Consultation outcome

Summary of responses and government response

Updated 12 June 2025

Introduction

Background

This document provides a summary of responses to the public consultation on fairer food labelling. This was a joint UK-wide consultation undertaken by Defra on behalf of the Scottish Government, Welsh Government and the Northern Ireland Executive.

The consultation ran for 8 weeks from 12 March until 7 May 2024. It sought views on proposals for clearer food labelling through improved method of production and country of origin labelling.

The consultation was published on the online digital platform Citizen Space which recorded responses through an online form. Responses were also received by email.

Overview of respondents

A total of 31,011 responses were received, of which 30,580 were received by email and 431 were received by the online form:

• 30,837 (99%) of total responses (online form and email) were from individuals
• 174 (1%) of responses were from a range of organisations, including public bodies, industry, non-governmental organisations (NGOs) and academic institutions

Of the 291 individual respondents who responded using the online form:

• 88% were from England
• 5% from Scotland
• 4% from Wales
• 1 % from Northern Ireland
• 3% from outside the UK

Of the 141 organisations who responded using the online form and provided this information:

• 23% had headquarters in England
• 4% in Scotland
• 1% in Wales
• 1% in Northern Ireland
• 1% had headquarters outside of the UK
• 70% did not provide the location information

As the majority of email responses did not provide this information, we have not included these in this analysis.

Many of the responses from individuals used standardised text as part of public campaigns. Due to varying degrees of personalisation within these responses, it is not possible to report an exact number of responses associated with campaigns.

A breakdown of respondents who provided this information on the online form is as follows: 

Type of respondent	Number of respondents
Individual You are responding with your personal views, rather than as an official representative of a business, or business association or, other organisation.	307
Non-governmental organisation (NGO) You are responding in an official capacity as the representative of a non-governmental organisation or, non-profit organisation or, other organisation.	35
Industry (multiple businesses) You are responding in an official capacity representing the views of multiple businesses or, the views of a trade association or, a business association.	17
Industry (single business) You are responding in an official capacity representing the views of a single business.	38
Other	16
Academia You are responding in an expert capacity as a faculty member or researcher at an academic institution	11
Public sector body	5
Did not specify	2

We are grateful to everyone who took the time to respond to this consultation and have comprehensively considered all responses in our analysis.

Headline messages

Country of origin labelling

There was support for changing mandatory country of origin labelling rules so that they apply to the meat used in minimally processed meat products, with a slight majority of online respondents stating that it is very important. These respondents cited the importance of consumers having the necessary information available to them to enable them to make informed decisions, along with the possible benefits for overall animal welfare. There was also some support for a few other interventions.

Respondents who did not believe changing country of origin labelling rules was important argued that it would add complexity and unnecessary costs to the supply chain, and that voluntary country of origin schemes and current regulations are sufficient.

There was a wide range of views from respondents when asked for further suggestions for improving country of origin information. For example, some respondents emphasised the need for more effective enforcement of the existing rules; some emphasised the need for a consistent, standardised, UK-wide approach.

Method of production labelling

There was strong support for mandatory method of production labelling reform, with over 99% of individuals and 69% of organisations who responded supporting mandatory labelling reform. Those who were supportive cited the potential benefits for animal welfare, consumer transparency, and farmers meeting or exceeding baseline UK welfare regulations.

Respondents who disagreed with a mandatory approach to method of production labelling, including many respondents from industry, argued that the current landscape of industry-led labelling is sufficient. Some respondents expressed concerns about the potential costs of mandatory labelling. However, some industry respondents were supportive of greater standardisation of terminology through legal definitions, for voluntary use by food businesses, to improve consistency in consumer information.

There was strong support from across all sectors, from over 99% of individuals and 86% of organisations, for mandatory method of production labelling reform to apply to both domestic and imported products .

There was strong support for method of production labelling reforms to apply on a UK-wide basis, from 88% of individuals and 68% of organisations who responded.

Methodology

Analysis methodology

All responses received within the consultation deadline were counted and the views presented were included in the analysis. Some respondents submitted answers in more than one format (for example, via both the online form and email). Multiple responses from the same respondent were counted as one response.

The consultation included both closed-ended questions (where there was a limited range of answers to select from, for example yes or no), and open-ended questions.

All responses were read individually with the exception of:

• closed-ended responses received through the online form, which were analysed using automated methods
• identical responses associated with public campaigns, which were automatically identified based on consistency of their content using language processing software – however all personal additions to standardised response text were read individually

Five campaigns, where individuals responded as part of a co-ordinated effort, were identified, including campaigns organised by the RSPCA, Compassion in World Farming, Feedback Global and the Humane League. One related to Part A of the consultation (on country-of-origin labelling) and 4 related to Part B of the consultation (on method of production labelling), with responses associated with campaigns forming over 90% of the total responses. This demonstrates a very high level of public interest in the proposals. These responses have been included within the analysis and reported in the same way as responses from other individuals or organisations.

Some organisations were umbrella groups whose responses represented the collective views of their member organisations. These responses counted as a single view in the analysis. However, their members also responded separately in some cases, and these were included in addition.

Due to the high number of responses from individuals compared to organisations, responses from individuals and responses from organisations have been considered and reported separately for each closed-ended question.

To better understand the general themes that emerged in response to the open-ended questions, we have also grouped the responses from organisations into 4 broad groups, using a best-fit primarily based on responses to the demographic questions and where relevant, our additional existing knowledge of the organisation or how it described itself on its website. This resulted in the following groups:

• public bodies (including UK local authorities and bodies in other countries)
• businesses and other industry organisations
• NGOs
• academic bodies

Our analysis considers all responses in relation to the consultation questions and its corresponding themes.

Reporting terminology

Not all respondents answered all questions. Where figures are given for the number of responses to a question with more than one part, the figure relates to the first part (part a) of each question. The number of responses to subsequent parts of each question (for example, part b or c) may differ from those who responded to part a. For responses which were submitted via email and did not clearly state which question each part of their response was responding to, an assessment was made based on professional judgement, so that the response could be included in the analysis of relevant questions.

When reporting different responses to closed-ended questions, we have reported proportions of total responses as percentages. Percentages are rounded to the nearest whole number.

This summary of responses is not an exhaustive list of all ideas provided by respondents but summarises the most common views expressed for different respondent groups.

Table 1 includes terminology that we have used to describe the frequency of responses to individual open-ended questions:

Term	Description
Large majority	Greater than 80%
Majority or most	Greater than 50% and less than or equal to 80%
Even number (of respondents)	Equal (to the nearest whole percentage)
Many	More than 20% but less than 50%
Small number, several, few or some	Less than or equal to 20%

Summary of consultation responses: country of origin labelling

For the country of origin labelling questions (from 16 to 32), a total of 433 responses were received on the Citizen Space platform, with a further 49 responses received by email. The responses from the Citizen Space platform were received from a wide variety of different respondents, ranging from those who identified themselves as public sector bodies, academia, non-governmental organisations and individuals. 

For a few of the questions (19, 20, 23 and 28), depending on the answer to the closed part of the question, respondents were then invited to provide further comments (‘open’ questions). For example, in question 19, if they selected ‘yes’ then there was a further open question. Most respondents who were invited to provide a further answer did so. In addition, others used the open question space to provide comments despite not having selected an option that invited them to do so. Where this was the case, we have taken these comments into account when pulling together this summary of responses.  

Most respondents did not respond to the open questions that did not also have an accompanying closed question. Finally, except for question 24, little difference was seen between the different stakeholder types.

Question 16 asked: How important do you think it is that mandatory country of origin labelling rules be changed so that they apply to the meat used in minimally processed meat products as they do already to unprocessed meat? Please explain your answer.

We received 416 responses to this question from:

• 324 individuals
• 92 organisations

Response	Individuals	Organisations
Very important	73%	60%
Important	17%	23%
Neutral	6%	9%
Not very important	1%	1%
Not at all important	0%	3%
Don’t know	3%	4%

Summary of key themes for the open-ended question:

While the majority of respondents thought that changing mandatory country of origin labelling rules so that they apply to minimally processed meat was very important, there were a range of views, including that:

• Many respondents who supported changing mandatory country of origin labelling explained that consumers should have the full information required to make informed choices. Some respondents further highlighted the need for consistency of rules regardless of processing and that the current rules in place are misleading, for example, where a UK processed product which uses imported meat as an ingredient is labelled as British or when a British-sounding farm name is used. A few respondents also noted that minimally processed meat makes up a large proportion of the market and therefore felt it should have country of origin labelling.
• There was some interest from respondents who flagged that they wish to see changes to include animal welfare labelling, environmental labelling and method of production labelling. Finally, there were some who highlighted that through mandatory labelling, they would have the necessary information to support the British industry and farmers by buying British produce.
• A few respondents who were unsupportive of changes stated that changing rules could impact international trade agreements and add costs to the food chain. A few others who were unsupportive suggested that any labelling changes should be voluntary (i.e. the current rules are sufficient), that new measures would confuse consumers or that they do not have enough interest in labelling to impact their purchasing decisions.

Question 17 asked: What five (minimally) processed meat products would be the most important to include?

We received 289 responses to this open-ended question.

Suggestions	Number of responses
Sausage	121
Bacon	119
Chicken Products	107
Ham	83
Pork	55
Sliced cooked meats	50
Fish/seafood	48
Beef	44
Burgers	39
Mince	29
Lamb	27
Poultry	22
Ready meats	22
Curled smoked meats	18
Pies	16
Gammon	13

Instead of selecting 5 meat products, or in addition to selecting 5 meat products, some respondents flagged other food groups or categories that they would like to see included in the list. For example, some suggested that any new rules should apply to all meat products or the most consumed meat products on the market. Some noted that a definition would be required for minimally processed meats. Additionally, creating such a definition could have negative impacts on international trade.

Question 18 asked: If we did not use a list approach, please describe any alternative approaches you would propose to define which minimally processed meat products are included?

We received 264 responses to this question.

Summary of key themes for the open-ended question: 

• One of the main themes coming from respondents related to groupings of meats to incorporate under minimally processed meats, including many who suggested that the term should include all products derived from animals. There were also some who suggested including products where meat is the main ingredient, all minimally processed meat, imported meat and products with a certain percentage of meat.
• There were a few respondents who were happy to proceed with a list approach and a few who wanted to see a definition for minimally processed meats.
• A few respondents wanted the approach to be based on market share/most consumed meats.
• Of those not in support, there were some respondents who stated that they did not support mandatory origin labelling or wanted to see a voluntary list.
• Finally, one other theme that some respondents flagged was for an animal welfare criterion to be included.

Question 19 asked: Do you think that the use of national flags on food requires more regulation than described above?  If ‘yes’, how would you further regulate the use of national flags on food?

For the closed part of this question, we received 407 responses from:

• 280 individuals
• 127 organisations

Response	Individuals	Organisations
Yes	72%	67%
No	11%	24%
Don’t know	17%	9%

For the open-ended part of this question we received 244 responses.

