Egg grading, packing and marking, read from the regulation.

What R.345 is, and what it is not

GN R.345 of 20 March 2020, published in Government Gazette 43108, is titled Regulations regarding the grading, packing and marking of eggs intended for sale in the Republic of South Africa. It was made by the Minister under section 15 of the Agricultural Product Standards Act, 1990 (Act 119 of 1990), came into operation on the date of publication, and repealed the earlier egg regulations, R.725 of 16 September 2011 and R.440 of 15 April 2016.

It covers the eggs of domesticated fowls, turkeys and ducks (the definition of "eggs" in regulation 1). Regulation 2(1) sets the core rule: no person may sell eggs for human consumption in South Africa unless they are:

• sorted according to size and grade reg 2(1)(a), 3, 4
• compliant with the standards for their grade reg 2(1)(b), 5
• packed in containers and outer containers that meet the packing rules reg 2(1)(c), 6, 7
• marked with the required particulars, in the required manner reg 2(1)(d), 8 to 11
• marked correctly when sold loose reg 2(1)(e), 12
• free of restricted or prohibited particulars reg 2(1)(f), 13

The Executive Officer may grant a written exemption from these requirements, in whole or in part, on conditions reg 2(2).

Health and nutrition style claims are a third regime again: any marking that implies eggs are healthy or healthier, additive-free, or nutritionally enhanced must comply with the regulations under the Foodstuffs, Cosmetics and Disinfectants Act, 1972, and the producer, packer or retailer must provide scientific evidence for the claim if the Executive Officer asks reg 8(1)(h).

Who is in scope

Anyone who sells eggs for human consumption is caught by regulation 2. The marking duties fall mainly on the packer, which regulation 1 defines broadly:

• Producers who pack their own eggs are packers.
• Re-packers who take eggs out of bulk trays or outer containers and pack them into their own containers are packers in their own right, and the containers they fill must carry their details.
• Brand owners who have eggs packed for them are also packers, because the definition includes "a person on behalf of whom such product is packed". Their details replace the actual packer's on the container reg 11(3).
• Importers of eggs already in retail containers are packers.
• Retailers selling loose eggs must meet the display and notice board rules reg 12, and every seller is caught by the general prohibition on selling non-compliant eggs reg 2.

A "pack station" is any premises where eggs are packed for sale to the retail trade reg 1. The Food Safety Agency states on its website that it has been assigned to conduct egg quality inspections under the Act and R.345, and that these take place at producers, re-packers, pack houses, distribution centres and retailers.

Egg sizes (Table 2)

Sorting eggs into sizes is optional. If you do sort, you must use the mass ranges and the exact size designations in Table 2. If you do not sort, the eggs may only be presented for sale as "Mixed sizes" reg 3(1).

• The size designation on the pack must be one of the expressions in column 1 of Table 2 reg 10(2)(a). A size claim has to be true for the eggs in that pack.
• A limited share of sorted eggs may weigh up to 2 g under the minimum for their size. The permitted percentage per consignment is set for each grade in Table 4 reg 3(2), Table 4 item 9.
• Eggs that do not comply with the standards for sizes in Table 2 may not be presented for sale reg 4(2).

Grades 1, 2 and 3 (Table 3)

Regulation 4(1) is short: eggs shall be graded as Grade 1, Grade 2 and Grade 3. Eggs that do not qualify as Grade 3 may not be presented for sale reg 4(2).

A grade is met when the eggs satisfy the standards in Table 3, defects stay within the per-consignment limits in Table 4, and the sample count limits in Table 5 are not exceeded reg 5. The main differences between the grades:

For all three grades, Table 3 requires: no cracks; a regular shape; a strong and smooth shell; no blood spots, blood rings, diffused blood or meat spots; no mould, poultry faeces or abnormal odours; a clear egg white; no swimmers or bubbly air cells; and no decay or germ development. Table 4 then sets the small percentages of specific defects that a consignment may still contain for each grade.

Containers and packing

A container is the wrapper in which a maximum of 60 eggs are packed for sale. An outer container is a container in which more than one container of eggs is packed reg 1. So a 6, 10, 12, 18 or 30-egg pack is a container, and the box they travel in is an outer container.

Container requirements reg 6

• Intact, and made from material that is suitable for the purpose and does not impart any taste or odour to the eggs.
• Strong enough to protect the eggs from damage during normal handling and transport.
• Does not absorb so much moisture during cooling that it loses its intended form.
• Holds nothing except the eggs and their customary packing material. Advertising material on or in the container, or on the eggs, is permitted.
• May be new or recycled. A recycled container must be cleaned thoroughly first, and all previous marks and labels must be removed or covered by new labels.
• Closed properly, in the way its design allows.
• Containers and other packaging must be compatible with the outer containers and fit snugly, with no unused space or gaps.

