HC 830 The implications of the Welfare of Laying Hens directive for the egg industry

Written evidence submitted by the UK Egg Producers Association Ltd (UKEP) (EGG 17)

 UKEP is the producer organisation representing the smaller to medium-sized producer/retailers who are responsible for their own marketing and do not supply through the large packers.

Because of this, their contact with their customers is on a more local and personal basis and they are, to some extent, cushioned against some of the vagaries of the price swings of the major packers.

UKEP has its own, widely-recognised and accepted, health and welfare assurance scheme - "Laid in Britain".

Two years ago, many of our members stated that they would not be changing to any other production system and would, in fact, be going out of production at the end of 2011, with a total bird loss of some 3/4 million.

Since that time, some have gone out of production already and a few more will go by the end of the year. However, because many others decided in the end to actually change to another system and continue, the total loss will only be of the order of 136,000 birds. The majority opted for enriched cages.

As a result of over-confident promotion by the major retailers and packers on the free-range front, there are currently far too many birds in lay in that system for the market. Consequently, free-range eggs are being 'hawked' at below cost of production and this is making life more difficult for cage egg producers, where market price is already tight compared to production price.

Recent large increases in feed cost have also played a significant part in cost of production. With feed being £100/tonne more than 1 year ago, this represents a 20p/dozen extra cost of producing a dozen eggs.

Current feed prices of some £280/tonne gives a feed alone cost of production of 55p/dozen eggs.

Those producers who have invested in enriched cages have done so at a per bird place cost of some £14. If this is depreciated over 10 years, this represents an added cost of 5.6p per dozen over what it cost to produce the same eggs in conventional cages.

This is true only if the enriched cages could be fitted into the existing houses. If not, the cost would double.

However, in spite of this extra cost, the market return will be the same as if the eggs were still being produced in conventional cages. There is no premium for enriched cages.

This, in spite of the welfare of the birds in enriched cages fulfilling the "five freedoms" desired by FAWC, RSPCA and others, some of whom still set their faces against enriched cages.

Production has been shown to be as good as, if not better than, in conventional cages and mortality is even lower, and considerably lower than alternative systems of production.

Some of our members have had "open days" for their customers to see the birds in enriched cages with nothing but positive feedback.

Producers changing to enriched cages have also had to pay the penalty of some £2-£3 per bird while the unit was empty and no egg income was being realised.

Our members, like others in the UK egg industry, will be 100% compliant with EC Council Directive 1999/74/EC by 1st January, 2012.

We, therefore, find it galling that an estimated 28% of the cage production in the rest of the EU will still be in conventional cages at that date and that there appears to be no action on the part of the Commission to take IMMEDIATE action against those not complying.

We have pushed for a Code 4 to be applied to eggs from enriched cages. We were astonished at the excuse for refusing this request by the Commission in that "it was likely to cause confusion to the consumer".

If the consumer can already distinguish the difference between 0,1,2 and 3, it is insulting to suggest they are incapable of understanding a further code, especially when the system of production could be clearly explained to them.

As a result, any egg, or egg product, coming from other EU countries labelled with Code 3, will not be identifiable as coming from legal (enriched) or illegal (conventional) cages.

This is even more true with egg products than shell egg. Whilst manufacturers may ask egg product suppliers if the product is from compliant cages, what tangible guarantees can be given?

A significant amount of egg product used in the UK is in the form of powder. As no powder is produced in the UK, all this will be imported, possibly from non-compliant cages in the EU, and certainly from third countries.

There are now strong suggestions that the Commission will offer a "transition" stage for those countries who have not fully complied by January, 2012, or will offer grants to help with conversion.

We find both of these suggestions to be totally unacceptable.

Our members find it hard to swallow that the government is prepared to give £37 million to help agriculture in developing countries, but seem unwilling to protect UK egg producers against unfair competition.

Added to this, the Valuation Office are now contemplating changing rating of the egg packing section of units from agricultural to business rates if a producer packs eggs for others.

Many of our producers have formed loose groups for mutual help and cost cutting, wherein, one of the members packs for all. The Valuation Office state that in such circumstances, they must form one company, with more added expense at a difficult time and a factor not to be repeated in the rest of the EU.

Should certain countries not be fully compliant by 1st January, 2012, then we insist that NO egg imports, shell or product, be accepted into the UK, even from enriched cages, until such time as that country can PROVE total compliance.

Our producers deserve no less.

February 2011