Consultation outcome

Consultation response: revised system of financial support for abattoirs and game handling establishments

Updated 4 September 2026

1. Introduction

The Food Standards Agency (FSA) carried out a public consultation on proposals for a revised system of financial support for abattoirs and game handling establishments in England, Wales and Northern Ireland from 19 March to 12 June 2026.

The consultation sought views and evidence on proposals for a revised system of financial support to be delivered, subject to ministerial agreement and central funding, through discounts to charges for FSA official controls (inspections).

The draft proposals set out in the consultation were informed by a Call for Evidence (autumn 2024), stakeholder engagement sessions (spring and autumn 2025) and consideration by the FSA Board in their public meetings of 11 December 2024, 18 June 2025 and 10 December 2025.

The Board agreed at the latter meeting that the FSA should conduct a public consultation on the detail of the proposal developed through the previous engagement. The consultation specifically sought views on: 

• the FSA’s rationale for change and the proposed revisions to the system of support to meet that rationale

• alternative views or suggestions that could help refine the proposals before presentation to the FSA Board and ultimately Ministers in the three countries

• the potential impact on FBOs, consumers and the wider food system that would arise from the changes

The consultation included preliminary evidence and models to aid individual businesses’ understanding of the impact on them and sought quantifiable evidence to inform an impact assessment.

In line with best practice, the FSA will submit its impact assessment of the revised discount regime to Ministers ahead of final decisions. The impact assessment will be published for stakeholders once publication arrangements have been finalised.

The consultation was published on the FSA website and received 3,050 views. Stakeholders were invited to respond using an online questionnaire, which also allowed stakeholders to provide more general comments, or by e-mail.

The consultation was promoted through direct communications with stakeholders across England, Wales and Northern Ireland, including invitations issued by email and post to 588 food businesses and 58 organisations, such as food business operators, trade associations and membership bodies. This was followed by a reminder notification sent on 2 June 2026.

During the consultation period, the FSA ran three stakeholder engagement events to raise awareness of the consultation, answer questions, encourage responses, and capture comments.

The sessions took place online and face-to-face in Belfast on 12 May, London on 15 May, and Cardiff on 5 June 2026. As well as the responses received to the consultation via the online questionnaire and e-mails, comments made by stakeholders in these sessions are also reflected in this document against the most appropriate section.

This document summarises the responses received and follows the sequence of questions asked in the consultation document. For each topic, it sets out the feedback received, the FSA’s consideration of that feedback and the conclusions reached following consultation.

Commercially sensitive information has been omitted from this document.

The FSA thanks all stakeholders who responded to the consultation and engaged through the stakeholder events. The consultation has emphasised the complex issues surrounding financial support in this area. The evidence and insights stakeholders provided have been extremely valuable in helping shape the proposals. It has enabled the FSA to further test the evidence-based assumptions which underpinned the discount model proposed in the consultation and to make adjustments (see paragraph 21) which will better achieve the FSA Board’s objectives. The complexity demonstrates the continuing need for the FSA to work with stakeholders to ensure that the information we provide is understandable and accessible to all with an interest.

Judicial review

On 3 June 2026, towards the end of the consultation period, judgment was handed down in a Judicial Review brought by the Association of Independent Meat Suppliers (AIMS). The National Farmers Union (NFU) and the Secretary of State for the Department of the Environment, Food and Rural Affairs and British Meat Processors’ Association (BMPA) acted as interested parties.

While the consultation did not seek views on the issues that were the subject of the judgment itself (the judgment was with respect to charges, not discounts) there is a clear link and some respondents referred to it in their feedback. Relevant comments have been considered where they relate to the consultation questions and are reflected in sections 4.13 and 4.16 of this document. The judgment also forms part of the wider context for future policy development and ongoing charging work.

The FSA does not agree with the rationale of the judgment and at the time of writing is seeking permission to appeal the decision handed down to the Court of Appeal. While the ultimate Judicial Review outcome may affect future charging arrangements (including the scale of the charges and therefore discounts), it does not alter the objectives underpinning the consultation, the rationale for support, the consultation process or the evidence received, including evidence on the regulatory burdens faced by different parts of the sector. The model itself is designed to accommodate change. Therefore, although the final outcome may affect the level and composition of charges and discount, the FSA considers that the policy objectives and proposed framework remain applicable under the reasonably foreseeable outcomes.

2. Executive summary

This response brings together conclusions from written consultation responses and wider stakeholder consultation discussions. The evidence gathered through this engagement has been thoroughly considered and used to test and strengthen the proposals, while ensuring alignment with the Board’s objectives. The responses received provided a rich range of views against each of the three areas on which the consultation sought evidence:

Rationale for change

Respondents broadly supported continuing and prioritising public funding for smaller establishments and many supported the objectives of a more predictable and transparent system. Many respondents emphasised the wider value that some abattoirs provide beyond their direct commercial role, including maintaining local slaughter capacity, supporting rural communities and farming diversity, improving animal welfare outcomes through shorter transport distances, and enhancing consumer choice. However, there was also challenge around the need for change, the evidence base or elements of the proposed model and respondents put forward a number of alternative proposals including retaining the current model and changing the underlying charging approach.

The FSA carefully considered these but concluded there was not an alternative model that would better achieve the objectives of targeting funding towards establishments less able to benefit from economies of scale, while maintaining a simpler, more transparent and predictable system of support. Further detail on the evidence received and the FSA’s consideration of alternative approaches is provided in section 4.1.

Suggestions to refine the proposals

  Respondents suggested several areas where the model could benefit from refinement. Responses queried the proposed threshold levels, the use of throughput as the primary basis for determining eligibility and support and the treatment of establishments in Northern Ireland.

Although tapering was generally preferred to a cliff edge, the proposed rate of taper and Threshold 2 (T2) attracted some of the strongest concerns, particularly about effects on growth and small-medium and medium-sized establishments.

The consultation formed part of a wider programme of policy development and evidence gathering. Alongside evidence, operational appraisal and the consultation responses received during this period, further analysis has informed recommendations to retain Threshold 1 (T1), increase T2, and retain the proposed livestock unit (LSU) methodology. Feedback also highlighted the need for clearer communication and guidance to support understanding of the model. Further detail is provided in sections 4.6 and 4.9 to 4.11.

