Urban Food Chains

the links between diet and power

royal-commission UK
MAF ducks change from the word go
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The Departmental Committee on the Distribution and Prices of Agricultural Produce, generally referred to as the Linlithgow Committee, was proactive in its assessments and investigations of agricultural prices. Its remit covered the empire. The committee took its name from Victor Hope, 2nd Marquess of Linlithgow. He went on to chair a Royal Commission on food in India in 1928. Linlithgow, as the media called him, became the last viceroy of India: his 7-year tenure of office ended in 1943, amid scenes of chaos and civil unrest.

On December 11 1924, the second day of the 1925 Royal Commission, a senior MAF (Ministry of Agriculture and Fisheries) civil servant gave the government response to a raft of administrative measures recommended by the Linlithgow committee. Like a rabbit caught in car headlights, the MAF defence was more a limp lettuce than a fig leaf.

First up was a recommendation to standardise financial reporting for large companies such as United Dairies. MAF headed off further discussion, explaining that the government had “considered” introducing a bill, before playing its trump card: “The matter is now in the hands of the Board of Trade.” Next up, a suggestion that co-operative dairy schools should be revived is fended off with the assertion that a circular on the subject has been issued to all local authorities and “…steps are taken as opportunity offers.” Try getting that back out of the long grass.

The proposition that standing milk advisory committees should be set up to consider and discuss dairy industry issues as the need arose got short shrift. One of these bodies would cover Scotland, another would speak for the dairy industry in England and Wales: the topic prised about a dozen words from MAF: “Separate committees have been set up for England and Wales and for Scotland.” To finish the dairy section of the Linlithgow agenda, the committee urged the government to set and enforce minimum fat contents for whole milk cheese, cream and milk powder, which should apply both to imports and UK production. Sensing an imminent change of subject, the civil servant was more forthcoming. The health minister had made regulations that had come into force during May 1924. Meanwhile, the ministry of agriculture was: “…conducting investigations with a view to determining what standards, if any, may be adopted in respect of whole milk, cheese, and single and double cream.” Nothing gets past a pen pusher.

The Linlithgow committee and its extensive social network existed to promote the interests of landowner members. Its purpose was to develop a consensus around what constituted good practice, modern management and new routes to market. A fair proportion of these families would have benefitted from the compensation lavished on former slave owners: it never occurred to anyone that former slaves had a stronger case for reparations.

The Linlithgow committee (Lc) makes further recommendations, some of which I will list here, with MAF responses where relevant, including paras 258; 260; 302 and 303.

Para 258

Lc urges colleges and local authorities to train students in dairy production, as well as the prevention of spoilage. MAF agrees that this is worthy plan, even if some sites have needed assistance to reinstate standards.

para 260

Lc warns that whey is an ongoing problem, with little prospect of being profitable. MAF reports that a pilot plant has been transferred to Reading university, where development work is in hand.

The topic turns to commercial sharp practice: paras 209, 302 and 303. Since MAF replies to all these items in a single paragraph, I will add MAF’s response at the end of this post.

Lc is concerned that the practice of “averaging returns” is illegal and “not infrequent”. Growers should be checking all the entries on their invoices, the committee warned. Growers were not impressed. Another scam on similar lines started to rear its ugly head. By logging into the sales system under multiple identities, traders could cover their tracks and extract money from linked systems without being caught out.

Faced with significant numbers of food traders routinely breaking laws that may or may not have been enforceable in the first place, MAF resolutely turned its back and looked the other way:

“Efforts are being made to secure voluntary agreement between both sides of the industry on the points raised in their recommendations. If these efforts do not meet with success, it will be necessary to consider the introduction of legislation to deal with the points at issue.”

It would be reasonable to assume that it is the task of government to enforce existing laws and to review legislation that fails to meet the changing needs of the country. Accepting the status quo and asking both sides to play nicely in future resolves nothing. The problems will not go away without appropriate action; on the contrary, they will degenerate into crises.

For discussion of this theme in a more recent context, go to the contents page for France Loses Out and follow the links to individual topics.

