Farming roadmap 2050: Fairness in the supply chain

Defra published the Farming roadmap 2050 this summer and outlined key aspects for the supply chain fairness.

It was stated the ongoing pressure on fertiliser and fuel prices because of the closure of the Strait of Hormuz underlined the need to shift to a more resilient farming system.

The key points to ensuring improved fairness and transparency in supply chains was stated to include:

• Bringing into force ‘fair dealings’ regulations for each relevant sector to target specific issues without broad and burdensome rules

• Enforcing these regulations in relevant sectors through the Agricultural Supply Chain Adjudicator (ASCA), building on the enforcement regimes already operating in the milk and pig sectors, providing a clear route for farmers and primary producers to raise concerns around contractual unfairness

• Introducing regulations for eggs and fresh produce, having already done so for the dairy and pig sectors

• Supporting clearer food labelling by working with farmers, food businesses, vets, scientists and animal welfare groups to strengthen information on origin and production standards

A key part of achieving fairness in faming is therefore based on the ‘fair dealing’ regulations. Although, where these have been implemented already in the pork and dairy sectors, many farmers have complained processors continue to maintain an unfair amount of power, using it to their advantage through periods of extreme price volatility. If these regulations are pushed out into all sectors then it will be important for every farmer that there is clarity around the application of that power.

Eggs

Defra consultation on the egg sector ran from December 2023 to February 2024, with a summary of responses published in May 2024.

The first draft of the egg fair dealings proposals was published in March 2025, followed by a second version in summer 2025, feedback on that version closed in September, finally further refinement led to version 3 being circulated in January 2026.

Current position

The version 3 consultation reportedly included revisions relating to:

• Notices to disapply the regulations

• Supply periods and purchase agreement terms

• Supply volumes

• Referral of variable pricing disputes to an independent third party

• Specifications

• Termination rights

• Dispute resolution procedures

One of the most significant areas was the scope of the regulations and how they define which producers are protected. It had been decided that protections apply to egg producers only, with packers and processors excluded on the basis that many are already covered by the Groceries Supply Code of Practice (GSCOP) in their retail dealings. Defra has indicated that this approach is consistent with the underlying aim of the Fair Dealings framework, which is to protect primary producers rather than regulate the entire downstream chain.

However, defining who qualifies as a protected producer has proven to be one of the most complex aspects of the policy. Under the current draft, scope is defined as applying to a primary producer that is not also a registered egg packing centre with the Animal and Plant Health Agency (APHA). Defra acknowledged that this wording has raised concerns and has assured industry they understand the importance of the issue and confirmed that work is ongoing to refine the wording so that producers are not inadvertently excluded. Version 3 is expected to be the final policy iteration; however, it is expected to be accompanied by guidance intended to explain and interpret the legislation.

Fresh produce

Defra has also published draft policy proposals for 'Fresh Produce Fair Dealings' regulations under the Agriculture Act 2020. The public consultation ran in early 2024. Defra shared its first draft proposals for minimum contract regulations in March 2025 and a second version later that year, with feedback closing later that year. The direction of travel is towards minimum contract regulations for fresh produce similar to the rules already in force for dairy and pig supply chains.

• Milk regulations are already in force through the Fair Dealing Obligations (Milk) regulations 2024

• Pig regulations are already in force through the Fair Dealing Obligations (Pigs) regulations 2025

To read the full summary of responses and intentions for fresh produce, visit the Defra consultation outcome page. 

Current position

The draft proposals would apply broadly to purchasers of fresh produce and include requirements such as:

• Mandatory written contracts

• Minimum contractual terms

• Contract duration requirements

• Volume commitments and over/under-supply mechanisms

• Pricing transparency and pricing mechanisms

• Product specifications and tolerances

• Transparency on deductions and charges

• Force majeure provisions

• Cooling-off rights

• Termination provisions

• Variation procedures

• Dispute resolution mechanisms

Defra also indicated that it was considering regulating certain commercial behaviours occurring before contracts are concluded, following evidence gathered that unfairness can arise during crop-planning and pre-contract negotiations. If retained, this could go beyond the milk and pig regulations and potentially address issues such as:

• Excessively late contracting before planting or harvesting decisions

• Uncertainty around volume commitments

• Delayed confirmation of purchasing requirements

Defra has not yet published final measures, but it is the area most likely to create new obligations that are not seen in the existing milk and pig regimes.

Combinable crops (cereals, oilseeds and pulses)

In December 2025 Defra launched a consultation. The consultation covered:

• Cereals (eg. wheat and barley)

• Oilseeds (eg. oilseed rape)

• Pulses

Defra stated that the review was intended to build upon the fair dealing reforms already undertaken/being undertaken for dairy, pigs, eggs and fresh produce.

The Contractual practice in the UK combinable crops sector consultation in particular sought the views of farmers, traders and processors about:

• Clarity of standards

• Sampling and testing procedures

• Supply volumes

• Data sharing

• Dispute resolution

The consultation ended in February 2026 and responses are being reviewed.

Overview

ASCA enforcement

Any final SI is likely to be enforced through the Agricultural Supply Chain Adjudicator using essentially the same model as milk and pigs. Existing powers include investigations, civil penalties and compensation remedies.

For a retailer, importer or processor, the safest assumption is that eggs, fresh produce and eventually combinable crop contracts will ultimately need to look much more like regulated milk and pig supply contracts: written, transparent, formula-driven, with clear volume, pricing, specification, deduction, variation and dispute-resolution provisions, and subject to ASCA enforcement.

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