Summary of key themes for the open-ended part of the question: 

• Many respondents wanted to see a flag used only for the country of origin of the primary ingredient, including where the animal was reared and slaughtered, while some respondents wanted to see the use of a flag only when the entire product is produced in the same country. A further few wanted to see multiple flags used for all the countries involved.
• Some individuals found that the current use of flags is misleading (for example if a Union flag is used on a UK-made product which contains imported meat), and a few did not want flags to be used at all.
• Another aspect raised by respondents was that some wanted to see the country of origin in writing alongside the flag while a few wanted the writing instead of the flag.
• Some respondents also suggested some changes to the rules and the current system in place, arguing that bigger text should be used to make country of origin labelling clearer or that country of origin should represent where the animal spent most of its life.

Question 20 asked: Should there be further controls on the use of flags on food labels?

We received 387 responses to the closed part of the question from:

• 278 individuals
• 109 organisations

Response	Individuals	Organisations
Yes	51%	63%
No	11%	19%
Don’t know	38%	18%

We received 173 responses for the open-ended part of the question.

Summary of key themes for the open-ended question:

• Some respondents raised issues with the existing system, suggesting that the current use of flags is misleading (for example if a Union flag is used on a UK-made product which contains imported meat); there should be more verification and that the current rules should be enforced.
• A few respondents mentioned that they wanted to see the use of flags only for country of origin of food, flags used for every country involved in production or only for the primary ingredient.
• Some respondents had some general comments including requesting clearer and more concise labelling of flags and a written statement of origin alongside the flag.
• Some respondents wanted to see the use of flags restricted to certain scenarios, including flags only being used if the food has been largely or entirely produced in the same country or the use of a single national flag restricted to use only where 100% of ingredients are from that country.
• Finally, a few respondents raised that any further labelling should be optional and not mandatory.

Question 21 asked: Should there be an additional requirement that mandatory origin information should be on the front of the pack?

We received 401 responses to this question from:

• 278 individuals
• 123 organisations

Response	Individuals	Organisations
Yes	75%	65%
No	9%	26%
Don’t know	16%	9%

Question 22 asked: What should the minimum size font be for mandatory origin labelling?

We received 388 responses to this question from:

• 270 individuals
• 118 organisations

Response	Individuals	Organisations
Make larger than 1.2mm ‘x’ height	71%	47%
Stay the same	9%	34%
Don’t know	20%	19%

Question 23 asked: Should the written origin of food be accompanied by a national flag or other symbol?

We received 377 responses to the closed part of the question from:

• 266 individuals
• 111 organisations

Response	Individuals	Organisations
Yes, a national flag	52%	48%
Yes, a different symbol (please specify)	4%	2%
Don’t know	15%	3%
Not necessary	29%	47%

We received 109 for the follow up open-ended part of the question.

Summary of key themes for the open-ended part of the question: 

• Of those who supported having a symbol or national flag, several respondents highlighted that a flag is more attention grabbing or easily understood, while a few respondents wanted to introduce a symbol for animal welfare standards. A small number of respondents wanted to see the use of flags only when the entire production and origin is from the same country.
• Of those who were against the use of flags or symbols, several stated that clear, written origin information is sufficient, that not all consumers will recognise flags and that a flag is difficult to print because of physical packaging restrictions. A few stated that a flag should be optional and not mandatory and that current rules are sufficient.
• Of those who wanted to see other symbols there were a few who wanted to see homegrown/British symbols, or another clear and easily recognisable symbol.
• Finally, some respondents also wanted to see a national flag alongside country of origin labelling text.

Question 24 asked: What role should be played by labelling requirements for seafood, farmed or wild-caught, in order to encourage consumers to buy more locally caught or produced seafood?

We received 264 responses to this question.

Summary of key themes for the open-ended question:

• Of those who identified as an ‘other’ stakeholder type, half of the respondents indicated that they would like to see labelling that shows information of how the seafood was farmed and/or caught. Several of these respondents also flagged that they wanted labelling to show where the seafood was caught or information on packaging to show the sustainability of methods used.
• Of the respondents who identified as non-governmental organisations (NGOs), many raised that they wanted to see labelling information on how the seafood was farmed and/or caught, information on where the seafood was caught or labels to show sustainability of capture.
• Many of these NGOs also wanted to see the introduction of port of landing and production information or of mandatory country of origin labelling. Finally, there were many who wanted to see detailed animal welfare information and for seafood labelling to have equivalent requirements/rules for other products, such as meat.
• Of the respondents who identified as ‘individuals’, responses were similar to the ‘other’ and NGO groups mentioned above. Many respondents flagged that they wanted to see labelling information on how the seafood was farmed and/or caught and information on where the seafood was caught.
• A few of the respondents who identified as industry (multiple businesses or trade bodies) wanted to see the same labelling rules applied as for other animal products (such as meat), whilst a few others wanted to keep things as they are (no changes).
• A few respondents wanted further labelling information to include sustainability of capture and detailed animal welfare information. They also felt that the same rules should apply as for other products, such as meat and the rationale provided by respondents flagged that they felt that consumers should have honest and clear information to make informed choices.
• When looking at the results overall (across all stakeholder groups), many responses wanted labelling information on how the seafood was farmed and/or caught and where the seafood was caught.
• Some respondents also wanted to see labelling information on sustainability of capture and detailed animal welfare information.
• Some respondents flagged wanting to see port of landing or production information, while others wanted to see the same rules as other products (meat).
• Some respondents stated that consumers should have clear and honest information so as to inform purchasing decisions, while a small number of respondents wanted to see a definition for the term ‘local’.

Question 25 asked: Do you think information on the origin of food is sufficiently clear when it is sold via online platforms (either from a mainstream grocery retailer or other general retail platforms)?

We received 389 responses for this question from:

• 283 individuals
• 106 organisations

Response	Individuals	Organisations
No, it is not sufficiently clear	48%	43%
It varies	24%	28%
Yes, it is sufficiently clear	3%	9%
Don’t know	25%	19%

Question 26 asked: What improvements would you like to see in how origin information is presented online, if any?

We received 265 responses to this question.

Summary of the key themes for the open-ended question: 

• There were a wide range of views expressed for this question. Many respondents flagged that they wanted to see origin information placed prominently/clearly on the webpage. There were also several who wanted to see origin information stated in the description or product information, stated within the title/subtitle, have the same information as on the physical packaging or in store, the full information from ‘farm to fork’, food processing/production information or the inclusion of animal welfare labelling.
• Some respondents wanted to see a mandatory inclusion of country of origin information and a few raised concerns that the current origin information practices for online sales are insufficient, for example when the origin of food products is not displayed in a prominent way or the online description lists multiple countries where the product could be sourced from.
• Some respondents wanted to see a buy British or ‘search by origin’ function online or the use of flags.
• Some of the more general points raised included having a consistent and standardised template or approach, and feedback that the information provided should not be misleading.
• There were a few respondents who felt that the current country of origin rules are sufficient or that any changes should be voluntary and not mandatory.

Question 27 asked: Should there be a mandatory requirement to state the origin of meat, seafood and/or dairy products in the out-of-home sector?  If yes, what form should this requirement take?

We received 397 responses to the closed part of this question from:

• 278 individuals
• 119 organisations

Response	Individuals	Organisations
Yes	75%	68%
No	8%	19%
Don’t know	17%	13%

We received 290 responses to the open-ended part of this question.

Summary of key themes for the open-ended part of the question.

• Many respondents wrote that they wanted to see origin information presented on menus.
• Some respondents suggested other forms of information including the use of flags, digital solutions (such as websites or QR codes), the use of posters/display boards, information being available upon request or having a separate printed document that contains ingredients and origin information that can be regularly updated.
• A few respondents also raised that they wished to see animal welfare information and information specifying the farm or region of origin.
• In terms of general points raised on this question, rather than specific format suggestions, some respondents wanted clear information on where the animals were reared/raised/slaughtered and where the products were produced. Some also expressed that customers should not be misled and should have clear information to make informed decisions, or that a standardised nationwide system should be implemented.
• Some respondents stated that there should be no mandatory requirements or simply did not support any changes. Some also suggested that implementing these changes could be burdensome to businesses.

Question 28 asked: Should the requirements be applied equally to all out-of-home food businesses?

We received 383 responses to the closed part of the question from:

• 277 individuals
• 106 organisations

Response	Individuals	Organisations
Yes	70%	73%
No	9%	7%
Don’t know	21%	20%

We received 71 responses to the follow-up open-ended part of the question.

Summary of key themes of the open-ended part of the question:

• Some respondents suggested that there should be no exemptions.
• A few respondents did suggest that there should be exemptions for smaller businesses but that large businesses should be included. A few respondents raised that there should be reasonable timescales for implementation of any new rules. A small number of respondents provided specific examples of businesses that should be exempt including public institutions, hospitals, schools, small restaurants and cafés and street food vendors.
• A small number of respondents stated that they did not support new proposals, explaining that it could be overburdensome for businesses and reasonable timescales for implementation is required.

Question 29 asked: If measures such as mandatory origin for minimally processed meat products, increasing the visibility of origin labelling, controlling the use of national flags and/or mandating origin labelling for the out-of-home sector were introduced, what do you think are realistic timescales for businesses to implement such policies from the point at which they are announced?

We received 377 responses to this question from:

• 266 individuals
• 111 organisations

Response	Individuals	Organisations
1 year	44%	16%
2 years	29%	30%
3 years	8%	19%
4 years	<1%	3%
5 years and over	2%	10%
Don’t know	17%	22%

Question 30 asked: What exemptions should be given if any?

We received 171 responses to this question.

Summary of key themes for the open-ended question:

• One of the main themes coming out from this question was that many respondents wrote that there should be no exemptions given to any business.
• Despite this, there were several respondents who suggested that small businesses, take aways or the out-of-home sector should be exempt or that exemptions should be considered on a case-by-case basis.
• While not stating a specific business type, a few respondents flagged that longer timescales for compliance should be given or that businesses should be allowed to ‘sell through’ stock that does not comply with any new rules.

A few respondents stated that they did not support the mandatory introduction of new labelling rules, while a few stated that they were unsure about exemptions.

Question 31 asked: Do you have any suggestions on how to smooth the costs and complexities of implementing these changes?

We received 131 responses to this question.

Summary of key themes for the open-ended question:

• There were a wide range of views on this question. Some respondents wanted reasonable and clear timelines and for government to consult with stakeholders.
• A few respondents felt that these changes should incur no added costs (or very minimal costs) while others wanted to see government financial aid/support.
• There were a few different points raised by respondents on what the government could do to help smooth costs and complexities, these included, a small number of respondents who wanted to see any changes aligned with other reforms (including EU reforms), the production of guidance and support documents, a phased/staggered introduction starting with big businesses, increased publicity and awareness campaigns, putting the financial onus on the wholesaler, introducing tax or tariffs on imports and consultation with stakeholders.

Question 32 asked: Do you have any other suggestions for improving country of origin information?

We received 147 responses to this question.

