McDonnell: Product of USA comments
Comments submitted to USDA FSIS Regarding NCBA’s “Product of the USA” petition.
These comments are submitted in opposition to NCBA’s petition on “Product of USA” labels, and their request to move from Product of USA to a “more appropriately descriptive generic claim”– “Processed in the USA”. FSIS-2021-0018-0001
NCBA has a long history of opposing Truth in Labeling claims. NCBA opposed MCOOL and was a joint plaintiff opposing COOL in our U.S. District Court, where they were soundly defeated. NCBA also lobbied hard to repeal MCOOL. NCBA more recently, in 2018, opposed cattle industry’s petition to exclude beef and meat names being used on synthetic and artificial beef products. NCBA also opposed cattle industry’s petition filed by U.S. Cattlemen’s Association in 2018 to ensure that label’s such as “Made in USA” or “Product of USA” claims be solely from cattle or beef, born, raised, and processed in the USA.
In fact, several years ago in partnership with the U.S. pork industry, NCBA using Beef Checkoff Funds was found to be promoting the pork industry to use several beef nomenclatures, including sirloin, T-Bone, Porterhouse, etc. which are all traditional beef nomenclatures to be used on various pork cuts.
With that said, NCBA has a long history of opposing U.S, cattle industry efforts for clear, concise, truthful labeling when it comes to U.S. Beef. Their petition is no different.
NCBA requests USDA create a new section that would “eliminate the broadly applicable Product of USA labeling but continues to allow more appropriately descriptive generic claims such as “Processed in the USA””. NCBA also requests that “all other claims relating to U.S. origin, production or processing of product are not eligible for generic approval”.
This request would allow imported cattle and imported beef to be labeled “Processed in the U.S.”. There is no doubt consumers would interpret such a label as being U.S. product—born and raised, and that such a label would be used to indirectly promote fraudulent origin of beef products.
Currently there is a petition filed with FSIS by U.S. Cattlemen’s Association that label’s such as, Product of U.S., Made in USA, etc be solely used for beef that has been born, raised, and slaughtered/harvested/processed in the US. This Is supported in numerous polls by a vast majority U.S. consumers and U.S. producers.
NCBA also argues that this requested change to limit labels to “Processed in the U.S.” … would increase the accuracy of label’s “, However, such a change will only create added confusion and misinterpretation of origin by consumers.
This request by NCBA clearly violates FMIA, which requires that no meat product label bare any false or misleading statement of origin or quality. Yet that is entirely the intent of NCBA to defraud our beef consumers. The Tariff Act of 1930 and Agriculture Marketing Act of 1946 requires the beef to clearly be identified to the product’s origin unless it underwent a substantial transformation in the U.S. Since beef is the ultimate end product of cattle production, and since people don’t eat cows, the simple processing and harvesting of cattle to beef is far from what would be considered substantial transformation.
This petition by NCBA is nothing more than a poorly veiled attempt to undermine and circumvent current industry and Congressional efforts to provide more truthful, transparent labeling of beef to consumer’s
FSIS needs to listen to U.S. Cattle Producers, consumers, and Congress who overwhelmingly support truthful and transparent labeling when it comes to any label’s that imply Country of Origin.
The establishment of a “Processed in the USA” claim will create more confusion in the marketplace and only hinder current efforts by Congress and other industry efforts for a truthful and transparent US Beef, Product of US, etc. claim for beef solely produced in the US.
Since 1999 I have testified at several House and Senate hearings on various cattle market and trade issues. I’ve also served as a Director on the American Angus Association which is the largest cattle breed organization, US Cattlemens Association, and sat on the Cattlemen’s Beef Board.
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