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Milk Quotas - FAQ

Approved Laboratories
Confiscations
Conversions
Direct Sales
Trader Registration
Transfers
Purchaser Approval
The Thomsen Judgement
Milk Production Under Production/Share Farming Agreements
The New Butterfat Adjustment Rules

Approved Laboratories


Which laboratories can a purchaser use for butterfat testing?

Purchasers can only use those laboratories that are approved by RPA. We will have examined their testing procedures, record keeping etc to ensure that they are complying with the appropriate requirements. A list of the approved laboratories can be obtained by contacting our Helpline.


How can a laboratory become approved?

Laboratories can apply for approval by contacting our Helpline. The approval process for laboratories can take up to of six months to complete. During this time purchasers will need to ensure that an approved laboratory is testing their milk.


Confiscations


How can I avoid confiscation of my milk quota?

You need to be a producer during the quota year or your quota will be confiscated. If you hold Direct Sales quota you must also make an annual declaration of sales by returning form MQ/15, or your Direct Sales quota will be confiscated.


What happens if my quota is confiscated?

Confiscated quota can be restored to you, or a new occupier, on request if the land to which the quota was attached is returned to milk production within 2 years of the start of the quota year in which the quota was confiscated.


I have temporarily ceased milk production, what must I do with my quota until I start again?

It really depends on how long you are ceasing production for. Please contact the Milk Quotas Helpline (01392 266466) with the details of why you are ceasing production, and for how long, and we will advise the action you should take.


Conversions


What is a conversion of quota?
A milk producer may convert their unused quota either permanently or temporarily from wholesale to direct sales and vice versa, if they have a change in their marketing requirements. Both types of conversions must be requested by a producer. The RPA can not automatically convert the quota for you.

What is a Temporary Conversion of quota?
A temporary conversion applies for one quota year only and must be needed because you have either made wholesale deliveries or direct sales in excess of quota. Only unused quota can be converted. For more information regarding this type of conversion, please contact our Helpline.

When can I request a temporary conversion?
A temporary conversion can only be requested on an MQ/15 after the end of the quota year in which you want the conversion to take place. If you hold direct sales quota, you will automatically be sent an MQ/15, however, if you do not hold any direct sales quota, you must call our Helpline, at any time within the quota year, and ask that your name be added to the list of producers who require an MQ/15 to be sent to them at the end of the year.

What is a Permanent Conversion of quota?
Producers can apply to the RPA to permanently convert from one type of quota to another. Only unused quota can be converted and in some instances, restrictions on quota movements for the remainder of the quota year will be imposed. To convert the quota you must use the converted quota on your own holding, and it must be needed because your marketing requirements have changed e.g. you have increased, or plan to increase, your direct sales or wholesale deliveries

When can I request a permanent conversion?
To request a permanent conversion you will need to complete an MQ/6 application form, which you can download from the RPA website (www.rpa.gov.uk / milk quotas / forms), after 1 August. Your completed application must be submitted to the RPA by the deadline of 31 December of the quota year in which you want the conversion to take place. For more information regarding this type of conversion, please contact our Helpline.

Are there any restrictions when I carry out a Permanent Conversion?
In some instances ‘Yes’. When you carry out a permanent conversion, you cannot lease out or transfer without land any quota of the type to which you have converted unless you applied for and received a temporary conversion in the previous year.

How long do the restrictions apply?
The restrictions will apply from the operative date of the conversion until the start of the following quota year.


Direct Sales


What are direct sales?
‘Direct sales’ cover the production, processing and marketing of milk and/or milk products within a single legal entity. The term ‘marketing’ of milk and/or milk products includes milk which is given away for consumption off the holding whether by humans or animals. However, direct sales also covers milk or milk products which are sold on the holding, e.g. in a farm shop or café. If you have any doubts as to whether your milk production qualifies as direct sales you should contact our Helpline on 01392 266466.

Do I need to get RPA approval?
There is no RPA approval procedure to become a direct seller of milk or milk products. However, anyone processing milk must be licensed to do so by DEFRA – contact your local Environmental Heath Office for further details.

