Mr. Barry Larkin:

I can answer that. I have a statement that I can read out, if that is okay.

Merchants' co-operatives and agri-retailers around the country have aligned their businesses in a way that best serves Irish farmers. The resulting landscape of the agri-retail trade in Ireland means that there are businesses of varying size across the country, but the core principles of these businesses remains similar across the board, with sales of fertiliser and animal health products playing a fundamental role in the economic survival of their businesses. Merchants and co-operatives around the country are acutely aware of the sustainability requirements set on the agricultural industry as a whole and they are willing to put their shoulder to the wheel. These businesses employ a significant number of suitably qualified people across the industry that they service, including nutritionists, agronomists, RPs for animal health, specialists for human-consumable foods, and so on. Many are qualified to a reasonable level, including to level 8, level 9, and even to PhD level. Farmers rely on these people for expertise and advice to maximise efficiency on their farms.

It is imperative for the industry that all of these businesses are kept economically viable so that the trade can continue to provide its far-reaching service to farmers. These businesses and the people who work there will be crucial to providing services, expertise, advice and knowledge to farmers as we all embark on the journey to reduce emissions from the sector without compromising output.

The implementation of the veterinary medicinal products medicated feed and fertilisers regulation Bill 2022 in its current form threatens the viability of many agri-retail businesses around the country and, in turn, also threatens the jobs of the many people with specific qualifications whom I have outlined. If the sale of animal health products is taken away from many of the smaller merchants around the country, then those businesses will become unviable and close their doors, leaving farmers with no option but to look further afield for the services and advice that they require.

I will note some issues with the Bill in its current form. With regard to the North of Ireland and the Border, there is free trade and movement of goods on the island of Ireland under historic agreements. While the Department of Agriculture, Food and the Marine correctly maintains that it cannot impose legislation on the North of Ireland, it makes it quite difficult to successfully implement legislation on one side of the Border. Fertiliser has been traded across the Border for many years by both farmers and agri-retailers. Until recently, this has tended to happen in just the Border counties. However, this has extended much farther with commercialisation. If farmers in County Cork want a load of fertiliser from a retailer in the North of Ireland, all they have to do is make a phone call and the fertiliser will land in their yard within days. It would be incredibly naive for anyone to think that farmers who are pushing boundaries will not use this angle to avoid recording some of their fertiliser purchases.

While we have been involved and engaged with the Department through stakeholder meetings, it seems that the current route of travel regarding the IT requirements of agri-retailers is overly comprehensive. There are currently two proposed ways by which the Department will accept sales information. In one, merchants have a responsibility to input fertiliser sales data into the agfood.ieportal, transaction by transaction. This is a laborious and tedious process.

The second option is for the Department's IT system to link with agri-retail systems through the use of an API, which will cost a significant amount for agri-retailers that have meticulous and secure IT systems. It would potentially force smaller merchants away from fertiliser sales, since they may not have the IT systems or resources to implement this Bill in their businesses. Some of these smaller businesses still use pen and paper to record sales. The API to link IT systems has yet to be disclosed to the trade, leaving very tight timeframes for it to be ready and successful. The requirement for the Department's IT system to link with the IT systems of agri-retailers for the purposes of the legislation seems to be overly comprehensive. A simple monthly reporting mechanism, where data can be exported to a .csv file and sent to the Department, which can use its IT system to seamlessly extract the required data, is a far more feasible solution that would not incur the huge costs and potential security problems that can arise from IT systems linking together.

In summary, agri-retailers around the country have many concerns about the Bill in its entirety. However, the availability of goods from the North of Ireland puts most aspects of the Bill in question. An all-Ireland approach would be better, if possible, or at least we could have the same processes in place on both sides of the Border, with RPs on both sides.

Merchants throughout the country have a full understanding of why the Bill is being introduced. It will address water quality and emissions from fertiliser and antiparasitic resistance, which is an animal health issue. All businesses are willing to achieve what is required to make our island a better place. However, an increasing financial burden is being placed on agri-retailer businesses across the country, including administrative, IT system, and staff training costs. The Department of Agriculture, Food and the Marine can take pathways to successfully implement this Bill. It seems that we are going down an overly comprehensive route for both the anti-parasitic medication and fertiliser issues.