Animal Welfare Label Claims: USDA Does Little to Deter Deception

Today’s grocery stores offer a dizzying array of options. And the competition for your attention doesn’t cool down when you reach the refrigerator and freezer cases—there, consumers of meat, poultry, dairy, and egg products are inundated with compelling images, claims, taglines, and certifications assuring them, among other things, that the items offered are environmentally friendly and the animals involved were well cared for. The chorus of claims, however, can easily confuse—especially when such pronouncements are allowed to stand on scant proof.

packaged meat - photo by hacohob
photo by hacohob

The US Department of Agriculture, for the most part, does not regulate how animals are raised within (or the environment affected by) animal agriculture. However, it does require producers to submit animal-raising and sustainability label claims for approval and is supposed to prohibit false or misleading claims. No USDA inspector, however, visits agricultural facilities to see whether claims and conditions coincide. Rather, the department’s evaluation of label claims relies solely on information supplied by the producers. And that information is often sorely lacking in substance.

For the past decade, AWI has been the only national nonprofit organization that routinely monitors the use of claims such as “humanely raised” and “sustainable” on meat and poultry packages and how the USDA addresses its responsibility to ensure that these claims are not false and misleading. We’ve conveyed our findings in a series of Label Confusion reports—the third version of which will be published this fall—which review every label approval application AWI has received from the USDA since 2013. The reports highlight how the USDA is failing consumers by continuing to allow deceptive marketing practices. 

In the latest analysis, we discovered that 85 percent of the label claims reviewed lacked meaningful substantiation of the claim, with inadequate evidence provided to support use of the claim. Often, there was no label approval file whatsoever—apparently, a significant portion of animal-raising claims that end up on food packaging are never even evaluated by the USDA. 

Producers are required to include a definition for any label claim on the package itself. This sounds promising in terms of consumer comprehension, but the definitions, it turns out, are of dubious value, because producers are allowed to define claims however they see fit. The same terms will have different meanings on different packages. Definitions are also offered that are largely irrelevant to the claim itself. For example, a producer might define “humanely raised” to mean the animals were raised on a diet that was vegetarian or free of antibiotics—actions that say little about the animals’ overall welfare. 

Producers are not just sailing past the approval process unchecked. They’re also creating their own lofty-sounding certification programs that merely codify the low-level standards of conventional factory farms. Industry-backed certification programs such as CARE Certified, One Health Certified, and FACTA Certified mimic legitimate third-party animal welfare certifications that actually do verify improvements to the standard of care for animals, programs such as Global Animal Partnership (Steps 2 and higher), Certified Humane, and Animal Welfare Approved by A Greener World. 

In evaluating substantiation for label claims, the USDA does not distinguish between industry certification programs and legitimate third-party animal welfare certifications. USDA policy in this respect is wholly unaligned with consumer expectations: According to polls conducted on AWI’s behalf, consumers overwhelmingly believe that the claim “humanely raised” should not be allowed unless a producer exceeds minimum industry animal care standards. 

Because the industry has taken advantage of the USDA’s lax labeling policy, AWI’s position on animal raising claims and the value of third-party certification programs has been refined. Previously, we urged the USDA to require certification from any third party in order to use high-value claims such as “humanely raised” and “sustainable.” Now that producers are certifying compliance with weak industry standards, AWI recommends that the USDA require producers using such claims to gain third-party certification to a standard that exceeds conventional production practices. Producers should also be required to comply with all of the certification’s standards and be audited by the certifier on a routine basis.

Our recommendations to the public have also evolved. AWI’s A Consumer’s Guide to Food Labels and Animal Welfare provides important information to consumers about what to look for and what to avoid in the marketplace. In our latest update to the guide, we added information about vegan, plant-based, and vegetarian labels and new organic certifications such as “Regenerative Organic Certified” and “Real Organic,” which are meant to go beyond the USDA’s National Organic Program. 

Of course, the most effective way to ensure that your food choices do not contribute to farm animal suffering is to choose a plant-based or vegan diet. And in any case, if we wish to stem the growth of factory farms and provide a greater percentage of farm animals with a life worth living, Americans as a whole need to eat fewer animal products—that means less meat, dairy, and eggs.

If you do consume animal products, look to the “best choices” category of our guide. These labels signify that the producer adhered to the highest recognized animal care standards, with compliance verified by a third-party auditing program. This category includes Certified Animal Welfare Approved by A Greener World, Certified Grassfed by A Greener World, Certified Humane pasture-raised eggs, Global Animal Partnership (Steps 4, 5, and 5+), and Regenerative Organic Certified (for products other than dairy). Following the “best choices” category in the guide are “next best choices,” “fair choices,” and “beware of these labels,” the last of which includes labels that are meaningless or misleading with regard to animal welfare. 

Thanks to ongoing efforts of AWI and other animal protection groups, the USDA has recently committed to revising its policy document relating to label approval. Drastic changes are necessary to ensure that the labeling is meaningful. 

Please take action today to help eliminate factory farming, support higher-welfare farms, and promote fairness in labeling by writing Secretary of Agriculture Tom Vilsack, asking him to put an end to misleading and deceptive labeling. You may contact the secretary via our website or send a letter addressed as follows: The Honorable Tom Vilsack, Secretary, US Department of Agriculture, 1400 Independence Avenue SW, Washington, DC 20250.