Complaints are an essential source of information and intelligence for any organisation involved in enforcement. We know that understandably complainants live with a real fear of repercussions if they make a complaint and allowing anonymous complaints can help with this, but the ability to actually determine that the law has been broken or to take enforcement action based on an anonymous complaint is very challenging in terms of implementation, in particular when it comes to penalties or levying fines. This is an issue that would have to be overcome for the proposals to have a real impact.

Another area of note of the proposed directive is the issue of fines. Ireland is an outlier with the rest of Europe's regulatory bodies in that our Constitution raises issues around the administration of fines by bodies other than the courts. In our current work we have found this to be a particular difficulty. We share the view that financial sanctions are essential as a deterrent but the issue of administrative fines is one that needs to be considered and overcome.

I have come this far without mentioning Brexit, but I must do so before I conclude. It is clear that uncertainty is the main issue at present for Irish food producers selling into the UK or UK retailers who operate here. We do not know what will happen in the weeks and months ahead, but we urge the committee to ensure that the Irish food industry is not put at a disadvantage compared to their UK counterparts which most likely will not be the subject of the proposed directive. Competitive balance could be a significant issue in the future, another area we will be happy to discuss further.

To sum up, what has become apparent from our work to date in the sector is that the relationships, contracts and issues experienced by those involved in the food chain are complex and are also evolving. I hope I have usefully highlighted to the committee that the proposals presents some significant practical challenges in terms of oversight and enforceability. We recognise the importance of a sustainable agrifood industry but it is our considered view, given the complexity, the scope and the goals of the proposals that the role of the competent authority for the proposed directive should be given to a sector specific regulator whose sole remit and focus would be overseeing this market and working with farmers, producer groups, wholesalers, retailers and other players to ensure their competing interests can be fairly balanced. We would be very happy to take any questions and to explain our views.