As part of its work on a new Food White Paper due to be published in 2022, Defra is consulting on animal welfare labelling. We have summarised the key points for you so we can get your views for the BRC response.

Background

As part of its work on food strategy, Defra is consulting on potential changes to animal welfare labelling. They believe it would encourage consumers to make better welfare choices, based on more information, presented in a consistent way to account for current claims and voluntary initiatives. It would also support farmers by enabling them to market their produce better against imports.

If you want to read the whole consultation it is here.

We will be responding to the consultation using input from our Agriculture WG on the value and applicability of more welfare labelling and our Labelling WG covering the technical aspects of labelling. This paper sets out the key themes and questions in the consultation.

1. Is it necessary

The consultation poses 2 questions on the purpose of change

• Are there barriers for consumers wishing to buy higher welfare food?
• Does the Government need to ensure greater consistency in the way information on higher animal welfare is presented?

The consultation asks about the standards which would underpin labelling and how they would be based. Should they be based on inputs, including the method of production or outcomes or even a combination of the two. It suggests outcomes could be used to support and measure the effectiveness of methods of production.

• How could standards be set using different levels of inputs?
• How could welfare outcomes be incorporated into standards?

It also suggests standards could be time or lifetime based, citing the difference between AFS and QMS in terms of lifetime assurance.

• What needs to be considered if standards are lifetime based, including breeding, transport and slaughter?

It also considers welfare standards in poultry production, both eggs and meat which have been carried over from EU law

• Should the marketing standards for poultrymeat and eggs be updated?

The consultation addresses the debate about transparency of labelling of non stunned slaughter for religious preferences.

• Do we think method of slaughter should be labelled? If so mandatory or voluntary based on agreed terminology or at discretion of producer?
• If we support labelling of method of slaughter should it be standalone or as part of a wider standard covering he entire production process?

The Government wants to know what approach to labelling will meet its criteria of rewarding UK farmers, improving animal welfare and ensuring a UK baseline for welfare.

• Which would deliver these criteria best, mandatory or voluntary, based on regulated standards to ensure consistency where they are used or industry led?
• Would you support mandatory labelling where it differentiates imported products not produced to the same baseline standard?
• Would labelling have any impact on the market, would it create more opportunities for UK farmers? Would that be different if labelling wasn’t mandatory?

The consultation also asks for views on the approach to labelling, for example should it be based on a tiered system (numbers, colours etc) linked to the standard of welfare, or a certification scheme awarded only to those achieving higher standards

• Do you believe there are merits in tiered labelling of production standards?
• Do you believe there are merits in labels describing different production standards?

The consultation also covers the scope of labelling in food businesses. To help its work, Defra has asked for data on how meat and dairy products are used in retail and catering, including the proportion that is processed before sale. I think they should be speaking to the levy boards about this but if you have data you want to share they are interested.

The consultation considers the coverage of mandatory labelling on processed and unprocessed meat and dairy.

• What would be the impact if mandatory production labelling was extended to all unprocessed produce, including imports?
• Do we think there is any difference/value across all supply chains ie dairy, meat, eggs?
• What are the impacts of increased welfare labelling?
• What would be the impacts of extending mandatory labelling to processed products? Including where the meat or dairy is a secondary rather than primary ingredient?

The consultation suggests that whilst Government would like to incorporate welfare standards and labelling into mass catering, including its own procurement and sales through hospitality there are barriers to implementation. It is encouraging responses based on possible labelling of primary ingredients eg chicken in chicken sandwich, pork in a sausage roll etc.

• How difficult is it for consumers to make informed choices on welfare when eating out?
• How difficult is it for catering businesses to make information available to consumers?
• If labelling is considered how would it be best delivered? Mandatory at point of sale eg menu; disclosure on request; disclosure through website; voluntary labelling based on agreed terms; rating for mass caterers based on an audit of products; voluntary only.
• Would it be more difficult for this sector to provide information on unprocessed produce and where meat and dairy is a primary ingredient of a processed product?

6  Enforcement

The consultation considers how claims and labelling can be verified and enforced. Within that what is the role for existing enforcement agencies alongside current assurance and accreditation

• What are the key elements of enforcement, could that build on existing mechanisms?
• What role could assurance schemes play in verifying claims on a label?
• Could accreditation play a role ensuring the welfare standards of imports?

The consultation asks about marketing terms which may be used but would not, necessarily be welfare based. For example, grass fed. Particularly where there is no agreement on how those terms are used.

• Are there non welfare related provenance marketing terms which could be defined in law, although display of them would be voluntary?

Defra is looking at al labelling as part of the White Paper and wants to know how welfare labelling can align with other labelling and, potentially how it might be integrated with environmental labelling to give consumers comprehensive information.

• How could animal welfare labelling be presented in a form which aligns with other labelling such as nutrition and eco-labelling?
• If the Government was to pursue comprehensive labelling bringing together environmental impact and welfare, how would that best be done? Label based on criteria for environment and welfare; separate labels for environment and welfare; assurance scheme covering both elements;