food products, sent a letter to the California Department of Food and Agriculture (CDFA) asking for clarifications related to Prop 12. “Our members are committed to complying with the regulations when they become final,” the UEA states in the letter. “Unfortunately, there remain a number of ambigui- ties”. For example, does Prop 12 apply to food products that contain liquid egg but are recognized by the US Department of Agriculture as meat products because they contain 2% or more cooked meat? The letter provides examples of these products, such as “cooked scrambled egg mixes, quiches, egg bites or egg frittatas with 2% or more cooked meat”. Other ar- eas of confusion abound. UEA members want certainty about the location where a company might take possession of liq- uid eggs to be sold into California in any form, whether the exemption for charitable donations of egg products applies to federal procurement programmes and whether or not Prop 12 completely supplants Proposition 2, passed in 2008.
Opposition to timeline The Association of California Egg Farmers strongly opposes the timeline in Prop 12 that requires all laying hen housing be cage-free by the end of 2021. The state government was re- quired to finalise the implementation regulations by Septem- ber 2019. The CDFA only issued the proposed regulations in
May 2021 and had a public commentary period that closed in mid-July. In terms of numbers, the association states that Cal- ifornia’s 40 million people each consume about 300 eggs per year and, typically, one hen produces that number of eggs during that time. Thus, 40 million hens are needed to meet California’s demand for eggs. Many of these hens are housed within the state. The association explains on its website that collectively, Cali- fornia egg farmers have been transitioning a percentage of hens to cage-free housing every year and that they are on track to become 100% cage-free by 2025. This was the date that had been agreed upon by the Humane Society of the United States and the US food industry to exclusively supply 100% cage-free eggs to consumers in California and beyond.
Deadline difficulty Changing the deadline to the end of 2021, says the Associa- tion of California Egg Farmers, could result in supply disrup- tions, price spikes and an egg shortage. It estimates that only 65% of the California eggs will be produced by hens in cage- free housing by the end of the year. “The California egg farm- ers who remain in business,” states the Association of Califor- nia Egg Farmers, “will be required to accelerate their business plans, seek construction loans, obtain permits and spend
▶ POULTRY WORLD | No. 8, 2021 15
Prop 12 requires that laying hens, nursing sows and veal calves “be housed in confinement systems that comply with specific stand- ards for freedom of movement, cage-free design and minimum floor space”.
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