The absolute state of being a small Scale egg farmer in ontario
August 2024
This essay is piggybacking off of a YouTube video I did on the economics of being a small scale egg producer (100 or less hens) in which I spoke about some nitty gritty elements related to expenses, marketing, and whether or not you can actually make any money. In this piece, I’d like to dig into the regulatory state of trying to produce eggs on a small scale in Ontario.
I got thinking about this after I had a conversation with a customer at our farm. She wanted some eggs and, after running inside to get some for her, she told me she would love to stop by on her way back into the city to pick some up. “Sure” I said, expecting her to want a dozen or two. “How about a dozen, dozen” she responded matter of factly. I explained to her that 12 dozen would be 3 or 4 days worth of production for my free range flock. She looked disappointed and I was disappointed that I couldn’t provide what she wanted – and that I was forced to let a good sale go due to something outside of my control.
Now, in my definitely very free province of Ontario, nobodies like me are allowed to own an absolute maximum of 100 laying hens. Why is this? Is it for the protection of the birds? The protection of me? The protection of you?
Let’s look at the pork industry for a second. There are currently no regulations defining how many hogs I can have: I could have two, or twenty, or two hundred. Nobody wants to come and inspect my property to ensure they have adequate space. Nobody comes to look at what I’m feeding them. Pigs, as you probably know, have the capacity to be a vector for human diseases and can be highly destructive to property if they escape. Yet there is no regulatory body preventing me from doing whatever I want with pigs on my own property.
Now, I’m not looking for some overzealous government employee to jump up out of their chair and hurry off to regulate my modest hog operation. I’m just shining a light on one of my other enterprises to show the lack of congruency in regulations for farmers.
All of my animals are regulated by different governing bodies that have varying levels of control over their respective industries. Chickens, and chicken eggs, are one of those industries that lean almost into cartel territory. For chicken eggs, specifically, the governing body in Ontario is the Egg Farmers of Ontario (EFO); a private body that has been deputized with regulating egg production within Ontario including the who, what, when, where and why you can access eggs. Like other government-adjacent corporations, they are run by people you and I did not elect. In fact, you likely have not, and will never hear about the people running the EFO or, in most cases, the EFO itself.
As a small scale egg producer, the EFO mandates that I may only have 100 hens. I also cannot sell my eggs anywhere outside of my own property without first undergoing an expensive and time consuming ‘grading’ operation which, it should be noted, is not generally available or viable for such a small amount of eggs. The EFO can show up at any time to confirm these rules are followed. Case in point, if I try to sell some eggs out of a cooler to people at the local arena, the EFO can come with a cease and desist – or else.
I know some backyard chicken holders might not think 100 chickens produce a ‘small’ amount of eggs, but keep in mind a chicken lays, at best, one egg daily. The production of my free-range heritage flock is booked solid every week at my little on-site farm stand.
I also don’t think the 100 bird max is for the protection of the birds. Here’s a photo taken from a training video provided for me in my artisanal broiler chicken farming program. This is a battery cage hen, clearly worse for wear, who is in fact alive at the time this screenshot is taken. Battery cages – where birds are crammed into tiny cages and unable to flap their wings or stretch, are currently how the majority of eggs in Ontario are currently grown. Notably, the growers employing this practice happily have their quota.
The chicken in this photo is ‘inside’ the system, while I am outside it. This hen does not look very protected to me.
**Note – The source video for this image is on vimeo and I am unable to provide a link as it’s only accessible through certain accounts such as my meat chicken governing body**
So back to my question: Why the limit? Could it be to protect the existing egg farmers from competition? So, you say “stop being a silly libertarian and play ball! Get in the official system and start producing eggs!” Okay let’s explore that.
If I want to play ball, I need to purchase “quota” from the governing body. Quota speaks to how many chickens – or ‘units’ as they call it – I am allowed to have on my farm. What do you think the minimum quota required to get involved is? After scouring documents, forms, and contracts I can only find the following number: 5000. And, as of 2022, according to the EFO, a “unit” was $295 (**UPDATE** as of 2025 this unit cost has increased to ~$450).
So, to step foot into the “real” world of growing eggs, I need to lay out $1,475,000. Yes, one million four hundred and seventy five thousand dollars.
This is just for the privilege to grow the eggs. It doesn’t include the actual chickens, or the barns, or the silos, or the myriad of other equipment that would cost another million or two to get started. How in the world do they expect anyone to get involved? Ah, but they’ve started a program: the “New Entrant Support Program”. The EFO will graciously ‘loan’ you half of that, so you have to put forward a measly $737,000 and they will front you the rest. However, moving forward you get to spend the next 20 years being a serf, making just enough money to pay back the EFO loan. And likely the loan on the millions of additional dollars of infrastructure you bought.
Where does this leave us? Well, it doesn’t leave us with more small scale egg producers raising free range flocks and meeting the needs of the market. It means:
- No young farmers, unless they are inheriting quota and hardware
- No new farmers from another industry without unrealistic financial backing
- Larger and larger conglomerations buying up all the quota: think family dynasties and/or corporations.
According to the EFO, in 2022 there were 435 quota holding egg farms in Ontario with an average of 22,775 hens per quota holder. I am not a threat to these farms. I would fail to be a threat if I could grow 500 chickens. So why the limits on my production?
