TOPIC (Testing of Products Initiated by Consumers) is a consumer-led organisation funded by consumers and retailers that are committed to transparency. We use laboratory testing, farm and factory visits and any other means necessary to verify that ingredients and label claims are accurate. 
Top consumer-nominated label claim
Pick n Pay free range eggs was the next top nominated product as chosen by consumers after TOPIC’s successful investigation into Elgin Free Range Chickens label claims.
At the end of 2019, the TOPIC SA team launched into its eleventh investigation to verify the Pick n Pay free range eggs label claim. For a combination of reasons, this report has taken a very long time to complete!
South Africa’s free range egg industry
According to the South African Poultry Association (SAPA), in 2019 South Africa had 25 million laying hens producing an average of 50 million dozen eggs per month, which equates to 600 million eggs per month or 20 million per day. Only 1 million of those laying hens were classified as free-range.
SAPA and the South African government classify egg production systems into four types: barn, caged, enriched-cage and free-range.
In 2020, SAPA informed TOPIC that the number of laying hens had increased to 29 million hens nationally. We have enquired about the total number of free range hens in 2020/2021 but have not received an update.
According to a comment from SAFCEI in an article from June 2021 in the Daily Maverick: “Over 86% of egg-laying hens in South Africa spend their entire lives in cages no bigger than an A4 sheet of paper.”
What is the definition of ‘free range’ eggs in South Africa? 
For the consumer, the term “free range” evokes an idyllic image of free roaming chickens scratching for worms and pecking at grass, then going to roost at night in a hen house. Additionally, it is sometimes assumed that free range hens feed themselves by foraging and are not fed a diet by the farmers/producers. The reality for some free range hens is quite different to consumer perceptions, especially in terms of the legal regulations for free range egg producers.
The rules regarding the conditions under which hens produce eggs that can legally be labelled free range are set out by Regulation 345 under the Agricultural Product Standards Act, 1990. The Department of Agriculture, Land Reform and Rural Development (DALRRD) released these revised labelling regulations in March 2020:
SA Poultry Association (SAPA) free range guidelines 
Established in 1904, SAPA was instrumental in setting up the now defunct egg board. They developed a Code of Practice with the intention of having minimum standards for all poultry and poultry products produced in South Africa. SAPA is not able to enforce these standards as they are a voluntary organisation.
Their Code of Practice takes cognisance of the internationally accepted ‘Five Freedoms’ in animal husbandry:
Why are consumers choosing free range eggs over cage or barn eggs?
According to research, consumers buy free range eggs because they believe that the hens are “happier”, “healthier” and that the eggs “taste better”. “Hen welfare” is rated as “important”.
The difference in price between free-range and cage eggs is quite significant. Price differences on Pick n Pay online as of 14 January 2022, shows that shoppers will pay between 8% to 64% more for eggs labelled as free range over non-labelled cage eggs.
Engaging with Pick n Pay
In November 2019, TOPIC contacted Pick n Pay requesting documentation which either supports or confirms the free range status of their eggs. We also requested a farm visit so that we could see the production facilities.
Two weeks later we received a response stating that Pick n Pay has six suppliers producing their free range eggs in various regions across the country. They also said the following:
In early February 2020, we contacted them again and asked for a copy of the report from their most recent external audit or inspection. We also emphasised that we understand biosecurity concerns and had complied fully during our Elgin farm visit the year before, therefore would they reconsider the farm visit to one of their Western Cape suppliers.
After some prompting, they responded in March with an apology for the delay and permission to contact three of their six suppliers:
- Windmeul Eggs, Paarl, Western Cape
- Alzu, Middelburg, Middelburg, Mpumalanga
- Quantum Foods, Wellington, Western Cape
Windmeul Eggs
Windmeul Eggs’ main free range farm is called Dundarach Poultry Farm and is located in Paarl in the Western Cape. Windmeul also produces conventionally farmed eggs at other farms. 
We first contacted Windmeul Eggs in February 2020, and received the following comment from Windmeul Eggs spokesperson, whose name we were asked to withhold:
“Currently due to high alert of HPAI, they are kept indoors. Normally the pop holes are open 24 hours and we close certain farms under normal conditions at 20:00 due to natural predators.”
Then, on the 27 March 2020, the South African government locked down the country in response to the Covid-19 pandemic and this investigation was necessarily paused. As restrictions began to be lifted, we contacted Windmeul Eggs in June to ask if it would be possible to arrange a farm visit for us to see the production facilities.
