Certification Programs / Product Claims

Nutrient claims about a product such as “lean” or “low-fat”, the claim must be verified at the producer’s expense, and the producer must have documentation that the product meets the requirements for the definition. Producers who wish to make the claims “Naturally Raised”, “Grass Fed”, or “Free Range” must have approval from the Labeling and Review Branch of the USDA to make an animal production claim. Independent auditors will certify the specific claims including “Humanely Raised” or “Certified Organic”. Provisions of the certifying agency must be complied with. There are no provisions to claim “Antibiotic Free” or “Hormone Free”; while “Chemical Free” is expressly prohibited.

The term “certified“ implies that the USDA’s Food Safety and Inspection Service and the Agriculture Marketing Service have officially evaluated a meat product for class, grade, or other quality characteristics (e.g., “Certified Angus Beef”). When used under other circumstances, the term must be closely associated with the name of the organization responsible for the “certification” process, e.g., “XYZ Company’s Certified Beef”.

“Antibiotic Free” is not an approvable USDA claim. “No antibiotics administered” or “raised without antibiotics” is permitted. This claim implies that the animal has not had any antibiotics administered within the course of its lifetime. There is no verification system in place currently. no meat sold in the U.S. is allowed to have antibiotic residues, so therefore it is all “antibiotic-free”. Because the USDA regulates language only on food labels, many companies get away with using unapproved terms in advertising and on their Web sites. Sufficient documentation must be provided by the producer to the Agency demonstrating that the animals were raised without antibiotics
Chemical-Free is expressly prohibited by the USDA as a label on any meat product including poultry. “No Chemicals Added” is not an official marketing claim, as it lacks a standardized definition and a certifying agency. This term creates confusion in the marketplace, as antibiotics are not considered chemicals.

“Free Range” “Free Ranging” or “Free Roaming” imply that the animal lived its life out of doors, in the open air, and was free to roam about, grazing, foraging and running about. There is no standard definition as it applies to amenable meat such as beef or pork. For poultry the term “free ranging” is regulated, and requires   that the bird have access to the outdoors, but for an undetermined period each day. That means that the door to the coop or stall could be opened for five minutes a day and if the animal(s) did not see the open door or chose not to leave it could still qualify as “free range”. Eggs, like beef and pork are not regulated. Producers must demonstrate to the Agency that the poultry has been allowed access to the outside.

“Grass fed” became an official marketing claim in October 2007. In order to be labeled as grassfed, the USDA Agricultural Marketing Service (AMS) requires that grass and forage be the sole feed source for the lifetime of the ruminant animal with the exception of milk consumed prior to weaning. Grass and forage are defined for the purpose of this label as: annual and perennial grasses, forbs, browse and cereal grain crops in the vegetative state. Hay, haylage, baleage, silage, crop residue without grain, and other roughage sources may also be included as acceptable feed sources. However, animals cannot be fed any grain or grain byproducts. In addition, animals must have continuous access to pasture during the growing season. Routine mineral and vitamin supplementation may be included in the feeding regimen. During times of adverse environmental conditions, an animal may receive incidental supplementation to ensure the animal’s well being. The producer must fully document what was fed, the amount fed, the frequency of feeding. Producers should retain receipts, ingredient labels and tear tags for documentation purposes. Raising livestock on a forage diet with little or no grain supplementation may increase the amount of beneficial fatty acids (Omega 3 and CLAs) in their meat.

Hormone-Free is not an official marketing claim. All animal products contain naturally occurring hormones. The USDA has defined the use of the term and can hold manufacturers accountable for using the “hormone-free” on all meat products. Do not use this term. Pork and poultry producers cannot use hormones when raising these animals. “No hormones administered” would be the proper way to make this claim, and then only on products from animal species such as beef where administration of some hormones is permitted. While there is no certifying agency for this claim, a producer using it can be held accountable to the USDA for improper use.

Meat that is certified as “humanely raised and handled” is from farms that have enrolled in a private certification program such as that of the Humane Farm Animal Care (www.certifiedhumane.com), a consumer certification and labeling program based on standards established by a scientific animal welfare committee. Private certification programs often require that a livestock producer sign an affidavit indicating that their livestock was raised under the agency’s scriptures. “Free Farmed” is the certification program of the American Humane Association.

Meat Tenderness Marketing Claim Standards are being explored by the USDA Agricultural Marketing Service (AMS). On December 30, 2002, AMS published a Proposed Rule on this and other voluntary standards in the Federal Register with request for comments. As a result of comments and discussions, AMS has determined a need for such a claim and is currently garnering information to develop a proposed standard.

