Free Range Egg Claims Don’t Add Up
According to an analysis of Australian egg industry data, an insufficient number of free-range layer hens exist in the country to produce the stated number of eggs sold that were labeled as “free-range.”
From January 2006 to January 2007, the number of free-range layer hens in Australia would have to have grown by over 37%, from 891,000 to 1.22 million hens, to produce the number of free-range eggs sold during this same time. Sales of free-range eggs grew from 811 million to 971 million, representing an increase in market share from 20.3% to 23.4%. During this time period, the total number of eggs produced declined by 200 million to 2.8 billion, and the overall size of the Australian layer flock decreased by 6%.
These statistics indicate the possibility that either producers could be labeling eggs as free-range when they are not, or that industry statistics may not be reliable, or both.

Citations:
Feedstuffs, Feedstuffs, 2008 International