A basic understanding of food labeling is helpful In order to make sure you have a healthy diet,.  Many food labels are confusing, and some are intentionally misleading. Some label claims are controlled by the government, but most are simply unverified marketing claims. This guide should give you an understanding of the issues and provide a basis for making your shopping decisions.

Organic Labeling for Agricultural Products and Processed Foods

USDA National Organic Program (NOP) requires that products bearing either the label “100% organic” or “organic” must be grown, handled and processed without the use of pesticides or other synthetic chemicals, irradiation, fertilizers made with synthetic ingredients, or genetic engineering.

Products labeled “100% organic” must contain only organically produced ingredients and processing aids, excluding water and salt. No other ingredients or additives are permitted.

Products labeled “organic” must contain at least 95 percent organically produced ingredients (excluding water and salt). Any remaining ingredients must consist of non-agricultural substances that appear on the NOP National List of Allowed and Prohibited Substances. The full list of substances is available on the USDA NOP website.

Products meeting either of these labeling requirements may display these phrases, as well as the percentage of organic content, on the product’s display panel. The USDA seal and the seal or mark of the organic certifying agent(s) may appear on product packages and in advertisements.

Processed products that contain at least 70 percent organic ingredients can use the phrase “made with organic ingredients” and list up to three of the organic ingredients or food groups on the display panel. Processed products labeled “made with organic ingredients” cannot be produced using any processes prohibited by the NOP. The percentage of organic content and the certifying agent’s mark may be used on the display panel. However, the USDA seal cannot be used anywhere on the package.

Processed products containing less than 70 percent organic ingredients cannot use the term “organic” anywhere on the principal display panel. They are permitted to identify specific ingredients that are organically produced on the ingredients statement on the information panel.

Natural Food Labeling

According to the USDA definition, food labeled “natural” does not contain artificial ingredients or preservatives, and the ingredients are only minimally processed. However, they may contain antibiotics, growth hormones, and other similar chemicals. Regulations are fairly lenient for foods labeled “natural.” Meat producers must submit a sort of application at the time of slaughter, detailing practices used throughout the life of the animal. Labels are evaluated to prevent mislabeling, but no inspections are conducted and producers are not required to be certified. Foods labeled “all natural” do not have a definition any different from “natural.”

Non-GMO Labeling

All organic foods are non-GMO, but not all non-GMO foods are organic. The DARK Act of 2016 makes it harder for consumers to find out whether their foods are genetically engineered, but third party verification is available through the Non-GMO Project. All products bearing their seal have gone through their verification process, which provides assurance that the product has been produced according to consensus-based best practices for GMO avoidance. You can look for their seal when you shop, or you can go to the website and browse products that have their seal. They do have one caveat:

Unfortunately, ‘GMO free’ and similar claims are not legally or scientifically defensible due to limitations of testing methodology. In addition, the risk of contamination to seeds, crops, ingredients and products is too high to reliably claim that a product is “GMO free.” The Project’s claim offers a true statement acknowledging the reality of contamination risk, but assuring the shopper that the product in question is in compliance with the Project’s rigorous standard. The website url is included as part of the Seal to ensure that there is transparency for consumers who want to learn more about our verification. While the Non-GMO Project’s verification seal is not a “GMO free” claim, it is trustworthy, defensible, transparent, and North America’s only independent verification for products made according to best practices for GMO avoidance.

Gluten-Free Labeling

The FDA’s definition of gluten-free is containing less than 20 parts per million. Although manufacturers who label their products as gluten-free and don’t meet the definition risk having their products recalled and potentially facing legal action, the FDA inspects only a tiny fraction of the foods in stores, and manufacturers aren’t required to have foods labeled as gluten free inspected by the government or by a neutral third party.

Labels for Meat, Dairy, Egg, and Poultry Products

The following information is taken from the Animal Welfare Institute. The labels are organized into three categories—”certified labels,” “unverified claims,” and “meaningless or misleading claims.” This information is also available as a concise pocket guide, and can be downloaded or ordered free of charge.The labeling system is so complicated that taking the pocket guide with you when you shop is a very good idea if you eat animal products.

Certified Labels

These label claims are defined by a formal set of publicly available animal care standards, and compliance with the standards is verified by a third party audit.

Animal Welfare Approved (dairy, eggs, chicken, goose, duck, turkey, beef, bison, lamb, goat, pork, rabbit).  The only USDA-approved third-party certification label that supports and promotes family farmers who raise their animals with the highest welfare standards, outdoors, on pasture or range. The program is offered free of charge to participating farmers. Beak trimming of poultry and tail docking of pigs and cattle are prohibited, while pain relief is generally required for removal of horn buds of cattle. Standards include the treatment of breeding animals, animals during transport, and animals at slaughter.