Summary of key themes for the open-ended question:

• For this question there was a wide range of responses. A few respondents highlighted that country of origin needs to be clearer, while some others raised wanting to see the introduction of clear animal welfare labelling and the standardisation of flag use with text.
• Other respondents raised that they wanted these proposals extended to other products/industries, to ensure that consumers are always informed on origin information, and method of production/slaughter labelling.
• Several respondents stressed the need for appropriate traceability systems in place to enable tracking from the farm to fork, the stricter enforcement of the rules and avoiding misleading practices and clear and legible packaging information.
• A few respondents raised that they wanted to see a standardised UK-wide approach.
• Finally, some respondents did not support new labelling rules being introduced.

Summary of consultation responses: method of production labelling

Approaches to labelling (Questions 33 and 34)

Question 33 asked: Do you agree that method of production labelling should be mandatory? Please explain your answer. If you answered no, please detail any alternative approaches that you feel would be effective in delivering informative, consistent and accessible information on method of production to consumers.

We received 30,385 responses to this question from:

• 30,228 individuals
• 157 organisations

Response	Individuals	Organisations
Yes	100%	69%
No	0%	25%
Don’t know	0%	6%

Summary of key themes for the open-ended question:

• Most respondents who supported mandatory method of production labelling argued that mandatory labelling is necessary to ensure clear and consistent product information and enable consumers to make informed purchasing decisions in line with their values. Individual respondents in particular, suggested that current labelling is insufficient due to the variety of terminology and images used. Many also felt that some information currently provided on labels could be misleading to consumers and suggested that mandatory labelling is particularly necessary to provide consumer transparency on lower welfare products, which are unlikely to be voluntarily labelled as such.
• Most respondents who supported a mandatory approach also argued that mandatory labelling would be fairer to farmers. Individuals and NGOs in particular, noted that mandatory labelling will create a level playing field for farmers, allowing those farmers producing to higher standards to differentiate their products from lower welfare products, which may currently benefit from the use of undefined marketing terminology.
• The majority of respondents who agreed with mandatory labelling also suggested it would provide an opportunity to significantly improve animal welfare by incentivising higher welfare production to meet consumer demand. Many respondents cited shell egg labelling as a success story for mandatory method of production labelling, that resulted in a significant shift to approximately 80% cage-free UK egg production.
• Respondents who disagreed with mandatory labelling, including many respondents from industry, argued that the current landscape of voluntary and industry-led labelling is sufficient. Respondents expressed concerns about the potential costs of mandatory labelling and that method of production is an imperfect proxy for animal welfare due to variation in welfare within production systems. Some industry respondents were supportive of greater standardisation of terminology through legal definitions, for voluntary use by food businesses, to improve consistency in consumer information.

Question 34 asked: Do you agree that any new mandatory method of production labelling should apply to both domestic and imported products? Please explain your answer.

We received 30,378 responses to this question from:

• 30,231 individuals
• 147 organisations

Response	Individuals	Organisations
Yes	100%	86%
No	0%	9%
Don’t know	0%	5%

Summary of key themes for the open-ended question:

• Individual and organisations who agreed that labelling should apply to both domestic and imported products, cited the following reasons:
  • Consistency - respondents argued that adopting a consistent approach to labelling across all products would enable consumers to make informed purchasing decisions in line with their values.
  • Level playing field - respondents, including many from industry and a large majority of individuals, argued that mandatory labelling should apply to both domestic and imported products to ensure a level playing field for producers. Some respondents noted that this would avoid domestic products having to compete with unlabelled imported products that may have been produced to lower standards.
• However, some industry organisations and public sector bodies raised concerns about potential disruption to trade, disproportionate financial impacts for exporters and the practicalities of labelling imports, due to variation in standards between different countries.

Principles to reduce business impact (Questions 35 to 37)

Question 35 asked: What changes would your business have to make in order to adopt a mandatory method of production labelling scheme?

We received 64 responses to this question.

Summary of key themes:

• Many respondents, including many from industry and the majority of individual farmers, suggested that changes for their businesses would be minimal.
• However, the majority of industry respondents suggested that they would have to make changes to their business such as redesigning and replacing packaging and introducing additional data collection, record-keeping and product segregation. Some respondents suggested they would need to make capital investments such as upgraded IT systems and additional product storage facilities.

Question 36a asked: Do you think the proposed 18-month implementation period, intended to reduce the cost associated with applying new mandatory labelling is appropriate?

We received 423 responses to this question from:

• 304 individuals
• 119 organisations

Response	Individuals	Organisations
It is about right	37%	43%
It is too long	41%	10%
It is too short	7%	34%
Don’t know	15%	13%

Questions 36b and 36c asked: If you do not agree with the length of the proposed implementation period, what length of implementation period do you think should be allowed to help reduce the costs associated with applying new mandatory labelling? Please explain your answer.

Summary of key themes:

• Of the individual respondents who did not agree with the proposed implementation period, a large majority called for an implementation period of 12 months or less, citing the importance of improving consumer transparency and animal welfare without delay. The majority of farmers and individual respondents from the food industry suggested that a period of 18 months or less was sufficient.
• The majority of welfare NGOs suggested an implementation period of 12 months or less, citing an urgent need to improve consumer transparency; however, some NGOs suggested a 2-to-3-year implementation period to allow time to put traceability systems in place. One NGO noted that mandatory method of production labelling for shell eggs was introduced with a one-year lead-in time.
• A large majority of industry respondents suggested that the implementation period should be longer, with the majority suggesting 3 to 5 years. Reasons given for a longer implementation period included to minimise packaging waste and allow businesses time to update packaging and implement data collection requirements throughout their supply chains. Others cited a need to allow sufficient time for utilisation of existing frozen stock, to assess and make any changes to current production practices and to undertake consumer research and education.

Question 37 asked if there were any other ways in which costs associated with applying new mandatory labelling could be reduced. 

We received 82 responses to this question.

Summary of key themes:

• Responses from individuals included suggestions that costs could be reduced through financial support from government and clear and timely guidance for businesses. Some respondents suggested additional financial support or longer implementation periods for SMEs. Others suggested that a simple label design or allowing ‘over-stickering’ could reduce costs.
• Additional suggestions from NGOs included the use of existing assurance schemes to demonstrate compliance with new labelling requirements, the use of digital labelling through QR codes linking to online information to minimise on-pack label updates, part-automation of on-farm inspections and phased implementation.
• Further suggestions from industry included aligning with any wider changes to labelling requirements.

Scope of labelling (Questions 38 to 46)

Species (Question 38)

Question 38 asked: ‘Do you agree that labelling reforms should initially focus on pigs, meat chickens and laying hens? Please explain your answer.’

We received a total of 13,414 responses to this question from:

• 13,270 individuals
• 144 organisations

Response	Individuals	Organisations
Yes, I agree labelling should focus only on these three species initially	98%	35%
Yes, but I think labelling should cover more livestock species from the start	2%	37%
Yes, I agree labelling should focus only on these three species initially	0%	0%
Yes, but I think labelling should cover more livestock species from the start	0%	0%
No, I think labelling should focus on fewer or different livestock species	0%	7%
Don’t know	0%	6%
Other (please expand below)	0%	15%

Summary of key themes for the open-ended question:

• A large majority of individuals, the majority of public bodies and many NGOs and academics agreed with the initial proposed species, citing reasons outlined in the consultation, including that these species are farmed in the greatest number and have the greatest differentiation in production systems as well as existing standards to build upon. A large majority of these respondents also suggested that labelling requirements should be extended in future to cover all meat and dairy products, to bring wider benefits to consumers, farmers, food businesses and farmed animals, with some respondents calling for a clear timeline for expansion to other species. There was strong support in particular, for the future inclusion of dairy cattle, with respondents citing concerns about welfare and consumer confusion around production methods.
• The majority of industry organisations, many welfare NGOs and academics and a minority of individuals felt that labelling should cover more or all livestock species from the start. Reasons cited included consumer demand for information across all animal products, to drive welfare improvements across the whole livestock sector and to create a level playing field for farmers and food businesses across different sectors, including providing the opportunity for other livestock farmers to differentiate their higher-welfare products. Individuals and NGOs supported the inclusion of farmed fish in particular in initial reforms, citing welfare concerns and the large number of fish consumed in the UK.
• A small number of respondents suggested an initial focus on a smaller number of species, in order to trial the reforms before rolling out more widely. Laying hens and meat chickens were most commonly suggested as initial species due to established information on method of production for these species.

Level of processing (Questions 39 to 43)

Question 39 asked: ‘How important do you think it is that a method of production label includes processed as well as unprocessed animal products? Please explain your answer.’

We received 5,251 responses to this question from:

• 5,136 individuals
• 115 organisations

Response	Individuals	Organisations
Very important	41%	64%
Important	59%	17%
Neutral	0%	4%
Not very important	0%	4%
Not at all important	0%	7%
Don’t know	0%	4%

Summary of key themes for open-ended question:

• Of respondents who agreed that processed products should be included, the most commonly cited reasons were that there should be transparency and consistency across products regardless of their level of processing to help consumers to make informed choices. Some respondents noted that processed products make up a high proportion of products sold for some species. Many of these respondents, in particular individuals, argued that including processed products will help ensure that products with lower standards are not hidden behind undefined marketing claims.
• Of respondents who did not agree with including processed products, the main reason cited was the complexity and cost of extending the label to processed meat. Some industry respondents also disputed the suggestion that lower welfare standards are more common in processed products.

Question 40 asked: Do you agree that labelling should include minimally processed products for pork, chicken and eggs? Please explain your answer.

For pork, we received 14,370 responses to the question from:

• 14,254 individuals
• 116 organisations

Response	Individuals	Organisations
Yes, I agree that labelling should cover minimally processed products	1%	35%
Yes, but I think that labelling should cover more processed products from the start	99%	41%
No, I think labelling should only cover unprocessed products	0%	9%
Don’t know	0%	15%

For chicken, we received 14,369 responses to the question from:

• 14,252 individuals
• 117 organisations

Response	Individuals	Organisations
Yes, I agree that labelling should initially cover minimally processed products	1%	31%
Yes, but I think that labelling should cover more processed products from the start	99%	47%
No, I think labelling should only cover unprocessed products	0%	9%
Don’t know	0%	13%

For eggs, we received 14,361 responses from:

• 14,249 individuals
• 112 organisations

Response	Individuals	Organisations
Yes, I agree that labelling should initially cover minimally processed products	1%	34%
Yes, but I think that labelling should cover more processed products from the start	99%	43%
No, I think labelling should initially only cover unprocessed products	0%	6%
Don’t know	0%	17%

Summary of key themes for the open-ended question:

• A large majority of those that responded with comments across all sectors agreed that there was a need for consistency, clarity and transparency across all products.
• Respondents who supported labelling minimally processed products, including a majority of individuals, supported their inclusion due to the high consumption of processed foods in the UK, to maximise the impact of labelling and reduce potential loopholes.
• Responses also suggested that existing voluntary labelling of processed products, such as the use of free-range eggs in mayonnaise or cakes, demonstrates that labelling of processed products is feasible and considered beneficial by food businesses. Respondents suggested that labelling minimally processed products could help producers and retailers gain market recognition for a wider range of products and potentially facilitate a price reduction on premium cuts, due to there being less reliance on charging a ‘mark-up’ solely on a few high demand products (such as chicken breasts) to recover any additional costs of higher welfare production.
• Of those that did not agree, many raised concerns about the complexity and cost of labelling minimally processed products. Respondents highlighted the need for a clear definition of ‘minimally processed’, as an inconsistent interpretation could lead to confusion amongst consumers. Some suggested trialling labelling requirements with unprocessed products and extending to minimally processed products if there was consumer demand.

