Tracing the Yellow River

Members of BFREPA who have raised concerns about liquid egg and other egg products now have the support of a leading politician.

Welsh free range egg producer Tony Burgess is one BFREPA member who fears that a large volume of liquid egg of ’dubious’ provenance is finding its way into the catering industry in the UK. Whilst EU rules on the labelling of shell eggs ensure they are marked with a code showing where they were produced, how they were produced and who produced them, there is no such legislation for egg products. "Egg is transported all over Europe in liquid form and you cannot trace it. I have heard it described as a yellow river," said Tony, who is the representative for Wales on the National Farming Union’s poultry board. Tony has 3,000 free range layers himself. Another 19,000 are on contract with other farmers.

MEP Neil Parish, the Conservative Party’s agricultural spokesman at the EU, says he is also concerned about the current system of regulation. He believes more needs to be done to ensure that UK egg producers are not undermined by unregulated imports.

"We need to make sure that we aren’t simply exporting our industry outside of the EU," he said. "We have the phasing out of battery eggs in 2012 and yet at the same time we will be importing large amounts of food containing egg products or liquid eggs that will have been produced under the same systems that we have banned in the EU." Under World Trade Organisation rules we are unable to ban imports from other countries because of the way they were produced. Current EU legislation does not require labelling on egg product to show where or how it was produced.

"Unless consumers can see exactly where the products have come from and under what animal welfare conditions they have been produced, our egg producers have little chance of competing on a level playing field with cheap imports. Our consumers have no idea where the food has come from or how it has been produced," said Neil Parish. "We impose the most stringent animal welfare rules in the world on our farmers, so we should at least help them compete with imported food by communicating that to consumers.

Otherwise we just drive the industry to those countries where standards

are not as high."

The British Egg Industry Council has been pressing for some years for specific labelling regulations for egg products. Chief executive Mark Williams said the BEIC was primarily worried about product from countries outside the EU. Without country of origin labelling it was impossible to tell the difference between EU and non-EU.

Mark noted some figures for January to October 2008 which showed that imports from other EU member states were nearly 13,000 tonnes of liquid whole egg, nearly 8,000 tonnes of liquid or frozen yolk, and nearly 3,000 tonnes of liquid albumen. "Also during that period, more than 45,000 tonnes of shell egg was imported. We estimate that about half would have been processed," said Mark.

As with shell eggs, there is a Lion code for Lion Quality Egg products. It operates under the British Egg Products Association and offers complete traceability, very strict hygiene controls on processing, pasteurisation and packing. The products undergo independent auditing.

Over the past year, there had been increased interest in the British Lion for egg products as manufacturers and retailers sought to guarantee British supply and incorporate the higher standards of the Lion within their egg products requirements, said Mark. Many companies had already committed to buying British Lion egg products, which ensured that they were supporting British farmers, minimising food miles and getting egg products produced to a code of practice which minimised risk to their businesses.

Over the course of the next year, the industry would be encouraging other companies in the industry to follow the lead of the likes of McDonalds, Ginsters and Hilton Hotels in stipulating Lion Quality egg products.

Legislation governing egg products, however, is very different. The legislation governing the labelling of shell eggs is already robust. EU law requires that eggs are stamped with a code identifying the establishment (production site), country of origin and method of production (ie organic, free range, barn or cage). Defra says the UK supported the introduction of these rules because they would help improve consumer information, choice, and assist with traceability and enforcement of the EU egg marketing regulations. The legislation covering liquid egg is less robust. The distinction between the law governing shell eggs and that covering egg product was confirmed in a statement to Ranger by Defra.

"Currently under EU regulations, shell eggs must be marked with a producer code - a code that identifies the farm that produced the eggs, the country of origin and the method of production. Egg cartons are required to have a label that shows the best before date, consumer advice, definition of country codes, and the address where the eggs were packed," said a Defra spokesman.

The Food Standards Agency also confirmed that there was no specific regulations governing egg product. "There are no specific regulations governing the labelling of processed eggs," said a spokesman in a prepared statement. "However, eggs, like other foods, must comply with the following legislation:

i. the Food Safety Act 1990 (as amended), which requires that food should be of the nature, substance and quality demanded by the consumer and that it should not be falsely described or presented

ii. the Food Labelling Regulations 1996 (as amended), which give the

general requirements as to how food should be labelled and

iii. Regulation (EC) 178/2002, which requires that food must not be unsafe

and that it should not be labelled, advertised or presented in a manner

which misleads consumers. This regulation also requires food business

operators, including egg processors, to provide the name of their suppliers

and customers (excluding sale to final consumers) for traceability purposes.

Allergen legislation also established a list of 14 foods (including eggs)

that have to be indicated by reference to the source allergen whenever these or their derived ingredients are used in pre-packed food."

One result of the difference in treatment between shell eggs and egg product is that responsibility for inspection is divided between different organisations. Egg inspectors are responsible for shell egg but have no responsibility for liquid egg. A spokesman for Animal Health said, "Animal Health has no responsibility for liquid egg marketing. Responsibility for this area would fall to the local authority’s trading standards department, who would be responsible for enforcing trade description legislation."

Tony Burgess says it would make more sense to make both shell egg and egg products the responsibility of one organisation rather than dividing responsibility between Animal Health and Trading Standards. "Egg inspectors would like to have everything related to eggs under their control. They have intelligence about egg and what we should probably do is press for them to have responsibility for liquid egg, too."

The trade description legislation under which egg products are policed does not require food to be labelled to show where it was produced, how it was produced and who produced it, although trading standards officer David Pickering said that there was provision for traceability. "There is provision requiring one up and one down traceability. A retailer would need to keep a record of where he bought something from. If you were a manufacturer you would need to be able to show where the liquid egg came from. If there was a claim that something was manufactured in the UK then it would have to be manuf