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Comment period extended for label petition

by Wyoming Livestock Roundup

Two groups seeking a more competitive edge for marketing American meat and dairy are petitioning the U.S. Department of Agriculture to change its 2005 policy that allows “deceptive” labeling as a “Product of the USA.”

USDA’s Food Safety and Inspection Service (FSIS) received a petition on June 18 from the Organization for Competitive Markets and American Grassfed Association. Originally, the comment period for the petition was set to close Aug. 14.

“However, the petition has generated significant interest from stakeholders, and on Aug. 14, FSIS received a request to extend the comment period. Therefore, FSIS is extending the comment period for an additional 30 days,” the agency announced in mid-August.


The FSIS 2005 policy guidebook defines what can be labeled as “Product of the USA.” 

“Labeling may bear the phrase ‘Product of USA’ under one of the following conditions,” according to the handbook, “if the country to which the product is exported requires this phrase, and the product is processed in the U.S. or the product is processed in the U.S.”

Consumers are demanding more information about where there food comes from, according to the two organizations’ petition.

“Consumers place a higher value on food that is local, regional and from the United States,” the petition states. “For U.S. consumers, the current labeling practice can lead to the disguising of the true origin of meat and meat products and allows foreign interests and multi-national corporations to take advantage of increased U.S. market opportunities.”

Deceptive labels

Further, this current labeling policy “allows for deceptive and misleading labeling of foreign imported meat and meat products,” the petition states. 

“As outlined in the FSIS Policy Book, meat products may be labeled ‘Product of USA’ if ‘the product is processed in the U.S.’ With a lack of clarity in the definition of ‘processing,’ the current policy allows foreign meat to be imported into the United States and bear the label ‘Product of USA’ if it passes through a USDA-inspected plant,” the petition states. “The current language must be clarified.”

The petition argues other federal statutes prohibit “this misleading labeling and practices.”

Organizational backing

Consumers’ ability to identify domestic meat they want to purchase is harmed, it adds, as are American farmers and ranchers. 

The Organization for Competitive Markets was instrumental in passing mandatory Country of Origin Labeling (COOL) in 2002, and it continues to advocate for “truth in labeling.”

The American Grassfed Association (AGA) is a leading organization for development of grassfed meat, dairy and pastured pork production and market development, the petition continues.

AGA pushed USDA to develop a legal definition for “grassfed,” and when it did in 2006, AGA’s certification program introduced its own “more stringent standard” in 2009.


Together, the two groups are petitioning to have the second paragraph of the FSIS 2005 policy changed to read, “If it can be determined that significant ingredients having a bearing on consumer preference such as meat, vegetables, fruits, dairy products, etc., are of domestic origin, minor ingredients such as spices and flavorings not included. In this case, the labels should be approved with the understanding that such ingredients are of domestic origin.”

This language would restore the 1985 FSIS policy memo that was canceled by the existing 2005 policy, according to the petition. It also claims that FSIS, being the primary agency for policies and regulations about labeling meat and meat products, has the legal basis to grant the petition.

Consumer preferences

The petition cites research showing consumers’ preferences for country of original labeling. As far back as 2003, consumer surveys stated their preferences for meat with its country of origin on a label.

A 2010 poll showed 93 percent surveyed want meat to have country of origin labels and a majority feels that the original countries’ name should be meat from animals brought into the U.S. In 2011, researchers concluded “the origin of beef was a ‘deciding factor’ when purchasing beef steaks.”

The petition also argues that in addition to harming consumers, “One of the biggest threats to America’s family farmers and independent ranchers who are losing out, as well.”

The petition asserts, “One of the biggest threats to America’s family farmers and independent ranchers is lax importation regulations” that allow imported meat and products to pass through a USDA-inspected plant and “come out on the other side of the plant bearing the brand ‘Product of U.S.A.’”

Joy Ufford is editor of the Pinedale Roundup and Sublette Examiner and a correspondent for the Wyoming Livestock Roundup. Send comments on this article to

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