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News, Blogs & Press Releases » Free-range eggs consultation: our response

Free-range eggs consultation: our response

A tray of free-range chicken eggs.

The Vegetarian Society has now responded to the government’s consultation on free-range eggs. Please read our response below.

We have disagreed with the proposal to remove the 16-week derogation period. This would allow eggs that are from laying poultry that are subject to a housing order to be labelled as ‘free range’ throughout the duration of an order.

In preparing a response to this consultation, we surveyed over 200 of our members and 77% disagreed with the proposed legislative change. Thank you for sharing your insights with us.

The ‘free-range’ standard, while not perfect in terms of animal welfare, is generally recognised by the public as an ethical welfare label and has led to
increasing purchase and consumption of free-range eggs. Indeed, a 2015 survey suggested that 80% of shoppers actively look for the label when buying
eggs.

This has driven up UK production of free-range eggs, with around 70% of retail sold eggs being free-range, up from 32% in 2004.

Allowing eggs to be labelled as free-range when hens have been kept indoors for extended periods beyond 16 weeks risks damaging the free-range brand: a brand which, based on the information above, has clearly driven up standards within the UK egg industry.

If public trust in ethical and sustainable brands and logos is to be retained, then they must not be watered down. The government’s own Food Standards Agency is clear in this respect, stating on its website:

“Food authenticity is when food matches its description. Labelling is regulated to protect consumers who should have the correct information to make confident and informed food choices based on diet, allergies, personal taste or cost. Mislabelled food deceives the consumer and creates unfair competition with manufacturers or traders. Everyone has the right to know that the food they have bought matches the description given on the label. Part of our role is to help prevent mislabelling or misleading descriptions of foods. The description of food refers to the information given about its name, ingredient, origin and processing.

We remain concerned that having open-ended time limits for birds to be kept indoors while eggs continue to be labelled as free-range could damage consumer confidence in the label; particularly, as the government’s consultation is clear that avian flu outbreaks could be with us for many more years to come. A growing awareness that ‘free-range’ may not in fact mean ‘free-range’ in the minds of the consumer could lead to them buying cheaper barn or caged eggs, instead of paying a premium for a ‘free-range’ label they cannot trust.

We contend that there is a consequent risk that egg producers may then adapt their operating models away from free-range, prioritising barn or caged eggs, if that is where consumer demand is focused. Particularly, when operating costs are rising and any marginal cost savings can help with profitability.

Our members have also expressed concern that some egg producers could seek to take advantage of the extended time periods and uncertainty of the
veracity of the free-range label and seek to retain birds indoors, beyond required time restrictions, if this was easier to operate with reduced costs, all
while still taking advantage of a free-range label. We would be concerned as to whether sufficient capacity exists to check that all egg producers have
reverted back to free-range operations (post avian flu restrictions).

Instead, we would prefer that government worked with the egg industry to prioritise hen welfare, in terms of reduced flock size, enhanced enrichment
and provision of netted outdoor space as a means of minimising avian flu risks, rather than the regressive measure of housing birds indoors for a substantial proportion of already limited working lives, with most laying hens slaughtered between 18 and 24 months.

We also suggest that government works actively with retailers to ensure that the costs of ethical egg production are supported by major supermarkets
in particular. There is clearly concern amongst free-range egg producers that supermarket pricing of eggs doesn’t adequately cover the cost rises being
experienced by farmers.

If farmers start to leave the industry or revert to production of barn or caged eggs due to increasing costs of meeting free-range standards, then when
combined with any potential loss of consumer confidence in the ‘free-range’ brand (due to the proposed changes in AI time periods for confinement), we
risk seeing a dramatic loss of hard-won welfare standards built up over many years.

Previously the public have demonstrated a willingness to pay more for milk, in support of declining dairy farmer incomes. While we are mindful that food inflation continues to impose substantial additional costs for consumers, we do believe there is scope for a public debate about food pricing and fairness in the
value chain, particularly around ‘free-range’ eggs and the public’s willingness to pay a little more to preserve the integrity of the free range label and prevent any risk of a decline in welfare conditions for hens.

In terms of the alignment of UK standards with EU and NI standards, we suggest that post-Brexit trading arrangements should allow us to require that
imports adhere to higher welfare standards, rather than simply aligning with other third party standards, even those from the EU.

Importers should therefore be required to clearly label eggs for import to the UK as barn or caged and not free-range (if hens are housed inside for longer than 16 weeks). This could be done using the same lower cost techniques of shell printing with the appropriate production code and stickering of packaging.

In this way, government can demonstrate that the UK’s trade freedoms can be exercised in support of maintaining animal welfare standards, while requiring that importers follow the same labelling requirements as UK producers, which will ensure a level playing field but one which prioritises animal welfare and consumer confidence.

Finally, our own Vegetarian Approved trademarks, which are displayed on thousands of products sold on the UK market, require that any eggs used in
product manufacture are free-range. We would be unable to guarantee the veracity of any free-range label and this could damage consumer confidence
in our own vegetarian trademark. 75% of vegetarian and vegans look for our trademarks when shopping. We are concerned that damage to the ‘free-range’ label could therefore also damage the integrity of our own vegetarian trademark, which has been in existence since 1969.

To date, housing orders have only ever been in place for limited time periods. We believe the proposed alteration to the Egg Marketing Standard Regulation could confuse consumers to a large extent.

We maintain that the risk of confusion is best mitigated by not adopting this proposal and maintaining the current time limit of 16 weeks. Where confinement extends beyond 16 weeks, it is right that consumers are informed through shell printing of the appropriate production code, plus on pack and point of sale messaging. We believe this represents a fair balance between the financial impact to egg producers and preserving the trust of consumers. We believe that any increased costs to producers from changes to shell printing or packaging could be supported by fairer supermarket pricing and increasing profit share with farmers.

There is clearly scope for low cost measures including carton stickering and point of sale messaging to help explain that eggs from housed birds (due to
AI outbreak) are temporarily not free-range (when the time limit of 16 weeks is breached). Government could support public understanding through a
public information campaign.

The government’s own guidance issued in early 2023 makes clear that there is scope for limiting any extra costs to producers and packers and the importance of retaining consumer confidence in the ‘free-range’ brand.

We suggest that this is a clear example where UK devolved administrations need to work together to ensure that the egg industry has a level playing field
across the UK, while also ensuring that the Windsor Framework does not permit eggs imported from NI to conform to lower standards.

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