Well, it’s not me in particular they are afraid of. Rather they are afraid of ‘us’: the estimated 1,500 small scale egg farmers in Ontario throttled by the 100 bird limit. ‘Us’ is also you – the diligent egg enjoyer who goes out of their way to look for small scale, responsibly grown, truly free range eggs. If even half of those 1,500 small scale producers began growing 500 hens under good management practices, that would insert 375,000 ‘units’ into the market. 375,000 units that none of the giant industrial producers could hope to match on quality. 375,000 units that would be circulating eggs demonstraing that good food can truly come right from the farm. Moreover, showing that we don’t need Burnbrae or the EFO or even the Federal government between my eggs, my farm, and you.
Now, I’m not some super libertarian who thinks that any oversight is a bad thing. But let’s be honest, none of these rules are there to protect you or me. They are to protect the quota holders from us. Worse yet, it prevents me, and farmers like me, from giving you, the customer, what you want. I can’t bring it to you and, even worse, you can’t come to me and get what you want when you want it. The fact that people cannot readily access enough high quality foods as basic as an egg is an affront.
Here are some of the things people have said about our eggs:
- “You’re free range right? I just don’t trust the eggs they try and sell at the supermarket”
- “These are the best eggs I’ve ever had, and that includes years of fine dining crap in Toronto”
- “Oh goodie! This is fantastic news, your eggs are THE BEST.” (after getting a spot in our weekly egg subscription)
I’m not saying this to boast. I’m saying this because I am so throttled by the regulatory body, I’m prevented from and unable to supply a market that clearly exists. People are, almost literally, fighting to get my eggs. While that’s all great and gives me a sense of pride, a sense of pride does not pay the bills. Without being able to take advantage of at least a small level of economy of scale, being a small scale egg producer makes almost no sense here in Ontario. I responsibly raise my chickens. I don’t push them to their maximum production. I don’t cull them at 2 years and force molt them to squeeze every egg possible out of them like they are a machine. I respect my animals, and I respect my customers, and I am punished for that.
The 100 hen limitation isn’t a random selection by the EFO. After doing the accounting, I would need to have around 300 hens to have it start making real economic sense. I wonder why the EFO selected 100 birds, instead of 50, or 500? (As an aside, 500 birds was the grandfathered flock limit prior to 1983.) Could it be that 100 birds is just low enough to make it economically impractical as a business model, but just high enough they can say they’ve given some ground? notably, in Alberta, Saskatchewan, and Manitoba farmers are allowed to have 300 hens. Ontario MUST do more for their small farms.
They (the quota holders) have every financial incentive to push me, and by association you, out of the market and sit comfy in their chokehold on the industry and on their battery cage chickens. This has to stop.
We – small scale farmers and the general public – need to demand better. We need to demand that small scale egg producers be able to hold more chickens in their flocks. We need the big quota conglomerates off our neck to allow small entrepreneurs to actually enter into the business.
Links & Sources
Animal Justice: Understanding the Labels: What’s the Real Deal on Egg Farming Systems
BCSPCS : Egg farming in Canada
CBC News: Canadian Egg Farmers to Abandon Battery Cages by 2036
EFO: Learn More About Our Operations Quota
EFO: 2024/2025 Quota Transfer System Schedule
A unit or single quota is roughly $450 at auction now. Ridiculous
Great information and I totally agree with the many points you made and I also learned something new. Yes we the people must demand better! Not only for ourselves, the quality of eggs but for the unfair treatment of hens in the large scale operations here on ontario. Thank you
Would one be able to have 100 chickens under, for example, one or more different ‘owners’ (whether corporations or sole proprietorship) using the same farm facilities?
Hens are at least partially tracked via property addresses so multiple “owners” using a single property would likely have to share the bird allotment rather than be able to circumvent it. Conceivably though, if one ‘owner’ had a number of different locations, they could register birds to each individual address using different company names or some such. Daily egg collecting could become quite the nightmare though!
This is very well written and makes a very good argument. As well as product quality and animal welfare I feel there is an environmental argument to be made for increases to small scale flock owners. Systems of huge scale are more energy hungry, create water pollution if manure isn’t handled with best management practices, and prevent innovation through functional design allowing chickens to play a part as an element in regenerative agriculture models.
The story of environmental benefit, product quality through nutrient analysis, and cobenefits of enhanced animal health and farm Stewardship would be difficult for the EBO to publicly argue against. Chickens and humans have colonized the world effectively for a reason. People have forgotten that and we have allowed industry to retell that story with their own spin making what they do seem best for everyone. People not having access to both types of farms to use all there senses to determine which is best makes arguing policy change a difficult conversation.
Maybe steadily increasing grocery prices will help encourage more people to seek alternative ways to find loopholes in these controls which will make it harder for industry to explain their rules to skeptical educated consumers. In the meantime thanks for telling your story
this article is very useful, thank you for making a good articl
How does the Alderwood brand operate?
It’s the only brand we buy at the super market, their eggs are certainly better than conventional.
Are you then allowed to collect eggs from small scale farms, package and resell?
Seems a bit too bold of a move.
I don’t know the Alderwood brand of eggs so I cant speak of them from a place of knowledge, but their website would imply that, yes, they are an egg reseller rather than an actual producer. My guess would be that they run or have access to an egg grading station and they work with a very large number of small(er) farms to have the farms’ eggs graded before selling them under the ‘Alderwood’ banner (all eggs sold off farm properties – this includes grocery stores and farmer markets – must pass through an inspected grading station first; and there aren’t many of those around). Note that this doesn’t necessary mean their eggs are now “lesser”. You already know that they are better than standard grocery store eggs. They very well (and hopefully do) source their eggs from pastured / free-range local farms! Its just hard to know as their website also doesn’t name any of their producers (that I saw in my very cursory look).
Time to Lobby the Provincial ministry of agriculture to be in line with other provinces.