What You'll Learn
- Text and language formatting rules for feed tags
- Labeling requirements for bulk shipping
- How organic regulations intersect with FDA and state commercial feed laws
Livestock feed labeling in the US is regulated through a mix of federal oversight and state enforcement. If your product is certifiable as organic and you intend to sell, label or represent your product as organic, it is also regulated by the USDA organic regulations. When you are designing your livestock feed label, it’s worth taking the time to fully understand the organic labeling requirements that apply to your product. Getting familiar with these requirements early in the design process allows you to integrate them seamlessly with the rest of your label content, including ingredient statements, rather than retrofitting them after the fact. This approach not only helps ensure regulatory compliance, but also results in a cleaner, more cohesive label that clearly communicates your product’s organic status to your customers and end users.
Organic livestock feed labeling has its own defined set of requirements. As an operation labeling organic livestock feed products, you’ll want to get familiar with which claims and statements are permitted on the label, and which ones you’re required to include, before finalizing your label.
Organic Claims and Statements Allowed on Livestock Feed Labels
The USDA organic regulations designate a list of claims and statements that are allowed for use as well as one statement that is required for use on livestock feed labels. Unlike products intended for human use, these claims and statements may appear on any panel of the product label.
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100% Organic Claim (modifies name of the product)
| 100% Organic Claim (modifies name of the product) | Allowed (if the product composition qualifies)2 |
|---|---|
|
Organic Claim (modifies name of the product) |
Allowed2 |
|
USDA Seal |
Allowed2 |
|
Certifier Seal |
Allowed2 |
|
Identify Ingredients as Organic in Ingredient Panel |
Allowed2 |
|
“Certified Organic By” Statement |
Required3 |
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Organic Claim
You may include the phrase “100% Organic” or “Organic” modifying your product name.2 Which you use depends on the percentage of organic ingredients in the feed formulation.
USDA Seal
You may use the USDA seal on any panel of your package, regardless of the percent organic content of the feed product.2 The regulations include strict parameters for the display of the USDA seal. These are explained in detail in Using the USDA Organic Seal.
Certifier Seal
The label may display the seal, logo, or other identifying mark of the certifying agent for the product, as well as for the ingredients in the product.2 Certifiers often have specific requirements for how their seals or logos are to be used, so gather that information before starting the design process for your label.
Identify Ingredients as Organic in Ingredient Panel
Under most state and federal regulations, your label must include a product ingredient list. This list is where you may distinguish organic ingredients from any nonorganic additives (like salt and other minerals). You can do this by either putting “organic” in front of each organic ingredient, or using a * or some other symbol next to the organic ingredients.2
Compliant Ways of Identifying Organic Ingredients
| Option 1 Ingredients: Organic Oats, Organic Corn, Organic Flaxseed Meal, Organic Peas, Organic Wheat, Organic Barley, Ground Limestone, Salt, Organic Sunflower Oil | Option 2 Ingredients: Dehydrated Kelp Meal*, Monocalcium Phosphate, Dicalcium Phosphate, Magnesium Oxide, Potassium Sulfate, Magnesium Sulfate, Brewers dried yeast, Saccharomyces cerevisiae yeast culture, Dried Enterococcus faecium fermentation product, Dried Aspergillus oryzae fermentation extract, Zinc Sulfate, Manganese Sulfate, d-Alpha-Tocopheryl Acetate, Manganese Amino Acid Complex, Zinc Amino Acid Complex, Ferrous Sulfate, Cobalt Sulfate, Vitamin D3 Supplement, Calcium Iodate *Organic |
|---|
“Certified Organic By” Statement
The only required statement on an organic livestock feed label is the “Certified Organic By” line.3 This exact statement, “Certified Organic By [your certifier],” must be placed on the information panel, directly below the identity of the handler or distributor of the finished product. You may also choose to include the certifier’s address, website, or phone number there.3
Navigating Cross-Regulatory Compliance
Organic livestock feed labels must follow the USDA organic regulations, but are also subject to the jurisdiction of other federal and state agencies, such as the Food and Drug Administration (FDA). The labeling requirements for other agencies cover separate elements from the USDA organic regulations.
Many specific livestock feed labeling requirements originate from the Association of American Feed Control Officials (AAFCO). To make communication clear within the industry and to consumers and buyers, AAFCO has regulations and definitions of the ingredients used in animal feeds. They are very specific about what needs to be listed. For example, in the AAFCO regulations you’ll learn which carriers or dilutants must be in the ingredient list, and when the term “wheat middlings” must be used instead of just “wheat.”
It is your responsibility to ensure that your feed tags are compliant with AAFCO, FDA, and state requirements. Your certifier will only review for and address requirements under the USDA organic regulations.
Label Updates and Formulation Changes
Market realities can change quickly in the organic grain and ingredient sector, and that’s especially true for organic. The ingredients that feed mills rely on are not always reliable: protein content, price, quantity available, and formulations for mineral premixes can all change from time to time. When different ingredients change the formulation of a product, the labels must also change to reflect the current and accurate ingredient list. Work with your certifier as you update your labels to reflect new formulations. Some certifiers will offer a template approach so that you will not need to have your label reapproved as frequently.
Labeling for Nonretail Containers and Bulk Feed Storage and Transport
Feed and feed ingredients are often sold or transported in bulk. Bulk feed moves in railcars, grain trucks, trailers, or large totes. These are all considered nonretail containers. Nonretail is any container used for shipping or storage that is not used in the retail display or sale of the product.4
The last thing that any handler would want is for their delivery of organic feed to be mixed up with conventional because the loads weren’t well labeled. Because shipment/transportation is a high-risk area, the USDA organic regulations specify that nonretail bulk shipments must be identified as organic. This identifier can be the word “organic,” an abbreviation like “OG,” or the USDA seal.5 Many handlers want to go beyond the regulations to reduce their risk of commingling, so they will ship loads secured with tamper-evident labels, especially if transporting long distances.
In addition to showing the load’s organic status, the transport label, invoice, or Bill of Lading must also display a production lot number, shipping identification, or other unique information that directly links the bulk container or truck to its audit trail documentation.5
Conclusion
Take your time to understand how the regulations apply to your products, and ensure that someone representing organic compliance is involved in label design. Then speak with your certifier about your label plans and find out any rules they may have. It can be very helpful to review the label drafts with them. When you know what the regulations and your certifier require, the label can be designed and printed correctly the first time. Then communicate with your certifier as your formulation changes and label updates are needed.
Your Next Steps
- Identify the required labeling elements (the “musts”) your label must include under the USDA organic regulations.
- Decide which permitted optional labeling elements (the “mays”) you will include, and plan where and how they will appear on your label.
- Determine how you will identify organic ingredients in your ingredient list.
- Confirm which FDA, state, and AAFCO regulations apply to your product, and verify that your label complies with all of them.
- Communicate your organic labeling requirements for transport containers to your suppliers, and document those expectations in writing.