“Natural” is a food label that does not refer to how the animal was raised but rather to how it was processed. Natural products can contain no artificial ingredients, coloring agents, or chemical preservatives and must be minimally processed. Meat can be ground, smoked, roasted, dried, or frozen as long as these procedures do not fundamentally change the raw product. The USDA has defined the use of the term and can hold manufacturers accountable to the proper use of the claim but does not have a verification system in place. The label must explain the use of the term natural (such as – no added colorings or artificial ingredients; minimally processed.)

The USDA adopted the “Naturally Raised” label claim in January of 2009. Livestock used for the production of meat and meat products that have been raised entirely without growth promotants or antibiotics (except for ionophores used as coccidiostats for parasite control). These animals have never been fed animal by-products derived from the slaughter/harvest processes, including meat and fat, animal waste materials (e.g., manure and litter), and aquatic by-products (e.g., fishmeal and fish oil). If all stated conditions are met, then the product may be labeled Naturally Raised. The label must specifically incorporate information stating that no growth promotants were used, that no antibiotics were administered, and that no animal by-products were fed to the animals. Examples of coccidiostats that are ionophores are Rumensin® (monensin) and Bovatec® (lasalocid). Another common coccidiostat that is not an ionophore is Deccox® (decoquinate).

“No Additives” there is no government definition behind this term, nor is there any certifying agency. “No additives” is a general claim that may imply a product has not been enhanced with the addition of natural or artificial ingredients. There is no guidance for the use of the claim “no additives” from the US Food and Drug Administration (FDA) or the United States Department of Agriculture (USDA). However, additives are defined and regulated by these agencies.

“No Animal By-Products” implies that no animal parts from slaughtering or rendering were used to raise or manufacture the product. There is no clear, standard definition of the term and no certifying agency. Its use should be carefully considered, as one could be liable if a complaint were acted upon by the Federal Trade Commission under truth in labeling as many products are made with animal by-products. Traceability is essential if making this claim.

Pasture raised, sustainably raised, and locally grown are very loose claim terms. For example, farmer markets handling only “local” product may require that the product be raised within 30 miles; while supermarkets may consider product to be local if it can be transported to the store within a set number of hours.

Certified Organic

“Certified Organic” meats are from livestock that have been raised and certified in compliance with the National Organic Program’s (NOP) standards. Their production must be certified by an accredited state or private certifying agency. Strict guidelines must be met. For example, the use of dewormers and antibiotics is forbidden not only for the slaughter animal itself but also for its dam during the last third of pregnancy (gestation) and lactation. Only animals that have been raised as certified organic from their last trimester in the womb onwards can be sold as meat that is certified organic. Poultry must be managed organically from the second day of life. Animal health is maintained through high quality nutrition obtained predominately through pasture grazing and by supplementing with organically grown feeds. Organic farmers are required to provide humane treatment, which includes access to the outdoors. Sick animals are to be treated as necessary, but can no longer be marketed as organic if dewormer or antibiotic intervention was required. All feed and bedding must usually be obtained from certified organic sources.

Just like their conventional counterparts, organic livestock and poultry processed for consumption as meat and meat products, must be inspected under appropriate federal and state regulations. Organic meat and poultry slaughterhouses and processing plants must comply with the Federal Meat Inspection Act and the Federal Poultry Processing Act. In addition, the processing plant and processor must be certified organic in the same way that other organic processing facilities are certified. The certification is held by the producer (farmer), allowing a number of certified organic farmers to work with a given facility. Such a facility may be designated organic and process nothing but organic product. Alternatively, it may use separation of time and space in combination with a thorough wash down and clean ups to separate organic from conventional product processing. In general, organic processing is done first in the morning followed by non-organic processing.

In all cases, organic meat and poultry must be kept separate from non-organic meat. Hanging carcasses must be separated in the same way that frozen product cannot be co-mingled.

Documentation must follow the animal from the farm through slaughtering and onto butchering and product manufacturing. Traceability is necessary for organic certification. This requires extensive record keeping and impeccable inventory management.

The USDA defines “cured” meats as those to which synthetic nitrates and nitrites have been added in the form of sodium nitrite and sodium nitrate. Nitrites serve a vital public health function of blocking the growth of dangerous bacteria in processed meats, and give “cured” meats their characteristic color and flavor. However, sodium or potassium nitrates and nitrites, as well as sulfur additives are not allowed to be used in any certified organic product. While the USDA does not prohibit organic hams, frankfurters and bologna, the manufacturing of these types of products manufactured without a nitrate or nitrite cure must be labeled as “uncured”. Because some of these products depend upon the additives to achieve a specific color, taste, or shelf life, “uncured” products may not be an equal substitute. In other cases, meat-processing technology has developed means by which nitrate and nitrite can be indirectly added to these products to achieve very typical cured meat properties, which can be labeled as organic but must be labeled as “uncured”. However not all “uncured” products are organic, neither are all “uncured” products actually uncured.