Impact on FBOs, consumers and the wider food system

Respondents offered useful information on potential impacts arising from the proposals. Responses recognised that the proposed model could be beneficial in providing greater predictability of support, a simpler charging support system, increased transparency and a clearer relationship between business throughput and discount levels. In addition to the responses regarding impact on business growth, some responses stated that reducing support to manage regulatory burdens could affect the viability of some abattoirs, particularly those of medium size, that play an important role in local and regional food systems and rural communities. 

Responses highlighted potential implications for consumers if higher regulatory costs are passed through the supply chain, as well as indirect impacts such as product availability. Some respondents also called for greater efficiency and transparency in the delivery of official controls to help minimise regulatory burdens on businesses while maintaining public confidence in food safety standards. 

The impacts identified by respondents were broadly consistent with the FSA’s own evolving understanding of regulatory burdens, charging arrangements and wider pressures affecting the sector. The evidence received informed further analysis and operational appraisal of the proposals, while reinforcing the importance of considering the revised support model alongside wider work on charging efficiency, transparency and reform. Further detail is provided in sections 4.13 and 4.14.

Conclusion

The consultation provided valuable evidence on the likely impacts of the proposed model and informed further analysis following consultation.

The FSA concluded there was not a practical alternative to throughput as a proxy for business size that would better meet the objectives of simplicity, transparency and predictability without creating additional administrative burdens. The consultation did provide additional evidence on the position of establishments that continue to face disproportionate regulatory burdens above the proposed thresholds, and this evidence informed further testing and refinement of the proposed model. 

The recommendations presented to the Board therefore retain the overall structure and rationale of the proposed model while incorporating changes informed by the evidence received. In particular, the FSA is recommending that:

• T1 remains unchanged and continues to align with the legislative definition of a small abattoir
• T2 is increased up to, and as close to, ten times T1 as available budgets permit to provide additional support to some small-medium and medium-sized establishments
• the proposed simplified FSA LSU values are retained as the basis for measuring throughput as a proxy for business size
• wild game killed away from the game handling establishment in which it is subsequently processed will not count towards throughput in LSUs (large game) or numbers of animals (small game)

In respect of Northern Ireland, evidence from the consultation supported earlier findings that the structure of both the agricultural industry and the abattoir sector warrant consideration of a different approach. The FSA is recommending the same basic model, while inviting Ministers to consider additional discretionary support within available budgets to reflect its distinct circumstances.

The FSA will continue to work with industry on issues relating to charging transparency, efficiency and wider reform of official controls that are beyond the scope of the revised support model.

Further detail on the responses received and the FSA’s consideration of those responses is set out in section 4. 

3. Responses received and respondent profile

FSA received 47 responses to the consultation from 42 respondents. Some representative organisations provided more than one response or provided both a survey and an email response.

Response route	Responses
Survey responses	21
Email responses	26
Total responses	47

Respondent / business type	Respondents
Abattoir	16
Trade association	11
Food business operator	6
Other / membership organization	6
Consumer	1
Unknown	2
Total	42

Country / geographical scope	Respondents
England	23
Wales	6
Northern Ireland	5
England and Wales	4
England and Northern Ireland	1
England, Wales and Northern Ireland (includes UK designations)	6
Unknown	2
Total	47

The overall number of responses was relatively low compared with the number of establishments potentially affected by the proposals, but it is recognised that responses from trade associations and membership bodies represent the interests of their members.

4. Summary of responses by consultation question

The summary below reflects evidence received through questionnaire responses, email submissions and stakeholder engagement events. Where the same issues were raised across multiple questions or response routes, feedback has been summarised under the question where it was considered most relevant, to avoid repetition.

As more than half of responses were submitted by email rather than through the questionnaire, respondent profiles have not been provided for individual questions. Any profile based only on questionnaire responses would not accurately represent the overall balance of feedback received.

4.1 Options and overall evidence base

Consultation question: What additional evidence can you provide to support or challenge the conclusions the FSA has drawn?

This general question was designed to allow respondents to raise wider issues with the model and charging or discount system. This section therefore captures broader points made here, from elsewhere in the questionnaire, in email responses or at stakeholder events.

Respondents expressed a range of views on the proposed model and the wider context around charging and discounts. There was broad agreement on the principle of prioritising financial support towards smaller establishments, although views differed on where support should end with some making the case for continuing a universal discount.

For many respondents support for the principle was accompanied by objections to particular elements of the proposed model.

The main alternative suggestions received were to maintain the current model or to change the charging model to eliminate the need for discounts (headage). A number of partial alternatives were also suggested including revising the allocation of funding between business size categories, providing greater support to medium-sized establishments, and/or considering different arrangements for different sectors.

Those critical of the broad approach were primarily concerned about the potential for negative impacts.

Concerns raised included increased costs, reduced profitability, business viability, loss of slaughter capacity and wider consequences for rural communities, local food systems and supply chains. Some respondents argued that the proposals could discourage growth and accelerate consolidation within the sector.

A number of respondents particularly raised concerns with regards to medium-sized businesses operating between the proposed thresholds, which would receive support according to a taper. They highlighted the potential for unintended consequences for businesses operating close to the proposed thresholds.

Some respondents raised concerns about aspects of the engagement process and questioned the fundamental nature of the proposals, drawing on the history and operation of the current system, and noting that they represent a substantial policy change.

Respondents also challenged the evidence base and called for further economic analysis, clearer impact modelling, greater transparency and assurance that all affected stakeholders had the opportunity to contribute.

Many respondents argued that greater priority should be given to improving the efficiency, transparency and effectiveness of official controls and charging arrangements before making significant changes to financial support. Adopting headage-based approaches to charging was suggested numerous times in both written responses and stakeholder meetings, as a potential route to remove discounts altogether.

Some respondents raised wider issues beyond charging, questioning whether official controls are aligned with the main public health risks and whether broader reform should accompany changes to financial support. Some also challenged assumptions and the presentation of legislative provisions about continuous Official Veterinarian presence, noting sectoral differences and the scope for some inspection activity to occur post-mortem.

Feedback relating to the specific circumstances of Northern Ireland, including the structure of the agri-food sector, competitiveness, distinct regulatory burdens and proposals for a different approach, is summarised in section 4.11.

FSA response

Targeting of support

Feedback throughout the call for evidence, stakeholder engagement and consultation has consistently supported continuing financial support for smaller abattoirs. Although some respondents questioned whether micro-abattoirs need the same level of support, the FSA has not identified sufficient evidence to justify further differentiation. Additional sub-categories would add complexity and administrative burden, with no clear evidence that the benefits or government savings would outweigh the costs.

