OPPOSE USDA’S PROPOSED “NATURALLY RAISED” LABEL

Please submit comments opposing USDA’s proposal by the March 3rd deadline.

The United States Department of Agriculture has issued a proposed “naturally raised” label standard that fails to recognize many sustainable and humane production practices normally associated with term "naturally raised". For example, livestock who spend their entire lives in a giant feedlot or CAFO, with no access to pasture, could be labeled "naturally raised". USDA's wholly inadequate proposal only states the animals cannot be administered antibiotics, hormones or animal by-products.

The true naturally raised market – a market that took decades for sustainable, family-based livestock producers to create - will be placed in serious jeopardy if USDA's proposal is implemented as currently written. USDA's proposed standard will cripple the ability of these pioneering livestock producers to provide true naturally raised meat to consumers. Additionally, should USDA’s proposal for an absurdly vague and extremely limited “naturally raised” claim proceed, consumers will be confused and consumer confidence in other vital USDA verified or certified labels will no doubt decline. Tell USDA to abandon the "naturally raised" label and focus their efforts on more important measures to support humane, sustainable livestock production.

It’s easy to submit your comments:

• Letters: Send written comments to Naturally Raised Marketing Claim, Room 2607-S, AMS, USDA, 1400 Independence Avenue SW., Washington, DC 20250-0254 or via fax to 202-720-1112.
• E-mail: Submit electronic comments at this link.

Important - Please Note: All Comments Must Reference “Docket No. LS-07-16” by writing at the top of the letter or email “Re: Docket No. LS-07-16”

Also: Be sure to include your name, address, and if appropriate, affiliation(s) and/or interest(s) in the issue.

Remember: The public comment deadline is January 28, 2008.

Some possible talking points to choose from and put in your own words in your comment letter to USDA:

• The proposed “naturally raised” standard fails to address many of the high standards consumers expect from sustainable livestock production, including animal welfare, access to pasture, and conservation and environmental requirements. Quite simply, the “naturally raised” label as proposed would not mean what consumers would think it implies and should be abandoned.

• The naturally raised label claim would completely defeat a very important purpose of providing the label in the first place -- to provide clear and reliable signals to consumers who want to make informed, environmentally-friendly, and healthy choices about their food purchases.

• Hormone and antibiotic supplementation, and the use of animal byproducts as a feed source, are extremely important issues that should be succinctly and accurately addressed through individual labeling claim standards. USDA’s Agricultural Marketing Service had previously proposed the development of “no antibiotics used” and “no supplemental hormones used” labels, both of which would provide clear and reliable signals to consumers. USDA should move immediately to issue these clear and unambiguous label claims rather than issuing a misleading and vague naturally raised label claim.

• The implementation of a “naturally raised” claim would further mislead consumers who are already uncertain and skeptical about the meaning of the “natural” label claim currently overseen by USDA’s Food Safety and Inspection Service (FSIS). The natural claim refers to processing of meat whereas the naturally raised claim refers to the production of livestock. The implementation of two distinct claims, both using the term “natural” yet addressing completely distinct issues and administered by two separate agencies, will create confusion for consumers and farmers alike.

Please personalize your message and include any additional points you would like to offer.

For more information, please contact, Traci Bruckner at (402) 687-2103, Ext. 1016 or by emailing tracib@cfra.org