Support New Three-Tiered Label SystemComments due April 19th, 2010

Should organic ruminants such as a dairy cows and beef cattle — which have evolved to eat grass — be permitted to be kept in feedlots or should they be required by USDA organic regulations to obtain at least a portion of their feed directly from pasture?

According to the USDA’s new organic pasture rule, released in February 2010, pasture grazing is required in organic dairy production, but organic beef cattle may be exempt from obtaining any of their feed from pasture during the last four months of their lives.

The New Pasture Rule’s Exemption for Beef Cattle

The rule states that organic producers must “maintain all ruminant animals on pasture,” but, in an apparent contradiction, may simultaneously also utilize “dry lots, yards or feedlots” for grain finishing of slaughter stock, such as beef cattle, during the last 120 days or one-fifth of the animal’s life, whichever is shorter. During these 120 days, these organic animals are exempt from the requirement to obtain at least 30% dry matter intake (DMI) from pasture.

The USDA is seeking comments as to whether or not the current language should be strengthened or weakened. The final determination on this language will more clearly define how organic beef is produced.

A comprehensive analysis of this issue can be found at:

Current Practices in the Organic Beef Industry

To gain a deeper understanding of current practices in the organic beef industry, Cornucopia surveyed organic beef producers from across the nation. Results of the survey revealed that 80% of organic beef producers graze their beef cattle on pasture until slaughter, never confining them to a feedlot. In fact, 60% of organic beef producers never feed any grain to their cattle (100% grass-fed), while 20% maintain their cattle on pasture but provide small amounts of grain. The new rule’s exemption for ruminant slaughter stock from obtaining feed from pasture is therefore not needed by the vast majority of organic beef producers.

Yet, the remaining one-fifth of the nation’s organic beef producers are currently using feedlots for finishing, The Cornucopia Institute understands that there is support from some stakeholders for an exemption from obtaining 30% DMI from pasture for ruminant slaughter stock. These farmers, ranchers and feedlot operators currently likely produce a majority of the nation’s organic meat supply.

Cornucopia’s Proposal for Three-Tiered Labeling System

Given the well-documented benefits of pasture grazing, for environmental protection, animal welfare, food safety and consumer health, Cornucopia proposes a three-tiered labeling system for organic meat from ruminants.

Under the proposed system, three labels would be used for organic meat from ruminants:

1. “Organic – Grain Finished” – For meat from animals that needed the exemption from pasture during the last 120 days (might include finishing in feedlots).

2. “Organic – Pasture/Grain Finished” – For meat from animals that were maintained on pasture until slaughter, obtained at least 30% of their feed intake from pasture during the grazing season but received small amounts of grain supplementation at some point.

3. “Organic – 100% Grass Fed” – For meat from animals that were 100% grass-fed, never receiving any grain in their diet.

Rationale for Three-Tiered Labeling System

Since organic farmers are making arguments on behalf of the three production systems (all currently in use), it would be beneficial for organic producers and consumers to be able to easily differentiate them in the marketplace, with a clear label for each one.

Consumers are increasingly interested in grass-fed meats, and some might be surprised to find out that “organic” and “grass-fed” are not synonymous. The environmental advantages of grass-based livestock agriculture, its nutritional superiority as well as animal welfare benefits, are reported not only in scientific articles, but are also covered extensively in the popular media, ranging from Mother Earth News to Time Magazine, Forbes and the Oprah Winfrey Show.

On the other hand, promoters of organic grain-fed beef strongly believe that consumer preference and the marketplace dictate their production practices. American consumers are accustomed to the texture and flavor of meat from corn-fed feedlot cattle, and the USDA’s grading system for meat rewards high levels of intramuscular fat in beef — which is more easily achieved through finishing cattle on grain instead of grass.

A three-tiered labeling system will allow the marketplace to determine the viability of each production system, as well as creating economic opportunity for farmers who want to raise organic beef matching the demands and desires of organic consumers.

There are arguments in favor of each production system, which are outlined in greater detail in The Cornucopia Institute’s full-length position paper, available at:

Send Your Comments to the USDA

While the exemption, allowing organic beef producers to use feedlots for grain finishing, has been published in the final rule, the NOP is accepting comments until April 19th from organic beef and other ruminant producers and the general public.

We urge both organic producers and consumers to share their thoughts with the USDA before the April 19th deadline, including expressing their support for a three-tiered labeling system.

Send your comments to the USDA before the April 19th deadline.


To send comments electronically:

1. Visit

2. Select “Submit a comment”

3. Enter “AMS-TM-06-0198” in the search bar

4. Click “Submit a Comment” (to the right of the first search result)

To send comments by USPS mail:

Address mailed comments to:

      Toni Strother, Agricultural Marketing Specialist


      National Organic Program, USDA–AMS–TMP–NOP


      Room 2646–So., Ag Stop 0268


      1400 Independence Ave., SW


    Washington, DC 20250–0268

Clearly identify your comment with the docket number: AMS–TM–06–0198;


The USDA asks that comments “clearly indicate whether you support §205.239(d) as published in this final rule, in full or in part, and the reason(s) for your position. Please include only relevant information and data to support your position.”

The new rule’s exemption, §205.239(d), reads as follows:

(d) Ruminant slaughter stock, typically grain finished, shall be maintained on pasture for each day that the finishing period corresponds with the grazing season for the geographical location: Except, That, yards, feeding pads, or feedlots may be used to provide finish feeding rations. During the finishing period, ruminant slaughter stock shall be exempt from the minimum 30 percent DMI requirement from grazing. Yards, feeding pads, or feedlots used to provide finish feeding rations shall be large enough to allow all ruminant slaughter stock occupying the yard, feeding pad, or feed lot to feed simultaneously without crowding and without competition for food. The finishing period shall not exceed one fifth (1/5) of the animal’s total life or 120 days, whichever is shorter.

USDA definitions added in new rule:

Dry lot

    : A fenced area that may be covered with concrete, but that has little or no vegetative cover.


    : A dry lot for the controlled feeding of livestock.

Graze: (1) The consumption of standing or residual forage by livestock. (2) To put livestock to feed on standing or residual forage.

Yard: An area for feeding, exercising, and outdoor access for livestock during the non-grazing season and a high traffic area where animals may receive supplemental feeding during the grazing season.

USDA existing definitions of interest:

    Pasture: Land used for livestock grazing that is managed to provide feed value and maintain or improve soil, water, and vegetative resources.

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