While support for smaller establishments has been a consistent theme, consultation responses placed greater emphasis on medium-sized businesses operating between the proposed thresholds. Respondents varied in how they defined medium-sized establishments and how far support should extend beyond the smallest businesses. This information has been used as a basis for conducting further analysis and is considered in the sections on thresholds and tapering.

Several respondents raised wider challenges affecting the abattoir sector such as local slaughter capacity, geographical distribution, supply chain resilience and the wider role of abattoirs in the food system.

Our consideration of issues such as these and the characteristics of the businesses involved informed the development of the policy rationale of supporting diversity of the sector and consumer choice and provide justification for moving away from the default position of full cost recovery. This rationale provides a firm policy anchor for targeted public funding where it can be demonstrated that financial support contributes to the delivery of those objectives.

The FSA also recognises that many of the challenges identified by respondents extend beyond the regulatory charging framework and cannot, and should not, be addressed solely through discounts on charges.

The revised support model will not, on its own, ensure a secure future for all smaller abattoirs and this was not its intended purpose. The evidence received throughout the development of this policy-led approach indicates that equalising the regulatory burden on smaller businesses will contribute significantly to their long-term sustainability compared with a full cost recovery approach and supports the objectives identified through the policy rationale for intervention.

The FSA recognises that the overall regulatory costs are significant across the sector and that these costs were a recurring theme throughout the consultation. However, the evidence considered through this process does not support a universal subsidy as a means of addressing those costs. Nor does it provide a basis for recommending wider financial assistance as part of the revised model. However, Ministers may choose to provide additional support for other policy reasons and the discount remains a possible mechanism through which support could be delivered.

Fairness and value for money

Many respondents referred to the ‘fairness’ of the current system with all businesses having access to the same progressive discount structure and the concern that this is lost in the new model.

The FSA hourly charging model means that everyone is charged at the same hourly rate for the amount of inspection resource they use, encouraging effective use of staff. However, there is an inherent issue with economies of scale and this approach results in a significantly higher regulatory burden (up to nine times) for smaller establishments. Both the current model, through the use of bands, and the new model seek to address this distortion.   

When developed, the current model sought to promote fairness by allocating a funding pot using a banded discount structure that distributed support across the sector according to throughput. Under this approach, fairness was understood as ensuring that all businesses received some level of support.

This resulted in a large amount of public funding going to very large businesses who are able to manage economies of scale and are affected much less by regulatory burden. The revised approach reflects a conscious policy shift towards targeting public funding where it can be more clearly linked to the Board’s rationale and the effective management of public money.   

The policy rationale for the new approach is broad, with a wide set of outcomes as a rationale for action and providing any financial support. However, as the goal is to contribute to these outcomes it is not intended or indeed possible to deliver them in their entirety. The intention is to give Ministers a firm basis for spending public money, but in doing so we must also demonstrate value for money.

Therefore, while aiming to deliver these benefits, the construction of the proposed model is much more focused on removing distortions by equalising regulatory burdens. This is the same rationale behind the progression in the current banding system. The difference is that the new model focusses funding only on correcting the distortion as a measure of fairness and in doing so provides much better value for public money.

Headage-based charging  

Several respondents advocated a headage-based charging system as an alternative approach to address fairness and the risk of unequal regulatory burdens.

A headage-based system would largely remove the distortion that the revised support model seeks to address, as every animal is charged at the same rate. Changes to the charging methodology were outside the scope of this consultation. Nevertheless, because the issue was raised frequently, the FSA has undertaken high-level analysis of a headage-based approach.

Headage rates are set in EU legislation and have not been updated since 2017. Initial analysis using the data currently available suggests that applying these rates in 2026/27 would require a substantial 4 fold increase in public subsidy, from the current level of £11.8 million to in excess of £40 million, with the majority of this additional public funding benefitting larger establishments.

Therefore, while it would address differences in regulatory burdens, it would do so at significantly greater cost and would not represent a more cost-effective means of delivering the identified objectives than the proposed support model.

The level of public subsidy required under the current statutory headage rates also helps explain why cost comparisons with countries operating headage-based charging systems can appear unfavourable to the UK. Decisions on whether support should be provided on this scale are ultimately for Ministers. However, based on the evidence considered through this process, the FSA has not identified a basis for recommending this level of public expenditure as part of the revised support model.   

Process and scope

Many respondents argued that wider reform of the charging system, official controls and supporting processes should take place before changes to the discount model are implemented. The FSA has noted these views and responded throughout the engagement process. We consider that establishing a clear and sustainable basis for the discount is important ahead of any reforms. This approach seeks to ensure that the benefits of targeted funding for smaller establishments are maintained while wider work continues.

Some stakeholders have raised concerns with the lack of engagement and the range of options being discussed. This consultation forms the last part of a 2-year policy development process which has included multiple stakeholder discussion and feedback processes throughout. All potentially affected food business operators (FBOs) have been kept informed and invited to participate throughout the process. Most have chosen to do this through their industry representative bodies, while others have engaged directly with the FSA. Feedback received throughout the process has directly informed the development of the proposals that will be considered by the Board, and the FSA is grateful for the time and evidence contributed by stakeholders.

The ‘do nothing’ (keep the current banding approach) and ‘do maximum’ (full cost recovery) options have been considered and discussed at length as part of the engagement and have been considered by the Board. The full decision process was summarised in the consultation. In order to ensure a deliverable approach, the Board agreed that the consultation should seek views on a number of key design features of the model. Analysis of the feedback received is set out in this document.

We have repeatedly sought specific information to support an impact assessment and have conducted our own analysis to address gaps. As a result, an impact assessment has been submitted to the Regulatory Policy Committee and will be available for Ministers when we seek their decision.          

Wider issues relating to the delivery of official controls rather than the design of the revised support model have been noted and will be considered separately from the proposals consulted upon.

Summary

Many of the issues raised in response to this question are not new, were discussed throughout the programme of stakeholder engagement, informed consideration of the proposals and were highlighted in discussions with the Board. The FSA recognises the continuing strong views of some stakeholders on these matters.

The evidence received supports the following actions:

• continue to improve communication on the new model, its purpose and intended effects
• recommend adjustments to some of the key parameters (described in the themes that follow)
• ensure wider concerns raised through the consultation process inform future work on charging and associated systems

4.2 Basic approach: annual single percentage discount

Consultation question: To what extent do you agree or disagree that, for each eligible establishment, the model should provide an annual determination of a single percentage discount applied to all eligible charges?

