The ACCC has called for public comment on the proposed Egg Standard Australia, the controversial industry standard that would allow massive increases to the stocking densities of free range layer hens and change how we farm free range eggs in Australia.
This is a one off opportunity to put an end to the industrialization of free range egg production! Don't miss it.
Download the ACCC letter here ....
Your Guide to Writing a Submission or Letter to the ACCC
Under the Trade Marks Act, an application for a Certification Trademark must first have its Rules and Standards examined by the ACCC to satisfy them that the applicant meets the technical requirements of the Act and not raise consumer protection, competition or associated concerns.
You will have to show the ACCC on what grounds they should deny this application. To do this, you will need to describe how AECL would affect consumer and producer rights and perhaps considerations of the Trade Marks Act.
Animal welfare will not come into this discussion. This is purely about what effect the proposed standards may have on consumer expectations and whether producers or other parties may be disadvantaged by these standards.
As a consumer, you could simply explain to the ACCC what your expectations are when you purchase free range eggs and perhaps your concerns that these eggs will become unavailable if this new standard defines free range for the entire industry and puts small producers out of business. Tell the ACCC the picture you have in your mind of what free range means and what you expect when you buy a carton of eggs labelled as free range. Example letter here ...
Producers, you need to discuss issues relating to the standards that you believe would be detrimental to the public. For example, would a consumer confusion over this new standard lead a consumer into error? Would a consumer buy ESA certified eggs with an expectation of what free range means? Would that expectation be based on the Model Code of Practice? Does AECL have any justification for increasing stocking rates?
Will this new standard mean unfair competition? Queensland already has legislation capping stocking rates at 1,500 per hectare. Will they be disadvantaged? There is currently a bill before SA Parliament to cap stocking rates at 1,500.
You can download a copy of the Egg Producers ESA Standard here ...
The Free Range section 3.19 appears on page 23 of the pdf.
AECL is the peak industry body that is supposed to represent all egg producers. Unfortunately the organization is structured so that the biggest producers have all the voting rights and control of AECL. The smaller true free range producer has no real input to industry decisions.
True free range producer need all the help they can muster to help stop the intensification of the free range industry for them, for you and most importantly, for the hens.
What is a Certification Trademark?
A CTM indicates to consumers that a product or service meets a particular standard. For example, the Heart Foundation Tick.
Send your comments to:
The General Manager Adjudication Branch
GPO Box 3131
CANBERRA ACT 2601
or email to: email@example.com
Closing Date: 20th June 2012
Example letter to the ACCC for Consumers
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