Animal labeling claim guidance offered

FSIS guidance upholds integrity of organic and grass-fed meat and poultry products.

December 31, 2019

5 Min Read

The U.S. Department of Agriculture’s Food Safety & Inspection Service (FSIS) issued a long-delayed revised guidance regarding meat and poultry labels that make claims about how the animals were raised, such as grass-fed beef or pasture-raised poultry.

The original guidance from 2002 was updated and posted for public comment in October 2016. The recently released revised version of the Labeling Guideline on Documentation Needed to Substantiate Animal Raising Claims for Label Submissions reflects some of the public comments that were submitted three years ago.

A label bearing an animal-raising claim must be submitted to FSIS with the necessary documentation to support the special statement or claim. Examples of animal-raised claims include, but are not limited to: vegetarian fed, grass fed and raised without the use of antibiotics.

The updated rule includes added information about additional terminology that should accompany claims regarding living or raising conditions such as the use of “free range” and synonymous claims such as free roaming, pasture fed, pasture grown, pasture raised and meadow raised on labels of poultry products.

FSIS also added “raised antibiotic free” and “no added antibiotics” as examples of claims that may be used to disclose the fact that animals were not administered antibiotics at any point in the animal production process. For sub-therapeutic antibiotics, the guidance also allows additional information for consumers stating that the claim means antibiotics may be administered only in the event of an illness that includes the circumstances for which FSIS will approve labels bearing these claims.

Regarding the claim “raised without hormones (no hormones administered or no steroids administered),” FSIS updated information to clarify that a qualifying statement is no longer required on pork products labeled as having been raised without hormones because federal law permits the use of certain hormones in swine, e.g., for gestation.

Kelly Nuckolls, food safety policy specialist with the National Sustainable Agriculture Coalition (NSAC), said it was pleased that FSIS has clarified that the USDA organic label is now sufficient documentation for making a variety of other label claims that are supported by the organic claim, including “raised without antibiotics,” “no added hormones,” “no animal byproducts” and “non-GMO” (genetically modified organism). This is consistent with NSAC's recommendation and will reduce unnecessary duplicative paperwork for organic producers, the coalition said.

Nuckolls also welcomed FSIS's clarification stating specifically that feedlot beef can never be labeled as grass fed. “While FSIS did not prohibit percentage grass-fed claims, as NSAC recommended, they did specify in the new guidance that percentage claims must more accurately reflect their feeding history by, for instance, reading: ‘Made from cows that are fed 85% grass and 15% corn,’ rather than simply saying 85% grass fed,” Nuckolls explained.

FSIS received more than 4,000 comments on the labeling guideline and stated that the majority were similar comments or groups of comments from individuals who made them as part of what appeared to be organized write-in campaigns. FSIS said it received 30 individual comment letters from animal welfare advocacy organizations, consumer advocacy organizations, trade associations representing the poultry, meat, egg or organic industries, beef marketing companies, organizations that provide third-party certification services, agriculture-specific coalitions/cooperatives, producers and an environmental advocacy organization. Comments from two animal welfare advocacy organizations also included more than 87,000 and 35,000 signatures, respectively.

Nuckolls commended FSIS for the label reviews the agency currently conducts within its available resources and said NSAC agrees with the agency that third-party certification may not always be economically feasible and practical. “However, in instances without third-party certification, there needs to be a verification system for animal raising claims -- not merely paper documentation and affidavits -- when there are suspect claims being made in the marketplace,” Nuckolls said.

NSAC has recommended to FSIS and USDA's Agricultural Marketing Service (AMS) that FSIS use AMS auditors to conduct on-farm verification visits when needed. In response, however, USDA lawyers have told the agencies that they do not have the authority to do so. “We encourage FSIS and Congress to continue to pursue whatever additional authority and funding may be necessary to address the problem of false claims. This is an urgent matter. False claims weaken the market that sustainable livestock producers have built, harming them economically and misleading consumers,” Nuckolls said.

A release from the Animal Welfare Institute (AWI) said the updated guidance document ignores “99% of comments opposed to the FSIS label approval process for ‘humanely raised’ claims and wrongly asserts that the department’s process prevents deceptive and misleading claims from entering the market.”

Dena Jones, director of the farm animal program for AWI, stated, “This new document does little to address the USDA’s inadequate oversight, which allows producers to exploit the system. Producers can continue to make high-welfare claims on their packages — and charge a premium — without actually improving the treatment of animals raised under their care.”

Among AWI’s concerns with the new guidance is that FSIS continues to allow the use of complex animal raising claims so long as the producer defines the claim on the package. “Because these are comprehensive claims, it is not appropriate or feasible for producers to define them on product packages in a manner that would benefit consumers. As mentioned in AWI’s 2014 rule-making petition, requiring third-party certification for animal raising claims could solve this problem and improve accuracy in labeling,” AWI said.

AWI also said FSIS behaves as though animal welfare were a subjective concept that can be defined by individual producers as they see fit. “In reality, animal welfare is a scientific concept, and many producer definitions for humane claims currently allowed by FSIS flout animal welfare science. For example, FSIS allows higher-welfare claims to be used on pork in situations where the pigs raised for the product were subjected to painful procedures and housed on barren, concrete floors without any bedding,” AWI said.

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