June 11, 2023
Docket Clerk
U.S. Department of Agriculture
Food Safety and Inspection Service
1400 Independence Avenue SW
Mailstop 3758
Washington, DC 20250-3700
Submitted online: https://www.regulations.gov
Re: Docket No. FSIS-2022-0015
Voluntary Labeling of FSIS-Regulated Products With U.S.- Origin Claims
The Cornucopia Institute is a national non-profit organization that uncovers the truth behind organic food and advocates for an organic label that consumers can trust. Through research and investigations into agriculture and food issues, we provide needed information to family farmers, consumers, and other stakeholders in the agriculture community.
Transparency in Food Labeling
Transparency in food labeling is central to a basic guiding principle – consumers deserve the truth about the production practices and origin of the food they purchase. Any claim or label that purports to represent a production practice, place of origin, or place of production should be clear and accurate. Any food label or claim that is misleading ultimately contributes to a general distrust of all food labels, even those that are informative and integrous.
Repackaged Imports Should Never Bear “Product of USA” Claims
The Cornucopia Institute supports allowing “Product of USA” and “Made in the USA” claims only if the Food Safety and Inspection Service (FSIS)-regulated product is derived from animals born, raised, slaughtered, and processed in the United States.[1] The proposed changes would codify this requirement. [2]
The current practice of allowing “Made in the USA” or “Product of the USA” on products derived from animals born, raised, and/or slaughtered in other countries is inherently misleading, and even false in some instances. Allowing these claims on FSIS-regulated products derived from animals that were merely processed or repackaged in the United States should no longer be allowed.
Consumers expect that beef, egg, and poultry products labeled “Product of the USA” actually means that the animals were born, raised, and slaughtered in the United States, not simply processed or repackaged here.
Consumers are unknowingly paying for products that do not align with their values or their desired intent to support domestic farmers and ranchers. The current policy is not only misleading to consumers, it harms U.S. family farmers and independent ranchers by giving unfair market advantages to the largest global food corporations that process and pack imported meat.
Conclusion
“Product of USA” or “Made in the USA” claims should mean exactly what they state based on generally understood consumer expectations. The consumer survey administered by FSIS confirms the “Product of USA” or “Made in the USA” claims, as currently used, are misleading to a majority of consumers as to the actual origin of meat, poultry, and eggs. Therefore, to enhance transparency in the food system, we support the proposed changes to the “Product of USA” and “Made in the USA” claims.
[1] FSIS is responsible for ensuring that meat, poultry, and egg products are safe and properly labeled. FSIS also provides voluntary inspection services for eligible meat, poultry, and egg products not requiring mandatory inspection.
[2] “Product of the USA” and “Made in the USA” are voluntary claims. FSIS is proposing to amend its regulations to define which voluntary claims may be used on the labels of meat, poultry, and egg products, as well as voluntarily-inspected products, to indicate that the product are of U.S. origin.