Packing rules reg 7

• Pack every container and outer container to its full capacity.
• Do not pack eggs of different grades together.
• Do not pack eggs of different sizes together, unless the pack is marked "mixed sizes" reg 7(3), 10(2)(b).

What must be on the pack

Containers and outer containers must be marked at least in English. Other official languages may be added reg 8(1). All required information must be on a contrasting background, clearly legible, and at least the minimum letter heights in Table 1 reg 8(7).

On an outer container, size and grade may be shown as a list with tick boxes, as long as the ticked boxes match the eggs actually packed reg 8(1)(a).

Size and grade must be the most prominent text

The letters and figures of the size and grade designation may not be smaller than any other letter or figure on the container, except those in the packer's trade mark or brand name and in the expressions "Eggs", "Free Range Eggs" or "Barn Eggs" reg 8(9). In practice: if your marketing copy is set in 6 mm type, your size and grade must be at least 6 mm too.

Best before date reg 8(1)(f)

• Unpasteurised eggs: not more than 40 days from the date of lay.
• Pasteurised eggs: not more than 56 days from the date of lay.
• Preceded by "best before", "BB" or "best quality before".
• Shown as day-month-year (dd/mm/yyyy) when numbers only are used.
• May not be removed or altered by any person.

The limit runs from the date of lay, not from the date of packing. A re-packer needs the lay date (or a reliable earliest lay date) from the supplier to set a lawful best before date.

Optional particulars with conditions reg 9

• "Fresh" may be used only on eggs that meet the Grade 1 Haugh value at every stage of their shelf life. It may not be used on pasteurised eggs or on Grade 2 or Grade 3 eggs, and its largest letter may not exceed 5 mm.
• "Heat treated" may only be marked on a container of pasteurised eggs.

Imported eggs reg 8(8)

Eggs imported in retail containers must show "Imported from" and the country of origin with the packer details. Eggs imported in bulk and repacked must show "Imported from" followed by "Packed by". Imported containers must also state "eggs have been refrigerated" (or words with a similar meaning) on the top or front panel, and the name of the farm in the country of origin.

Packer details and traceability

What the packer block must say reg 11(1), (2)

• The initials and surname, or the trade name, of the packer.
• Followed by an address, which is either:
  • the physical address in South Africa of the premises where the eggs are packed, or of the packer's ordinary place of business, followed by the town, suburb, city or magisterial district; or
  • a postal address together with a telephone number.

Eggs packed on someone else's behalf reg 11(3)

If eggs are packed on behalf of another person, that person's name and address are used instead. That person must at all times be able to tell the Executive Officer who the supplier of the eggs is: "eggs shall at all times be traceable to the farm from which they originate" reg 11(3)(d). Keep the supplier, delivery and batch records that make this possible.

Eggs sold loose reg 12

• Keep eggs of different grades, types (pasteurised or not), sizes, origin and production system separate on display, except mixed sizes.
• Show on a notice board in the immediate vicinity, in letters at least 10 mm high: the size designation or "mixed sizes", the grade, the country of origin, the name of the packer, the best before date, and "pasteurised" where applicable.

Restricted wording on containers

Regulation 13 is the part of R.345 most often missed in pack design and marketing copy. It restricts three things on any container or outer container of eggs.

1. "Super" and "extra" reg 13(1)(a)(i)

These words, and their translations, may only be used as part of a size designation ("Super Jumbo", "Extra large").

2. Messages about rearing, medicines, safety or diet reg 13(1)(a)(ii)

No message of veterinary-medicine-free production, of more humane treatment or rearing of poultry, that the eggs are safer, or that the poultry was fed a special diet. The regulation gives examples "such as, but not limited to" the following, and ends the list with "etc.", so it is illustrative rather than complete. They are listed here only to explain that they are restricted:

3. Anything misleading, in words or pictures reg 13(1)(a)(iii), 13(1)(b)

Any other wording that is a misrepresentation, or that directly or by implication may create a misleading impression about the contents, quality, origin, grade, size group, production method or diet. The same test applies to any illustration, depiction or logo, so a picture can breach the regulation as readily as a phrase.

Only the production methods defined in the regulations (cage, barn and free range) may appear on a container or outer container reg 13(1)(c).

The pre-2016 trade mark exception reg 8(1)(b)(iii), (iv)

Two narrow carve-outs allow certain registered trade marks or brand names to precede or follow the word "eggs": marks that refer to a particular feed ingredient, and marks that include a farm name, an owner, packer or producer name, or a company name and make no health or nutrition claim. Both apply only where the mark was registered for use on eggs, or allowed on eggs, before 15 April 2016, the date the 2016 egg amendment regulations were published. A mark registered after that date does not qualify.

