Label Approval Process
Obtaining grass-fed meat label approval by the USDA requires submitting a label application and a sketch of your proposed label. Up to eight different components may be required on the label itself. What these eight components include can vary depending on the objectives for an individual label. Other supplemental information may also be necessary if “animal production” or “nutritional claims” are made.
Below is a breakdown of how California State University, Chico (CSU, Chico) obtained approval of two similar labels. Each required submission of supplemental information because an “animal production” and “nutritional claim” were made. Since the labels were very similar, the same supplemental information was submitted for each of the labels.
The outline below is meant to serve as a guide to getting your label approved by the USDA. There are links to the USDA/ FSIS labeling guidance website, USDA label application form, and samples of CSU, Chico’s application materials. Use these resources to help navigate your way to successful label approval.
II. Submit a (computer generated) sketch of your intended label containing up to eight essential pieces of information which include
- Product Name
- USDA Inspection Legend
- Net Weight
- Handling Statement
- Address (Signature) Line
- Ingredients Statement
- Nutrition Facts
- Safe Handling Instructions
You can look at CSU, Chico’s two grass-fed meat labels to see how label information should be formatted and what specific information was required for these labels. If you deviate from the format of the sample labels (i.e. font sizes, measurement units, content, etc.) you may want to visit the “Suggested Label Submission Checklist” webpage. It is the best tool for assuring label compliance. Details for each of the eight label components are linked to this webpage with their respective codes of federal regulation (CFRs). Reading through the CFRs will facilitate customizing your USDA compliant label. Reviewing the USDA labeling guidance webpage may be helpful if you still require further information.
III. Since a grass-fed claim constitutes an animal production claim, all grass-fed meat labels will require development of a Production Protocol and Husbandry Guidelines. Before submitting your label, review the California State University, Chico protocol and guidelines.
- The language within these guidelines is explicit which provides the opportunity for additional product claims to be made on your label in addition to “grass-fed.” Applicants should remember that any statements made in this document are auditable and the USDA can request documentation at any time to substantiate your statements (e.g. source verification of cattle purchased and entered into a grass-fed beef operation; or operations claiming no use of antibiotics or growth promotants).
IV. California State University, Chico made a voluntary omega-3 fatty acid claim for its two grass-fed beef labels. Since this constituted a nutritional claim, a nutrition facts panel was required. Analytical nutrition data were derived from a full nutritional analysis performed by a private laboratory.
- For a grass-fed ground beef product this entailed submitting a 1” rib steak collected between the 12th and 13th rib to a reputable nutrition lab for a complete nutritional analysis and fatty acid analysis (CSU, Chico lab analysis).
- Using this laboratory analysis, CSU, Chico produced a separate nutrition facts information label for compliance. Therefore, 2 labels per package of grass-fed ground beef are included; the regular product label and the nutrition facts panel label. You can include the nutrition facts information on your regular label if sufficient space is available. For nutrition facts information compliance, reviewing the Nutrition Facts CFR on “Suggested Label Submission Checklist” webpage is recommended. For a quicker reference look at this PowerPoint presentation from the USDA.
- Because omega-3 fatty acids were not considered a nutrient by the USDA at the time these labels were approved California State University, Chico had to submit a petition to make an omega-3 nutritional claim for the level of omega-3 fatty acids in grass-fed beef. Peer-reviewed scientific literature was necessary for the USDA’s consent. The FDA has since acknowledged the nutritional value of omega-3 fatty acids and the USDA permits omega-3 fatty acid claims on a voluntary basis and no longer requires a nutrient claim petition.