American Grassfed Certified (dairy, beef, lamb, goat) A third-party certification program administered by the American Grassfed Association. The program’s standards require continuous access to pasture and a diet of 100 percent forage (no feedlots). Unlike the USDA’s voluntary standard for grass fed claims, confinement and the use of hormones and antibiotics is prohibited. Pain relief is not required for physical alterations like docking of tails and removal of horns. No standards exist for the treatment of breeding animals, animals during transport, or animals at slaughter.

American Humane Certified (dairy, eggs, chicken, turkey, beef, veal, bison, lamb, goat, pork)  A third-party welfare certification program administered by the American Humane Association. Access to the outdoors is not required for meat birds, egg laying hens, beef cattle, and pigs. Provides the lowest space allowances of the main humane certification programs, and is the only welfare program to permit the use of cages for housing egg-laying hens. Beak trimming of poultry and tail docking of pigs without pain relief are allowed. Standards include the treatment of breeding animals, animals during transport, and animals at slaughter.

Certified Humane (dairy, eggs, chicken, turkey, beef, veal, lamb, goat, pork)  A third-party welfare certification program administered by the non-profit Humane Farm Animal Care. Access to the outdoors is not required for meat birds, egg-laying hens, and pigs; however, minimum space allowances and indoor environmental enrichment must be provided. Feedlots are permitted for beef cattle. Beak trimming of hens and turkeys and tail docking of pigs are allowed under certain circumstances. Standards include the treatment of breeding animals, animals during transport, and animals at slaughter.

Certified Organic (dairy, eggs, chicken, goose, duck, turkey, beef, bison, lamb, goat, pork)  Standards are defined by regulations of the National Organic Program. The standards are general and apply to all animals. They don’t address many animal care issues such as weaning, physical alterations, minimum space requirements, handling, transport, or slaughter. They do, however, require some access to the outdoors for all animals, access to pasture for ruminants (cattle, sheep, goats), fresh air and sunlight, and freedom of movement. Physical alterations such as the removal of horns and the docking of tails are allowed, and pain relief is not required. Compliance with the standards is verified by a USDA-accredited organic certifying agency, but an audit by the USDA Office of Inspector General revealed that inconsistency among certifiers is a problem.

Food Alliance Certified (dairy, eggs, chicken, beef, lamb, pork)  A non-profit sustainable agriculture certification program that supports “safe and fair working conditions, humane treatment of animals, and good environmental stewardship.” Standards provide for access to natural light, fresh air, and space, but access to the outdoors is not required for all animals. Pain relief is not required for most physical alterations, including beak trimming and tail docking. The program’s audit criteria allow a farm to become approved based on an average score for some areas instead of requiring that every standard be met. Standards do not include the treatment of animals at slaughter.

Global Animal Partnership (chicken, turkey, beef, pork)  This is an animal welfare rating program as opposed to a humane certification program. Producers are certified on a six-tier scale, from Step 1 to Step 5+. Standards for Step 1 are only marginally better than those of the conventional industry; only Steps 4, 5, and 5+ require access to pasture, and feedlots are permitted for beef cattle for Steps 1 and 2. Beak trimming of turkeys raised at Steps 1–3 and tail docking of individual pigs are allowed. Standards include the treatment of animals during transport, but not the treatment of breeding animals or the handling of animals at slaughter.

Unverified Claims

These claims have no legal definition and standards are vague and/or weak. Compliance with USDA’s definition is not verified on the farm by the government or any independent third party.

Cage Free (eggs)  According to USDA, this claim indicates the eggs came from hens who were “never confined to a cage and have had unlimited access to food, water, and the freedom to roam,” but usually only within the confines of a shed. In fact, cage free hens often have scarcely more space than caged birds, and may not be given access to sunlight and fresh air. (The term “cage free” is typically not used on eggs from hens who have access to range or pasture.) Beak cutting is permitted. The USDA Agricultural Marketing Service (AMS) verifies “cage free” claims when made by USDA-inspected egg producers. The claim is not verified when used on non-USDA inspected eggs.

Free Range/Free Roaming (all products)  No legal definition exists for these claims when used on any food products, although USDA does apply an informal guideline to applications requesting use of the claims. Moreover, USDA does not conduct on-farm inspections to verify compliance with its guideline for the claims. The guideline merely states that the animals must be given continuous, free access to the outdoors, but the number and size of exits to accommodate all animals, the size of the outdoor space, and the presence or amount of vegetation or other environmental enrichments are not specified.