Supporters of the proposed model valued the simplicity, predictability and transparency of a single annual determination of discount levels and the clearer relationship between eligibility and discount levels.

Opposing respondents argued that the approach could produce unfair outcomes where businesses with similar characteristics received different levels of support because they fell on different sides of a threshold. They were concerned that discount eligibility could be withdrawn from businesses that continued to face similar cost pressures and regulatory burdens and that the model was insufficiently sensitive to individual circumstances.

Some respondents were uncertain how support would reduce as throughput increased and questioned whether the taper would operate as a smooth reduction or through a series of practical cliff edges, with some favouring more graduated arrangements or alternatives based on headage, public value or sector-specific need.

FSA response

The consultation identified broad support for the objective of creating a simpler, more transparent and predictable system, which was a key aim. Respondents generally favoured greater certainty regarding future discount levels and a clearer relationship between throughput, eligibility and discount levels, although views differed on the detailed design of the model.

Under the proposed model the annual discount percentage for each business would be known at the start of the year rather than only being calculable retrospectively under the banded system, improving transparency and predictability.

The FSA also notes that some concerns, particularly those relating to sharp changes in support either side of thresholds, appear to reflect a misunderstanding of how the proposed taper would operate in practice. Under the current arrangements, businesses already receive different effective levels of discount through the banding structure and each business receives an effective overall annual discount.

Unlike the current approach, where  changes in a series of steps, the proposed model provides for a continuous reduction in support as throughput increases between the two thresholds. This avoids the creation of additional cliff edges within the taper.

Further analysis of the concerns raised and the alternative approaches suggested by respondents are provided in later sections of this document.

The evidence received supports the following actions:

• proceed with the proposed single annual percentage discount model
• improve communications on how the discount will work

4.3 Historical throughput as the basis for eligibility

Consultation question: To what extent do you agree or disagree that historical throughput is an appropriate basis for determining eligibility for financial support?

Those supporting the use of throughput generally considered it a more transparent, understandable and predictable basis than the current system. Respondents noted that throughput data are readily available and easier for businesses to understand and verify.

However, many respondents questioned whether throughput alone is an appropriate basis for determining eligibility. They argued that it does not fully reflect the regulatory burden and operating costs faced by businesses, their financial resilience or profitability, the public value they provide, geographic circumstances, service provision or their role within the wider supply chain.

Respondents noted that establishments with similar throughput can operate under very different business models and cost structures. Some also argued that throughput does not distinguish between efficiency and utilisation of Meat Hygiene Inspector (MHI) / Official Veterinarian (OV) time and may disadvantage establishments that incur costs associated with unused official control hours, despite operating efficiently within local market constraints.

Respondents suggested using additional measures such as operating costs, profitability and / or operational efficiency instead of or alongside throughput when determining eligibility for financial support. Some respondents alternatively advocated headage-based charging at the rates set out in official controls legislation.

Some respondents emphasised the need to accommodate exceptional circumstances, such as changes in business model and new entrants to the sector. A small number also called for an appeals mechanism should an operator wish to query the throughput data used to determine eligibility or discount levels.

FSA response

As set out in the consultation, one of the aims of the revised model is to provide a support system that is simpler, more transparent and more predictable than the current arrangements, while targeting funding towards establishments that are less able to benefit from economies of scale. This requires a proportionate and consistent method of distinguishing between establishments.

The consultation identified support for throughput as a basis for determining eligibility. Throughput data are already collected by the FSA, can be verified against existing records and provide a transparent and consistent basis for determining eligibility without creating additional reporting requirements.

No single measure will capture every factor that may affect individual businesses. However, stakeholder engagement consistently indicated that approaches based on wider financial or operational measures would create additional complexity and administrative burdens for both businesses and the FSA.

The revised model is focused on addressing a specific issue: equalising regulatory burden. It is not intended to account for every factor affecting the costs or circumstances of individual businesses. Establishments with similar throughput may operate different business models and face different cost structures, whether as a result of commercial choices or factors outside their control, such as location or premises layout.

Using throughput as a proxy for size allows businesses flexibility in  how they organise their operations and utilise OV and MHI resources, without making those decisions a determining factor in eligibility support. The aim is to reduce differences in regulatory burden, which is best measured on a cost-per-animal basis, rather than to ensure that all businesses operate at equal cost or achieve the same commercial outcomes.

In this respect, the proposed approach captures many of the benefits associated with headage based models in terms of equalising the direct regulatory burdens, while avoiding the disadvantages associated with fixed statutory headage charging rates.    

The FSA also explored the use of official control hours as an alternative proxy for business size as the data are similarly available. Analysis indicated that this would produce outcomes broadly comparable to the proposed throughput-based approach. However, official control hours may fluctuate as a result of operational changes and efficiency improvements and therefore provide a less stable basis for determining eligibility.

Throughput was considered to offer a simpler, more predictable measure of business activity and to align more closely with existing legislative parameters.

The FSA does not propose a separate appeals process. However, businesses will continue to be able to raise queries regarding the data used to determine eligibility and discount levels through existing processes.

Summary

The evidence received does not identify a practical alternative that would provide a materially better balance between accuracy, transparency, simplicity, predictability and administrative burden.

The evidence received supports the following actions:

• recommend to the Board that throughput remains the basis for determining eligibility and discount levels within the revised model

4.4 Throughput time base

Consultation question: Which approach should be used to determine historical throughput: three-year rolling basis, previous year basis, or another approach?

The three-year rolling basis attracted clear support because respondents considered it better able to smooth seasonal variation, livestock availability, abnormal demand, supply disruption and one-off events. Those favouring a previous-year approach considered it to be more reflective of the current scale of operations, particularly where businesses had experienced recent changes in throughput. Some respondents used this question to request an appeals mechanism, which is considered in section 4.3.

FSA response

The strong preference expressed for a three-year rolling average supports the FSA’s view that this approach provides a more stable and representative measure of throughput by reducing the influence of short-term fluctuations, exceptional events and year-to-year volatility. It also avoids eligibility and discount levels being disproportionately influenced by a single atypical year.

The evidence received supports the following action:

• recommend to the Board that throughput is calculated on a three-year rolling basis for the purpose of determining eligibility and discount levels within the revised model

4.5 Throughput categories

Consultation question: To what extent do you agree or disagree with establishments being placed into red meat / large game and poultry / lagomorphs / small game categories?

