January 22 2006 ~ What legislation demands returning the inventory to DEFRA?
Intensely irritated by a letter from Defra (confusingly, it apparently emanated from the Scottish Executive) which told a reader of warmwell that
“New legislation requires you to return an inventory (total number) of all sheep and goats that you keep on any holding(s) at 1st January each year...“You must complete the enclosed form and send it back to us in the envelope provided by February 1st 2006.... we also need you to tell us your occupation (farmer, doctor etc.) and the type of production (e.g. meat, wool or milk) at each holding.”the farmer wrote:
"After experience of the massive incompetence of Defra in dealing with anything relating to animal keeping (BSE, FMD, TB, scrapie etc.), I am extremely reluctant to give them any information whatsoever about the animals on my farm nor my occupation. So I rang the information line number and asked to be told what was the “new legislation”... The chap who dealt with my enquiry couldn’t tell me but volunteered to ring me back after making enquiries. He rang me back and still couldn’t tell me. "The farmer's conclusion?
"The bottom line of all these is that if one keeps sheep and receives the single farm payment, one must keep a register or inventory of one’s sheep. The same was true for sheep quota. One had to keep a flock register on the farm, along with the movement record and cattle herdbook. It was occasionally inspected by Defra inspectors.
I can’t see anything that says that the record (inventory) now has to be sent or reported to Defra – and no new legislation that says so. I can’t see anything that requires the reporting of one’s occupation either…" (ends)
The sheep and goats register has caused groans on various internet forums example: http://www.torfaen-fighttheplan.org.uk/about17613-annual-sheep-goat-census.html and we noted in particular this comment where the writer (from the other end of the country from the first) is self-evidently a farmer who is another intelligent, responsible and benign person from whose ears smoke is starting to rise:
A search of the DEFRA website - taking both time and skill to perform - leaves one less than enlightened. Its labyrinthine website eventually reveals the following information - if one has a spare couple of hours to search. But is it relevant? And anyway, mentioning a couple of dense and unreadable EU outpourings hardly illuminates or justifies DEFRA demands.
Have you looked at your Sheep& Goat census form yet?
It is so simple I had to telephone the helpline.
Its very simplicity is its downfall; it is not capable of giving an accurate breakdown of the national sheep & goat flocks.
The sensible body I spoke to in York told me I was not the first to query the form, nor would I be the last.
Column 1: holding number. That's not too difficult is it? Mind you it continues over the page just in case anyone has multiple holding numbers.
Column 2: Total number of sheep/goats. Once again, pretty straightforward stuff.
Column 3 onwards: Tick ONLY ONE box. Problem!
Does one keep sheep/goats for (a) Meat; (b) Milk; (c) Wool; (d) Breeding stock; (e) Pets; (f) Other, please specify.
Remember, one may only tick ONE box.
Questions: As all my sheep will eventually end up as meat do I list my total as Meat?
OR, as the vast majority will be sheared more than once do I tick them all as Wool?
OR, as the majority, once again, are ewes put to the ram in 2005 and ewe lambs born in 2005 to be put to the rams in Nov. 2006 plus the attend and (and attentive) Rams do I tick the Breeding Stock column?
Answers: The form was apparently designed by someone in London who has never had anything to do with sheep/goats. (Answer to question I didn't actually ask, merely implied.)
If answered as directed the census will be distorted and Defra will be even more ignorant than before.
Solution: Yes there is one.
In column 1 write the holding number and in column 2 put the number of sheep/goats in ONE category and tick the relevant box under Col. 3. Then, in column 1 write the holding number AGAIN and in Col. 2 the total number of sheep/goats in the next category and tick the next relevant box under Col. 3; and so on.
.so long as the total of animals in column 2 equals the number that one can justify from one's other records.
That should be clear.
On the other hand, the sheep market being what it is, why not list the whole damned lot as pets? They may as well be. We aren't making a whole lot out of them. (In fairness, she didn't recommend the latter course. Her superiors wouldn't be able to see the joke!)" (ends)
Page 44 42 Cross Compliance Handbook for England 2006 edition 176. Key elements As of 9 July 2005, the rules that apply for cross compliance purposes to sheep and goats were changed. They are broadly the same and are summarised below: a. Identification: All sheep and goats born before 9 July 2005 must be properly identified in accordance with EC Directive 92/102
From the DEFRA book http://www.defra.gov.uk/animalh/tracing/sheep/sheepgoatsrules-idbook.pdf
From 5 December 2005, when you order your ear tags we will allocate (give you)
ear tag numbers automatically, using our database.
• As the keeper, at the beginning of each year, you must make an inventory of all
sheep and goats on your holding.
• We are introducing a slightly revised flock or herd register for all keepers.
• Sheep and goats born after 9 July 2005 must be double-tagged for trade with
other countries in the European Union or for export to countries outside the
It also says,
" On 9 July 2005, a new European law came into force which has introduced a new
system of identifying sheep and goats. We already have temporary permission (until
May 2006) not to follow the requirement to double-tag animals. By following the
requirements set out in this document, you can help to make sure that we do not have
to double-tag animals until 2008.
"New sheep and goat identification rules now in force", said DEFRA http://www.defra.gov.uk/animalh/tracing/sheep/
New rules to ensure we avoid 'double tagging'.
The European Union's Standing Committee on the Food Chain and Animal Health, have agreed the UK’s application for a derogation to continue with the national system of sheep identification (i.e. no double tagging) We have received a temporary derogation until April 2006.
A follow up inspection is planned in December so Commission inspectors can confirm that we have put in place certain enhancements to the current system. It is important that keepers comply in full with the national requirements as failure to do so could lead to our derogation being withdrawn. We will be sending out full guidance detailing the requirements in the autumn.
The positive outcome means that keepers will be able to continue with the current system of movement (S) and replacement (R) tags instead of having to apply double tags. Double tags will only be needed in the case of animals born after 9 July, which are intended for intra-community trade or export. There will be a few changes to the current system to reflect the new EU requirements that do not form part of the derogation. The following will be taking effect immediately:
So, after exhaustive searching, the legislation behind all this ID of sheep and goats would appear to be European Council Regulation (EC) 21/2004 and EC Directive 92/102
See http://www.defra.gov.uk/animalh/tracing/sheep/5mil-rule-letter.pdf ".....As a result of new EU rules (Council Regulation (EC) 21/2004), we are changing the way we record sheep and goat holdings, and the rules on reporting movement. The National Sheep Association, the National Farmers’
Unionand the Meat and Livestock Commission participated in the design of the new rules. You must start complying with the requirements laid down in this letter with immediate effect. You may consider your holding to be all the land where you keep sheep and/or goats. However, this is no longer the case. You will not need to report movements if the land you are moving animals between is under your sole management and control and is within 5 miles (8km) of your main site. Please see Annex A for full details of the new requirements. Defining your main site Your main site is where the main buildings and livestock facilities are, together with all adjoining fields. If your fields are separated from your farm by a road, stream or boundary (ie a hedge or fence), then these fields are considered part of your main site. Effectively, your holding will become your main site, plus any outlying parcels of land wholly or partially within 5 miles. Please see Diagram 1, attached. Any land outside the 5 mile zone is still yours, but is a separate holding..."
But when even DEFRA's helpline officials are unable to interpret letters sent out, it is evident that efficient explanations are not on offer. None of this inspires confidence. None of this encourages anyone to want to cooperate. It might inspire confidence if information sent to stockholders expressed in clear English why certain regulations were deemed important for everyone. Above all, if the advice given to government and thus passed on to farmers was self-evidently based on a sound understanding of farming and animal husbandry.