Question 41a asked: ‘To what extent do you agree or disagree that it is important that the following processed products be labelled with method of production standards?’

Overall, a large majority of individuals and a majority of organisations agreed with including each of the processed products, with little variation in responses between each product, as show in the table below.

	Total number of responses	Strongly agree	Agree	Neutral	Disagree	Strongly disagree	Don’t know
Bacon	314	92%	6%	0%	0%	1%	1%
Sausages	313	93%	5%	0%	0%	1%	1%
Gammon	313	93%	5%	0%	0%	1%	1%
Sliced Cooked Pork Meat	312	93%	5%	0%	0%	1%	1%
Scotch Eggs	313	90%	6%	1%	1%	1%	1%
Breaded Chicken	313	93%	5%	0%	0%	1%	1%
Ready-to-cook Chicken	311	94%	4%	0%	0%	1%	1%
Sliced Cooked Chicken Meat	313	93%	5%	0%	0%	1%	1%
Egg Whites	311	89%	6%	1%	1%	1%	2%
Hard Boiled Eggs	313	89%	7%	1%	1%	1%	1%
Quiche	312	88%	8%	1%	1%	1%	1%
Marinated Meats	312	91%	6%	1%	0%	1%	1%

Responses from organisations are summarised in the table below:

	Total number of responses	Strongly agree	Agree	Neutral	Disagree	Strongly disagree	Don’t know
Bacon	113	64%	9%	3%	4%	11%	9%
Sausages	114	65%	8%	3%	4%	11%	9%
Gammon	113	65%	9%	3%	4%	11%	8%
Sliced Cooked Pork Meat	114	65%	9%	3%	4%	10%	9%
Scotch Eggs	112	62%	12%	4%	4%	9%	9%
Breaded Chicken	113	65%	12%	3%	4%	8%	8%
Ready-to-cook Chicken	113	64%	12%	4%	5%	8%	7%
Sliced Cooked Chicken Meat	113	65%	12%	3%	5%	8%	7%
Egg Whites	112	62%	11%	4%	5%	8%	10%
Hard Boiled Eggs	113	59%	13%	5%	5%	8%	10%
Quiche	113	61%	11%	5%	4%	9%	10%
Marinated Meats	113	64%	14%	3%	4%	8%	7%

Question 41b asked: ‘If you would like to propose an additional priority for labelling, please state below.’

We received 145 responses to this question.

• The majority of responses simply called for all animal-origin products to be labelled, including products from both farmed and wild animals.
• Some respondents suggested specific additional pork, chicken or egg products for inclusion, including egg mayonnaise, freeze dried egg, charcuterie items, burgers, ready meals, sandwiches and baked goods such as cakes.

Question 42 asked: ‘If we did not use a list approach, please describe any alternative approaches you would propose to define which minimally processed products are included?’

We received approximately 134 responses to this question, although many of these did not suggest alternative approaches. 

• The majority of respondents, in particular individuals and industry respondents, suggested that we could define which minimally processed products are included based on a minimum threshold of animal product content, in line with the approach used for existing definitions of certain meat products under  The Products Containing Meat etc. (England) Regulations 2014.
• Some suggested defining which items are included by the procedure applied to them (e.g. curing, blending, cooking etc), building on existing definitions of processed and unprocessed products. Others suggested the potential use of broad retail categories such as chilled meats.
• Some respondents suggested that a list approach would require regular updates to adapt to food product innovation and any changes in consumption patterns. Some also raised concerns that a list approach would require clear definitions to avoid erroneously uncategorised items and possible ‘gaming’, for example by changing the name of items to avoid labelling requirements.

Question 43a asked: ‘To what extent do you agree or disagree with our proposal to label the production standard of only one ingredient when labelling minimally processed products (for example, Scotch eggs)?’

We received 411 responses to this question from:

• 297 individuals
• 114 organisations

Response	Individuals	Organisations
Strongly agree	14%	9%
Agree	13%	14%
Neutral	9%	10%
Disagree	25%	29%
Strongly disagree	31%	29%
Don’t know	8%	9%

Question 43b asked: ‘Do you agree with our proposal to assign production standards based on the lowest standard of animal welfare in a batch?’

We received 432 responses to this question from:

• 313 individuals
• 119 organisations

Response	Individuals	Organisations
Yes, I agree that the lowest standard should be labelled	78%	55%
No, I think that products should be labelled as containing a mix of welfare standards	17%	25%
No, I think the highest standard should be labelled	3%	6%
Disagree	0%	2%
Don’t know	2%	12%

How products are packaged (Questions 44 and 45)

Question 44 asked: ‘To what extent do you agree or disagree with our proposal that all unprocessed and minimally processed pork, chicken and egg products in scope are labelled regardless of whether they are packed at the consumer’s request, prepacked for direct sale or prepacked in a factory before sale? Please explain your answer.’

We received 426 responses to this question from:

• 309 individuals
• 117 organisations

Response	Individuals	Organisations
Strongly agree	82%	58%
Agree	14%	20%
Neutral	2%	6%
Disagree	0%	6%
Strongly disagree	1%	6%
Don’t know	1%	4%

Summary of key themes for the open-ended question:

• The majority of respondents across all groups wanted transparency and consistency regardless of how or when an item was packaged, stating this would help consumer decision-making.
• Those that disagreed, raised concerns around disproportionate complexity and the potential for error in segregating and labelling ‘loose’ foods, and the cost of verifying claims for these items. Some respondents felt that providing information at the point of purchase, for example, the meat counter would suffice instead of on-pack labelling.

Question 45 asked: ‘Do you agree or disagree that all unprocessed and minimally processed products in scope are labelled regardless of whether they are sold in shops, supermarkets, restaurants, cafes or from an online retailer? Please explain your answer.’

We received 28,537 responses to this question from:

• 28,423 individuals
• 114 organisations

Response	Individuals	Organisations
Strongly agree	100%	60%
Agree	0%	17%
Neutral	0%	4%
Disagree	0%	6%
Strongly disagree	0%	9%
Don’t know	0%	4%

Summary of key themes for the open-ended question:

• The majority of respondents, in particular individuals, called for consistency in labelling across all sales outlets. Reasons cited included benefits for consumer transparency, animal welfare and farmers meeting higher welfare standards, and avoiding the creation of potential loopholes. Respondents suggested that many products are already segregated and sold on a quality basis across these sales outlets and that extending this segregation to include production standards would therefore be unlikely to have significant impact.
• However, respondents from industry and some public bodies felt extending labelling to all outlets would be disproportionately complex and costly, particularly as many were small businesses with ever changing suppliers and dynamic menus. Some respondents noted that these outlets use other methods to inform their customers.

Food service sector (Question 46)

Question 46 asked ‘To what extent do you agree or disagree with our proposal that labelling applies to products sold through the retail sector only? Please explain your answer.’

We received 15,574 responses to this question from:

• 15,458 individuals
• 116 organisations

Response	Individuals	Organisations
Strongly agree	0%	4%
Agree	0%	12%
Neutral	0%	10%
Disagree	0%	27%
Strongly disagree	99%	42%
Don’t know	0%	5%

Summary of key themes to the open-ended question:            

• The majority of respondents who disagreed that labelling should apply only to products sold through the retail sector, including a majority of individuals and NGOs and many respondents from industry, argued that labelling should apply across all sectors due to the importance of consumer transparency in the food service sector.
• In addition, many respondents who disagreed, including a majority of industry respondents and many NGOs, felt that the food service sector should be held to the same standards as the retail sector and that it introduced unfairness if labelling is not applied consistently across different sectors.
• Respondents who agreed that labelling should only apply to the retail sector felt that it would be too complicated to introduce labelling for the food service sector, due to more dynamic, changeable supply chains. Some respondents suggested they would like to see method of production labelling start with the retail sector and then expand to the food service sector at a later date.

Defining production standards (Questions 47 to 54)

Standards based on inputs (Questions 47 to 48)

Question 47 asked respondents: ‘To what extent do you agree that standards should be based on inputs which are important for welfare, given the lack of examples of labels based on welfare outcomes and the additional supply chain complexity this would involve? Please explain your answer.’

We received 443 responses to this question from:

• 302 individuals
• 141 organisations

Response	Individuals	Organisations
Strongly agree	63%	30%
Agree	21%	30%
Neutral	5%	10%
Disagree	5%	11%
Strongly disagree	1%	15%
Don’t know	5%	4%

Summary of key themes for open-ended question:

• Respondents who supported basing the standards on inputs suggested they are simpler to monitor and therefore provide a more objective measure of the conditions in which animals are reared. Some respondents, NGOs in particular, argued that inputs are a key determinant of welfare as they describe the physical environment in which animals are reared, and therefore the ‘welfare potential’ of a system. In addition, respondents who supported basing the standards on inputs suggested that inputs are simpler for consumers to understand than welfare outcomes.
• Respondents cited issues with monitoring welfare outcomes, such as quality control, the large number of animals required to obtain statistically robust results and the increased inspection burden on farmers. Respondents suggested that further work is required to define the best outcome measures for each species and ascertain where any thresholds could be set, particularly for behavioural measures. Some respondents also suggested that fluctuations in welfare outcomes on farms which could occur from batch to batch would add complexity to supply chains, as frequent labelling updates could be needed, to reflect the label tier for each batch.
• Respondents who disagreed with the use of inputs suggested that outcomes are a better indicator of welfare. Some respondents, in particular those from industry, argued that outcomes are not necessarily dependent on the production system, citing examples of indoor systems which can achieve higher outcomes than outdoor systems. Respondents suggested therefore that relying purely on inputs could provide a misleading measure of welfare to consumers.
• Some respondents, including several NGOs and industry bodies, suggested that standards should be developed over time to incorporate both inputs and outcomes when there is a standardised and practical approach available. Respondents also suggested that welfare outcomes data could be used to assess whether inputs prove to be a reliable indicator of welfare.

Question 48 asked respondents ‘To what extent do you agree or disagree with requiring welfare outcomes assessments to be carried out for products labelled tier 3 and above? Please explain your answer.’

