When we look at the egg industry over recent years, and in particular the free-range egg sector, it would be fair to say that farmers have certainly lived through some turbulent times.
These have provided a number of reasons to drive the market into temporary, albeit painful downward cycles.
Overall we have seen an increase in consumer demand for free-range eggs, which have become the majority shareholder when viewed across total UK egg production.
However, as we already know, along with this growth comes increased scrutiny and the need to adhere to stringent regulations, and for some, this includes the additional need to comply with what is commonly known as IPPC or Integrated Pollution Prevention and Control.
So where does all of this originate? To be precise the answer is Directive 2010/75/EU of the European Parliament and of the Council on industrial emissions (integrated pollution prevention and control).
The directive set by the EU is aimed at minimizing pollution from various industrial sources, and poultry farms are included within this.
For some poultry farms, this means implementing best practices to control and reduce emissions, manage waste, and ensure environmental protection, farms are encouraged to use BAT’s (best available techniques) to display a control and or reduction in emissions and waste etc.
Up until very recently in Europe the directive applied to poultry farms with more than 40,000 bird places. This included laying hens, broiler chickens, as well as other poultry types.
Farms exceeding this threshold were already required to obtain an IPPC permit, which involves stringent controls on emissions, waste management, and resource use.
However, on 12 April 2024 the European council adopted a revised directive on industrial emissions (IED).
Whilst this may not have necessarily hit the headlines up to this point, the revised directive is a result of numerous discussions and proposals within the EU and includes changes regarding adjustments to the thresholds that determine which poultry farms fall under the IPPC regulations.
These changes aim to better address environmental impacts and ensure that a larger proportion of poultry operations are adequately regulated.
When you drill down specifically into the detail regarding laying hens the changes to the IED will reduce the threshold from 40,000 to 21,400 birds.
his change aims to encompass more medium-sized operations, reflecting a growing concern about environmental impacts from farms previously considered too small to regulate under IPPC.
So, what about emissions standards legislation in the UK, and how could this affect egg producers?
With a new government now in place it would perhaps feel appropriate to raise that very question around their current stance, if for no other reasons than to firstly understand the new regimes understanding and intentions, thereby helping us to be better prepared for what may be to come, but secondly to also establish if the UK would be driven to go a step beyond the revised EU regulation in an effort to differentiate or lead.
If we look at the previous government’s stance, this will lead you to think an EU legislation with bells on approach is not too far from reality. The aim of the EU withdrawal act of 2018 states:
“The UK is committed to maintaining environmental standards and continues to apply the existing successful model of integrated pollution control, ensuring that existing EU environmental law will continue to have effect in UK law, including the IED and BAT Conclusion Implementing Decision made under it.
"The UK government has introduced secondary legislation under the EU Withdrawal Act 2018, to ensure the domestic legislation that implements the IED (including the Transitional National Plan) can continue to operate.
"It’s the government’s aim to ensure that the future UK BAT regime continues to endorse the collaborative approach of the current system and industry will be a part of that approach.”
But for those producers not already under the umbrella of IPPC regulation and compliance, what would be the headline implications should a new ruling encompass you and your farm.
Permit Application and Renewal
• As stated, in the UK this currently applies to farms with a capacity of more than 40,000 laying hens which thereby must apply for an IPPC permit. This involves detailed documentation of farm operations, including waste management plans, emission control measures, and environmental impact assessments.
• Permits are subject to regular reviews and renewals, requiring farms to stay updated with any changes in regulations.
Emissions Control
• Ammonia emissions from manure and other waste must be minimized through proper ventilation systems and manure management practices.
• Dust and particulate matter emissions should be controlled using appropriate filtration systems.
Waste Management
• Manure should be stored in covered areas to prevent leaching and runoff into water sources.
Water and Energy Efficiency
• Implementing water conservation techniques, such as efficient drinker systems with an aim to reduce water usage.
• Energy-efficient lighting and heating systems contribute to lower energy consumption and reduced greenhouse gas emissions.
Monitoring and Reporting
• Regular monitoring of emissions and waste management practices is mandatory. This includes keeping accurate records and submitting reports to environmental authorities.
• Farms should also be prepared for periodic inspections to ensure compliance.
With all that in mind, what can you currently do to try and be ahead of the game should threshold changes come to fruition in the UK.
Stay Informed:
• Keep up to date with the latest information from the European Commission, UK government and national environmental authorities regarding potential changes to the IPPC thresholds.
Evaluate Current Practices:
• Conduct a thorough review of current farm operations to identify areas that may need improvement to comply with the regulations.
Seek Professional Guidance:
• Consult with environmental experts or agricultural advisors who can provide tailored advice and assistance in meeting any new IPPC requirements.
Invest in Upgrades:
• Should you consider investing in technology and infrastructure that enhance emissions control, waste management, and resource efficiency.
Training and Education:
• Ensure that all farm staff are trained and aware of the requirements and the importance of maintaining compliance should an adjustment to the threshold capture your farm.
While adhering to IPPC rules may seem daunting, the benefits could perhaps extend beyond mere legal compliance.
Could a broader implementation of these practices have the potential of uncovering outcomes that may be leveraged in a positive way for the industry?
Could a combination of better waste management and resource use reduce your operating costs?
As consumers are increasingly choosing products from sources that follow sustainable and ethical practices, could a broader IPPC compliance approach across a wider production base focusing on environmental protection lead to any commercial advantage for our UK industry in an increasingly competitive and eco-conscious market?
For more detailed information on the egg market, farmers can join the British Free Range Egg Producers Association and get the monthly magazine the Ranger.