The spokesperson replied:
“Thank you for your interest in our product. We will gladly schedule a visit to one of our free range farms. We are currently on full lockdown due to the winter season being a very high Highly Pathogenic Avian Influenza (HPAI) risk period. Furthermore, the COVID 19 pandemic has our pack station also closed to outside visitors for obvious reasons. I am more than happy to set up a date and time in October [2020] when we are in a better position to open up.”
Due to ongoing events at the end of 2020 and delays over the holiday period, we were unable to conduct a farm visit in 2020. We contacted Windmeul Eggs in March 2021 to try again.
The spokesperson replied:
“Thank you for the enquiry. Unfortunately with a high alert announced on HPAI we are under strict instructions to close all production farms for unnecessary traffic in and out of the premises. I am sorry to have to decline but again will be more than happy to assist in November in the warmer climate.
Quantum Foods
Quantum Foods is an animal feed and poultry business, and claims to be the largest producer of eggs in South Africa. Nulaid is the name of the egg-layer division of Quantum and the group owns 12 commercial layer farms, with free-range eggs being produced on two of these farms. One of these is in Gauteng and the other one is in the Western Cape.
Nulaid’s spokesperson was quick to respond to our first enquiry into their free range status, as follows:
“Hereby we confirm that all eggs that we pack as free range, are produced by free range hens, on our free range farms. We adhere fully to the SAPA definition of free range hens and eggs. We also use an external company to audit our free range operations.”
Nulaid also supplied the name of the company that does their welfare audit and we began discussing a possible farm visit, which Nulaid was open to and which was planned for April 2021.
Initially, Nulaid wanted a Pick n Pay technologist to accompany our team on the farm visit. However, after an exchange of emails, Pick n Pay’s spokesperson stated that a technologist from their team was not necessary as our visit was “not a PnP initiative” and was not part of the retailer’s normal scope.
Nulaid then agreed to the TOPIC visit, however a week or so prior, there was another outbreak of bird flu. The Nulaid spokesperson said the following in April 2021:
“I am sure you have heard about the big outbreak of bird flu in South Africa. This happened last week-end.
“Unfortunately, due to the huge risk, we don’t allow any people, except the farm workers, onto any farms. As soon as I get the go ahead from the relevant executive, I will let you know. We can then decide on a date that is in order for you.”
By May 2021, four different strains of bird flu had been detected at South African poultry farms. According to an IOL report from August 2021 “nearly 2.7 million birds in the broiler and egg industries” were culled as a preventative measure which represents around 2% of the national flock.
Free range hens may legally be confined indoors during bird flu outbreaks
The DALRRD regulations make a dispensation for altered living conditions for free range flocks during high risk periods of HPAI. Under these conditions, free range laying hens may be confined indoors 24 hours a day continually during an outbreak of bird flu, for a maximum of 24 weeks during a year. If this 24 weeks is extended, the producer is permitted to sell the eggs labelled as ‘barn eggs’, as the permitting stocking density in sheds is the same for barn and for free range laying hens. There is no DALRRD regulation preventing farm visits, audits or inspections during such periods.
There have been high risk periods and outbreak periods for HPAI intermittently in South African in both 2020 and through most of 2021. In a follow up email to Pick n Pay on 28 September 2021, we asked:
Please can you provide records of the dates that your supplier’s free range hens have been confined indoors during the avian flu outbreaks of 2020 and 2021?
Pick n Pay replied: “This can be obtained from the supplier.”
In a follow-up question in January 2021, we asked: What is the current status regarding avian flu on your supplier’s farms?
We received a reply on this from Pick n Pay relating to Windmeul farm:
“The last known commercial outbreak was in November and DAFF extended the moratorium on keeping birds indoors until end of February.”
We also asked: Are consumers notified that the free range hens are confined indoors due to avian flu outbreak? And if so, is the period of confinement clearly specified ?
Pick n Pay replied, with an example of the posters displayed in-store:
“Yes, directive was given by the Department of Agriculture on the period that the free range hens were allowed to be confined indoors and posters were placed in our stores notifying customers of this dispensation.”
Alzu Eggs
Alzu, like Nulaid, is a large South African company with multiple divisions including feeds, beef, eggs and petrol service stations.
Alzu Eggs buys day-old chicks which are then transferred to the company’s laying sites at 17 to 18 weeks. According to their website, they have two laying sites, one is a “caged-housing systems for commercial egg production”, while the other is a “free range housing system”.
On their free range eggs, they state the following: 
We first contacted Alzu Eggs in mid-August 2020 asking for any documentation supporting or confirming the free-range status of their eggs. We received no response from them, and we emailed them again in November 2020.