More follows later

Turnor UK UK economy
Crusty home truths
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In 1916, the UK was  growing a scant 20% of its total wheat needs. Bearing in mind that most people eat bread, it made the imported 80% of the ingredients for the nation’s bakery goods vulnerable to attacks from early German submarines. The rapid deployment of U-boats left the British vision of the Blue Water policy in tatters, as policymakers relinquished their once unshakeable belief in the Royal Navy’s invincibility. The country’s agriculture was trailing behind the Netherlands and Denmark, leaving unmet demand for cereals to be patched with shiploads of imports.  There was no lack of demand among the hungry cities – British consumers were spending some four hundred million pounds a year on food, a figure bandied about by Christopher Turnor, no less. 

The country’s disproportionately extensive grassland was not supporting beef production on a comparable scale to continental Europe. Could it be true, as some hardliners argued, that the fabric of British agriculture had been weakened by years of indifference of, among others, policymakers, but also by a shadowy network of traders, fixers and miscellaneous n’er-do-wells? While British livestock accounted for some 60% of meat consumed by the nation, no less than 80% of the UK’s foreign meat imports shipped from a single port in Argentina, by a single firm based in Chicago, oddly enough.

crunchy numbers retail royal-commission UK economy
Like rabbits out of a hat
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Unlike any other science, economics is prone to give away the plot before the curtain rises. Behind the scenes, everyone is committed to turn out a happy ending, almost regardless. There is ambivalence towards change, even though the job description is built around identifying and predicting the future without fear or favour.

In the summer of 1914, the Ministry of Labour started collecting the food data for the Cost Of Living Index Number. Straight out of the gate, there is no way in which vegetables other than potatoes can be included in a year-round constant economic indicator. Potatoes can be stored all round the year and can be shipped from growers all over the world, whatever the season. We have already listed the foodstuffs that were monitored and index-weighted against other products or  sectors. Having seen what the Ministry of Labour brought to the table, it is time to look at how the price points for these goods were settled. The researchers searched out prices displayed by over 5,000 retailers, even though there was a lot of repetition in the mix. In some areas,  shopkeepers voluntarily maintained the same prices for known value items (KVI), a practice that would be unthinkable in the twenty-first century.


In the initial layout stages, some prices would be queried: if the point is to gather live data, it should be taken as found, warts and all. Modern food manufacturers refer to a group of products that are “liquid with identifible lumps” and I would apply the “identifiable lumps” analogy to raw price data. The lumps are the very point of the work in hand, giving both insight and substance. The process moves up a gear, averaging the product families and applying percentage shifts to some big and bulky calculations. Statistics at this level is not for the faint-hearted. The table below, taken from November 1924,  is an example of the genre. Readers will notice that in this table, farthings are counted as 0.25, but this will change in the not-too-distant future to an integer, pure and simple.


The consumer panel was first used by the Board of Trade in 1904, when 1,944 urban working households were recruited. A footnote on page nine of the evidence volume reads:

The validity of using the budgets of 1904 was confirmed by the Working Classes Cost of Living Committee of 1918, under the Chairmanship of Lord Sumner, who reported that it was fairly certain that “Between 1904 and 1914…..no considerable changes took place in the mode or standard of living.”

The household data was calculated on the basis of the weight of food purchased, making comparisons between years more reliable, the civil servants argued. It is a moot point that a shop price in pounds, shillings and pence should resolve into a comparable pounds and ounces value at the table. To start with, the purchasing power of cash can and does change. The world in which we live is moving away from meaningful comparisons with previous eras, which need to be taken with a pinch of salt.

crunchy numbers FFCC food manufacture UK economy
What can £38/week buy?
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The impact of Government policy to improve the national diet comes with proportionally higher costs for poor households. This would apply to any government, of any stripe and any motivation. Structural change in food policy throws differences in earnings into sharp relief. When the Food Standards Agency published the Eatwell Guide in 2016, a headline price rise of £38 a week would mean a doubling in food bills for poor households, compared to increases of just over a third for affluent consumers. Using Eatwell data on a national scale, the Food, Farming and Countryside Commission (FFCC) researchers calculate that legislating for a healthy, sustainable national diet would come with a £57 billion price tag. This is not unreasonable, indeed it is good value, given that the direct cost of healthcare arising from diet-related illness is running at £91 billion, lost productivity is costing the economy an estimated £116 billion a year and the human cost a further 60 billion a year. The numbers basically accuse the food industry of being more interested in making money than feeding people. However, the scale and scope of the money extracted from UK health authorities by pharmaceutical corporations is several orders of magnitude greater and no less reprehensible.