Free Range/Free Roaming (eggs) This claim, indicating that hens were allowed access to the outdoors, may be used on eggs that are USDA Certified Organic. In this case, the claim would be verified by a USDA-accredited organic certifying agency. Non-organic free range claims on eggs are not recognized or verified by any federal entity, although state regulation of the claim is possible. For non-organic eggs, “free roaming” likely means the hens are not confined in a cage.

Free Range (chicken, turkey, goose, duck)  USDA allows the use of these claims on poultry products if the farmer submits testimonials and affidavits describing the conditions under which the birds are raised. USDA informally defines free range for poultry as having “access to the outside.” However, because birds may be housed indoors for inclement weather and other reasons, and given that chickens raised for meat are slaughtered at just 42 days, it is possible that some free range chickens never step outside.

Free Roaming (beef, bison, lamb, goat, pork)  In order to receive approval from USDA to put a “free roaming” label on meat, farmers must show that the animals had “continuous, free access to the outdoors for a significant portion of their lives.” According to the USDA Food Safety and Inspection Service (FSIS), which approves the claim, “feedlot-raised livestock or any livestock that were confined and fed for any portion of their lives are not amenable to the meaning of these terms.”

Grass Fed (dairy, beef, bison, lamb, goat) A voluntary standard for “grass fed” has been established for producers wishing to have this claim verified by AMS. The standard requires a lifetime diet of 100 percent grass and forage, including legumes and cereal grain crops (in a pre-grain vegetative state) but excluding grains and grain byproducts. Pasture access during most of the growing season is required, but animals may be confined to feedlots and antibiotics and hormones are allowed. Producers may use the claim without AMS verification, in which case the label claim is approved by FSIS. FSIS may apply a different standard than the AMS grass fed standard.

Humanely Raised/Humanely Handled (all products)  Not a USDA-approved term, meaning “humanely raised” claims should be accompanied by an explanation of what is meant. USDA has approved third party certification programs making “humane” claims, including Animal Welfare Approved, Certified Humane, and American Humane Certified. USDA AMS has also approved “humanely raised” and “humanely handled” claims under its Process Verified Program. USDA does not have a set of independent standards for certifying products as “humanely raised,” however. The agency is merely verifying that the producer has met its own standards, and as such the claim may simply represent a marketing tactic with little or no relevance to animal welfare.

Naturally Raised (chicken, duck, goose, turkey, beef, bison, lamb, goat, pork) A voluntary standard has been established for producers wishing to have this claim verified by AMS. However, the claim may also be used by producers not participating in an AMS verification program. The claim can be used on meat and poultry, but not on dairy and eggs, and indicates the meat came from animals who did not receive antibiotics and hormones and were fed only a vegetarian diet. The definition does not require any specific living conditions for the animals, let alone access to the outdoors or pasture. USDA is not currently approving this claim due to confusion over the difference between “natural” and “naturally raised.”

No Added Hormones/No Hormones Administered (dairy, beef, bison, lamb) USDA does not approve “hormone free” claims, as all animals produce hormones naturally. “No added hormones” or “no hormones administered” claims can be used if documentation is provided showing no hormones were administered during the course of the animal’s lifetime. USDA does not routinely test for the presence of hormones, so no verification system exists.

No Antibiotics Administered/Raised Without Antibiotics (all products) The claim “antibiotic free” is not allowed because antibiotic-residue testing technology cannot verify that an animal has never received antibiotics. However, USDA does allow “no antibiotics administered,” “no antibiotics added,” and “raised without antibiotics” claims if the producer can show documentation that the animals have not received antibiotics at any point in their lives for any purpose, including treatment of illness. Producers must also document procedures for handling sick animals. Since non-therapeutic antibiotic use can be one indicator of intensive confinement, this claim has some relevance to animal welfare. On the negative side, however, some producers may choose to allow a sick animal to suffer instead of treating the animal, for fear of losing the opportunity to use the “raised without antibiotics” claim.

Pasture Raised/Pasture Grown/Meadow Raised (all products)  Generally, “pasture raised” is used to indicate that a dairy, egg, meat, or poultry product came from animals provided with continuous access to pasture and natural vegetation. However, no regulatory standard for the term exists, and for meat and poultry the USDA applies the same definition as it does for the “free range” claim – animals had continuous, free access to the outdoors for a significant portion of their lives. The term “significant portion of their lives” is not defined, so confinement for some period of time is not ruled out. There is no independent verification of the claim unless the farmer participates in a third-party certification program, such as Animal Welfare Approved.