We eventually received the following response from an Alzu spokesperson in early November:
“We have a veterinarian that audits the facility regarding the free range standards.”
They also provided us with some information about Alzu’s free range egg operations from their auditing veterinarian:
TOPIC returns to the retailer
In April 2021 we emailed Pick n Pay to request a copy of the free range audit that Windmeul Eggs had informed us had been done. Their spokesperson replied as follows:
“Yes we indeed are busy with Free Range GAP audits with certain suppliers and NSF is doing the audits for us, as it was only a GAP audit we are not distributing the audits done at the fresh poultry and egg pack stations as we are still fine tuning the audits, we are having a meeting with NSF next Thursday to confirm the final audit criteria and will then engage with all the suppliers identified in both fresh poultry and eggs and will then start actively audit all in later part of this year on this audit.
“Windmeul’s audit was done in January and the GAP audit done was on an audit criteria that covered both fresh poultry and eggs, so will not give a true reflection on the egg pack station, once the actual audits start the suppliers will be able to share their audits and results with you.
“We are very excited about this development and don’t want a R&D version of the audit in the public that might get circulated and then is not the final one and comments are made on it.”
We replied that this meant that at this time, we had still been unable to verify any of their free range labelling claims. Their spokesperson replied:
“At the moment the AI [Avian Influenza] is hindering our visiting of plants and implementation of the new audit.”
She also attached a customer fact sheet on Pick n Pay’s free range eggs.
What are the differences between an egg laying chicken that is intensively farmed, free range or pasture reared?
It may not be clear to the consumer as to the actual differences between different chicken production methods, so we have outlined them in the table below.
For the purposes of this table, we have compared cage, barn and free-range. Pick n Pay’s suppliers follow SAPA free range standards. On shop shelves, cage or enriched-cage is never found on an egg label but eggs labelled “barn” and “cage-free” are to be found, as well as “free-range” and “pasture-raised”.
The information was sourced from SAPA’s 2018 Code of Practice. 
Left: Hen comes down ramp from shed. Windmeul. Right: Hen at Alzu. Images supplied by suppliers via Pick n Pay.
Hens in outside area. Windmeul. Image from supplier via Pick n Pay.
Hens in outside area. Windmeul. Image from supplier via Pick n Pay.
Hens in outside area at Alzu. Images from supplier via Pick n Pay.
What do Pick n Pay free range egg chickens eat?
Pick n Pay states the following:
“The broilers are fed a scientifically formulated commercial 100% plant origin feed that may not contain any protein derived from animal origins (including bird, mammal or fish). However, the rearing feed for egg-laying chickens will include fishmeal as the protein and calcium is vital to the birds’ health and productivity.
“The feed mills blend different feeds that are available to the industry.”
What about antibiotic use?
We asked Pick n Pay if the free range hens producing the eggs are given routine antibiotics and what the antibiotic protocol is in case of disease.
Pick n Pay replied:
“There is no antibiotic routine and only given for specific issues. The antibiotic protocol is specific to each farm and their assigned vet. Should the hen be sick and require antibiotics, the farm will follow a withdrawal period that the farm’s vet closely administrates.”
“We have a policy of medicating the birds if there is a known problem that can be identified. As a company we have a rule to withdraw these eggs for a 14 day period. There are protocols and processes in place that are documented and audited.”
Do Pick n Pay’s free range egg suppliers use hormones, growth stimulants or other feed additives, and if they have documentation or testing that verifies this?
Pick n Pay stated the following:
“For broilers, the use of in-feed growth promoters and/or digestive enhancers is prohibited. The use of any other feed additives is discouraged and avoided as far as possible. In-feed antibiotics may only be given for therapeutic reasons under the direction of the attending veterinarian and appropriate withdrawal periods must be observed and documented.”
“No hormones, growth stimulants or additives are added to the feed for free range egg laying hens. This can be verified at the farms as the vet on site keeps records of this.”
What happens to the chicken waste?
We asked Pick n Pay what the protocol for chicken waste is on the farms that supply them with free range eggs. Pick n Pay replied:
“As we use six suppliers across the country, the protocol is unique to each farm.”
Pick n Pay free range egg supplier compliance
Pick n Pay’s suppliers follow SAPA’s Code of Practice and guidelines for free range hens, as well as the South African government’s 2020 free-range egg labelling regulations. SAPA’s standards are more concerned with the welfare of free range laying hens than the current legislation, and is more comprehensive about both indoor and outdoor conditions for the laying hens.