If the market economy functions as one might have hoped, would this ever have occurred in the first place? Part of the problem with economics is that its practitioners quite cheerfully play “what if?” games as they go along. The problem is not that a variable might be unreliable, but that the outcome can change in so many ways that it is impossible to attribute a given outcome with a single input. Treating the food/health sectors as a series of events, for example, creates a dislocated view of the biosphere, with more gaps than development. Some gaps are inevitable, but you can have too much of a good thing.

Brexit's legacy customs clearance datacrumb Europe UK
They still don’t get it…
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Amazingly, there are still folk around Britain who have failed to grasp the meaning of the words”third country”, let alone why it matters. The Centre for Inclusive Trade reports a 16% drop in British food exports to the EU and is calling for concessions that would be unfair to other third countries. There isn’t a cat in hell’s chance of the European Commission doing a special deal for a former member state that opted to become a third country.

City life datacrumb FFCC food manufacture raw UK UK economy
Process of elimination
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If there is so much money at stake, how strong is the case for accusing food manufacturers of Ultra Processed Foods (UPFs) of wilful distortion? The arrival of wall to wall processed foods in British aisles in postwar years has been accompanied by rising numbers of patients needing treatment for heart disease and diabetes. While the nation gorges on sugar, salt and saturated fats, there is a drop in foods that bring whole grains, let alone fruit and vegetables. Processing very finely divided ingredients allows fertilisers and other toxic residues to spread downstream through the food chain. More worrying is the uptake of UFPs in the population. These foods now account for 57% of the adult diet and 66% of adolescent food intake. The health issues in later life are already filling up British hospitals and soak up two thirds of the health budget.

crunchy numbers FFCC food manufacture UK UK economy
Big Food’s Big Secret
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The UK government spends more than GBP 90 billion a year treating chronic food-related illness, according to the Food, Farming & Countryside Commission (FFCC). Researchers estimate that investing half that sum would be enough to make a healthy diet accessible to everyone living in the British Isles. The full extent of the damage caused to the UK economy by a dysfunctional food sector is GBP 268 billion pounds a year, taking lost productivity and early mortality into account, FFCC warns.

The Food, Farming & Countryside Commission is an independent charity, set up in 2017 to inform and extend public involvement in ongoing discussions about food and farming. Using government data as a starting point, FFCC argues that it would be significantly cheaper to produce healthy food in the first place. More to the point, it is not an option to go on footing the bill for damaged public health resulting from the commercial sector’s activities. There is simply not enough money in the kitty and time is running out. 

Researchers took into account government estimates of productivity and lost earnings arising from chronic illnesses. These indirect costs are borne by a range of actors in the economy, such as local government departments. Such costs are real expenditure, but the total figure is not recorded as a single aggregate figure. When combined with the initial figures, the result is a more imposing figure and looks like figure S1.

The direct costs (in red) are existing government data; indirect costs (in orange) indicate the economic impact associated with the prevailing levels of unemployment and early mortality. Like the submerged part of an iceberg, we ignore these costs at our peril.

Working with indirect costs opens the door to accusations of misinterpretation, but economists have worked hard to establish methods that can avoid serious pratfalls. Healthcare is supported by a wide range of funding sources, from government down to private individuals. The money is real enough, even when it comes from private individuals. It just becomes harder to count. There are times when budgets for nearby or related units will be skimmed to meet ad hoc requirements. Welcome to the economists’ underworld, where early retirement due to ill health is just another negative variable.

food manufacture UK UK economy
Pink, salty and out of stock
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The UK’s high spending foodies have been facing empty shelves, where they would normally find taramsalata. The strike action at a Bakkavar factory in Lincolnshire has successfully kept the salty pink dip out of big name retailers, including Waitrose, Sainsbury and Tesco. These industry heavyweights will get their on back on all those involved in due course — and reduce dependency on Bakkavar by recruiting other suppliers. Here is how the BBC covered the story.

Brexit's legacy UK economy
Delivering results?
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Turn the clock back to 2013 and the UK was divided over its membership of the European Union. Given the vehemence of the anti-EU campaigners, buoyed up with sympathetic media treatment,  the 4% majority in 2016 was hardly a ringing endorsement for such a major change. The most memorable slogan of the time was “Brexit means Brexit.” Not surprisingly, there were also opportunities to use Machiavellian creativity to plug gaps in the Leave campaign.

