The letter, which invokes the behavior of "dominant egg producers," largely provides data on one company, Cal-Maine Foods, the biggest producer and marketer of shell eggs in the country.
Separately, Democratic voices are urging the Trump administration to take action around corporate conduct as it relates to food prices. FTC Commissioner Alvaro Bedoya, a Biden appointee, has also urged Ferguson to open an investigation into egg production and marketing practices—pointing to a 2023 request from Farm Action to the FTC to investigate potential antitrust violations in the egg industry.
And last week Sen. Elizabeth Warren (D-Mass.) wrote that she had sent President Donald Trump a list of ways he "can use his executive authority to tackle high food costs by focusing on corporate profiteering."
Egg prices have risen starting in 2022, coinciding with the arrival of bird flu in the United States, and are likely to keep rising in 2025.
The wholesale price of "Grade-A, Large, White, Shell Eggs" rose from $0.50-$1.30 per dozen in 2021 to $1.50-$5.00 per dozen in 2022, and then eased in 2023 before climbing up again in 2024. As of January 2025, the national index of weekly prices for that same type of eggs was up to $6.00-$8.00 per dozen, according to Farm Action.
"The previous all-time high [for wholesale prices] was late December 2022 heading into Christmas, when we touched $5.46 per dozen," Ryan Hojnowski, a market reporter at Expana, wrote in an e-mail to CNBC. "Of course we have blown way past that this time."
Retail prices have also increased. Retail prices for large, Grade-A eggs reached an average of $4.25 per dozen in December 2022 after never reaching above $3 a dozen in the 2010s. Retail prices declined in 2023 and then rose again throughout 2024, reaching $4.15 per dozen in December of last year.
Farm Action argues that while bird flu has been cited as the main driver for rising egg prices, its actual impact on production has been minimal. According to the letter, bird flu has forced the culling of roughly 115 million egg-laying chickens, but the impact of these losses on the total size of the U.S. supply of egg-laying flock has been "relatively modest." Huffman wrote that this culling has caused egg production to drop from 8.1 billion eggs per month in 2021 to 7.75 billion eggs per month at the end of 2024.
But crucially, according to the letter, per capita production of eggs has not been below per capita consumption of eggs in any year between 2022 and the present—while the total value of egg production has risen from $8.8 billion in 2021 to $17.9 billion in 2023.
Cal-Maine specifically has seen its profits soar. The company tallied gross profits of $179.6 million in fiscal year 2020, but the producer reported $1.2 billion and $541.6 million in gross profits in fiscal year 2023 and 2024, respectively, according to the letter. Between fiscal year 2020 and fiscal year 2024, sale levels have remained fairly consistent, wrote Huffman.
"Evidence indicates that by not increasing their supply, the five dominant egg firms are forcing prices to stay high while reporting dramatic profit increases and level sales. These same firms are then using their increased profits to acquire their competition, further driving market consolidation instead of investing in replenishing or expanding their flocks," Farm Action wrote in a statement on Wednesday.
As evidence, they cite a number of mergers that took place in the industry in 2023, and point to the fact that the top five egg producers' share of the "U.S. layer hen flock" increased from 37% to 46% between 2023 and 2025.
"There appears to be a remarkable unwillingness among large egg producers to invest in the internal reconstruction or expansion of their egg-laying flocks in response to persistently high prices," wrote Huffman, which she contrasts with the quicker flock recovery that took place during the first bird flu outbreak in 2014-2015.
The "lagging recovery" and "the fact that egg producers are showing unusual discipline in their pricing and output decisions" indicates that market forces are not "operating as they should be." The letter suggests a few factors that may contribute to the lack of competition.
The group is urging the two agencies to launch investigations, specifically encouraging the FTC to launch an investigation into pricing and production practices of dominant egg producers and their hatchery suppliers to make sure the market is "truly free and fair."
This is far from the first time that the food and grocery industry has been accused of inappropriately raising prices.
In August 2024, a top executive at the supermarket chain Kroger even admitted under questioning from a Federal Trade Commission attorney that the grocery chain raised its egg and milk prices above the rate of inflation.