We received 427 responses to this question from:

• 291 individuals
• 136 organisations

Response	Individuals	Organisations
Strongly agree	50%	32%
Agree	30%	27%
Neutral	4%	12%
Disagree	3%	10%
Strongly disagree	1%	13%
Don’t know	12%	6%

Summary of key themes for open-ended question:

• Respondents who agreed that welfare outcomes assessments should be carried out for products labelled tier 3 and above felt that this was important for consumer transparency and trust in any labelling scheme. However, some respondents argued that lower tiers should also include an outcome assessment to ensure fairness across different production systems and ensure that this requirement does not create a disincentive for farmers to move to the higher tiers. Respondents suggested that it is important to encourage improvements in response to outcome assessments and suggested that this could be achieved by either requiring farms with poor outcomes to submit action plans in response to these and assessing farms on the effectiveness of their action to resolve any issues identified, as proposed in the consultation, or by using the results of outcomes assessments to inform the label tier applied to products from those animals.
• Respondents who did not support including outcomes assessment for tiers 3 and above provided a variety of reasons as to why these should not be included. Some respondents, including many from industry, argued that including outcomes assessments would increase costs, and be too complicated and burdensome on farmers, which could potentially disincentivise them from shifting to higher tiers.

Standard metrics (Questions 49 to 50)

Question 49 asked ‘Are there additional metrics you think should be included in the standards (set out in the table above)? If yes, then please list the proposed metric(s) and explain your reasoning’.

We received 137 responses for laying hens, 129 responses for meat chickens and 133 responses for pigs.

Summary of key themes:

• There were a number of suggestions for additional metrics to include in the standards, particularly from NGOs and academics. The most commonly suggested additional metrics across all species were:
  1. Inclusion of specific welfare outcome measures, such as levels of disease, injury, mortality, positive behaviours, and time spent outdoors
  2. Environmental indicators, such as levels of noise, humidity, air quality and temperature, litter quality, management.
  3. Herd or flock size
  4. Age at slaughter
  5. Access to veterinary care and health planning
  6. Type of feed and access to feed
  7. Usage of antibiotics
  8. Use of CCTV monitoring of herds/flocks
• The most commonly suggested additional metrics for laying hens and meat chickens specifically, were quality of range, including access to shade and shelter
• The most commonly suggested additional metrics for pigs specifically, were:
  1. Sufficient shade during the summer
  2. Use of teeth trimming and notching ears
  3. Bedding systems and provision of straw
  4. Weaning age

Question 50 asked ‘Are there any proposed metric(s) you think should NOT be included in the draft standards? If yes, please explain why.’

We received:

• 67 responses for laying hens
• 67 responses for meat chickens
• 69 responses for pigs

Summary of key themes:

• Specific metrics which some respondents suggested should not be part of the standards included:
  1. Beak trimming: it was argued that leaving beaks intact could result in poorer welfare outcomes for hens where feather pecking outbreaks occur.
  2. Outdoor access for pigs, laying hens and meat chickens: it was argued that issues relating to extreme temperatures, inclement weather and disease control mean that outdoor access may not always be desirable or possible in certain regions.

Setting tiered standards (Questions 51 to 52)

Question 51 asked ‘To what extent do you agree with the proposed tiered system above?’

We received 441 responses to this question from:

• 293 individuals
• 148 organisations

Response	Individuals	Organisations
Strongly agree	48%	27%
Agree	33%	28%
Neutral	6%	13%
Disagree	4%	10%
Strongly disagree	4%	19%
Don’t know	5%	3%

Question 52 asked ‘If you would like to suggest changes to the levels at which individual standards are set in the draft tiers, available in Annex B, please do so.  Please explain your answer.’

We received:

• 13,008 responses for laying hens
• 13,007 responses for meat chickens
• 13,014 responses for pigs

Summary of key themes:

• Respondents who agreed with the proposed tiered system felt that they provide a useful structure for the standards and a sensible way to differentiate between production systems. They also felt that the tiers were simple and understandable to consumers and would therefore help them make informed choices.
• Respondents who did not agree with the proposed tiered system, in particular respondents from industry, argued that:
  • methods of production do not necessarily indicate the level of welfare of an animal and using a tiered system to represent different production systems is therefore a subjective measure of the level of welfare within each system
  • the label tiers should align exactly with existing egg marketing standards for hens, and farm assurance scheme standards for pigs and meat chickens, for simplicity and to avoid additional burden on businesses throughout the supply chain
• Respondents suggested a variety of changes to the tiers, which are summarised below:
  • Placing Red Tractor core standards in a tier above the baseline. Some respondents, in particular from industry, suggested that including products meeting Red Tractor core standards in the proposed tier 4, along with products meeting the UK legal baseline tier would disincentivise farmers who belong to Red Tractor assurance scheme from continuing to meet standards above the legal baseline and therefore lead to the lowering of welfare standards. These respondents therefore suggested that Red Tractor core standards should be recognised as a separate tier to the UK legal baseline.
  • Some respondents, in particular NGOs, academics and individuals, suggested that more ambition was needed across the tiers to promote higher welfare standards. This included increasing space requirements for tiers 3 and 4, including outdoor access for tier 3, greater stipulations on light/dark requirements for tier 3 for meat chickens, not allowing temporary crating for tier 3 for pigs and inclusion of greater specification on outdoor access requirements. In addition, respondents suggested adding more detail on acceptable enrichment, especially for tier 3 for laying hens.
  • Removal of outdoor access as a criterion for higher tiers. Some respondents, particularly from industry, argued that outdoor systems do not necessarily correspond to better welfare outcomes. Some respondents also suggested that because outdoor systems are not feasible in all geographic areas, it should not be a requirement for the higher tiers.  Others, especially NGOs, argued that outdoor access provides greater welfare potential than indoor systems and should therefore be a criterion for the higher tiers.
• There were conflicting views on increasing or reducing the number of tiers.
  • Some respondents argued that fewer tiers would be simpler for both consumers and the supply chain, whereas others argued for an increased number of tiers. This was the case especially for the pig standards, where a majority of individuals argued that the greater variation in pig production systems would merit the inclusion of additional tiers to capture these differences, for example, respondents suggested splitting out outdoor-reared and outdoor-bred into separate tiers, which some respondents noted would align more closely with the existing Pork Provenance Code.
  • There were some suggestions to merge the top two tiers for each species; however, a large majority of individuals argued for keeping a distinction between them to ensure enough differentiation that farmers are rewarded for meeting the highest standard.
• Removing the requirement of verandas from the top two tiers for laying hens and meat chickens was suggested, especially by industry respondents, with some respondents arguing that verandas are impractical, especially for tenant farmers, while; however, others, especially NGOs, argued that verandas have a clear welfare benefit and should therefore be included.

Period of life covered by the standards (Questions 53 to 54)

Question 53a) asked ‘Do you agree with the proposal above detailing the period of life covered by the draft standards for each sector? Please explain why.’

We received 15,554 responses to Question 53a for laying hens from:

• 15,431 individuals
• 123 organisations

Response	Individuals	Organisations
Yes, it is the right length of time	0%	28%
No, it is too long	0%	3%
No, it is too short	99%	41%
Don’t know	0%	28%

We received 15,543 responses to Question 53a for meat chickens from:

• 15,421 individuals
• 122 organisations

Response	Individuals	Organisations
Yes, it is the right length of time	0%	43%
No, it is too long	0%	3%
No, it is too short	99%	29%
Don’t know	0%	25%

We received 15,535 responses to Question 53a for pigs from:

• 15,414 individuals
• 121 organisations

Response	Individuals	Organisations
Yes, it is the right length of time	0%	41%
No, it is too long	0%	2%
No, it is too short	99%	26%
Don’t know	0%	31%

Summary of key themes to open-ended questions:

• Respondents who felt that the period of life was too short argued that breeder lay, rearing pullets and male chicks should be included in the laying hen sector, grand-parent stock should be included in the pig sector and broiler breeders should be include in the meat chicken sector.
• A large majority of individuals and a majority of NGOs argued that method of slaughter should be included, either as part of the standards or as a separate label. These respondents suggested that method of slaughter, such as whether animals were stunned and for pigs whether CO2 was used for stunning, can play a large role in the overall welfare of an animal. Similarly, a majority of individuals and many NGOs argued that method of transport should be included, suggesting that this can be particularly stressful for animals and should therefore be included as part of the standards or included as a separate label.
• However, the majority of respondents, including the majority of industry and individual respondents, stated that the criteria used to differentiate the tiers should relate to the on-farm rearing phase only. Respondents argued that introducing transport and breeding stock in the tiers would introduce a level of complexity and potential contradictions, where animals spend some of their lives in different types of systems, which would make it difficult to categorise products into tiers. Respondents also suggested that farm assurance scheme labels can help to provide more detail on the full period of life, for example, method of slaughter, which could provide additional information alongside a method of production label for consumers who are concerned about this.

Question 54 asked ‘We are considering extending the period of coverage for laying hens to include the pullet rearing stage. Do you have any view on how this could be applied in practice and on the impacts of such an approach?’

We received 156 responses to this question.

Summary of key themes:

• Respondents provided a variety of views on how extending the period of coverage for laying hens to include the pullet rearing stage could be applied in practice. Respondents supportive of including pullet rearing in the standards felt that, as the pullet stage has a bearing on adult hen health and welfare, it should be included in the standards.
• Respondents who were not supportive of including the pullet rearing stage suggested that extending the period of coverage would be too complex to implement as it would introduce additional traceability and monitoring requirements. It was also suggested that as voluntary schemes, such as Lion Code of Practice and RSPCA Assured already include standards for pullet rearing, adding additional standards could be duplicative.

Label format and terminology (Questions 55 to 64)

Effective presentation of the product tier on the label (Questions 55 to 56)

Question 55 asked: ‘Which of the following would be the most effective for presenting the tier of the product on a label? Please explain your answer.’

We received 5,241 responses to this question from:

• 5,107 individuals
• 134 organisations

Response	Individuals	Organisations
Numbers	1%	15%
Letters	97%	19%
Stars	2%	24%
Letters or Numbers	0%	0%
Alternative option	0%	5%
I don’t want to see the tier included in the label format	0%	23%
Don’t know	0%	14%

Question 56 asked: ‘Do you feel that the label should include colours corresponding to each tier? Please explain your answer. If yes, please provide colour suggestions for each tier. Are there any impacts of inclusion of colour which should be considered?’

We received 421 responses to this question from:

• 291 individuals
• 130 organisations

Response	Individuals	Organisations
Yes, it is important for colours to be included	65%	52%
No, it is not important for colours to be included	20%	30%
Don’t know	15%	18%

Key themes for open-ended questions:

• Respondents who did not want to see the tier included in the label format, in particular those from industry, argued that animal welfare standards are too complicated to simplify into one label and that trying to do so could lead to confusion among consumers.
• Across all organisation types and individual types there was a consensus regarding certain elements. Common themes across all groups included:
  • Respondents who preferred using letters in the label design explained that with letters they found it easier to understand which tier is the highest and which is the lowest, compared with numbers and stars, which were felt to be potentially misleading.
  • Many respondents thought it was important to include a green to red colour spectrum to correspond against each tier with respondents noting that, while colours are helpful in conveying information quickly, another indicator, such as a letter grade should be included, so that those who are colour-blind can still understand the label.
• Respondents who did not think it was important for colours to be included provided a variety of arguments for this, including that:
  • colours could oversimplify the label or conflict with existing colours on labels such as for nutrition labelling
  • colours can be more expensive to print

Label terminology

Question 57 asked: ‘Do you feel the label should include terminology describing both method of production and level of welfare?’

