Recently, FSIS announced it would provide guidance for using the grassfed label claim, something lacking since AMS rescinded the grassfed standard earlier this year. The new guidance is similar to the old AMS standard:

“‘Grass Fed’ or ‘100% Grass Fed’ claims may only be applied to meat and meat product labels derived from cattle that were only (100%) fed grass (forage) after being weaned from their mother’s milk. The diet must be derived solely from forage, and animals cannot be fed grain or grain by-products and must have continuous access to pasture during the growing season until slaughter.”

The guidance also spells out the documentation needed for FSIS approval:

1. A detailed written description explaining controls for ensuring that the raising claim is valid from birth to harvest or the period of raising being referenced by the claim; (e.g., controls to ensure cattle that are supposed to be raised 100% grass fed are not fed grains);

2. A signed and dated document describing the diet of the animals to support that the claims are not false or misleading;

3. A written description of the product tracing and segregation mechanism from time of slaughter or further processing through packaging and wholesale or retail distribution;

4. A written description for the identification, control, and segregation of non- conforming animals/product.

While AGA is pleased that FSIS has listened to producers and consumers and issued guidelines, we believe that a system that relies on affidavits for verification, rather than actual third-party inspections, is flawed and incomplete.

The new guidelines ignore the perception of many consumers that grassfed meat is raised without antibiotics and hormones. Also, with country-of-origin labeling no longer available, consumers are left in the dark about whether the meat they’re purchasing came from the family farm down the road or a massive facility half-a-world away.

Finally, FSIS is admittedly short-staffed and has no plans to add trained employees to evaluate the additional requirements of the guidance. We fear this will mean a rise in the numbers of unsubstantiated grassfed label claims and lead to further erosion of consumer confidence in the grassfed label.

FSIS is seeking public comments on the new guidance. We urge you to review the document and then comment before December 5, either online or by mail.

To comment by U.S. mail, send to Docket Clerk, U.S. Department of Agriculture (USDA), FSIS, Patriots Plaza 3, 1400 Independence Avenue SW, Mailstop 3782, 8-163A, Washington, DC 20250-3700.

All items submitted by mail or electronic mail must include the Agency name, FSIS, and document title: Food Safety and Inspection Service Statement of Labeling Guideline on Documentation Needed to Substantiate Animal Raising Claims for Label Submissions. Comments received will be made available for public inspection and posted without change, including any personal information, to

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