Most respondents accepted the distinction between red meat / large game and poultry / small game, recognising that these sectors operate at very different scales. A small number sought clarification on the treatment of pigs, in terms of livestock unit (LSU) conversion, while others used this question to reiterate concerns about throughput as the basis for determining eligibility.

A small number of respondents also referred to headage-based approaches. In some cases, it was unclear whether this referred to using actual animal numbers (without LSU conversion for red meat / large game) as a measure of throughput or advocating for a different charging methodology.

Feedback relating to throughput as a proxy for business size and headage-based alternatives is considered further in section 4.3 and 4.1 respectively.

FSA response

The FSA notes requests for clarification regarding the classification of pigs and confirms that pigs are included within the red meat / large game category for the purposes of determining eligibility and discount levels (see discussion of LSU conversion rates in section 4.6).

The evidence received supports the following action:

• adoption of the two separate categories set out in the model and use these to determine separate threshold values

4.6 Throughput conversion rates

Consultation question: Are Livestock Units appropriate for red meat / large game, and are animal numbers appropriate for poultry, lagomorphs and small game?

In the context of throughput being used as a proxy for business size, there was overall support for the principle of using LSUs (for red meat/large game) and animal numbers (for poultry, lagomorphs and small game) to measure throughput.  

Several respondents raised concerns about the proposed conversion rates and called for alignment with the Agriculture and Horticulture Development Board (AHDB), animal welfare or other recognised methodologies to improve transparency and avoid confusion.

Particular concern was raised regarding the proposed LSU conversion rates for sheep, lambs, goats, pigs and large game. Respondents argued that assigning higher LSU values to some species would increase an establishment’s calculated throughput despite no change in the number of animals processed.

For establishments above threshold 1, this could reduce the level of discount received by moving them further through the taper or into a higher throughput category. Respondents considered that this could disproportionately affect mixed-species operators and businesses processing higher proportions of these species.

Some respondents supported further engagement with industry before finalising the conversion rates, while others argued that any methodology should align with EU, SPS and wider regulatory and policy frameworks, wherever possible.

FSA response

The FSA notes the support expressed for using LSUs and animal numbers to measure throughput, together with concerns regarding specific conversion rates, particularly for sheep, goats, pigs and large game, and the potential future regulatory alignment with EU approaches.

We recognise the benefits of using existing or more detailed LSU conversion rates. However, these benefits must be balanced against the burden of collecting additional information that is not currently gathered.

The LSU is being used to inform the creation of a proxy measure for business size, where both LSU values themselves and the relationship between throughput and business size are already approximations.

There is, therefore, a risk of introducing false precision, with significant additional administrative burden, without a corresponding improvement in the accuracy or effectiveness of the model.

An important consideration is the sensitivity of the relationship between throughput and official control hours to different LSU methodologies.

In response to consultation feedback, we examined a range of different LSU values and levels of granularity. Our analysis found that increasing the number of LSU categories had little effect on the correlation between throughput and hours used.

However, obtaining and maintaining the additional data required would significantly increase regulatory burden. Given the purpose of LSU conversion within the model, the FSA therefore considers the simplified conversion rates based on data already collected to be sufficient.

In reviewing responses, the FSA identified inaccuracies in Table 1 of the consultation document detailing livestock conversion unit set out in legislation. The corrected table is reproduced below. In developing the simplified LSU conversion rates, the FSA considered the figures in their correct regulatory context and used the correct LSU values when preparing the consultation proposals on which respondents provided feedback.         

Table 1: LSU conversion rates set out in legislation

Species	Conversion Rate
—	(LSUs)	LSUs
Regulation 1099/2009 (Animal Welfare) *	Regulation 2019/624 (Official Controls) *
Adult bovine animals the live weight of which is more than 300kg and Equidae	1	1
Other bovine animals	0.50	0.50
Pigs with a live weight of over 100kg	0.20	0.20
Other pigs	0.15	0.15
Sheep and goats	0.10	0.05
Lambs, kids and piglets of less than 15kg live weight	0.05	0.05
Small (< 100 kg live weight) Deer	N/A	0.05
Other Large Game	N/A	0.20

*Article 17(6) of Assimilated Regulation 1099/2009 (England and Wales) and Article 17(6) of Regulation (EU) 1099/2009 (Northern Ireland) / Article 7(2) of Assimilated Regulation 2019/624 (England and Wales) and Article 7(2) of Regulation (EU) 2019/624 (Northern Ireland).

Having considered the evidence, the FSA concludes that the simplified LSU conversion rates provide the clearest, least burdensome and most predictable approach for determining throughput within the revised support model. The methodology will continue to be kept under review as wider policy and regulatory developments emerge.  

Further to comments made in the engagement sessions concerning the treatment of wild game for the purposes of measuring throughput the FSA confirms that small wild game killed away from the game handling establishment in which it is subsequently processed will not be counted towards throughput (number of animals) and a similar approach will be adopted for large game as now reflected in the simplified LSU conversion rates in Table 2 below.

Table 2: Proposed LSU conversion rates for use in measuring throughput for the purposes of determining eligibility for support

Species	FSA Proposed Conversion Rate
—	(LSUs)
Bovine animals, Equidae	1
Pigs (including piglets)	0.2
Sheep and goats (including lambs and kids)	0.1
Large game	0.2
Large wild game killed away from the game handling establishment in which it is subsequently processed	0

The evidence received supports the following actions:

• recommend to the Board use of the conversion rates set out in the consultation
• keep the methodology under review and assess whether it is creating unintended  consequences for particular sectors

4.7 Insufficient historical data and mixed-category establishments

Consultation question: To what extent do you agree or disagree with the proposed approaches for insufficient historical data and for mixed-category establishments?

Direct questionnaire responses were relatively limited and mostly neutral, suggesting either broad acceptance of the principles or uncertainty about how the proposed arrangements would operate in practice.

Respondents generally supported the need for specific arrangements for new businesses, establishments that had undergone significant changes and situations where historical data may not provide a representative basis for determining throughput.

Some respondents sought greater clarity on how mixed-category establishments would be treated. Concerns were raised that the proposed approach could result in cross-subsidy between species or create unintended advantages or disadvantages for establishments engaged in diverse operations.

