Cross compliance: at crossed purposes?

The objectives of the present incarnation of the CAP are the subject of intense debate in policy circles. Cross compliance is seen by some as a way to justify the Single Payment Scheme, by aligning the receipt of largely untargeted subsidy payments to the delivery of public goods. To some extent this is true. Farmers need to meet a set of fairly basic standards centred on pre-existing EU environment, food safety and animal welfare legislation (called Statutory Management Requirements (SMRs) in CAP jargon). They must also respect a set of baseline soil and habitat maintenance standards (collectively referred to as standards for Good Agricultural and Environmental Condition (GAEC)). In the event of non-compliance, recipients of the Single Payment risk a deduction to the following year’s subsidy payment.

The Commission’s recent Communication on the Health Check, however, calls into question the effectiveness of cross compliance in promoting sustainable agriculture. Indeed, some difficulties have been experienced by Member States in defining standards that are meaningful to farmers, and can be checked during a control visit. The scope and ambition of the standards, as implemented, also varies across the Member States. The recent evaluation of cross compliance for DG Agriculture provides evidence of Member States’ initial experiences with cross compliance.

The Commission is considering removing a number of the requirements from some of the SMRs. Whilst this may aid the cause of simplification – one of the mottos surrounding the Health Check – it may be of questionable benefit to the core aim of promoting sustainable agriculture, unless new or more meaningful standards are identified and introduced.

The core ability to promote, and perhaps no less achieve, sustainable agriculture lies in amending the GAEC framework, a possibility also touted in the Commission’s Communication. For example, GAEC may be a suitable home for a post-set aside environmental management option. Standards for climate change and water management may also be introduced. However, the standards, as defined by the Member State, need to be understood by farmers, be enforceable and be flexible enough to account for regional differences in order to be effective. In addition, the standards implemented by Member States should be held up to greater scrutiny in order to ensure cross compliance delivers more for the environment in the future.

The Health Check is an opportune moment to consider the future role of cross compliance if the budgetary relationship between the first and second Pillars shifts in favour of rural development in the future. A key advantage of cross compliance is the leverage it has over the vast majority of EU farmland and farmers. A smaller Pillar I budget could lead to the loss of this leverage over the most competitive farms, and undermine calls to strengthen the delivery of environmental performance through cross compliance. Questions about the ideal relationship between cross compliance, under Pillar I, and agri-environment payments, provided by Pillar II and for which farmers receive a payment for delivering above and beyond cross compliance SMRs and GAEC standards, also need to be answered.

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