Meat and Poultry Marketing Claims Guide

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Meat and Poultry Marketing Claims Guide

Going to the fresh meat and poultry section at your local grocery store can be quite confusing these days. Some products are labeled as “Raised without antibiotics”. Others are labeled as “No antibiotics”. Others are labeled as “Raised without antibiotics or hormones. Free-range. Grass fed.” Others have no label claims. Bah! 

Now, these various claims have permeated commercial pet food as well. More on that later.

During the Obama Administration, the United States Department of Agriculture (USDA) made a concerted effort to rein in these marketing phrases. We’ll give you a guide to help you decide what is best for your household.

Only Trust Reliable Websites

The internet is great because you can find out so much information very quickly. Unfortunately, some of the information is outdated or found on several webpages – even on the USDA’s site. So, please trust http://www.fsis.usda.gov, the Food Service and Inspection Service (FSIS) subdomain of the USDA, when it comes to meat and poultry labeling claims. 

If you visit http://www.ams.usda.gov – Agricultural Marketing Service (AMS) – you might believe that the USDA no longer regulates these claims due to its notice, “Withdrawal of United States Standards for Livestock and Meat Marketing Claims” from January 2016. However, if you dig deeper, you will find out why:

“When AMS verifies a production/marketing claim, a company often seeks to market the USDA-verified production/marketing claim on a food product label. However, the company must first receive pre-approval from the USDA Food Safety and Inspection Service (FSIS) or meet the Food and Drug Administration (FDA) labeling requirements. These agencies regulate food labels for the vast majority of agricultural commodities produced in the U.S. and ensure the labels are truthful and not misleading.”

(Note: It appears that cage-free and free-range hen eggs marketing claims fall under the umbrella of an AMS voluntary program.)

Additionally, once the FSIS started regulating these claims, pro-industry articles further confused the issue with statements such as, “All meat and poultry is free of antibiotics because they go through a withdrawal period before slaughter.”

Current Federal Activities

At the 21st Annual Food Safety Council Summit held in Chicago on May 6-9, 2019, Paul Kiecker, Deputy Director of FSIS stated that FSIS plans to make 2019 a year of modernization, especially for swine inspections and maybe beef by year-end. He strongly objects to critics of the new swine inspection program, as “nothing could be further from the truth”. He also acknowledged FSIS is under pressure to manage the Salmonella issue.

Steve Mandernach, Executive Director of the Association of Food and Drug Control Officials (AFDO) shared their work on food recalls, specifically the Class 1 recalls with the potential for causing human illnesses or even death. FSIS and FDA each have their own recall procedures and he says there are differences between the two.

Frank Yiannis, Deputy Commissioner of the FDA’s Food Safety Policy and Response, notes the world is moving at digital speed and their new “Smarter Food Safety” program is about moving faster. Even though the FDA delayed the dates for compliance with water quality standards under the Food Safety Modernization Act (FSMA) produce rule they are moving forward behind the scene.

Water, likely contaminated with E. coli 0157: H7 from nearby feedlots was implicated in the recent romaine and leafy green outbreaks. It’s not certain if these outbreaks would have been prevented if the new water quality standards were in place.

While all meat and poultry are expected to go through an antibiotic a withdrawal period before slaughter, antibiotic residue is still present from agricultural waste. Like humans, animals do not fully metabolize antibiotics: 75–80% of tetracyclines, 60% of lincosamides, and 50–90% of macrolides are excreted unchanged. Agricultural waste is therefore expected to contain high levels of antibiotics; numerous studies have confirmed this antibiotic presence in agricultural waste from a variety of animals. The fact that this situation can promote antibiotic resistance is of significant concern.

FSIS Guide

To help stop confounding the marketing claim issue, we have extracted verbatim from the Food Safety and Inspection Service Labeling Guideline on Documentation Needed to Substantiate Animal Raising Claims for Label Submissions.

Animal Welfare and Environmental Stewardship

These claims describe how animals are raised based on the care they receive by the producer or how the producer maintains the land and replenishes the environment.

FSIS has not defined these claims in regulations or policy guidelines. For animal welfare claims, such as “Raised with Care” or “Humanely Raised,” FSIS will only approve a claim if a statement is provided on the label showing ownership and including an explanation of the meaning of the claim for consumers, e.g., “TMB Ranch Defines Raised with Care as [explain the meaning of the claim on the label]” or “TMB Ranch Defines Sustainably Raised as [explain meaning of the claim on the label].” The claims may appear on any panel of the package. The definitions may appear with the claim or may be connected by a symbol and placed elsewhere on the same panel that bears the claim. For example, if a claim is made on the principal display panel (PDP), the part of the label most likely to be seen by consumers when offered for retail sale, the explanation of the claim’s meaning may be placed with the claim or placed elsewhere on the PDP provided the claim and explanation are connected by a symbol.

Examples of this type of claim: Humanely Raised*, Sustainably Farmed*, and Raised with Environmental Stewardship*. (*Note: These claims require additional terminology to define their meaning on the label. The definitions must appear with the claim or be connected by a symbol on the panel in which the claim was first made.) For example, the claim “TMB Ranch Humanely Raised*” on the PDP should be linked by an asterisk to a statement elsewhere on the PDP explaining the meaning of the claim; the statement it is linked to could be, “*Cattle are grass fed on our family farms according to our strict animal welfare practices (weblink to animal welfare practices).”

