Is fairer food labelling reasonable?

Defra’s recent consultation on fairer labelling for Pigs, Poultry and Eggs was conducted to address perceived existing shortcomings in both Country of Origin (COO) and Method of Production (MOP) information for consumers. Country of Origin could be seen as a simple exercise, but for pigs it’s not as simple as it first appears.

Following current regulations, if pork is imported into the UK but is then processed, cured, or otherwise significantly transformed in a way that meets the criteria outlined by Defra, it may be eligible to be labelled as British. For example, currently, EU pork can be imported, cured in the UK and labelled as British using an oval identification mark with a UK or similar prefix. In this example the label also needs to state, ‘made using EU pork’. It is unsurprising that consumers are confused; and with the additional requirement for a ‘not for EU’ statement on labels also enforced, it is clearly time for a rethink.

“Without a current UK legal definition of minimally processed pork, implementation may prove challenging.”

Method of Production, although not explicitly described as animal welfare labelling is exactly that and is trickier to implement than COO. As defined in the consultation notes, MOP will apply to unprocessed and minimally processed pork for both domestic and imported products. Without a current UK legal definition of minimally processed pork, implementation may prove challenging and there’s a real possibility that imported products will match the UK’s tier-four, indoor baseline MOP - but at a significantly lower cost, making UK pig meat uncompetitive.

Add to that the likelihood that the UK imposes stricter labelling requirements than its trading partners, we may face challenges in negotiating trade agreements and maintaining market access for our pig meat exports.

The consultation proposes a label with five tiers “that are based on method of production, differentiating between products that fall below, meet and exceed relevant baseline UK welfare regulations.” Using a mandatory five-tier system will place ‘free-range’ in the highest tier, with baseline UK existing standards at tier four. This will make the proposed ranking system confusing for consumers who are familiar with the current information, and will not encourage consumers to trade up to higher welfare. For UK processors, segregation of the different raw material tiers and particularly the new enhanced indoor category will add time, complexity and cost - especially when different parts of the pig carcase go into multiple markets.

Regulations already in place

The UK already has regulations in place to ensure that pig meat production meets certain standards of hygiene, safety and animal welfare. Compliance with current regulations helps ensure pig meat rearing systems meet basic consumer expectations for food safety and animal welfare. Indeed, standards in the UK are considered among the highest in the world.

Assurance schemes also set criteria for pig welfare and production practices. This allows standards to evolve in response to developments in animal welfare science, continuously improving welfare outcomes while simplifying consumer choice. Most farmers already seek to reach higher standards of animal welfare through existing assurance schemes, but under the proposed methodology would only reach level four.

“The proposed ranking system… will not encourage consumers to trade up to higher welfare.” 

This consultation proposes: stocking density, enrichment, outdoor access, assessment and management of welfare outcomes, finishing accommodation, farrowing system, tail docking (and other procedures) as the MOP assessment criteria. However mandatory labelling will not deliver continual improvement of farm animal health, as MOP alone is not the key determinant. The science is clear that attention to detail and professional stock management is a greater determinant of animal welfare, but this is harder to translate into a clear and useful consumer labelling framework.

Animal welfare labelling should be voluntary but follow compulsory rules when certain terms are used. This approach will allow businesses to be market-led, enabling them to unlock the value from their dedicated supply chains. For consumers, labelling needs to be placed in a wider context of the many factors that drive purchasing decisions, providing all the information required to make informed choices.