTES:
1. For more info see the following reports: https://apgaw.org/wp-content/uploads/2020/06/The-Future-for-Small-Abattoirs-in-the-UK.pdf ; https://sustainablefoodtrust.org/wp-content/uploads/2022/03/Re-localising-farm-animal-slaughter-low-res.pdf
2. The impact of increased OV presence when abattoirs process more than the 1,000 LSU limit is why we have been lobbying for adoption of the 5% flexibility which allows smaller abattoirs to process up to 5% of the total national throughput without triggering full inspection. We are grateful this is being pursued by Government and wish to reiterate its importance.