Diet

Diet claims refer to what animals are fed prior to harvest and processing. These claims require that the animals only eat the diet claimed for the lifetime of the animal, with the exception of milk consumed prior to weaning. “Grass Fed” or “100% Grass Fed” claims may only be applied to meat and meat product labels derived from cattle that were only (100%) fed grass (forage) after being weaned from their mother’s milk. The diet must be derived solely from forage, and animals cannot be fed grain or grain by-products and must have continuous access to pasture during the growing season until slaughter. Forage consists of grass (annual and perennial), forbs (e.g., legumes, Brassica), browse, or cereal grain crops in the vegetative (pre-grain) state. Hay, haylage, baleage, silage, crop residue without grain, and other roughage sources may also be included as acceptable feed sources. Routine mineral and vitamin supplementation may also be included in the feeding regimen. If incidental supplementation occurs due to inadvertent exposure to non-forage feedstuffs or to ensure the animal’s wellbeing at all times during adverse environmental or physical conditions, the producer should provide a signed and dated document to the establishment attesting the above incident is not a routine occurrence. The establishment should include this information as part of the labeling documentation verifying the product the meets the grass fed claim.

Examples of this type of claim: Grass (Forage) Fed, Grain Fed, Vegetarian Feed, and Fed No Animal By-Products.

Living/Raising/Raising Conditions

These claims refer to the environment in which the animals were raised during their lifespan.

Examples of this type of claim: Cage or Crate Free*, Free Range*, Not Confined*, and Pasture Raised.*

(*Note: These claims require additional terminology to define their meaning on the label. The definitions must appear with the claim or be connected by a symbol on the panel in which the claim was first made.)

Additional examples of this type of claim: Free Roaming, Pastured Fed, Pasture Grown, Meadow Raised. These claims are also acceptable when the animal from which the products are derived has continuous free access to the outdoors for a minimum of 120 days a year.

Raised Without Antibiotics – Livestock/Red Meat

To use this claim, source animals cannot have been given antibiotics in their feed, water or by injections. This includes ionophores which are recognized as antibiotics by FSIS.

Examples of this type of claim: No Antibiotics Administered, No Antibiotics Administered the last 150 days, and Raised Without Sub-Therapeutic Antibiotics. (Note: The claim “No Antibiotics Administered” is synonymous with “Raised Without Antibiotics”).

Raised Without Antibiotics – Poultry

To use this claim, source animals cannot be administered antibiotics in their feed, water, or by injections. Animals also cannot be administered Ionophores, which are recognized as antibiotics by FSIS.

Examples of this type of claim: No Antibiotics Administered, Raised Without Antibiotics and No Added Antibiotics Ever.

Raised Without Hormones (No Hormones Administered or No Steroids Administered)

Hormones are only approved for use in beef cattle and sheep (lamb) raising. They are not approved for use in poultry, swine, veal calves, or exotic, non-amenable species (e.g., bison and goats). Therefore, FSIS will not approve the phrase “no hormones administered” on poultry, pork, veal, or exotic, non-amenable meat products labels, unless it is immediately (directly) followed with the statement: “Federal regulations prohibit the use of hormones in poultry (or pork, veal, or exotic, non-amenable meat products).”

Examples of this type of claim: Raised Without Growth Promotants (Stimulants).

Natural

“Natural” is not listed in the above defined FSIS Guide. However, it is defined on the Meat and Poultry Labeling Terms webpage:

A product containing no artificial ingredient or added color and is only minimally processed. Minimal processing means that the product was processed in a manner that does not fundamentally alter the product. The label must include a statement explaining the meaning of the term natural (such as “no artificial ingredients; minimally processed”).

What About Other Microbial Drugs?

Antibiotics treat bacterial infections. So, what about other microbial drugs that treat fungal, viral or parasitic infections?

The FDA states in its 2017 Summary Report on Antimicrobials Sold or Distributed for Use in Food-Producing Animals, “Antifungal and antiviral drugs are not included in this report because, with the exception of formalin and hydrogen peroxide water immersion products, there are currently no approved drug applications actively marketed for these purposes in food-producing animals.”

Antiparasitic drugs are often given to livestock to deworm. However, public scrutiny has not focused on this class of drugs yet.

Pet Food

Pet food is regulated by the FDA. More than likely, the labeling requirements above do not extend to pet food.

According to the Pet Food Industry website:

Just as pet food makers are governed by both federal and state laws and regulations, the labels that go on these products are also regulated by these government entities. Both the U.S. Food and Drug Administration (FDA) and the Federal Trade Commission (FTC) govern pet food advertising and labeling claims and can take action against claims that are untruthful or misleading. At the state level, model regulations developed by the Association of American Feed Control Officials (AAFCO) are adopted by almost every U.S. state. Federal requirements include net weight and the manufacturer’s name, while AAFCO’s model regulations require labels to:

  • Clearly identify the product as a dog or cat food;
  • Present a brand name that is not misleading (evaluation includes ingredients and nutritional content);
  • Display guarantee of the certain nutrients within the product;
  • Display an ingredient list in descending order by weight – names of ingredients must be accepted by AAFCO or accepted as standard or in common use, and no single ingredient can be given undue emphasis;
  • For products identified as “complete and balanced,” provide feeding instructions so that pet owners understand how much of the product to feed daily;
  • Indicate how nutritional adequacy was determined if the product is “complete and balanced.” Companies must determine nutritional adequacy by sound scientific methods, such as analysis or feeding studies.

So, we would suggest purchasing from pet food companies that are either transparent in their sourcing or claim to only contain “human grade” ingredients.

Food Safety News, Dan Flynn, May 12, 2019. “Letter from the Editor: The four horsemen speak at Town Hall”, http://www.foodsafetynews.com.

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