Respondents also highlighted the need for fair and flexible treatment in exceptional circumstances and requested clearer guidance on how the arrangements would operate in practice.

FSA response

The FSA recognises the need for arrangements that can accommodate new entrants, significant changes in business activity and situations where historical throughput data may not provide a representative basis for determining eligibility.

We also considered concerns regarding mixed-category establishments and the potential for cross-subsidy between species. The proposed methodology remains appropriate because it ensures that the discount applied reflects the category that most effectively represents the overall nature of the business.

This reduces the risk that support is disproportionately influenced by a secondary element of an establishment’s activities and provides a consistent basis for determining support where establishments operate across more than one category.

The evidence received supports the following actions:

• retain the provisions set out in the consultation for these circumstances

• develop additional guidance to support consistent implementation where required

4.8 Maximum discount level

Consultation question: To what extent do you agree or disagree with the proposed maximum discount level?

There was substantial support for a high maximum discount. Respondents who supported the proposal of 90% often linked justification to business viability, disproportionate regulatory burden and the value of smaller abattoirs to rural communities.

Some respondents raised concerns about how quickly support would reduce beyond the maximum threshold rather than concerns with the level of maximum discount itself. Those who answered the question negatively generally used the opportunity to argue that support should continue for larger establishments rather than challenging the maximum level.

While one respondent questioned whether a 90% maximum discount would be sufficient for some small or vulnerable businesses, another suggested a lower maximum level for micro establishments.

FSA response

The consultation identified broad support for retaining a maximum discount of 90% for the smallest establishments. Respondents generally considered this level necessary to address the disproportionate regulatory burden faced by smaller businesses while maintaining an appropriate contribution towards official control costs.

While some respondents suggested alternative levels of support, both higher and lower, these views were limited and did not identify a compelling case for changing the proposed maximum discount. The FSA therefore remains of the view that 90% provides an appropriate balance between targeted support and maintaining an incentive to manage official control resources efficiently.

The evidence received supports the following action:

• maintain the maximum discount level at 90%

4.9 Threshold 1

Question: To what extent do you agree or disagree with setting Threshold 1 at 1,000 livestock units per year for red meat / large game and 150,000 poultry / lagomorphs / small game per year?

Respondents generally welcomed the principle of maximum support for the smallest businesses, but many considered the proposed T1 too low. They argued that a threshold of 1,000 LSU was more representative of a micro-abattoir than a small abattoir and  would exclude some establishments that continue to face disproportionate regulatory costs, provide important local services and have not achieved the economies of scale assumed by the model.

Some respondents expressed concern about the impact of the proposals on small-medium and medium-sized businesses, arguing that establishments above T1 may still face disproportionate regulatory burdens despite receiving reduced levels of support. Some respondents also advocated a higher threshold or additional intermediate categories.

FSA response

The FSA selected T1 at this level because it reflects the throughput threshold used in legislation to define “low throughput” establishments (Article 7(1)(a) of Assimilated Regulation 2019/624 (England and Wales) and Article 7(1)(a) of Regulation (EU) 2019/624 (Northern Ireland). It is also consistent with provisions in official controls legislation relating the reduction of charges for such establishments (Assimilated Regulation 2017/625, Article 79(3). The threshold therefore aligns with the rationale for targeting support towards businesses least able to benefit from economies of scale.

The FSA notes the concerns that T1 may be set too low. However, setting it at this level is expected to result in more establishments receiving the maximum 90% discount than under the current banding system, increasing the level of support available to the smallest businesses.

The consultation also highlighted concerns that some small-medium and medium-sized establishments with throughput above threshold 1 continue to face significant regulatory costs. The FSA accepts that these concerns merit consideration and therefore examined the impact of higher T1 and T2 values.

Analysis indicated that adjustments to either threshold would provide additional support for businesses currently above T1. However, increasing T2 delivered greater benefits as support for businesses just above T1 increases automatically as the taper extends over a wider throughput range.

Given the benefits of retaining a clear legislative anchor for both of the thresholds (as T2 is defined as a multiple of T1) the FSA concluded  that any changes should focus on T2, where the effects are more substantial.

The evidence received supports the following action:

• retain T1 at the legislative low-throughput values

 4.10 Taper and Threshold 2

Question: Do you agree that a taper avoids a cliff edge, supports realistic growth and creates a fair balance between supporting smaller businesses and avoiding over-compensation?

Respondents generally supported the principle of tapering support between T1 and T2, recognising that it would avoid a sudden cliff edge reduction in support as throughput increased.

However, the taper and proposed T2 attracted some of the strongest concerns in the consultation.  Many respondents considered the proposed taper too steep and T2 too low.

Some respondents misunderstood how the taper would operate, assuming support would reduce through a series of stepped reductions similar to the current discount bands and expressed concern that this would create multiple smaller cliff edges.

Others were uncertain how support would change within the taper and whether relatively small increases in throughput could lead to disproportionate reductions in support.

Respondents argued that the proposed model could discourage growth and encourage businesses to remain below thresholds.

Many considered that establishments operating above the proposed T2 continue to face disproportionately high regulatory costs and had not achieved the economies of scale assumed by the proposed model.

Many respondents considered that the taper and proposed T2 did not adequately reflect the circumstances of small-medium and medium-sized establishments and argued that support should remain available further up the throughput scale.

The most frequently suggested alternative was to increase T2 for red meat to around 10,000 LSU, while others suggested introducing additional thresholds.

Several respondents also called for further business-level impact analysis before final decisions are taken.

FSA response

The consultation confirmed broad support for tapering as an alternative to a cliff-edge reduction in support. However, respondents raised significant concerns regarding the proposed rate of taper and the level of T2.

For the consultation, T2 was proposed at five times T1 (5T1) in order to maintain a clear legislative link and parity between the red meat and poultry models.

Stakeholder engagement and consultation responses suggested T2 at 5T1 was too low and could reduce or remove support from some establishments that continue to show the characteristics outlined in the rationale. The Board has previously recognised the potential diversity and benefits of some small-medium and medium-sized abattoirs, together with the need to avoid creating barriers to business growth.

Although limited quantitative evidence was submitted through the consultation, the FSA undertook further analysis and qualitative assessment with FSA Operations colleagues. This indicated that some businesses above the proposed 5T1 level for T2, and some near the lower end of the taper receiving relatively small discounts, continue to share characteristics associated with disproportionate regulatory burden and a more limited ability to absorb costs.