Free range, barn and cage

A production method is optional on the pack: it "may precede or follow" the word "eggs", in letters of the same size, font and colour, and the method stated must at least comply with its definition reg 8(1)(b)(i). If you state one, it must be true.

Avian influenza and Newcastle disease confinement reg 8(2)(a)(ii)(bb), 8(2)(b), 8(2)(c)

During the high risk period for Highly Pathogenic Avian Influenza, or an outbreak of virulent Newcastle disease, free range flocks may be housed indoors for a maximum continuous period of 24 weeks during a year and keep the free range marking, provided that:

• the 24 weeks start on the day the flock is confined;
• the producer informs the designated assignee on or before the first day;
• the producer keeps accurate records of when the flock was confined and when it went outdoors again;
• the producer informs its distribution channels and their customers, on or before the first day, that the flock is confined under veterinary instruction, and advises them to display notices telling consumers about the confinement (Table 1 also sets a minimum letter height for the confinement indication).

If the 24 weeks are exceeded, all eggs produced after that must be marked and sold as "barn eggs" reg 8(2)(b). Distributors and retailers are part of this chain: if a supplier tells you a flock is confined, the notice obligation is aimed at you too.

R.6634 and production-method claims

R.345 is no longer the only regulation that touches the words "free range". This section sets out what the newer regulations say, and is careful about what has not yet been confirmed.

What the regulations say

• GN R.6634 of 19 September 2025 (Government Gazette 53361), the Regulations relating to the Management Control System in respect of the sale and export of certain agricultural products, was made under section 15 of the same Act. It came into operation 12 months after publication R.6634 reg 20, which is 19 September 2026.
• A "management control system" is a method of production claimed through a name, word, expression or indication, alone or together with illustrated or visual material R.6634 reg 1.
• No person may use a management control system in connection with the sale of agricultural products unless it has been applied for, processed, registered with the Executive Officer, labelled as the regulations require, and audited R.6634 reg 3(1). The Executive Officer may grant written exemptions R.6634 reg 3(2).
• Users of a registered system are audited by the assignee, at their own expense R.6634 reg 16.
• R.345 itself anticipated this. Its minimum requirements for "barn eggs", "cage eggs" and "free range eggs" apply only until regulations for management control systems addressing those methods have been promulgated R.345 reg 17.

What is not yet clear

• At the time of writing we have not been able to confirm, from the department's published register, that a management control system for free range eggs has been registered, who the assignee for it is, or how packers and re-packers (as opposed to farms) are expected to come under it.
• The department has circulated draft method-of-production protocols for comment, including one covering free range poultry meat and eggs. Drafts are not law, and their final wording may differ.
• R.6634 contains a transitional provision for products that have been marketed under a name for at least five years before a notice of application is published R.6634 reg 15. How it applies to egg claims has not been confirmed.
• How R.345 reg 17 interacts with R.6634 in practice, including whether the R.345 definitions still apply until a free range system is registered, is a question for the department.

Inspection, offences and self-audit

An "inspector" under R.345 means the Executive Officer, an officer under his or her control, or an assignee or an employee of an assignee reg 1. Inspectors may take whatever samples they consider necessary reg 14. Samples are numbered and examined visually and by candling, air cells are measured with a calibrated plate (or the inspector may use the Haugh value instead), and defects are expressed as a percentage of the eggs inspected reg 15. The Haugh value is measured with a Haugh meter or micrometer, with the egg brought to between 7°C and 15°C reg 16.

Contravening or failing to comply with any provision of R.345 is an offence, and on conviction a person is liable to a fine or imprisonment in accordance with section 11 of the Act reg 18. R.6634 has its own offence provision R.6634 reg 19. We do not quote penalty amounts here; read section 11 of the Act and take advice if you need them.

A short self-check before an inspection

1. Every size designation on your packs is one from Table 2, and is true, or the pack says "Mixed sizes".
2. Every grade says Grade 1, Grade 2 or Grade 3, and nothing else.
3. Size and grade are on the front or top panel, at least 5 mm, and no other text (except brand and "Eggs") is taller.
4. The packer name and address are on every container, at least 1 mm.
5. Best before is no more than 40 days from lay (unpasteurised), dd/mm/yyyy, preceded by "Best before" or "BB".
6. Recycled trays and boxes have had all previous marks removed or covered.
7. No restricted wording or imagery on packs, notice boards, website or social media.
8. Any production method stated is defined, true and evidenced.
9. You can trace every pack back to the farm it came from.

The free PDF expands this into a full, ticked self-audit with a column for evidence and actions.