Do I need to get additional quota to cover my direct sales?
You will either need to convert some of your wholesale quota to direct sales quota, or buy extra quota for your direct sales , there are two types of quota: ‘wholesale’ and ‘direct sale’. As a direct seller, in order to avoid incurring a levy bill if the UK is in a direct sales levy situation at the end of the quota year (as it has been in the 03/04 and 04/05 quota years) you must ensure you hold sufficient direct sales quota on 31 March to cover all direct sales that you have made within that quota year.

In order to cover your direct sales you can either lease/purchase direct sales quota, or request a temporary conversion of any clean wholesale quota you hold at the end of the quota year. You can only request a temporary conversion on your annual declaration (see below)

Do I need to let the RPA know how much direct sales I do?
Yes, if you make direct sales, or hold direct sales quota at any time during the quota year, you are required by law to submit an annual declaration (form MQ/15) to the RPA. At the end of the quota year an annual declaration will be issued to all producers who held direct sales quota within that quota year. If you make direct sales but do not hold any direct sales quota you will not automatically receive a form and you must therefore call our Helpline to ask for an MQ/15 to be sent to you.

I have leased in Direct Sales quota, which I want to use to cover my wholesale deliveries. Do I have to submit a direct sales annual declaration?
Yes. You will be liable to a penalty charge of 100 Euro (currently just over £80) if you fail to submit the form before the deadline of 14 May. In addition, if the form is sent in too late you will not be able to apply for a temporary conversion to wholesale quota which you will need to cover your excess wholesale deliveries.

I make direct sales but do not hold direct sales quota, do I need to let Milk Quotas know?
Yes. You must contact the RPA to notify them you are making direct sales but do not hold any direct sales quota. This will ensure you are registered correctly and receive the annual declaration at the appropriate time.

I am thinking about separating my production and processing businesses, will this make a difference to Milk Quotas?
Yes, it will. As soon as you separate your business in any way, regardless of whether or not you own both units, your status as a direct seller will cease.

At that time, as a milk producer, you will be classified as a wholesale producer and the processing business will become a milk purchaser, for which you must gain RPA approval. For further information on this please contact our Helpline.

Is ‘Contract Processing’ counted against Direct Sales quota or Wholesale quota?
Where milk leaves the holding for processing, under contract, at another premises and is then returned to the holding for sale (‘Contract Processing’), the milk counts against Wholesale quota only and cannot be declared as Direct Sales. The company that processes the milk must also be registered with the RPA as an approved first purchaser of milk. For further information regarding contact processing, please call our Helpline.


Trader Registration


I am changing my trading title, do I need a new registration number?

You must tell us if your trading title changes, but you may be able to keep the same registration number if the same business is continuing (e.g. if one or more of the original partners are continuing the business or you are keeping the same company registration number). If you are setting up a Ltd. Company you will need to re-register with the Rural Payments Agency and transfer any quota applicable to the new registration number.


Transfers


How can quota holders transfer/sell their milk quota?

Quota holders can transfer their milk quota by applying for either a permanent transfer or a temporary transfer (lease).


What is the difference between a permanent transfer and a temporary transfer?

When quota is temporarily transferred (leased), it remains with the transferee (lessee) until the end of the quota year, and reverts to the transferor (lessor) from the start of the nest quota year. When quota is transfered permanently, it does not return to the transforer, but remains with the transferee.


What is a transfer of quota with land? How is quota transferred with land?

Quota will be permanently transferred when there is a change of occupation of the land to which the quota is attached, e.g. if a farm is sold or inherited, or at the beginning or end of a tenancy.


Can I transfer milk quota without land?

Yes, provided the transferee is a milk producer. The quota will be removed from the transferor'd holding and attached to that of the transferee. The same Milk Quota form (MQ/1) is used for transfers with land and transfers without land.


Who can permanently transfer/sell milk quota?

Quota holders can apply to permanently transfer their milk quota. However,

they must obtain consents of all the parties who have an interest in their holding (i.e. a mortgagee, landlord etc) before permanently transferring quota.


Who can temporarily transfer quota?

Only a producer can lease milk quota out.


Who is a “producer”?

A producer is someone who is producing and marketing milk, or preparing to do so in the very near future.


What is meant by "beginning milk production in the very near future”.

