Mr. Thomas Burke:

We suggest that time and space be given to the regulations so that we can see what comes of them. Retailers have worked hard to comply and it has not been without significant cost to the industry, at €100 million. A risk officer has been appointed in each of our member companies to oversee compliance and retailers have been working with the CCPC to make sure they are in compliance with the rules as they are laid out.

There are misconceptions of the margins and other things in the retail sector. The traditional retail model operates on a margin of between 1% and 3%, which is vastly different from that of some of the very large multinationals and branded goods companies, which potentially stand to benefit from the directive as it is currently structured. The proposal to extend the remit to all actors in the supply chain would significantly benefit those multinational companies, which operate at margins of between 30% and 40%. The relationship is inverse in the case of those particular companies so we would caution against an extension to include them.

Some points were made about the relationship between farmers and retailers.

In the vast majority of instances there is an individual who is an intermediate between the two. It is rare for there to be a relationship directly between the farmer and the retailer, with only 5% of European contracts agreed directly between retailers and farmers. The person in the middle is usually a processor or some such person.

It is not in the interest of retailers that the farming sector is in any way disadvantaged or left in an unsustainable position. We have a very good relationship with farmers and each of our individual companies has spent a lot of time, money and effort to ensure Irish produce is profiled, not only in the local market but on international stages in the UK and beyond. As an industry we are extremely committed to this. We want a good deal for farmers but this cannot be at the expense of retailers or consumers, who ultimately pick up the tab. In a sector with a margin of between 1% and 3%, we are very concerned at some of the amendments which have arisen out of the parliamentary process, particularly those which seek to impose only legally binding standards. We do not believe it is in farmers' interests to drive standards down. This is particularly the case with respect to Irish farmers, who have among the highest standards in the world, something we should use as a marketing tool. Anything that dumbs down standards is not in the interests of retailers or the farming community.

We are also very concerned about the suggestion that retail buying groups should be outlawed. The Irish retail model is a unique one and we have been very successful in building a raft of Irish retail entrepreneurs who have operated stores all around the country, in every single town and village in the members' constituencies. They have worked hard and the suggestion that it be unlawful for them to join symbol groups, or align with brands to form a retail buying group, is of great concern and one of the most worrying aspects to have arisen from the process thus far.