Some “cured” organic products use a  curing process that uses the nitrates naturally present in celery juice and many other vegetables, a lactic acid starter culture, and salt. During the old-fashioned process of wood smoking, the naturally occurring nitrates in the celery juice are converted to nitrites through a lactic acid fermentation process.

Other Labels

Here, from USDA’s Food Safety and Inspection Service (FSIS), is a glossary of meat and poultry labeling terms. FSIS is the agency responsible for ensuring the truthfulness and accuracy in labeling of meat and poultry products. Knowing the meaning of labeling terms can make purchasing of meat and poultry products less confusing.

BASTED or SELF BASTED: Bone-in poultry products that are injected or marinated with a solution containing butter or other edible fat, broth, stock or water plus spices, flavor enhancers and other approved substances must be labeled as basted or self basted. The maximum added weight of approximately 3% solution before processing is included in the net weight on the label. Label must include a statement identifying the total quantity and common or usual name of all ingredients in the solution, e.g., “Injected with approximately 3% of a solution of ____________ (list of ingredients)”. Use of the terms “basted” or “self-basted” on boneless poultry products is limited to 8% of the weight of the raw poultry before processing.

FRESH POULTRY: The USDA/FSIS published a rule in August 1995 attempting to modify the definition of “fresh” to refer to poultry whose internal temperature has never been below 26 °F. The rule stated that poultry whose internal temperature is between 26 °F and 0 °F cannot be called “fresh” but must be called “hard-chilled” or “previously hard chilled”. In January 1996, the final rule was published in the Federal Register. However, Congress did not appropriate money for enforcing the rule. On August 8, 1996, Congress asked FSIS to revise the final rule. FSIS has now amended the Poultry Product Inspection Act to prohibit the use of the term “fresh” on the labeling of raw poultry products whose internal temperature has ever been below 26 °F. In addition, labels of raw poultry products whose temperature has ever been below 26 °F, but above 0 °F, will not be required to bear any specific, descriptive labeling terms, including “hard chilled” or “previously hard chilled”. To comply with the revised rule, raw poultry products that are labeled as “fresh” but have ever had an internal temperature below 26 °F will have to have the “fresh” designation deleted or removed from labeling on the package. The final rule also sets a temperature tolerance for raw poultry products. The temperature of individual packages of raw poultry products labeled “fresh” can vary as much as 1°F below 26 °F within inspected establishments or 2 °F below 26 °F in commerce. The revised final rule went into effect in December 17, 1997.

FROZEN POULTRY: Temperature of raw poultry is 0 °F or below.

IRRADIATED MEAT: The international symbol for irradiation is called a radura. On a food label, this symbol is accompanied by the words “Treated by Irradiation” or “Treated with Radiation”.

“MEAT” DERIVED BY ADVANCED MEAT/BONE SEPARATION AND MEAT RECOVERY SYSTEMS: The definition of “meat” was amended in December 1994 to include as “meat” product derived from advanced meat/bone separation machinery that is comparable in appearance, texture, and composition to meat trimmings and similar meat products derived by hand. Product produced by advanced meat recovery (AMR) machinery can be labeled using terms associated with hand-deboned product, e.g., beef trimmings and ground beef. The AMR machinery cannot grind, crush, or pulverize bones to remove edible meat tissue and bones must emerge essentially intact. The meat produced in this manner can contain no more than 150 milligrams of calcium per 100 grams product. Products that exceed the calcium content limit must be labeled “mechanically separated pork”. In 2004 as part of the precautions implemented to protect against possible BSE transmission, the USDA limited mechanical separation of beef. The following year they prohibited all mechanical separation of beef.

MECHANICALLY SEPARATED MEAT: is a paste-like and batter-like meat product produced by forcing bones with attached edible meat under high pressure through a sieve or similar device to separate the bone from the edible meat tissue. Mechanically separated meat has been used in certain meat and meat products since the late 1970s. In 1982, a final rule published by FSIS on mechanically separated meat said it was safe — restrictions on level of use and products it can be used in are based on safety. Mechanically separated meat must be labeled as “mechanically separated beef or pork”.

MECHANICALLY SEPARATED POULTRY: is a paste-like and batter-like poultry product produced by forcing bones with attached edible tissue through a sieve or similar device under high pressure to separate bone from the edible tissue. Mechanically separated poultry has been used in poultry products since 1969. In 1995, a final rule on mechanically separated poultry said it would be used without restrictions. However, it must be labeled as “mechanically separated chicken or turkey” in the ingredients statement. The final rule became effective November 4, 1996.

OVEN PREPARED: Product is fully cooked and ready to eat.

OVEN READY: Product is ready to cook.