The Irish Farmers' Association - IFA

Lobbying Organisation The Irish Farmers' Association - IFA

Date published 21 Sep, 2024

Relevant Matter Matters involving public funds

Public Policy Area EU Affairs

Period 1 May, 2024 to 31 Aug, 2024

Specific Details European Commission Public Consultation on Amending Rules on Exemptions for Small Amounts of Aid (De Minimis Aid) in Agriculture

Intended results To acknowledge efforts to increase De Minimis thresholds but to request the Commission honour the position of a multitude of EU Ministers of Agriculture and increase the De Minimis Aid limit to €50,000 given the ongoing uncertainty facing the sector. To reject the proposal to establish a Mandatory Register of Aid Beneficiaries. This will add an increased level of bureaucratic burden which contradicts recent efforts to simplify these processes for farmers. This disclosure of private information is also unnecessary given the aid itself has no potential to distort markets or competition in principle. To highlight that in recent years Irish Agriculture has been faced with a plethora of inflationary pressures following the onset of the COVID-19 pandemic in 2020, resulting in mass supply chain disruption and followed soon after by Russia's invasion of Ukraine, leading to hyperinflation of essential farm inputs such as fertiliser and energy. To highlight that, while the effects of the above vulnerabilities on primary producers have somewhat subsided, it has become increasingly evident in the face of more complex markets, geopolitical uncertainty and climate change, that farmers require increased temporary and targeted fiscal support to offer business continuity during these volatile periods. To emphasise that agricultural inflation has far exceeded general and indeed food price inflation in recent years, with negative terms of Irish trade evident throughout 2022 to date. Aggregate input prices for most of the main on-farm cost centres (i.e. feed, fertiliser, fuel), although stabilising, or marginally declined from their recent peaks, remain well above normal multi-annual levels. To highlight that these events have eroded already low margins for most farmers which further exemplifies the need for an increased threshold for De Minimis Aid that accounts for the new realities that farmers are operating in, as geopolitical risks coupled with depressed output prices remain present across multiple sectors. To welcome the decision of the Agriculture Ministers of Germany, France, Austria, Croatia, Romania, Hungary, Cyprus, Slovenia, Latvia, Luxembourg, Malta, Slovakia, Estonia, Poland and Bulgaria, to send a letter to commissioner Vestager calling on the Commission to increase the ceiling of “de-minimis” aid in the agricultural sector per single undertaking to €50,000 over the course of three years. To express disappointment that this request, which was overwhelmingly supported by EU Agriculture Ministers at the Agri-Fish Council in April 2024, for a threshold of €50,000 has not been included in the proposed Amendment by the Commission, but rather limited to €37,000. It is particularly relevant to note that during the periods of hyperinflation recently experienced by farmers that many input prices doubled for farm inputs and in the case of some fertiliser, quadrupled. Given the volatility the sector continues to face, it can be hypothesised that the proposed increase in De Minimis Aid will be insufficient to deal with the combined potential challenges that lie ahead for farmers. To reject the establishment of a mandatory register for small levels of state aid under the proposed amendment. This adds an unnecessary level of bureaucracy for farmers especially during periods when aid should be delivered promptly and effectively in times of crisis or market failure. Reporting obligations are already in existence to monitor higher allocations of aid which IFA believe are currently sufficient to prevent distortions of competition. To show concern atthe proposal to publicly publish the names of beneficiaries given most farms do not operate under a company name in Ireland. This level of scrutiny is unwarranted and disproportionate given the aid will have no market effects, other than to support producers often during periods of economic hardship. To question the fairness of Article 3(5) as stated. Full ‘De Minimis' should not be allocated at the point of legal acceptance in Year 1 of a multi-annual scheme, but instead distributed out over the lifetime of the scheme. To propose that, in relation to Article 3(9) proportionality should apply and an undertaking be entitled to the amount of funds (at least) that would bring them from existing position to the threshold amount rather than dismissing it entirely. To highlight that while extending the expiry date to December 31st is a positive development, having an expiry date at all is premature given the EU Agriculture Sector has historically always contended with market challenges, supply chain disruption, geopolitical events and more recently climate change. To emphasise that agriculture underpins EU and often Global Food Security and there must remain a consistent, reliable and financially robust mechanism to support farmers in all 3 pillars of sustainability - economic, social and environmental.

Name of person primarily responsible for lobbying on this activity Shane Whelan IFA Senior Policy Executive, Rachel Moloney IFA Policy Executive

Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?) No

Did you manage or direct a grassroots campaign? No

Was this lobbying done on behalf of a client? No

Lobbying activity

The following activities occurred for this specific Subject Matter Area.

Email (2-5)

Submission (1)

Meeting (1)

Informal communication (2-5)

Designated public officials lobbied

The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them. As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.

Aodhan O'Riordain MEP (European Parliament)

Barry Andrews MEP (European Parliament)

Billy Kelleher MEP (European Parliament)

Ciaran Mullooly MEP (European Parliament)

Cynthia Ní Mhurchú MEP (European Parliament)

Kathleen Funchion MEP (European Parliament)

Luke Ming Flanagan MEP (European Parliament)

Lynn Boylan MEP (European Parliament)

Maria Walsh MEP (European Parliament)

Michael McNamara MEP (European Parliament)

Nina Carberry MEP (European Parliament)

Regina Doherty MEP (European Parliament)

Sean Kelly MEP (European Parliament)

Jackie Cahill TD (Dáil Éireann, the Oireachtas)

Michael Collins TD (Dáil Éireann, the Oireachtas)

Michael Fitzmaurice TD (Dáil Éireann, the Oireachtas)

Michael Ring TD (Dáil Éireann, the Oireachtas)

Joe Flaherty TD (Dáil Éireann, the Oireachtas)

Paul Kehoe TD (Dáil Éireann, the Oireachtas)

Claire Kerrane TD (Dáil Éireann, the Oireachtas)

Brian Leddin TD (Dáil Éireann, the Oireachtas)

Johnny Mythen TD (Dáil Éireann, the Oireachtas)

Tim Lombard Senator (Seanad)

Victor Boyhan Senator (Seanad)

Paul Daly Senator (Seanad)

Denis O'Donovan Senator (Seanad)

Barry Cowen MEP (European Parliament)

Charlie McConalogue Minister (Department of Agriculture, Food and the Marine)

Amii McKeever Adviser to Minister (Department of Agriculture, Food and the Marine)