Labeling and Consumer Protection
Natural and Organic Claims
March 8, 1999
This letter is in response to your request for information on the terms "natural" and "organic" as applied to the labeling of meat and poultry products. The Labeling and Additives Policy Division (LAPD), Labeling Review Branch (LRB), administers policies regarding the use of these terms.
The circumstances under which the use of the term "natural" may be used on the labeling of meat and poultry products are described in Policy Memo 055, "Natural Claims" (enclosed). Policy Memo 055 provides that the term "natural" may be applied only to products that contain no artificial ingredients, coloring ingredients, or chemical preservatives; and the product and its ingredients are not more than minimally processed. Minimally processed products that do not contain these types of ingredients, such as fresh meat and poultry, will automatically qualify for the use of the term "natural" on product labeling.
Over the past few years, some livestock producers have proceeded one step further than that which is required for "natural" labeling; they have elected to raise their animals without the use of sub-therapeutic levels of antibiotics, growth stimulants, etc. These raising practices have resulted in the emergence of "negative" labeling claims related to the production of the food animals. Although many individuals regard these conditions as an integral part of "natural" labeling, the labeling statements remain independent of the policy on the use of the term "natural" on product labeling.
In order to verify claims about animal production practices, the Division relies on testimonials and affidavits provided by the producer. The affidavits and testimonials must include the producerís operational protocol, which describes, in detail, the production practices employed at the ranch or feedlot that support the labeling claims. For example, if a claim on a label for a beef cut conveys that no antibiotics were used during the last 100 days of finishing the animal from which the beef cut was derived, the protocol should include information covering that time period. If the claim states that "no antibiotics were used during raising," the protocol should cover the entire life of the animal from which the product is derived. The affidavits and testimonials must be provided to officials at the Federal establishment at the time of slaughter. A carcass identification program (i.e., receipt through processing) is required at the slaughter plant to assure that only the labeling of products derived from qualified carcasses bear such claims.
During the process of approving labels for meat and poultry products, labeling is evaluated to ensure that the claim statements are truthful and not misleading. Claims may only be made about the non-use of a common production practice (e.g., administering antibiotics or other growth promotants unless further qualified. For example, because growth-promoting hormones are not permitted in the raising of poultry or swine, such claims on the labeling of poultry or pork products would not be allowed unless qualified by an accompanying phrase, e.g., "Federal regulations prohibit the use of hormones in poultry." This is an example of a "negative" labeling claim.
Although the term "organic" has not yet been defined by USDA, and may not be used by itself as a claim on labeling of meat and poultry products, we are aware of the publicís interest in "organic" food, including "organic" meat and poultry products. On January 14, 1999, FSIS released labeling policy guidance that permits the use of the claim "certified organic by.... (name of a certifying entity)," on meat and poultry products produced under Federal inspection. By this action FSIS has not defined the term "organic" or the criteria for applying the term to the labeling of agricultural products. Another agency in the USDA is responsible for defining the criteria for using the term "organic."
Passage of the Organic Food Production Act of 1990 established criteria that broadly govern "organic" labeling claims for agricultural products, including livestock and poultry. Consequently, the Agricultural Marketing Service (AMS), another Agency of the USDA, was given the responsibility of developing the detailed regulations necessary to implement the standards defined in the Act and is in the process of doing so. Proposed rules for the National Organic Program (NOP) were published in the Federal Register on December 16, 1997 (FR 62: 65849-65967). For further information regarding the proposed regulations you may wish to contact Ms. Johna Pierce at Area Code (202) 720-4623 or connect by computer to the NOP web site at http://www.ams.usda.gov/nop/rule.htm.
If you have any questions regarding the use of the terms "natural" and "certified organic by..." on the labeling of meat and poultry food products, please contact Ms. Tammie Myrick, Food Technologist, or Mr. Merle Evans, Food Technologist, Labeling Review Branch, Labeling and Additives Policy Division, at Area Code (202) 205-0623.
Robert C. Post, Ph.D., Director