At the end of October we informed members of a Defra consultation on exclusions to the requirements of the Gangmaster Licensing Act.

The consultation set out the four options for activities that would be exempt from the need for the suppliers of temporary labour to be licensed, making a distinction between activities that could be defined as “initial processing” or “secondary processing”.

The FPC has always taken the view that the licensing arrangements should be as broad as possible to ensure that unscrupulous labour providers have as little room as possible to operate.

Consequently we submitted the recommendation that the fourth option - which stated there should be no exclusions for processing and packaging of food and agricultural products - be adopted.

It is our understanding that “initial processing” and “secondary processing” activities are often carried out on the same premises, so it is not realistic or practical to make such a distinction.

We believe that for the sake of avoiding the creation of loopholes and for the sake of enforcement of the legislation, there should be no exclusions to the requirements of the Act.

This has been the position adopted by almost all the members of the Temporary Labour Working Group, which has included major retailers, trade unions and labour suppliers.

If you would like a copy of our response to the Defra consultation, please contact the FPC office.