Sustainably Farmed (all products)  USDA has no official definition for this claim. Evaluation of the claim is made on a case-by-case basis, dependent upon the raising protocol supplied by the producer with signed affidavits. According to USDA, the producer can further explain the claim by other claims offered on the label. In other words, as with “humanely raised,” this claim can likely mean just about anything the producer wants it to mean

Meaningless or Misleading Claims

The following claims are meaningless or misleading with regard to animal welfare. (They may not be meaningless or misleading in terms of other issues.)

Cage Free (chicken or turkey) The label is meaningless when used on chicken or turkey products since birds raised for meat are not typically caged prior to transport to slaughter.

Halal (chicken, turkey, goose, duck, beef, lamb, goat)  Halal” may be used on the labels of meat and poultry products prepared according to Islamic law and under Islamic authority. The U.S. Humane Methods of Slaughter Act exempts animals killed for religious purposes from the requirement that they be rendered insensible to pain (“stunned”) before shackling, hoisting and cutting. Consequently, Halal products may come from animals who have been slaughtered without being pre-stunned. Most animal welfare advocates consider slaughter without prior stunning to be inhumane.

Kosher (chicken, turkey, goose, duck, beef, lamb, goat)  “Kosher” may be used on the labels of meat and poultry products prepared under rabbinical supervision. Kosher products are produced from animals who have been killed without being rendered insensible to pain (“stunned”) before shackling, hoisting and cutting, which is allowed under an exception to the U.S. Humane Methods of Slaughter Act for ritual or religious slaughter. Most animal welfare advocates consider slaughter without prior stunning to be inhumane.

Natural (chicken, turkey, goose, duck, beef, bison, lamb, goat, pork)  Although a “natural” claim may be used on eggs and dairy, the USDA definition for the term only applies to meat and poultry. According to USDA policy, “natural” can be used on a product that contains no artificial ingredients or added color and is only minimally processed. The label must explain the use of the term. Unless so noted, the term is not an indication that no hormones or antibiotics were administered. The claim has no relevance whatsoever to how the animals were raised. No regulatory definition for “natural” currently exists, but USDA is considering establishing one.

No Added Hormones/No Hormones Administered (chicken, turkey, goose, duck, pork)  USDA prohibits the use of hormones in the production of poultry and pork, and any “no added hormones” claims on these products must be accompanied by a statement to the effect that the administration of hormones is prohibited by federal regulation. Such a claim on pork or poultry should be considered a marketing ploy with the sole intent to mislead consumers.

United Egg Producers (UEP) Certified (eggs)  A certification program developed by and for the egg industry. Since the standards are set by UEP itself, the certification cannot be considered independent or third party. The program’s standards allow hens to be crowded into small cages for their entire lives without any access to pasture, fresh air, and sunlight. The birds are also denied litter for dust bathing and boxes for nesting. Beak cutting without pain relief is allowed. UEP renamed the seal after federal regulators and the Better Business Bureau found the previous “Animal Care Certified” label to be misleading.

USDA Process Verified (all products)  USDA Agricultural Marketing Service offers this seal to producers as a marketing tool. Participating producers submit their standards for consideration, and after approval is granted, USDA conducts audits to verify that the company is following its own standards in raising animals. Hence, the meaning of a term such as “humanely raised” can vary widely among producers, yet all are eligible to receive USDA Process Verified approval for the claim. In fact, products from factory-farmed animals can and do carry the PVP seal.

Vegetarian Fed (all products) This claim, indicating the diet did not contain animal byproducts, has no relevance to the conditions under which the animal was raised

Seafood Labels

The U.S. has no organic standards for aquaculture (seafood). There are, however, third party certification bodies such as the Marine Stewardship Council, which is the world’s leading certification body for sustainable wildcaught seafood. The blue MSC label insures that fish and seafood was responsibly caught by a certified sustainable fishery. There are also seafood watch programs, such as Monterey Bay Aquarium’s, which ranks wildcaught seafood as “Best,” “Good” or “Avoid.” If you go to the website you can print out a guide and take it with you when you shop.The guide is also available as an app for iOS and Android. Whole Foods has a third party verification system in place for their farmed seafood to ensure it has no antibiotics, added growth hormones, preservatives or by-products in feed.





© 2018 - Janet Maker Ph.D.

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