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

Written evidence submitted by The Co-operative Group (EGG 18)

1) Executive Summary

1.1 High animal welfare standards are an integral part of our food business. Over the last 15 years, we have been a leading retailer in driving forward better standards in egg production, even when technically illegal. We were the first retailer to label eggs as "intensively produced", because we wanted customers to be aware of what they were buying, in recognition of the low welfare of intensive production. We also only use free-range eggs as an ingredient. We are aware that the UK egg production industry will be compliant with the Welfare of Laying Hens Directive by 1 January 2012, but have concerns that other producers in other Member States will not be compliant. This needs to be tackled by the appropriate authorities.

2) About The Co-operative Group

2.1 The Co-operative Group is a business owned by over six million customers, not a small group of shareholders. Becoming a Co-operative Group member gives people the right to share the profits of the business and exercise their democratic control upon it. We have core interests in food, financial services, travel, pharmacy, funeral and farms. Our annual turnover is £14 billion, we employ 120,000 staff and operate over 5,000 retail trading outlets serving more than 20 million customers a week.

2.2 We are the fifth largest food retailer in the UK and the UK’s largest farmer. We have over 3,500 food stores with a presence in every postal area in the UK. We believe that customers should have access to high quality and affordable food that is produced in a sustainable way and marketed in a manner they can trust, thereby combining value with values.

3) Our approach to animal welfare

3.1 High animal welfare standards are an integral part of our food business. This is a policy strongly supported by our members through a Food Ethical Policy (Appendix A), which prioritises animal welfare. Our animal welfare credentials incorporate policies on eggs, meat, fish and also a long-standing opposition to animal testing for household and beauty products. We have been publicly recognised for our policies on these issues by organisations such as the RSPCA (Royal Society for the Prevention of Cruelty to Animals), CIWF (Compassion in World Farming) and BUAV (the British Union for the Abolition of Vivisection).

4) Our policy on shell egg sourcing and sourcing of liquid eggs

4.1 Like most retailers, all of our eggs are produced to the standards required by the "lion code" a farm assurance system for the egg industry. But in 1994, we worked with the RSPCA to develop the Freedom Food standard, and became the first national retailer to sell RSPCA-accredited Freedom Foods when we launched "Freedom Food Free Range" eggs.

4.2 In 1995, we were the first retailer to label eggs as "intensively produced", because we wanted customers to be aware of what they were buying, in recognition of the low welfare of intensive production. This was a technically illegal policy, but subsequently the law was changed to reflect this.

4.3 We only source shell eggs, which are reared on farms in the United Kingdom. In September 2006, we banned the sale of shell eggs from caged hens under the Co-operative brand. Since then, all Co-operative Brand shell eggs have been produced from Freedom Food, Free Range or Organic flocks.

4.4 We used to sell independently-branded eggs from caged hens in certain stores . But in 2008 we had stopped selling shell eggs from caged hens in any store in the United Kingdom.

4.5 In 2010, following a number of years’ work, we moved to using only free-range eggs as an ingredient. This means that all egg ingredients and derivatives of egg used in Co-operative own-brand products have been replaced with free range egg across the entire product range.

4.6 We were the first retailer to remove the artificial colour, Canthaxanthin, from the diets of chickens. We have now removed all artificial colours from the diets of our laying hens. The feeds which our suppliers use for our laying hens contain grass meal and marigold extract which help make a brighter yolk.

5) The implications of the Directive for the egg production, food processing and manufacturing sector

5.1 We believe that the EU egg industry has had adequate time to prepare for the introduction of the legislation given the long lead-time to 1 January 2012. We have concerns that not all producers in the EU will comply with the ban by the 2012 date and as a result, around 29% [1] of EU egg production is forecast to be "illegal" by 1 January 2012. But the adequate lead-times meant that egg producers should have been planning for the impact of this legislation and re-specifying their production systems accordingly.

5.2 We are aware that UK processors have invested around £400 million to comply with the legislation. The UK industry, which has 80% self-sufficiency in egg production, will be placed at a disadvantage if other producers in other Member States are not compliant. UK self-sufficiency in egg production has declined in the last decade, and if non-compliance is not dealt with, it will have a detrimental impact on the competitiveness of UK egg producers and could further reduce self-sufficiency levels.

6) How the European Commission plans to ensure compliance with the Directive and DEFRA support for the egg and egg products industry

6.1 Close to a third (as above) is a high level of non-compliance with the Directive. The Commission needs to decide exactly how this issue of non-compliance will be dealt with because the legislation will render the sale of these eggs and egg products illegal. A derogation is not good enough and rewards non-compliance. We would rely on DEFRA to make representations to ensure that the UK egg production industry is not left at a competitive disadvantage because of its compliance in comparison to other producers in other Member States.

February 2011