The RSCPA has announced revisions to its 2023 laying hen standards after surprising producers with a swathe of far-reaching changes to its welfare standards.
In this article, the British Free Range Egg Producers' Association (BFREPA) outlines what has changed.
BFREPA has sought to engage positively with representatives from the assurance scheme, aiming to ensure that revisions were practical, and timescales for implementation reasonable.
Gary Ford, Head of Strategy and Producer Engagement for BFREPA, responded to the RSPCA's announcement regarding revisions to the 2023 laying standard.
He said: "We welcome the fact that nearly eighteen months after the RSPCA Amended laying hen welfare standards were announced in November 2023 the new standards have now been finalised.
"BFREPA, along with other industry representatives, have worked diligently and determinedly, over that period, to convey the strength of feeling of our members and that we need a pragmatic and workable outcome.
"The RSPCA rightly paused the implementation of the original standards to engage with industry to explore a way forward," he explained.
"We believe that the outcome of those discussions meets our aims whilst, at the same time, keeping the RSPCA as part of the free-range sector - a sector that stands for higher welfare which differentiates ourselves from other systems of production and imported product.
"At a time of great uncertainty and threats from overseas eggs, produced to different standards, this is crucially important to help secure our future and confidence in our sector.
"We will continue to represent our members with ongoing engagement with the RSPCA."
Much of the initial debate was in response to the need for hens to be provided with natural daylight via the installation of windows.
This requirement remains but, in the case of existing houses, the timeframe for installation has been relaxed.
In a letter to the RSPCA Assured membership, assistant director of certification and assurance, Neil Scott, highlighted the changes to policy.
Either at the time of refurbishment cycle or by 1 January 2035 (whichever is sooner) free-range members must provide 3% natural daylight to hens.
When carrying out planned internal refurbishments, free-range members must include the extension of pop holes or light inlets (i.e. windows) within the current structural framework of the house to meet 3% natural daylight.
From 1 October 2025, free-range members building a new house or conducting major structural refurbishments to an existing house, must provide 3% natural daylight through windows. This is in addition to the natural daylight provided through pop holes.
From that same date, all free-range hens must have access to natural daylight through their pop holes during housing orders (e.g. in the event of avian influenza (AI) outbreaks).
In order to achieve this, producers could put clear material (e.g. acrylic) over pop holes, rather than closing them, when birds need to be housed during the natural daylight period.
If hens are placed before 1 October, members can wait until they depopulate and place the next flock to meet this requirement.
In addition to the extended implementation timetable, a further derogation period of up to 5 years could allow farms who cannot ‘reasonably or realistically’ refurbish their sheds by 2035 until 1 January 2040 to comply.
But producers will need to wait to determine whether such a derogation could apply to them, with the application process for this derogation not due to open until June 2034.
The new edition of the standards come into full effect from 11 July this year, some 16 months after the initial implementation date referenced back in November 2023.
A set of guidance notes accompanies Mr Scott’s letter to members, containing useful information such as definitions of different refurbishment levels and a Q&A summary on each of the contended topics such as fencing on the range and natural cover.
In addition, RSPCA Assured have provided responses to the concerns raised during the consultation.
Managing injurious feather pecking, coping with the legal requirement to provide 8 hours of darkness and dealing with higher indoor temperatures are all addressed.
In addition, the farming engagement team at RSPCA Assured are a key resource to farmers seeking support in understanding or implementing any of the standards.
BFREPA strongly encourages its members to get in touch with this team if they have any questions of need any guidance or support at farmingengagement@rspcaassured.org.uk
Heralding both the final result but also the consultative nature of their creation, Mr Scott said: “We’re so proud to have such an engaged and dedicated membership to work with.
"Working together to find solutions gives the greatest chance of achieving this standard, ensuring that all hens experience natural daylight.”
The rest of the changes
Existing barn houses must provide 3% natural daylight from 1 May 2032, with new builds incorporating windows from 1 October 2025.
From 1 May 2030, all barn houses must have verandas installed. Free range houses have no requirement for verandas.
Away from the subject of natural light, discussion between the stakeholder groups has led to some compromise. Fences within the range are no longer required to have a 45cm gap beneath them.
Instead, there is no prescriptive measure beyond ensuring the birds are not restricted in their access of the range.
Farmers have been given an additional year, until 1 May 2027, to extend natural cover on the range to 20% to allow members two full planting seasons to grow the required trees, shrubs and cover crops.
The RSPCA are aware that in some regions it is difficult to grow trees and shrubs. Members in this situation are encouraged to contact their farming and technical engagement team so that they can provide expert advice on alternatives that will work for their specific environment.
They will also provide members with examples of natural cover and help guide them on how to implement the standard. They will develop these with the help of the producer working group.
Pophole heights greater than 40cm from the floor in existing sheds required that birds were given ramps or platforms to ease access outside.
This threshold has been increased by 5cm, as has the equivalent maximum measure in new houses, now 25cm not 20cm.
Nick Allen, CEO of the British Egg Industry Council (BEIC) commented: "We are pleased that RSPCA Assured has listened to the industry’s concerns following a prolonged period of lobbying.
"It is good news for everyone that the revised RSPCA Assured standards have now been finalised, offering a sensible, pragmatic solution that is workable for producers.
"The BEIC is committed to ensuring that the UK continues to lead the world in free range egg production."
BFREPA chairman James Baxter added: “BFREPA, on behalf of our members, have worked hard with RSCPA Assured to achieve a final result through extensive consultation RSPCA and discussion with producers.
"This included involving RSPCA Assured in the recent regional roadshows, where many took the opportunity to constructively raise their concerns.
"We’re grateful to all who provided feedback or attended these events," he went on to say..
"The presence of a such a well-recognised welfare protection trademark in our industry is absolutely necessary and provides all RSCPA Assured scheme members with true consumer value.
"From this point, we at BFREPA will engage with packers, processors, retailers and food service outlets to understand their needs, aiming to secure the market clarity required to support the investment these new standards mandate.”
