Labeling Guidance
For Raised Without Antibiotic Claims and the Use of Ionophores
Rescission of Label Approvals
An FSIS review of recently approved labels bearing “Raised without
Antibiotics (RWA)” or similar claims revealed that some labels
for poultry products have been approved in error.
Specifically, the RWA claim is present on the labeling of some
poultry products that were produced from poultry that were fed
a diet that included ionophores, e.g. salinomycin, narasin,
and monesin. The term “antibiotics” is defined by the American
Veterinary Medical Association (AVMA) as “a chemical substance
produced by a microorganism, which has the capacity, in dilute
solutions, to inhibit the growth of or to kill other microorganisms.”
It is longstanding FSIS policy that ionophores are antibiotics
because they meet the AVMA definition. The Food and Drug Administration
(FDA) agrees that by strict definition, ionophores are antibiotics
thus; poultry meat from birds to which ionophores have been
administered is not eligible to bear a “RWA” claim.
Effective immediately, all poultry product labels bearing a
RWA or similar claim for birds administered ionophores are rescinded.
Any company using ionophores in the feed formulations of poultry
that are labeled with a RWA claim needs to 1) remove the claim
from its labeling, 2) remove ionophores from the feed formulation
of such poultry, or 3) submit a new label application with appropriate
supporting documentation, for approval of a revised claim regarding
ionophores.
The company may submit a request for temporary approval consistent
with
9 CFR 381.132(f) (PDF Only) while it removes the
RWA claim from its label, removes ionophores from feed formulations
for poultry that is to be labeled with such a claim, or awaits
FSIS approval of a revised claim.
Companies may petition FSIS to initiate a public process to
consider the use of ionophores in the feed formulations of poultry
that are used to make products labeled with a RWA or similar
claims.
Parameters for the Use of a Claim about Antibiotics
when Ionophores Are Used
FSIS will consider approving claims about antibiotic use in
poultry fed ionophores. Such claims should be consistent with
the following parameters:
The claim should not assert that the poultry was raised
strictly without antibiotics, e.g., the unqualified claim
“Raised without Antibiotics” would not be acceptable.
The claim, specifically the term “antibiotics,” would
need to be qualified to reflect the characteristics of ionophores,
e.g., “Raised without Antibiotics that impact antibiotic
resistance in humans.”
The claim should be a single statement.
The type size of the words that qualify the term “antibiotics”
needs to be at least ½ the size of the smallest letters
(including any highlighting or outlining) of the largest
letter in the words “Raised without Antibiotics” or similar
terms and should be in the same color type and provide for
easy readability. The entire claim must be prominent and
conspicuous.
Such labeling should be submitted to the
Labeling and Program Delivery Division for sketch approval
including supporting documentation detailing the feed formulation.