We received 15,198 responses to this question from:

• 15,059 individuals
• 139 organisations

Response	Individuals	Organisations
Yes, both	2%	45%
No, a method of production descriptor only	98%	20%
No, a welfare level descriptor only	0%	5%
No, the label should not include descriptive terms	0%	13%
Other	0%	8%
Don’t know	0%	9%

Question 58 asked: ‘Please share any comments on the label terminology options based on the draft standards in Annex B.’

We received 74 responses on the level of welfare terminology and 90 responses on the method of production terminology.

Summary of key themes:

• Respondents who did not support the label including level of welfare terminology, including the majority of individuals and some industry respondents, argued that level of welfare terminology can be subjective and therefore could be misleading to consumers. Some respondents, in particular those from industry, also argued that including a level of welfare term would make the label too busy.
• Respondents who supported including both method of production and level of welfare terminology felt that the more information the better and that level of welfare terminology would make it easier for consumers to make informed choices according to their values.
• Some respondents felt that the method of production term ‘standard’ was not clear, and instead suggested using the term ‘minimum standard’.

Question 59 asked: ‘If you have proposed alternative production standards in your responses to previous questions, please provide suggestions for accompanying label terminology to match your proposals.’

We received 39 responses to this question. We received a variety of responses sharing terminology for suggested alternative production standards. We will consider all the responses offered to this question in any subsequent future policy development.

Additional label format considerations (Questions 60 to 64)

Question 60 asked: ‘To what extent do you support the inclusion of a picture illustrating the method of production? Please explain your answer.’

We received 431 responses to this question from:

• 293 individuals
• 138 organisations

Response	Individuals	Organisations
Strongly support	47%	25%
Support	17%	17%
Neutral	18%	16%
Oppose	9%	14%
Strongly oppose	3%	22%
Don’t know	6%	6%

Summary of responses to the open-ended question:

• Respondents who were supportive of including a picture, including a majority of NGOs and many individuals, explained that pictures can help to convey different production systems more successfully than words and that they help to make the information more accessible to consumers.
• Respondents who were not supportive of including a picture, including some individuals and many respondents from industry, argued that it is not possible to accurately represent different production systems through a picture and risks misleading consumers by oversimplifying different systems.

Inclusion of the assurance scheme logo to the label (Question 61)

Question 61 asked: ‘Do you feel that the label should include a space for an assurance scheme logo?’

We received 381 responses to this question from:

• 273 individuals
• 108 organisations

Response	Individuals	Organisations
Yes – the assurance logo should be part of the label	32%	33%
Maybe – it would depend on assurance scheme	35%	23%
No – the assurance logo should be separate to the label	17%	33%
Don’t know	16%	10%

Question 61b) asked: ‘Do you think it is important that the label tells a consumer whether the product comes from a farm which is assured or is not assured? Please explain your answer.’

We received 368 responses to this question from:

• 264 individuals
• 104 organisations

Response	Individuals	Organisations
Yes – it is important for the label to provide this information	61%	51%
No – this information is not relevant to the label	19%	35%
Don’t know	20%	14%

Summary of key themes:

• Respondents who supported including assurance scheme logos on the label felt that assurance schemes could provide confidence to consumers where they may already recognise assurance scheme logos. Others felt that it is helpful to consumers to know that products are assured.
• Many respondents who were not supportive of including assurance scheme logos on the label, suggested that consumers lack confidence in assurance schemes and therefore including them on the label would undermine the label. In addition, some respondents who were not supportive of including assurance scheme logos on the label suggested that consumers lack understanding of assurance schemes and associated standards and that the inclusion of assurance scheme logos could therefore confuse consumers.
• Some respondents supported including assurance schemes on-pack, separate from the method of production label to avoid consumer confusion and ensure that the full range of standards, such as method of slaughter and traceability, covered by assurance schemes is clearly communicated to consumers.

Comments on the mocked-up example label (Question 62)             

Question 62 asked: ‘Please share comments on the mocked-up example label.’

We received 278 responses to this question.

Summary of key themes:

• Some respondents, felt that there is too much information included on the mocked-up label which could confuse consumers. Conversely, other respondents felt that more detail is needed on the label to explain what the standards mean, such as an explanation for what terms like ‘enhanced’ mean.
• Some respondents suggested amending the colour scale to use a more traditional green-red spectrum, in line with existing nutrition labelling, and replacing the purple tier with orange.
• Some respondents were confused by the numbering of the tiers, and preferred either amending the tiers so that 5 is the highest tier and 1 is the lowest tier, or using letters instead.

Providing a link to further information on the label (Question 63)  

Question 63 asked: ‘Do you support providing a link to further information on the label?’

We received 423 responses to this question from:

• 291 individuals
• 132 organisations

Response	Individuals	Organisations
Yes	81%	73%
No	10%	14%
Don’t know	9%	13%

Summary of key themes for the open-ended question:

• The most common suggestion for how further information could be provided, was to include a QR code or URL to a webpage with further information, such as a GOV.UK page.
• Respondents who did not support providing a link to further information provided a variety of reasons. Some suggested that all relevant information should be on the label, while others suggested that consumers can find additional information themselves if they choose to.
• The most common suggestion for signposting consumers to additional information online was to include in store signage, such as posters.

Question 64 asked: ‘Please share any other comments on the label format and terminology.’

41 respondents provided additional comments on the label format and terminology. Comments in response to this question have been incorporated into the summaries of the above questions on the label format and terminology.

Monitoring and enforcement (Questions 65 to 73)

Question 65 asked: ‘To what extent do you support or oppose the proposed system of Food Business Operators (FBOs) being responsible for ensuring the labelling applied to their products is accurate? Please explain your answer and share any relevant supporting evidence.’

We received 342 responses to this question from:

• 237 individuals
• 105 organisations

Response	Individuals	Organisations
Strongly Support	35%	31%
Support	25%	31%
Neutral	10%	11%
Oppose	4%	8%
Strongly Oppose	8%	10%
Don’t Know	18%	9%

Summary of key themes to open-ended question:

• Many responses to this question, in particular from NGOs and individuals, suggested that independent enforcement is needed alongside FBO responsibility to ensure that labelling is accurate, and were concerned about placing too much responsibility with FBOs.
• Conversely, other respondents, in particular those from industry, argued that because FBOs are currently legally responsible for ensuring the accuracy of existing labelling, they are the right party to hold this responsibility for any new labelling scheme.

Question 66 asked: ‘To what extent do you support or oppose the proposal that membership of a recognised farm assurance scheme could be used by a Food Business Operator to help verify the production standards for UK farmers? Please explain your answer and share any relevant supporting evidence.’

We received 335 responses to this question from:

• 230 individuals
• 105 organisations

Response	Individuals	Organisations
Strongly Support	26%	29%
Support	31%	34%
Neutral	9%	12%
Oppose	7%	10%
Strongly Oppose	8%	7%
Don’t Know	19%	8%

Summary of key themes for the open-ended question:

• Respondents who supported the use of farm assurance scheme membership to verify the production standards provided a variety of reasons why:
  • Many respondents, including a majority of NGOs and many from industry, argued that this would reduce duplication of farm assurance inspections and burden on farmers.
  • Many respondents, including many NGO and industry respondents, argued that the use of farm assurance schemes would provide credibility in verifying standards.
  • Some respondents suggested the need for additional oversight from government to ensure consistency and accuracy in the verification of production standards.
• Respondents who did not support relying on membership of a farm assurance scheme, including many individuals and NGOs, argued that assurance schemes are not credible, citing recent investigations which uncovered assured farms not meeting the required scheme standards.

Question 67 asked: ‘To what extent do you support or oppose the proposal to use guidance to recognise bodies in other countries to help support labelling verification for the UK market? Please explain your answer and share any relevant supporting evidence.’

We received 328 responses to this question from:

• 227 individuals
• 101 organisations

Response	Individuals	Organisations
Strongly Support	24%	23%
Support	32%	40%
Neutral	14%	11%
Oppose	4%	5%
Strongly Oppose	3%	7%
Don’t Know	23%	14%

Summary of key themes for the open-ended question:

• Respondents who supported the proposal cited the following reasons:
  • Promoting international harmonisation of standards and facilitating trade by providing a level playing field for international products. Some respondents suggested this could also incentivise improved animal welfare standards in other countries.
  • Simplification of the compliance process and reduced cost burden for businesses and UK authorities, with some respondents suggesting that this approach is already aligned with existing practice.
  • However, some respondents who supported the proposal caveated that this approach would need to be supported by a robust monitoring and enforcement process to verify standards in other countries.
• Respondents who opposed this proposal raised concerns about how reliably standards would be verified in other countries, with some suggesting a need for UK or local authorities to perform additional assurance checks.
• In addition, some respondents, particularly from industry, suggested that all imported products should be required to meet a set of minimum standards comparable to domestic products in order to access the UK market.

Question 68 asked: ‘Please identify any assurance schemes or bodies operating abroad that you would see as equivalent to one or more of the different draft tiers, detailed in Annex B.’

We received 34 responses to this question.

Respondents to this question provided various suggestions of assurance schemes and bodies operating outside the UK or countries with existing schemes. Suggestions included:

• Beter Leven (in the Netherlands)
• Tierschutzbund and Haltungsforum (in Germany)
• Etiquette Bien-Etre Animal (in France)
• CIWF Italia/Legambiente (in Italy)
• Bedre Dyrevelfaerd (in Denmark)
• BePork (in Belgium)
• SPCA certified (in New Zealand)

Respondents also suggested that Global Animal Partnership and organic accreditation schemes operating in various countries would be equivalent to one or more of the draft label tiers.

Question 69: ‘To what extent do you support or oppose offering a process where country-level recognition could be included in the guidance if a country’s legal minimum standards met those of a particular tier? Please explain your answer and share any relevant supporting evidence.’

We received 323 responses to this question from:

• 225 individuals
• 98 organisations

Response	Individuals	Organisations
Strongly Support	17%	12%
Support	29%	40%
Neutral	18%	13%
Oppose	8%	10%
Strongly Oppose	5%	8%
Don’t Know	23%	16%

Summary of key themes for the open-ended question:

• Respondents who supported the use of country-level recognition argued that this was a fair approach that would facilitate trade by promoting mutual recognition of standards between countries and could also encourage the adoption of higher welfare standards in other countries.
• Respondents also argued that this approach would reduce burden for FBOs and UK agencies; however, some respondents who supported this approach caveated that this approach would need to be based on robust and reliable monitoring and enforcement of international baseline standards.
• Respondents who opposed the use of country-level recognition also cited concerns about variability in national monitoring and enforcement processes, with some suggesting a need for independent inspection. Respondents also suggested a need, alongside this approach, to recognise international production standards that exceed their respective national baseline.

Question 70 asked: ‘Under the proposals above, farm assurance schemes would need to submit documentary evidence that they certify to one or more of the label standards, in order to be included in the government register. How frequently do you feel this evidence should be re-submitted, to ensure the register remains accurate and up to date?’

We received 176 responses to this question. The majority of respondents across all groups suggested that farm assurance schemes should re-submit documentary evidence annually; however, several respondents from the public, NGOs, academics and industry suggested a lower frequency of up to 5 years.

