Brussels and Scottish Government Must Work to Deliver CAP Simplification

NFU Scotland has laid out its list of priorities if European Commissioner Phil Hogan’s urgent review on CAP simplification is to deliver a badly-needed cut in red tape and simplify rules.

The Union’s demands on simplification focus on the new direct support (Pillar 1) CAP package – and the new Basic Payment Scheme (BPS) - that came into operation at the beginning of 2015, where there is most to gain from a reduction in the administrative burden.

Despite its long gestation period, Scottish farmers continue to be confused and frustrated by the rules associated with the new BPS, including those concerning ‘Agricultural practices beneficial for the climate and environment’ (Greening) and Good Agricultural and Environmental Conditions (GAEC).    

Reasons for this include increased complexity of the EU legislation; the late publication of delegated and implementing acts; a considerable amount of missing detail in the legislation; late changes to guidance by the Commission and Scottish Government and unsatisfactory communication from the EU Commission to competent authorities like Scottish Government and from Scottish Government to farmers.

Commenting on the NFU Scotland submission on CAP simplification, President Allan Bowie said: “Scotland needs to take advantage of the flexibility provided in the new CAP in order to tailor the package to best support agriculture here. We accept that this introduces complexity but there is so much that has come from Brussels that could easily be simplified.

“The best example of unnecessary complication is the EU Commission’s determination to maintain the three basic Greening requirements relating to Permanent Pasture, Crop Diversification (CD) and Ecological Focus Areas (EFA).  This has simply hamstrung competent authorities (CA) like the Scottish Government as the regulations do not provide the required flexibility to address differing climate and environment priorities despite imposing a high degree of complexity in both implementation and regulation.

“We welcome Commissioner Hogan’s commitment to simplification and the agreement by the Scottish Government that simplification is needed.   We recognise, however, that addressing some issues will require changes to the basic regulations agreed in 2013 and that achieving a consensus for any significant changes with the European Parliament will neither be quick nor easy.”

Notes to Editors

In summary, NFU Scotland’s priorities for simplification are as follows:

The EU Commission should:

  • amend delegated and implementing acts to include detail currently only provided by guidance documents or by word-of-mouth
  • adopt a less prescriptive approach to mapping requirements, especially of the ‘reference layer for Ecological Focus Areas (EFA)’ so as to reduce the administrative burden on Competent Authorities (CAs).
  • simplify/reduce the complexity of rules applying to various EFA options to reduce administrative burden on farmers and CAs and so encourage uptake
  • remove the opt-out allowing CAs to not implement some EFA options or at least allow Member States to amend their choice of options.
  • simplify the calculation of EFA areas by combining Conversion and Weighting Factors
  • simplify the definition of crop for the purposes of Crop Diversification (CD) and provide a list of crops considered to be separate
  • provide greater latitude for measures that provide equivalent value for the climate or environment despite not being targeted at the same issues as the three standard Greening measures
  • amend regulations relating to ear tags to include reference to the slaughter tag derogations permitted in Scotland
  • amend regulations on spot-checks to minimise the risk of multiple inspections
  • accept all forms of evidence as proof of CD compliance
  • amend rules on application of reductions and penalties to make these more proportionate and fairer to larger farms.

The Scottish Government should:

  • remove additional requirements imposed on the Nitrogen Fixing Crop (NFC) EFA option
  • take advantage of the flexibility available under the existing legislation to make full use of the conversion factors for Field Margins and Buffer Strips
  • progress meaningful Greening equivalence schemes that better address climate and environment issues in Scotland than the standard Greening requirements
  • amend Good Agricultural and Environmental Conditions (GAEC) requirements to revert to those in effect up to 31 December 2014 on the protection of landscape features.

A copy of the full NFU Scotland submission in CAP simplification is available on request from


Contact Bob Carruth on 0131 472 4006

Date Published:

News Article No.: 40/15

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