Many respondents proposed setting T2 at ten times T1 (10T1) for red meat establishments (10,000 LSU). The FSA modelled this scenario and found that it would further reduce differences in regulatory burden, retain support for a wider range of smaller and medium-sized businesses and did not over-subsidise businesses in a way likely to discourage growth.

The estimated direct effects of increasing T2 to 10T1 would be:

• 81 small and medium-sized establishments within the new taper receiving an increase in support compared to the previously proposed level of T2 set out in the consultation, including 18 establishments previously ineligible for support

• 25 businesses that would have experienced a reduction in support compared to this year under the consultation proposal will instead retain current levels of support or receive increased support

The FSA therefore considers that a higher T2 at 10T1 brings more businesses into scope of support and more effectively delivers the rationale and objectives of the revised model. However,  increasing T2 also increases the level of public funding required and represents a greater departure from full cost recovery.

The FSA therefore considers that T2 should be set at a value up to, and as close to, 10T1 as is affordable within available budgets during the current Spending Review period, with 10T1 used as the working assumption for future Spending Review bids.

The consultation also identified some misunderstanding of how the taper would operate. Under the proposed model, support reduces on a linear basis between T1 and T2 as throughput increases. It does not reduce through a series of bands, thresholds or cliff edges. The FSA will therefore undertake further communication work to improve understanding of how the taper operates in practice.

The evidence received supports the following action:

• recommend that T2 is set at a value up to, and as close to, ten times T1 as possible within available budgets within this Spending Review period

• recommend that, for future Spending Review bids, T2 at ten times T1 should be used as the working assumption

• undertake further communication work to ensure the effect of the taper is understood by businesses and stakeholders

4.11 Northern Ireland

Question: Should the basic model be integrated with discretionary support in Northern Ireland, and what assumptions should guide any support for larger Northern Ireland abattoirs?

Respondents consistently argued that the circumstances of the Northern Ireland meat sector differ materially from those in England and Wales in its structure, regulatory environment and competitive position and this should be reflected in the support model.

The core Northern Ireland themes were that large abattoirs serve many small and family-run farms, farm structure is fragmented, the sector depends on exports and cross-border trade, the island of Ireland creates distinct competitive pressures, and regulatory or post-EU-exit factors create additional cost and complexity.

These establishments play a critical role in supporting farm viability and maintaining routes to market for small producers in a way that is not fully reflected by throughput alone.

Respondents highlighted the additional transportation, logistics and regulatory costs associated with Northern Ireland’s geographic position, export profile and post-EU-exit trading arrangements.

They argued that these factors create additional operational complexity and costs not experienced to the same extent elsewhere in Great Britain, resulting in a structural disadvantage that should be recognised when determining support arrangements.

Some respondents also contended that any additional costs arising from reduced support would ultimately be passed through the supply chain to farmers or consumers.

Some respondents challenged the assumption that larger establishments require less support, arguing that throughput alone does not fully reflect their contribution to maintaining routes to market and supporting the wider agricultural sector.

For these reasons, there was broad support among respondents commenting on this issue for a Northern Ireland-specific approach. This included different thresholds, ministerial discretion, continued support for all establishments or greater flexibility to reflect the unique characteristics of the Northern Ireland meat sector.

FSA response

The consultation responses provided substantial evidence that the abattoir and farming sectors in Northern Ireland operate in a distinct regulatory and commercial environment and face some unique challenges. The evidence indicated that some of these factors may contribute to additional regulatory burdens for Northern Ireland establishments of all sizes.

Respondents also highlighted a range of wider commercial and structural challenges affecting the sector. These included lairage controls, low operating margins, reliance on export markets, transport costs, competition from Republic of Ireland establishments and costs associated with post-EU-exit trading arrangements.

Respondents argued that any charge increase would ultimately be passed through the supply chain, with potential implications for farmers and Northern Ireland’s rural communities.

The FSA recognises these concerns. However, many of the issues raised extend beyond the regulatory burdens arising from the delivery Official Controls.

Based on our analysis of the evidence received, the FSA will recommend that Northern Ireland Ministers adopt the same basic model as England and Wales.

However, we will also invite them to consider whether additional discretionary support should be provided in Northern Ireland within available budgets, to reflect the specific regulatory and wider sector challenges identified through the consultation.

The proposed approach would provide a mechanism through which support could be made available to Northern Ireland establishments, while allowing Ministers flexibility to determine the level of any support in light of available budgets, wider policy objectives and the legislative framework.

The evidence received supports the following actions:

• recommend that Northern Ireland Ministers adopt the same basic model as England and Wales

• invite Northern Ireland Ministers to consider whether additional discretionary support should be provided within available budgets to support establishments of all sizes and the scale of such support

• establish a mechanism through which support could be provided to establishments of all sizes, should Ministers wish to do so

4.12 Transitional arrangements and review

Question: To what extent do you agree or disagree with the principles of the transitional arrangements?

Respondents generally recognised the need for transitional arrangements but many considered the proposed transition too short or insufficiently evidenced.

Respondents called for a longer, predictable and transparent transition period supported by business-level impact modelling to provide greater certainty regarding future costs and mitigate risks to local slaughter capacity.

Some respondents also suggested that the arrangements should include flexibility for businesses experiencing significant changes in circumstances after support levels have been determined. Particular concerns were raised about introducing a new support system during a period of wider regulatory uncertainty, including potential changes associated with UK-EU SPS arrangements.

A small number of respondents also commented on the frequency with which thresholds and support arrangements should be reviewed, balancing the need for stability against the need to respond to changing circumstances.

FSA response

The FSA recognises the importance of ensuring an orderly transition to any revised support model. Consultation responses and stakeholder engagement highlighted concerns about sudden increases in charges, the potential for cliff-edge effects and the need for businesses to have sufficient time to adapt to new arrangements.

The FSA recognises the importance that stakeholders place on certainty and predictability when planning for future costs.

The detailed design of any transitional arrangements will be considered alongside wider meat charging developments, the costs of delivering official controls, available funding and relevant legislative or policy decisions.

The FSA will continue to keep the revised model under review to ensure it remains aligned with policy objectives and responds appropriately to future legislative, regulatory and operational developments.

The evidence received supports the following actions:

• consider transitional arrangements as part of the implementation of any revised support model

• keep the model under review to ensure it remains aligned with future policy, legislative and operational developments

4.13 Potential future elements

Question: What evidence supports or challenges future revisions, including potential treatment of unworked time and other elements?