Question 71 a) asked: ‘In cases where a Food Business Operator has not met their responsibility to accurately label products, we propose to ensure that prosecutions can be brought for the more serious cases of non-compliance. To what extent do you support or oppose this proposal?

We received 335 responses to this question from:

• 236 individuals
• 99 organisations

Response	Individuals	Organisations
Strongly Support	72%	44%
Support	17%	26%
Neutral	3%	6%
Oppose	0%	3%
Strongly Oppose	0%	8%
Don’t Know	7%	13%

Question 71b) asked: ‘If you oppose the proposal to allow criminal prosecutions to be brought for non-compliance, what alternative would you prefer? For example, civil sanctions. Please explain your answer and share any relevant supporting evidence.’

We received 45 responses to this question.

Summary of key themes:

• The most common suggestion for alternatives to criminal prosecutions was civil sanctions, including fines or monetary penalties.
• The majority of industry respondents who responded to this question suggested that advice should be provided to non-compliers on how they need to improve, or alternatively that a warning system should be introduced.

Question 71 c) asked: ‘If either criminal sanctions or civil sanctions are available, what do you think the appropriate penalties should be? Please explain your answer and share any relevant supporting evidence.’

We received 133 responses to this question.

Summary of key themes:

• Many respondents, including the majority of industry respondents and many NGOs, suggested that penalties should be proportionate to the non-compliance. Some respondents, in particular NGOs, suggested that penalties must be sufficient to act as a deterrent.
• Many respondents, in particular members of the public and NGOs, suggested suspending the FBO’s operations or suspended jail sentences for non-compliers.

Question 72 asked: ‘Do you feel there is an additional need for government inspections to form part of the certification for the label standards? Please explain your answer and share any relevant supporting evidence.’

We received 408 responses to this question from:

• 288 individuals
• 120 organisations

Response	Individuals	Organisations
Yes, there is a need for government inspections	81%	51%
No, there is not a need for government inspections	7%	37%
Don’t know	12%	12%

Summary of key themes for the open-ended question:

• Respondents who said that there is a need for government inspections provided a variety of reasons why. Many respondents, especially individual respondents and NGOs, felt that on-farm government inspections are necessary to increase the credibility of any labelling scheme and ensure there is accountability for producers.
• Some respondents suggested that the government should inspect assurance schemes to ensure they are upholding the standards which they set.
• Respondents who did not support additional government inspections, including many respondents from industry, argued that current assurance scheme inspections are sufficient and that government inspections would be costly and bureaucratic.

Question 72c) asked: ‘How could such a system, where government plays a role in certifying standards, operate for imported products? Please explain your answer and share any relevant supporting evidence, including any examples of existing systems you are aware of.’

We received 128 responses to this question.

Summary of key themes:

There was a range of views among those who responded to this question; with a lack of consensus around what role government should play. Some respondents suggested checks should be done:

• In the overseas country of production, for example, by the government working with foreign governments or independent third-party inspection bodies overseas, to certify standards in the country of production. Some suggested this could work similarly to existing mutual recognition of organic certification standards between countries.
• In the UK, by, for example, appropriate government bodies undertaking inspections at the point of import. For example, respondents suggested inspections could take the same form as existing inspections under the Official Controls Regulation, such as the phytosanitary controls.
• In both the overseas country of production and in the UK.

Question 72d) asked: ‘Please share any additional impacts you feel may result from requiring government certification and inspection, with any relevant supporting evidence.’

We received 50 responses to this question. Additional impacts suggested by respondents included:

• Additional cost and time burden on government resources.
• Additional cost and time burden on farmers and other businesses, with some respondents noting existing pressures associated with current audits. Some respondents suggested that this could lead to increased prices for consumers.
• Potential supply chain impacts such as loss of perishable products in the case of any delays caused by government inspections, or delays in bringing products to market due to increased bureaucracy.
• Some respondents commented that the new proposed measures would have little impact. However, others suggested that additional government oversight would provide greater accountability, leading to better welfare standards and increased consumer trust in the labelling scheme.

Question 73 asked: ‘Please share any further comments on the monitoring and enforcement proposals.’

We received 48 responses to this question. Comments in response to this question related to the previous questions and have been incorporated into the summaries of the relevant questions on monitoring and enforcement.

Impacts on businesses (Questions 74 to 78)

Geographic scope (Questions 74 to 76)

Question 74 asked: ‘Do you agree or disagree that our proposed method of production labelling requirements should apply on a UK-wide basis? Please provide any evidence to support your view.’

We received 399 responses to this question from:

• 287 individuals
• 112 organisations

Response	Individuals	Organisations
Strongly agree	88%	68%
Agree	9%	16%
Neither agree nor disagree	1%	4%
Disagree	0%	1%
Strongly disagree	0%	4%
Don’t know	2%	7%

We received 112 free text comments to the open-ended question, but little evidence was provided.

• Respondents who supported a UK-wide approach suggested that it would be consistent and less confusing for consumers who value transparency and animal welfare across the UK.
• Others suggested that a UK-wide approach would be fairer for farmers and raise welfare standards across the UK.
• Some respondents, particularly from industry, agreed requirements should be UK-wide as this would be simpler and less costly for businesses and avoid internal barriers to trade, as supply chains are generally UK-wide.
• Respondents also raised concerns that a GB-wide approach could create potential loopholes that would undermine the policy objectives and could disadvantage GB producers if goods from NI could be sold in GB without the same labelling requirements.
• Respondents who disagreed with a UK-wide approach, noted that any approach would need to be compatible with the Windsor Framework

Question 75a) asked: ‘What differential impacts would these proposals have on you and/or your business if mandatory method of production labelling requirements were to apply on a GB-wide basis only, and the principles of the UK Internal Market (UKIM) Act continued to apply, so that qualifying NI goods moving from NI to GB not meeting the method of production labelling requirements could be sold on the GB market?’

We received 58 responses to this question.

Summary of key themes:

• Many businesses and trade associations suggested that GB-wide labelling requirements would increase the complexity and cost of operations, and cause supply chain disruption; however, some businesses suggested that there would be little or no impact on them.
• Some respondents suggested that a GB-wide labelling approach could give an unfair advantage to NI products over GB products due to greater compliance costs for GB businesses and greater market access for NI goods that do not meet the labelling requirements. Some suggested that this could encourage GB businesses to relocate production to NI and for companies to import via NI.
• Respondents also raised concerns relating to transparency and consumer confusion, with many individuals suggesting that they would avoid purchasing products from NI if they did not meet GB labelling requirements.

Question 75b) asked: ‘How would your business manage these impacts if method of production labelling requirements were to apply on a GB-wide basis?’

We received 31 responses to this question, the majority of which were from industry respondents.

Summary of key themes:

• Responses from businesses and trade associations suggested that GB-wide labelling requirements would add complexity for domestic and international businesses, such as increased stock segregation and reduced flexibility in the supply chain and would therefore increase costs.
• One retailer who operates UK wide suggested that these issues could result in reduced product supply to NI. However, other respondents suggested that impacts could be managed without significant impact given a reasonable implementation period.

Question 76a) asked: ‘What differential impacts would these proposals have on you and/or your business if mandatory method of production labelling requirements were to apply on a GB-wide basis only, with respect to the movement of goods from GB to NI? How would your business manage these impacts if method of production labelling requirements were to apply on a GB-wide basis?’

We received 32 responses to this question, with the large majority from industry and trade organisations.

Summary of key themes:

• A large majority of respondents suggested that there would be additional production, supply and export complexity and cost if the proposals were to apply on a GB-wide basis only.
• One industry respondent raised concerns over having multiple tier labelling requirements across GB, NI and the EU, while another industry stakeholder suggested that NI products may be disadvantaged if perceived as a lesser standard due to the absence of the label.

Question 76b) asked: How would your business manage these impacts if methods of production labelling requirements were to apply on a GB wide basis?

There were 21 responses to this question.

Summary of key themes:

• The majority of responses suggested that labelling requirements applied on a GB wide basis would add significant complexity and cost for businesses.
• One retailer who operates UK-wide, suggested they would need to invest in additional staff, storage space and transportation in order to manage the need for segregation of products requiring different labels for different markets.
• Another retailer also raised concerns about the complexity and cost of potential divergence and suggested that they would take any available steps to avoid the need for separate labelling of products for GB and NI markets.

Supporting small and medium businesses (Questions 77 to 78)                                                                                                

Question 77 asked: ‘To what extent do you agree that this exemption would mitigate the burden on small businesses?’

We received 299 responses to this question from:

• 209 individuals
• 90 organisations

Response	Individuals	Organisations
Strongly agree	12%	17%
Agree	23%	23%
Neutral	22%	14%
Disagree	7%	12%
Strongly disagree	9%	7%
Don’t know	27%	27%

Question 78 asked: ‘What other exemptions might mitigate the impacts of our proposals on small and medium businesses?’

We received 79 responses to this question.

Summary of key themes:

• Many respondents disagreed with including any exemptions for SMEs. Reasons given for this included that exemptions would undermine policy objectives to increase consumer transparency and improve animal welfare.
• Many respondents, particularly from industry, also argued that exemptions should not apply to ensure fairness across the food sector and avoid creating loopholes. Some NGOs and individuals also suggested that SME exemptions could disadvantage small businesses that may be selling higher welfare products but would not be rewarded for meeting these standards in the absence of a label.
• Of the responses which suggested additional exemptions or other mitigations for SMEs, suggestions included financial support and additional time to transition, simplified compliance requirements, seasonal exemptions for businesses operating on a seasonal basis and exemptions for farmgate sales.

Impact assessment (Questions 79 to 90)

Direct costs (Questions 79 to 83)

Question 79 asked: ‘Based on submissions to the 2021 call for evidence, we understand that most food products have a routine labelling refresh every 1 to 3 years. For our central estimate, we assume that 80% of label changes can take place as part of routine refreshes. Do you agree with this estimate? Please provide evidence to support your answer.’

We received a total of 284 responses to this question from:

• 201 individuals
• 83 organisations

Response	Individuals	Organisations
Yes	13%	10%
No	2%	26%
Don’t know	85%	64%

Summary of key themes for the open-ended question:

• Among the individuals who responded, the majority thought that the estimate seemed broadly reasonable.
• Among the organisations who responded, there were mixed views. Many believed that the cost of labelling changes would be greater than estimated, with some noting that routine refreshes can be less frequent than 3 years. However, other industry respondents believed that the costs would be lower than estimated and suggested that labelling is updated more frequently than assumed in the consultation.

Question 80 asked: ‘If you are able to provide an up-to-date figure for the cost per SKU of labelling changes, please do so below. Please provide any evidence to support your response.’

We received less than 10 responses to this question. We will consider all the responses to this question in any future policy development.

Question 81 asked: ‘To what extent do you agree or disagree with our assumption that all producers will incur familiarisation and compliance costs as a result of these proposed labelling requirements? Please explain your answer.’

