Comment on USDA Guideline for Environment-Related Labeling Claims on Meat/Poultry Products
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Resource summary
On November 12, 2024, CSPI submitted a comment on the updated USDA Food Safety and Inspection Service (FSIS) Guideline on Substantiating Animal-Raising or Environment-Related Labeling Claims jointly with the Environmental Working Group (EWG). This page includes a brief summary of our comment. To view the full comment, click the “View Resource” button above!
Background
Climate change poses an existential threat to all facets of life and can be mitigated by reducing greenhouse gas (GHG) emissions, including from agriculture, which accounts for 10% of U.S. GHG emissions. Environment-related claims on meat and poultry labels could encourage more environmentally sustainable production and consumption, but only if such claims are trustworthy and properly regulated. Failure to adequately regulate these claims will leave consumers susceptible to greenwashing (i.e., false or misleading claims about the environmental impacts of a product).
About the USDA Guideline
The guideline provides producers with information on how to use and substantiate animal-raising and environment-related claims on meat and poultry products regulated by USDA FSIS.
Regarding substantiation of environment-related claims, the updated guideline strongly encourages establishments:
1) to provide USDA FSIS with data or studies to support environment-related claims on product labels
2) to use third-party certification to help review and evaluate environment-related claims
and recommends that establishments:
3) coordinate with the FSIS Labeling and Program Delivery Staff to discuss the development of environment-related claims and supporting documentation.
The fundamental flaw in this schema is its voluntary nature, which will likely fail to ensure that environment related claims are truthful and not misleading for the consumer. Moreover, the guideline stops short of defining relevant terms and standards for making specific environmental-related claims.
Our comments
The comment from CSPI and EWG was limited to a discussion of environment-related claims. Our recommendations for USDA FSIS to ensure that environment-related claims are truthful, not misleading, and promote more environmentally sustainable production and consumption include:
- FSIS should make it mandatory, not voluntary, for establishments to provide documentation to support environment-related claims prior to approval.
- FSIS should establish standards and definitions for specific environment-related claims and prohibit any environment-related claims, including “climate-smart” or other emissions-related claims, that do not meet those standards and definitions.
- FSIS standards for claims related to emissions reductions should require that these claims be accompanied by an on-package numerical carbon disclosure and specify a standardized methodology for calculating product-level emissions.
- Third-party organizations should not be used to establish standards and definitions for specific claims because such certifications are not sufficient for ensuring that claims are truthful and not misleading. Third-party organizations should only be used to verify compliance with FSIS standards or to signify that a product making a FSIS-approved claim meets even more rigorous standards than are required by FSIS for that claim.
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