Respondents were generally cautious about linking discount eligibility to compliance, quality standards or animal welfare outcomes, noting that existing inspection, audit and enforcement arrangements already address non-compliance.

Several respondents argued that changes to financial support should not be considered in isolation from wider questions about how official controls are delivered, funded and allocated across the sector.

Suggestions included modernising inspection delivery arrangements, making greater use of technology, reviewing Statements of Resources and increasing transparency in the calculation and allocation of charges.

A recurring theme was the need to explore opportunities for greater efficiency in the delivery of official controls.

Suggestions included reviewing the deployment of Meat Hygiene Inspectors and considering alternative approaches to service delivery where appropriate. Respondents emphasised that any efficiency measures should not compromise food safety or place additional burdens on business.

Several respondents continued to advocate the use of animal numbers (headage) as an alternative basis for determining support.

FSA response

The FSA recognises that stakeholders wish to see a more efficient, transparent and sustainable system for the delivery and funding of official controls. Respondents put forward a range of suggestions including use of technology, which have been noted and will help inform future work.

Matters relating to wider reform of official controls and charging arrangements, including those arising from the recent Judicial Review, fall outside the scope of this consultation and are being considered separately.

Any future reforms will need to maintain food safety, consumer protection and regulatory assurance, while taking account of the costs of delivering official controls, available funding and relevant legislative and policy developments.

The evidence received supports the following actions:

• note the suggestions received regarding future reforms to official controls and charging arrangements

• consider this evidence as part of any future work in these areas

• continue to assess wider reforms separately from the revised support model

4.14 Impact evidence

Question: What evidence was provided on the impacts of the model, the value of Threshold 2, familiarisation, consumer impacts, administration, wider economic impacts and other impacts?

With regards to the proposed threshold values, most respondents who commented on the thresholds considered that a T2 value of 5,000 LSU would place some smaller abattoirs under increased financial pressure.

Respondents suggested that this could contribute to a range of potential impacts. These included increased operating costs, reduced profitability, lower farm-gate prices, loss of local slaughter capacity, business closures, reduced consumer choice, reduced investment, increased sector consolidation and weaker supply-chain resilience.

Particular concern was expressed about the implications for niche, rare and traditional livestock breeds, where access to suitable slaughter facilities may already be limited. Some respondents also highlighted potential impacts on specialist markets, including private kill and religious slaughter services.

Regarding familiarisation costs, respondents expressed mixed views. Many either did not provide a definitive view or indicated that requirements would vary depending on the size and structure of the business.

Those who commented suggested that a wider range of staff may need to review guidance than originally envisaged and that familiarisation could require more time than estimated because of operational complexities.

Views were similarly mixed regarding the potential impact on consumers. Many respondents considered that additional costs arising from the reforms could be passed on through the supply chain, ultimately resulting in higher prices for consumers.

Some also suggested there could be indirect effects on consumer choice or product availability if businesses changed their operations in response to increased costs.

Northern Ireland respondents considered these pressures particularly significant because of export dependence, competitive pressures and additional regulatory burdens.

However, respondents generally provided little evidence of the scale or likelihood of these impacts and the evidence received was largely speculative.

In relation to administrative impacts, responses generally anticipated some increase in time associated with monitoring and record-keeping requirements under the proposed discount system. However, few respondents provided quantifiable evidence regarding the scale of any additional burden.

Respondents identifying wider impacts frequently highlighted concerns that increased regulatory costs could place additional financial pressure on businesses, particularly smaller establishments. Potential consequences identified included effects on competitiveness, profitability, investment decisions and business resilience.

Several respondents also raised concerns about potential indirect impacts on supply chains and the wider food sector.

Respondents also identified potential benefits associated with the proposed model, including greater predictability of support, a simpler approach to annual discount determinations and a clearer relationship between throughput and support levels.

However, many respondents emphasised that any such benefits should be balanced against the potential impacts on businesses currently receiving higher levels of support under existing arrangements.

Some respondents argued that greater transparency in charging arrangements and improvements in the efficiency of official controls should be explored alongside any changes to the discount system.

FSA response

The consultation responses informed both the Impact Assessment and additional analysis undertaken following consultation. Particular consideration was given to concerns regarding business viability, local slaughter capacity, supply-chain resilience, rural communities and the potential impacts on farmers and consumers.

Consultation responses also informed further operational appraisal and modelling of alternative threshold values.

Respondents challenged a number of assumptions used in the Impact Assessment. Where evidence supported amendment, these assumptions were reviewed and updated.

For example, the assumed familiarisation time was increased from 30 minutes to two hours to better reflect stakeholder feedback on the time businesses required to understand and implement the revised model.

As set out in section 4.10, additional analysis supported increasing the proposed value of T2 to reduce potential impacts on smaller and medium-sized establishments.

The FSA carefully considered the wider impacts, including potential consumer impacts identified by respondents. However, these were generally indirect in nature and could not be robustly quantified or monetised. Consequently, they have not resulted in further changes to the Impact Assessment or the recommended model.

The evidence received supports the following actions:

• update the Impact Assessment where consultation evidence identifies a robust basis for doing so

• reflect consultation evidence in ongoing assessment of the potential impacts of the revised model

• retain the recommended model, subject to the changes described elsewhere in this response document

4.16 Communications with stakeholders

Question: Would respondents be happy for future meat-charging communications to be sent electronically, where legally possible?

There was broad support for electronic communication. Several respondents supported it without further comment. One wider point raised was that communication should be accompanied by transparent and understandable charging information so businesses can check the basis of their invoices, charges and discounts.

FSA response

Support for the use of electronic communications is noted and the FSA will take forward the necessary implementation arrangements, including engagement with businesses.

The FSA also notes the comments received regarding transparent and understandable charging information and will work with industry to improve this as part of wider work on charging arrangements.

5. Next steps

The consultation responses, stakeholder engagement and further analysis undertaken by the FSA have informed recommendations that will be presented to the FSA Board on 16 September 2026.

Subject to Board agreement, the recommendations will be provided to Ministers in England, Wales and Northern Ireland for consideration alongside the Impact Assessment and supporting evidence.

If approved, the FSA will work with Governments and stakeholders on implementation of the revised support model, including further communications and guidance to support understanding of the new arrangements.

The FSA will also continue work relating to charging transparency, efficiency and wider official controls reform through separate programmes of work.