Farm Action Tells USDA: Save Geographical Labeling for Upcoming “Product of U.S.A.” Rule

Today, Family Farm Action Alliance submitted public comments to the United States Department of Agriculture’s (USDA) Food Safety and Inspection Service (FSIS). Comments addressed the Proposed Rulemaking (PR) to expand the list of generic statements a company can make on a food label without those statements being approved by FSIS. Currently, statements — like allergens or religious considerations — fall under FSIS’s generic label prior approval system, which means producers do not need express approval from FSIS to print these claims on their labels. 

This proposed rule would expand prior approval generic labeling to the following criteria, allowing these statements to be added to labels without FSIS approval:

  1. Labels on products for export that deviate from FSIS requirements;
  2. Labels that list ingredients in the ingredients statement as being “organic” under the Agricultural Marketing Service National Organic Program;
  3. Labels that display geographic landmarks, such as a foreign country flag, monument, or map;
  4. Labels that make “negative” claims identifying the absence of certain ingredients or types of ingredients;
  5. Labels of products that receive voluntary, not mandatory, FSIS inspection (exotic species for example).


Family Farm Action Alliance opposes the inclusion of “geographic landmarks” (criterion 3) in the final version of the PR. This is because FSIS’s upcoming “Product of USA” label claim rulemaking will directly address “geographic landmark” label requirements for meat and meat products. 

Family Farm Action Alliance will submit thorough input and comments to strengthen the integrity of “Product of USA” label claims for meat and poultry products. Including “geographic landmark” claims in this current FSIS rule, and quickly changing those criteria again, would add compliance burdens on processing plant personnel, and unnecessary market strife for independent US farmers and ranchers.

“Our supporters rely on the reinstatement of sound inspection of “Product of U.S.A.” and Country of Origin Label claims by FSIS. Unfortunately if geographic claims stay on the table in this PR, it would only add confusion to an already contentious and complex labeling arena for meat and poultry products. We look forward to taking on geographic label claim changes in the upcoming FSIS “Product of U.S.A.” label rulemaking,” said Emily Miller, Policy and Research Manager at Family Farm Action Alliance.

Family Farm Action Alliance recommended no other changes to the remaining criteria in the PR, and is eager to contribute to FSIS’s upcoming “Product of U.S.A.” rulemaking.

Media Contact: Angela Huffman,