We received 271 responses to this question from:

• 186 individuals
• 85 organisations

Response	Individuals	Organisations
Strongly agree	16%	38%
Agree	31%	25%
Neutral	10%	7%
Disagree	3%	3%
Strongly disagree	1%	0%
Don’t know	39%	27%

Summary of key themes for the open-ended question:

• Respondents who agreed that all producers will incur familiarisation and compliance costs provided a variety of reasons, including:
  • Some respondents, particularly from industry, suggested that all businesses will need to spend time familiarising themselves with the implications of new labelling requirements.
  • Some respondents also suggested there would be compliance costs to meet additional auditing requirements and associated additional labour, in particular, associated with welfare outcomes data collection.
• However, some respondents, including industry bodies and individuals suggested that there would be limited familiarisation and compliance costs for some businesses, such as producers who are already members of assurance schemes or who sell direct to consumers, and for many retailers who already require full supply chain traceability.

Question 82 asked: ‘Please provide any further evidence on likely traceability costs for a business. Please specify the sector or group this evidence relates to, and use worked examples if helpful.’

We received 34 responses to this question.

Summary of key themes:

• A majority of industry respondents said that any additional traceability requirements created by the method of production labelling policy should and could fit into current traceability practices. Additionally, several industry respondents stated that supply chains were already auditable for method of production tracing. However, many other industry respondents suggested that any additional traceability requirements would create new costs for businesses due to costs around carrying out an audit, if new traceability requirements do not fit within current audit procedures.
• Many NGOs who responded felt that any additional traceability requirements should be integrated into current capabilities and that any additional costs would be minimal as many retailers and assurance schemes already require full supply chain traceability.

Question 83 asked: ‘Please provide any company-level data on the costs of undergoing an audit (for example, the costs to your business of undergoing a farm assurance scheme inspection).’

We received 25 responses to this question from a range of different categories of respondent. We will consider all the responses to this question in any future policy development.

Indirect Costs (Questions 84 to 85)

Question 84a asked: ‘To what extent do you agree or disagree with our assumption that retailers set prices at a product category or business level? Please provide any evidence you can to support your view.’

We received 267 responses to the question from:

• 192 individuals
• 75 organisations

Response	Individuals	Organisations
Strongly agree	10%	9%
Agree	22%	28%
Neutral	10%	8%
Disagree	4%	4%
Strongly disagree	1%	7%
Don’t know	53%	44%

Limited evidence was provided in response to this question. We will consider all the responses to this question in any future policy development.

Question 85a asked: ‘To what extent do you agree or disagree with our assumption that food business profits would overall stay the same in the long term? Please explain your answer.’

We received 268 responses to this question from:

• 193 individuals
• 75 organisations

Response	Individuals	Organisations
Agree	31%	19%
Disagree	0%	1%
Disagree, I think profits would overall decrease in the long term	6%	19%
Disagree, I think profits would overall increase in the long term	14%	5%
Don’t know	49%	56%

Limited evidence was provided in response to this question. We will consider all the responses to this question in any future policy development.

Business decisions (Questions 86 to 89)

Question 86a asked: ‘How do you anticipate the number of higher welfare (tier 1-3) unprocessed and minimally processed products on shelves in scope would change due to this intervention?’

For pork, we received 262 responses to this question from:

• 182 individuals
• 79 organisations

Response	Individuals	Organisations
Increase	48%	27%
Stay the same	5%	15%
Decrease	2%	6%
Don’t know	45%	52%

For chicken, we received 252 responses to this question from:

• 183 individuals
• 74 organisations

Response	Individuals	Organisations
Increase	49%	28%
Stay the same	4%	22%
Decrease	2%	5%
Don’t know	45%	45%

For eggs, we received 253 responses to this question from:

• 182 individuals
• 71 organisations

Response	Individuals	Organisations
Increase	48%	27%
Stay the same	7%	20%
Decrease	1%	3%
Don’t know	44%	50%

Summary of key themes for the open-ended question:

• Respondents who felt that the number of higher welfare products would increase, cited public interest in animal welfare, and suggested that purchasing behaviour would therefore shift in response to increased transparency. Many of these respondents referenced the case of shell egg labelling, which led to a significant shift in consumer demand towards higher welfare eggs, as evidence that such a shift in the market can occur.
• Respondents who felt that the number of higher welfare products would remain the same or decrease, suggested that price is the most important factor in consumer purchasing decisions, and that higher welfare products are already voluntarily labelled in the marketplace.

Question 87 asked: ‘What percentage of all imported unprocessed and minimally processed poultry and pig meat do you believe is used in processed products (retail and out of home sector)? Please provide any evidence you have to support your view.’

We received 124 responses to this question from:

• 86 individuals
• 38 organisations

Response	Individuals	Organisations
Less than 25%	1%	3%
25% to 50%	29%	18%
50% to 75%	44%	45%
More than 75%	26%	29%
Don’t know	0%	5%

Summary of key themes for the open-ended question:

• Across all respondent groups, many explained that their estimate for this figure was a guess, due to the complexity of the supply chain and limited available data. Some respondents suggested that meat is often imported due to its lower price and may therefore be of lower welfare standards, so is most likely to be used in processed products where there is less certification of standards.
• For pork in particular, one organisation suggested, based on AHDB’s Porkwatch in-store audit, which recorded 88% of fresh primary pork facings as British on average in 2023, and import data for fresh and frozen pork, that a significant proportion of imported pig meat is used in processed products.

Question 88 asked: ‘Please provide detail on any additional impacts you can identify to businesses (domestic or abroad) as a result of the proposals being applied to imported products. How do you think the cost and/or volume of imported products will be affected by the labelling requirements?  Please provide any evidence to support your answer.’

We received 49 responses to this question.

Summary of key themes for the open-ended question:

• Many respondents suggested that the cost of imported products may increase as a result of the labelling requirements, particularly if producers choose to invest in higher welfare systems, which could lead to increased prices of imported products.
• Respondents also suggested that demand for lower welfare products, such as those which do not meet UK baseline standards would decrease, which might result in a reduced volume of imports.
• A small number of industry respondents suggested that the labelling requirements could result in a reduced choice of products for consumers. In contrast, one retailer did not foresee any impact on the cost or volume of imported products, stating that they already required imported products to meet UK welfare standards.
• Some respondents also raised concerns that the labelling requirements consider applicable World Trade Organisation rules, to ensure fair treatment of domestic and imported products.

Question 89 asked: ‘Do you have any further comments on our Impact Assessment or any other evidence you would like to share with us?’

We received 23 responses to this question.

Summary of key themes:

• Some respondents suggested that the animal welfare benefits are likely to be significant and should be further quantified. Others suggested that further benefits such as reduced antibiotic use and disease incidence should also be included in the assessment.
• Some industry respondents raised concerns that further evidence is needed to demonstrate that farmers will be rewarded by the market for moving to higher-welfare production systems.
• Some public bodies noted the need to consider the costs to government to monitor and enforce the labelling requirements.

Additional Impacts

Question 90 a) asked: ‘To what extent do you agree that the proposals are likely to impact or improve relations between groups within the following categories protected under the Equality Act (2010): age, gender reassignment, being married or in a civil partnership, being pregnant or on maternity leave, disability, race including colour, nationality, ethnic or national origin, religion or belief, sex, sexual orientation?’

We received 286 responses to this question from:

• 209 individuals
• 77 organisations

Response	Individuals	Organisations
Strongly agree	8%	5%
Agree	5%	6%
Neither agree nor disagree	40%	21%
Disagree	6%	7%
Strongly disagree	7%	7%
Don’t know	34%	56%

Question 90 b and c asked: ‘To what extent do you agree that the proposals are likely to impact or provide an opportunity to improve relations between groups within the following categories protected under Northern Ireland equality legislation: persons of different religious belief, political opinion, racial group, age, marital status or sexual orientation, men and women generally, persons with a disability and persons without, between persons with dependants and persons without? Please provide any evidence to support your view.’

We received 282 responses to this question from:

• 205 individuals
• 77 organisations

Response	Individuals	Organisations
Strongly agree	8%	3%
Agree	6%	4%
Neither agree nor disagree	33%	23%
Disagree	6%	6%
Strongly disagree	6%	7%
Don’t know	41%	57%

We received limited responses to the open-ended questions. These responses generally suggested there would be no impact or opportunity to improve relations between these groups.

Wider labelling reforms (Question 91)

Question 91 asked: ‘We recognise that respondents to this consultation may wish to highlight other areas where labelling reforms could offer improved transparency and consistency, providing better information to consumers and enabling farmers to receive a fair market reward for producing high-quality, high-standard food. Please share any additional areas of potential labelling reform which may deliver the benefits described above, for future consideration. Please include evidence where available.’

We received 106 responses to this question.

Summary of key themes:

• The most common suggestions raised in response to this question related to method of slaughter labelling, carbon and environmental impact labelling and extending the method of production labelling proposals to include a wider range of species or a wider range of products.
• A small number of responses flagged other suggestions for wider labelling reform including:
  • The use of pesticides (suggestions were both as part of wider environmental impact labelling, and separately)
  • Genetically modified/engineered or precision-bred foods
  • Ultra-processed foods, or the degree to which a food is processed
  • Vegetarian and vegan foods
  • Information on animal feed type or content, including whether the animal was grass-fed and whether the feed contained potential carcinogens

Government response

This joint consultation was undertaken by the 2022 to 2024 Sunak Conservative UK Government along with the Devolved Governments.

Country of origin labelling

On country of origin labelling, we have noted the support of the majority of respondents for informative origin information, alongside the risks and barriers that have been raised about changes. We are committed to using this evidence on an ongoing basis as we consider the UK and Devolved Governments’ priorities on food labelling and information.

Method of production labelling

On method of production labelling, having considered all the responses to this consultation along with responses to the preceding 2021 Call for Evidence on animal welfare labelling, the UK and Devolved Governments recognise the strong support from members of the public and many other stakeholders for the provision of clearer information for consumers on the welfare standards of their food. 

We have heard and understood the views raised on the detail of the consultation proposals by the many interested parties who have responded to this consultation, and which are summarised in this document. We will consider all views as we go forwards, and will continue to work with relevant stakeholders including farming and food industry stakeholders, vets, scientists and NGOs as part of this continuing policy development.  

The UK’s food system is fully integrated across the four nations, although food labelling and animal welfare are devolved policy responsibilities. Recognising this, the UK and Devolved Governments will continue to work closely together on this matter, considering existing food plans and strategies across the four nations, such as the Welsh Governments’ work relating to food policy within Food Matters: Wales and the Scottish Government’s ongoing work to develop a national Good Food Nation Plan. 

The UK Government is committed to introducing the most ambitious programme for animal welfare in a generation. We are working in partnership with the food system to create an ambitious food strategy that will set the food system up for success and ensure that it can feed the nation, realise its potential for economic growth, protect the planet, and nourish individuals, now and in the future.

Recognising the strong support from the public and other stakeholders for clearer food information on welfare standards, we will consider the potential role of method of production labelling reform as part of the UK Government’s development of an overarching approach to animal welfare and the wider food strategy.  We will continue to work with the Devolved Governments on this.