It was a time in British politics when the civil service was flexing its muscles and in a position to engineer bids for power with a free hand, actively encouraged by Tory grandees like Francis Maude. Running the Cabinet Office, Maude had a  new vision for the Civil Service, which was going to be set free from such tawdry constraints as public service: it was to be redefined and rewritten using People Impact Assessments (PIAs). The Cabinet Office led the way, setting up hybrid public/private joint ventures and mutuals in a bid to gain the best of both worlds, so to speak. These were not just government departments on steroids, these were new power structures of a sort that could be presented as a public service and a commercially savvy business at the same time.

The first employee-driven joint venture was the Behaviour Insights Team (often referred to as “the nudge unit”) which opened for business in March 2013. Here is what was said at the time (https://www.gov.uk/government/news/government-launches-competition-to-find-a-commercial-partner-for-the-behavioural-insights-team):

“The government’s Behavioural Insights Team will take its first step to becoming a profit-making joint venture today as the Cabinet Office launches a competition to find a commercial partner for the business. Less than three years after it was set up in the Cabinet Office the team is the first policy unit set to spin off from central government. This has been employee-led as the staff of the BIT have driven the process and will continue to run the organisation.

“The team was established to find ways of encouraging, supporting and enabling people to make better choices for themselves. Since then it has delivered rapid results – identifying tens of millions of pounds of savings, spreading understanding of behavioural approaches within government, and developing a reputation as a world leader in its field. Demand for its services from within government, the private sector and foreign governments has grown significantly.” 

The decade was to see a blurring of the distinction between public servant and executive power. If political  factions ever needed to inject reliable, hand-picked people to oversee critical functions in the political process, a joint venture with a government department takes a lot of beating.

Networking and data services have been at the heart of a number of government joint ventures, with the government’s 25% stake being sold off at the end of the first ten years. So it was that the French business Sopra Steria bought out the Cabinet Office’s stake in Shared Services Connected Ltd in October 2023. Here is what they said at the time:

“The transition from joint venture to wholly owned subsidiary will not affect the management, employees, clients, or services of the business, which has delivered significant savings and value for money for the taxpayer.

“Since Sopra Steria founded the company with the Cabinet Office in 2013, SSCL has become the largest provider of critical business support services for the UK Government, Ministry of Defence, Metropolitan Police Service, and the Construction Industry Training Board (CITB), delivering shared services at scale.”

It is not uncommon for IT suppliers to be over-confident about their system’s ability to cope and there are signs that all is not well at the points of delivery in the UK. Dover issued a note to port users in early June, seeking details of operational failures with BTOM. Invoicing for the Brexit border tax has been plagued with errors, including double-billing.

Ten years ago, there can be little doubt that Francis Maude knew and understood the Sopra Steria motto of the day: “The world is how we shape it.” Reality has since dawned on the management and it has been withdrawn.

Brexit's legacy UK economy
Taxing times
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Time is running out for importers of food to the UK. On September 4 HMRC will demand its pound of flesh and the UK food industry will find itself between a rock and a hard place. This is not the first time that the deliberate destruction of the British economy by the departing government has been discussed on this site: it is still a live topic. Called the Common User Charge by civil servants, the UK’s stealth tax on food imports is also known as the Brexit border tax and doubtless has cruder titles.

Since August 4, many importers have been receiving their first invoices for Common User Charge (CUC. Importers of animal and plant products that would usually be considered for food safety checks can expect to pay over the odds for driving a lorry off a ferry at Dover to join the UK road network. Hauliers booking a DFDS one-way ticket online to Dover pay three pounds for this indispensable service, while lorries carrying grouped consignments of SPS foods face open-ended bills in the hundreds or low thousands for the same access. The simple explanation is that Britain is playing catch-up: the European Union had everything in place to trade with the UK as a third country the minute it ceased to be a member state. Britain was so totally convinced that it would somehow negotiate a favoured nation package Brexit that there was not even a sketchy idea of what a post-Brexit customs system might look like. The years passed, conveniently putting off the awkward moment when Brexit would be complete. As recently as November 2023,  DEFRA describes the organisational basis for European food imports to the UK thus: 

“Currently, imports from the EU and certain imports from Greenland, Faroe Islands and EFTA countries do not need to enter Great Britain via a BCP and are not subject to veterinary checks at the border.” 

