Comments on USDA-AMS "Naturally-Raised" Label

The USDA recently published for comment a voluntary label aimed at clarifying standards for livestock used for meat and meat products under the “natural” label.  Currently, the term “natural” only applies to products with minimal processing.  All fresh meat could essentially earn the label “natural”.  The Agricultural Marketing Service (AMS) has proposed the new term “naturally raised” to develop a marketing claim standard for naturally raised with the idea of bringing clarity to the marketplace.  However, in the attempts to make this standard a minimal threshold it will only add more confusion to an already confused consumer. 

November 28, 2007 the USDA-AMS proposed label for naturally-raised was published for comment and the public has until January 28 to weigh in with their opinions.  The claim reads as follows:

“Naturally Raised – Livestock used for the production of meat and meat products have been raised entirely without growth promotants, antibiotics, and have never been fed mammalian or avian by-products.  This information shall be contained on any label claim that an animal has beef naturally raised.” 

This Federal Register notice can be found at http://www.ams.usda.gov/lsg/stand/naturalclaim.htm.

This proposed label claim makes no reference to animal welfare or housing conditions and is entirely based on the feeding practices.  I have deep concerns, as do many sustainable producers with this proposed label claim and the flaws contained within.  The flaws that I see with the proposed naturally raised label are as follows:
• There is a lack of any reference to animal welfare or to how an animal is raised.
• The proposal gives minimum standards with a bar set so low that it will make the claim meaningless; it would more properly be called “Naturally-Fed” since it does not address how the animal is raised. 
• It will allow for large factory-farm producers to comply with minimal standards and not address animal welfare or confinement feeding operations.
• It will lead to further consumer confusion over natural products and their labeling. 

Quality production practices established by sustainable livestock producers are appreciated and have value with many consumers in the market today.  This label threatens to erode this reputation.  I feel like it is another example of how industrial agriculture is trying to hijack a name.  We have seen it in organic, in grassfed and now in naturally-raised.  A marketing claim that uses “Naturally Raised” should include standards for animals care, stewardship of land and resources, health and feeding, and include standards for allowing the animal to fulfill its natural behaviors such as grazing.  That natural behavior doesn’t happen in a feedlot where the producer is only making a concession to not feed growth promotants, antibiotics and animal by-products.

A Zogby survey conducted in 2007 showed that 48% of respondents believe that meat, dairy and eggs labeled as “natural” come from animals that are raised with free access to the outdoors where they can move around and live in a manner in which nature intended them to live.  This label addresses nothing concerning how the animal is raised.  Hence, large industrial producers could have a CAFO (Confined Animal Feeding Operation) omit the antibiotics and hormones and label the product “Naturally Raised”. 

In 2006 when the USDA grassfed claim was published for comment nearly 20,000 consumers and producers answered the USDA and expressed the idea that they believed the term belonged to animals raised on pasture not in a feedlot.  I believe that the same would apply here and that consumers have the image that “Naturally Raised” involves the idea that these animals (ruminants anyway) are raised with free access to pasture.  This label will not provide the consumer with enough information to make an informed choice concerning their food purchases.  As such it is a disservice to those consumers who would vote for what exists in the world by how they spend their money.

What would cause the AMS to allow for a label that causes more confusion instead of making clear standards that would leave the producer and the consumer in complete understanding?  Is there something more sinister behind this claim?  One wonders if large industrial producers who see the label as having value in the marketplace and hence adding profit to the bottom line have lobbied and pushed for this vague standard.  It will allow these producers to jump on the natural bandwagon.

If you share a concern about this label then please comment to the USDA concerning how you feel.