Soyuzmoloko asks to remove animal husbandry from regulation of the law on greenhouse gases

Soyuzmoloko considers it inappropriate to regulate agricultural organizations within the framework of the mandatory requirements of Federal Law 296 “On limiting greenhouse gas emissions”. This is stated in a letter sent by the Director General of the Union Artem Belov to the Government of the Russian Federation.

On February 16, a meeting of the subcommittee on improving the control (supervisory) and licensing functions of federal executive bodies under the Government Commission for Administrative Reform was held on the topic of mandatory accounting of greenhouse gas emissions by organizations. The requirements are proposed to be established by the draft PP “On approval of the criteria for classifying legal entities and individual entrepreneurs as regulated organizations”, they also apply to agricultural organizations. As Soyuzmoloko noted, the industry's position on the inappropriateness of regulating agricultural organizations within the framework of the mandatory requirements of 296-FZ, which is also supported by the RSPP, Opora Rossii and the business community as a whole, was not taken into account.

As arguments, the head of Soyuzmoloko cites the fact that in international practice, the regulation of directly agricultural producers in terms of the climate agenda is an exception, not a rule.

Examples of such regulation in the world are isolated (New Zealand and the USA ), while many developed and developing countries, including those with a huge livestock population, do not impose such requirements (Germany, China , Canada, Brazil, India, Great Britain, Australia, Israel, etc. .d.). Agriculture is also not included in the European Emissions Trading System (EU ETS), which eliminates the external economic risks for the industry associated with the introduction of cross-border carbon regulation (CTR) by the EU.

Also, according to industry representatives, accounting for emissions at agricultural enterprises is a costly and knowledge-intensive process. Filing reports under 296-FZ involves burdening agricultural producers not only with requirements, but also with the development of a methodology for meeting these requirements. This will require the involvement of external consultants, which, according to Soyuzmoloko, will cost about 1-5 million rubles per report, excluding its mandatory verification. This will lead to additional costs in the industry and exacerbate existing inflationary trends.

At the same time, reporting will not lead to an improvement in the quality of monitoring of greenhouse gas emissions, Soyuzmoloko is sure. After all, the value of the data obtained by aggregating the reports of regulated organizations is still doubtful: more than 40% of the low-productive livestock is owned by private farms, which makes it not entirely correct to collect data from the largest producers - the vast majority of greenhouse gas emissions will not be covered by reporting.

Another business argument is the fact that the further development of regulation involves its tightening: the introduction of emission quotas or a carbon tax, which will reduce the competitiveness of the industry in the domestic and global markets.

As measures to be taken, the head of Soyuzmoloko names the exclusion of the item “Livestock (internal fermentation)” from the project, while maintaining the possibility of reporting on greenhouse gas emissions by agribusiness organizations on a voluntary basis. It is also necessary to update the methodology for calculating greenhouse gas emissions for agriculture based on the IPCC methodology, including revising national coefficients. All this should be accompanied by regular consultations with foreign countries, including the EU, in order to identify trends towards a possible tightening of regulation abroad.

In conclusion, the head of Soyuzmoloko asked First Deputy Prime Minister Andrei Belousov and Deputy Prime Minister Victoria Abramchenko to instruct them to conduct additional consultations on the issue of classifying agricultural organizations as regulated under 296-FZ at the Government site with the participation of the Ministry of Economic Development of the Russian Federation, the Ministry of Agriculture of Russia, the RSPP and Soyuzmoloko.