(Source: http://apha.defra.gov.uk/documents/bip/iin/vcap.pdf)

Just two months later, Britain was rolling out its three-phase Border Target Operating Model (BTOM). (The label ‘world-beating’ is optional.) Lorry drivers arriving in Britain have not been impressed by the service standards they have encountered on  the ground (https://urbanfoodchains.uk/sevington-gives-cause-for-concern/), which is more of a hostile environment than a workplace.  

Brexit’s hostile environment

DEFRA has gone from absentee administrator to nitpicking zealot overnight and is chafing over the accuracy of form-filling, notably for consignment detail on Export  Health Certificates (EHC). Hang on to your hats, here is a sample:

“Continuous and/or deliberate non-compliance  

It has come to our attention, that some traders and logistics companies are making continuous and/or deliberate errors including:

mis-declaring goods as low risk when they are medium;

or as medium when they are high;

 not including a relevant Export Health Certificate (EHC) or Phytosanitary certificate.”

Or the consequences… :

“Continued non-compliance within either the EHC or the CHED is not acceptable and will not be tolerated by Port Health Authorities (PHAs). Deliberate misdeclaration is a criminal offence.  PHAs will be actively looking to identify such behaviour.

“Where there is repeated non-compliance or evidence of misdeclarations, the appropriate authority will take statutory action. This will result in goods being held at a Border Control Post (BCP) for a physical inspection, which may lead to the consignment being ultimately returned or destroyed at cost to the person responsible for the load.”

Entering a conversation with a tone like that is doomed to become a monologue. Enough said. Now it just remains for the law enforcers to round up a bunch of suspects.

Since the end of April, Dover has been receiving a steady trickle of complaints about the way the Brexit border tax has been implemented. Here is what Dover had to say on the subject, again verbatim:

“As you are aware, the Border Target Operating Model (BTOM) checks have been operational for a month. Aside from initial teething problems, we are receiving a growing number of queries and concerns about how the checks are being carried out versus the costs that are being charged, delays to consignments, poor responses to calls and/or appropriate live assistance with your imports, the impact on biosecurity and the possibility of using Dover BCP to complete checks.

“It is important to understand your experiences so far to enable us to help establish simple solutions moving forwards, so we would like to set up a short call to discuss this with yourselves.

“Please drop us a line outlining your concerns and suggested solutions so we can escalate these for you. In addition, a member of our team may also call you.” 

The simple fact is that the CUC started off on the wrong foot and is compounding ongoing problems on the way. It was cobbled together out of retained EU law. Its stated aim is to recover the operating costs of Border Control Posts in the UK, but this does not stand upto close inspection. Officially, CUC rates for privately-owned ports are set by their owners. At regular intervals, DEFRA kicks the distinction into touch by stating that the tax is being charged at Dover and the Eurotunnel terminal. 

The port of Dover  has belonged to the town since it was incorporated in 1608 by James 1. Some members of the port harbour authority board are appointed by the department of transport, but this is a working arrangement rather than a power grab.

At the beginning of June, Dover issued the following statement, which I cite verbatim:

“We are writing to you with reference to the ‘Operational Border Target Operating Model Information’ Defra circulated on the 03/06/2024 which contained a significant inaccuracy regarding the BCP for high risk food not of animal origin arriving via Dover within the section ‘Moving high-risk food and feed not of animal origin at the Short Straits’.

“To clarify, if you are importing high risk food not of animal origin (HRFNAO) through the Port of Dover, either via RORO ferry terminal and / or deep sea cargo, you must continue to pre-notify Dover Port Health Authority on IPAFFS using the Dover Terminal BCP code GBDOV2P and not, as outlined in the Defra information update, Sevington BCP.

“Official border controls on high risk food not of animal origin arriving via RORO freight have been undertaken at the BCPs in the Western Docks for over a decade and since 2019 at the Cargo Terminal GBDOV2P (in the Western Docks).  

“Dover Port Health Authority will continue to provide this statutory function and ensure that your goods are handled efficiently and without undue delay. Please note, the Common User Charge does not apply to the Dover Cargo Terminal BCP. The Common User Charge will be applied if your goods are notified to Sevington BCP by selecting their different BCP code on IPAFFS.”