Pick n Pay stated the following about their processes being monitored:
“Farms and abattoirs are regularly inspected by Pick n Pay Food Technologists to ensure that the standards and requirements are met. Third party food safety audits are also carried out on a regular basis by Pick n Pay approved independent auditors at the abattoirs.”
No documentation supporting this claim was sent to TOPIC.
Industry stakeholder comments
TOPIC reached out to numerous industry insiders for comment on the final report but unfortunately we did not receive much feedback.
Solitaire free range egg farm owner, Graham Grindley-Ferris, said the following:
“The stocking density standards and living standards specified by SAPA and referenced by these companies are in line with our understanding of acceptable free range standards and practices, to which we at Solitaire adhere or exceed.”
In a transparent manner and without prompting, Grindley-Ferris also attached examples of Solitaire’s free range proof and credentials referenced by poultry vets.
He further said:
“My view is that the unrealistic and strict ‘access’ controls are completely over the top. It’s simply a matter of inviting you in, provided you have not been on another poultry farm within the past day or so and provided your boots / vehicle / clothing are cleaned, there is NO problem at all to access and view the hen houses and camps…as all our staff do on a daily basis.
In fact staff and suppliers are more risky because they travel and move between hen houses and sites multiple times per day! Please visit us at Solitaire and come and view specifically what a compliant free range farm should look like.”
Pick n Pay response
In reply to the statement from Solitaire’s Grindley-Ferris, Pick n Pay’s spokesperson said:
“Our agreement with suppliers doesn’t extend to the entry policies on their business premises. You are welcome to make contact with the farms again with any further questions.”
Conclusion
Both Windmeul Eggs and Nulaid state that they are compliant with SAPA’s code of conduct and guidelines, and then would also appear to be compliant with the limited free range egg labelling legislation.
SAPA’s conditions make reasonable provision for the welfare of hens raised in free range production systems. They allow for adequate rest, expression of natural behaviours, protection from predators and from the sun, and six hours of continuous daytime access to vegetated areas, but SAPA does not monitor or audit its members.
The TOPIC team has not received evidence to support the claims of conditions at Pick n Pay’s suppliers (whether from Pick n Pay or their suppliers, or from audits) and due to a combination of Covid-19 lockdowns, and farms not allowing visits due to the Avian influenza outbreaks, TOPIC has been unable to be on site to verify such claims.
In response Pick n Pay states:
“We are concerned that the report strongly infers that because you couldn’t visit any farm, that they are not free range. This as you know, is not true, and we don’t believe fair to our suppliers who are reputable brands. As you know, access to the farms has been very limited with the pandemic, lockdowns and AI (Avian influenza) persisting. We checked the status on farm visits and these are still on hold but they’re happy to welcome you as soon as restrictions have lifted, hopefully Nov/Dec. Windmeul Eggs and Alzu have kindly shared photos of their farms.
“We have visited all the supplier farms and they follow the SAPA guidelines. As you are probably aware through your investigations, free range in South Africa is self-regulated, so we have invested in developing our own free range audit which is currently underway. I can share the auditing criteria for you to have sight of it but it can’t be for distribution or be published as it is still underway and our IP.
“I would really appreciate it if you could take these points into consideration for your report, as it is really unfortunate our suppliers are being judged by conditions outside of their control.”
TOPIC always strives to be objective and only report on facts as we know them. We have not made any inference from the fact farm visits were not possible to arrange due to external factors despite our best efforts. We would have liked to wait until visits could be arranged, but since this investigation started at the end of 2019, we felt it necessary to complete and release this report even if it is in some ways incomplete. Should a visit be arranged in the future, we will publish a follow-up report.
As always, we believe well informed and aware consumers are crucial for holding suppliers and retailers accountable and hope that the information above will go some way towards achieving that in regard to free range eggs. It is also important that suppliers are aware that questions are being asked, and that they need to ensure their internal processes are well defined, documented, up to date and open to public scrutiny.
TOPIC works with retailers and producers who are committed to transparency and we are supported by Faithful to Nature, Wellness Warehouse, Organic Zone, Jackson’s Real Food Market, Bryanston Organic & Natural Market and UCOOK.
We have completed numerous successful investigations so far, including Naturally Organic, Elgin Free Range Chicken, Nature’s Choice GMO-free claims, Woolworth’s organic vegetables, Cape Town Market, Mrs BreadCare, Wakaberry, Le Chocolatier, Freedom Bakery, Frys and Futurelife.
Consumers are encouraged to nominate products for investigation via our online form: https://buff.ly/2PCSBK8
Follow us on Facebook or Twitter or contact the TOPIC SA team via email.