December 12, 2019

December 12, 2019

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Food Safety and Inspection Service Requests Comments on Labeling Guidance for Animal Raising Claims

FSIS is seeking comments on an updated compliance guideline regarding the documentation needed to support animal raising claims on meat and poultry product labels.

  • USDA’s Food Safety and Inspection Service (FSIS) administers the Federal Meat Inspection Act (FMIA) and the Poultry Products Inspection Act (PPIA).  The FMIA and PPIA authorize FSIS to approve labels for meat and poultry products, including animal raising claims placed on such labels, before they are marketed in interstate commerce.  Examples of animal raising claims include but are not limited to:  “Raised Without Antibiotics,” “Organic,” “Grass- Fed,” “Free-Range” and “Raised Without the Use of Hormones.”  Current FSIS policy governing the use of such claims is set forth in a compliance guideline issued in 2002; an outline of the Agency’s current process for reviewing animal production claims – which describes the documentation that animal processors and plant operators must provide to the Agency to substantiate a given animal raising claim – is available here.

  • On September 30, 2016, FSIS announced the availability of an updated compliance guideline regarding the documentation needed to support animal raising claims on product labels that processors must submit to the Agency for approval of their use on product labels.  The updated guideline includes explanations of animal-raising claims that FSIS may approve, as well as the types of documentation the Agency requires to approve such claims.

  • For most animal-raising claims, the documentation typically needed to support these claims includes:

  • A detailed written description explaining the controls used for ensuring that the raising claim is valid from birth to harvest or the period of raising being referenced by the claim;

  • A signed and dated document describing how the animals are raised (e.g., vegetarian-fed, raised without antibiotics, grass- fed), to support that the specific claim made is truthful and not misleading;

  • A written description of the product-tracing and segregation mechanism from time of slaughter or further processing through packaging and wholesale or retail distribution;

  • A written description for the identification, control, and segregation of non-conforming animals or products; and

  • If a third party certifies a claim, a current copy of the certificate.

  • The Agency will be accepting comments for 60 days following the imminent publication of the updated compliance guideline in the Federal Register.  In the meantime, the Agency encourages stakeholders who wish to submit requests for approvals of animal-raising claims on product labels to begin using the updated guideline.

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Keller and Heckman offers global food and drug services to its clients. Our comprehensive and extensive food and drug practice is one of the largest in the world. We promote, protect, and defend products made by the spectrum of industries regulated by the U.S. Food and Drug Administration (FDA), the European Commission and Member States authorities in the European Union (EU) and similar authorities throughout the world. The products we help get to market include foods, pharmaceuticals, medical devices, veterinary products, dietary supplements, and cosmetics. In addition...

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