CalfImage source: rawdonfox, Flickr

Comment by December 2

[This action alert is over.]

Under pressure from organic dairy farmers, farmer and consumer groups, and Congress, the National Organic Program (NOP) recently re-opened the comment period for the 2015 proposed rule on Origin of Livestock.

Despite overwhelming support in 2015 for closing this loophole via the proposed Origin of Livestock Rule, the USDA has yet to publish a final rule. As it languishes, authentic organic dairy farmers are being undercut in the marketplace by factory farms whose certifiers interpret unclear regulations to their economic advantage. As a result, many authentic organic dairies have closed their doors. Most organic consumers are unaware of the bait and switch.

Your public comments matter. Let the NOP know that they must issue a final rule immediately to prevent the continuous conversion of conventional dairy animals into organic herds. Read more about the origin of livestock issue.

Read the proposed rule and submit your comments
(Docket No. AMS-NOP-11-0009)
by 11:59 p.m. ET, December 2, 2019

When commenting, please use your own words to address the proposed Origin of Livestock Rule and its effect on organic dairy. Regulators ignore comments that have been copied and pasted by multiple people. For more on submitting effective comments, read these tips on

If you already commented on this issue in 2015, please only comment now if you have something new to add.

Your comment could address any of these concerns:

  • A final Origin of Livestock Rule is needed immediately; delay is particularly harmful to legitimate organic dairies.
  • The final rule must close the loopholes that currently allow the continuous transition of conventional livestock to organic on individual dairies.
  • Inconsistency surrounding the origin of organic dairy cows disadvantages farmers who follow the intent and letter of the organic law and weakens consumer trust in the organic label.
  • If you are an organic dairy farmer, tell the NOP how the lack of regulation in the area of origin of livestock has affected your farm, livelihood, and family. Personal stories from farmers are particularly instructive for regulators.

Reports from organic dairy farmers around the country make it clear that we need a final rule on origin of livestock as quickly as possible, although the proposed rule may still be vulnerable to the most dedicated exploiters of the organic label. Read Cornucopia’s detailed comments for more insight into the nuanced aspects of the proposed rule.

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