Producers in this category will be required to produce evidence of their state of preparedness to begin milk production. This will require more than the submission of a business plan, but of actual steps taken. The RPA will be looking for evidence of the holding, forage, milking facilities and arrangements to acquire the milking herd. The RPA will apply a restrictive interpretation to this category of producer. Whilst, therefore, no time limit is mentioned, the RPA – as a rough guide – would not expect any proposals to be submitted for consideration which are not likely to be translated into active milk production more than a few months in the future. The RPA would expect that producers in this category would have so prepared as to be on the verge of entering milk production.

As a guide, the RPA would not regard the following situations as satisfying the definition of this category.

a. Those with no land (holding);

b. Those with land (holding), but no milking facilities;

c. Those with land (holding) and milking facilities, but no animals;

Of course, the acquisition of quota (individual reference quantity) is essential for a producer and there may be other instances than those examples listed above where the RPA would not be satisfied that the person satisfied the requirements to be regarded as a producer.

Essentially, therefore, the RPA would expect persons in this category would most definitely not just be in the planning stage but would need to take just one more step, such as the delivery of milking animals already purchased, to enable them to start actual production.

It will assist the RPA in making a determination of whether a person can be regarded as a producer to have a fully detailed and frank account of the position reached and what still requires to be done.


Can I sell quota that I have leased out in the current quota year?

Yes, but it must be transferred as used quota.


Does the RPA accept signatures of a third party (i.e. a quota agent) on a milk quota transfer form?

Yes, provided we have a valid letter from the registered quota holder, authorising the third

party to sign the form on their behalf.


What is the deadline for submission/receipt of milk quota transfer forms?

A list of form submission/receipt deadlines can be accessed via the Important Dates link under the Related Links heading.


Purchaser Approval


How do I apply to become an approved purchaser of milk?

If you wish to apply for approval as a purchaser, you will need to complete form MQ/11. This will include giving details of your processing premises, hauliers and the laboratories that will be used to test milk samples. A copy of the form can be obtained by contacting our Helpline.

Approval is conditional upon your ability to demonstrate that your business has a sound financial trading base by providing a minimum of 2 years accounts, or similar information. Approval will not be given where there is a prior history of offences under any European or Government funded scheme.

In addition, before approval is given, we will arrange for visits to be made to the premises where you maintain your records and to the laboratories you intend to use for the analysis of milk samples to ensure that they meet our standards. You should allow at least a month from the date of your application for these visits to be made.

What conditions do I need to fulfil to become an approved purchaser?

By signing an MQ/11 form you will be agreeing to comply with the conditions detailed in the schedule attached to the form. These cover:

  • submission of an annual declaration of milk purchases
  • submission of monthly returns form MQ/12
  • record keeping and the retention of these records for inspection
  • the sampling of milk and the analysis of the samples
  • the calculation of your producers delivery figures
  • provision of information to RPA and your producers
  • meeting deadlines
  • payment of levy

Full details of the conditions you must fulfil are given in the RPA milk purchaser’s handbook that can be obtained by contacting our Helpline.


How does a producer know if a purchaser is approved?

All approved purchasers have an RPA approval letter and must supply details of that registration on request. To ensure that the approval is still in force, producers are advised to contact RPA for confirmation.


What happens if a purchaser buys milk from a producer but is not approved by RPA?

The milk will be regarded as sold outside the quota system. The full rate of levy will be payable on each litre delivered to the unapproved purchaser by the producer. Both producer and purchaser will be leaving themselves open to prosecution for failing to comply with EU and domestic legislation.


The Thomsen Judgement


What was the Thomsen judgement ?
It was a case heard in the Eurpean Court of Justice (ECJ) in 2003. The ECJ's ruling confirmed that non-producers may only transfer in quota if they are about to start production or if thay are taking over a holding to which quota is attached. In the second case, they can only hold on to the quota for a very short time, to enable them to transfer the quota on to an active producer. A second consequence of the judgement was that non-producing quota holders (NPQHs) may not lease out quota, as the EC Regulations state that only producers may do so.

Milk Production Under Production/Share Farming Agreements


Information relating to this topic can be accessed via the following link.

The New Butterfat Adjustment Rules


Information relating to this topic can be accessed via the following link.