Label Claims on Meat and Poultry Products

March 21, 2022

More Info

This session focused on label requirements and label claims. Certain aspects are required to be on a meat or poultry product label. Other claims, including animal diet, raising claims, or other practices require approval from the U.S. Department of Agriculture. Learn what various label claims (e.g., raised without antibiotics, free grange, grass fed, Organic, and more) mean and what is necessary to include them on a package label.

The 2022 MI Ag Ideas to Grow With conference was held virtually, February 28-March 31, 2022. It was a month-long program encompassing many aspects of the agricultural industry and offering a full array of educational sessions for farmers and homeowners interested in food production and other agricultural endeavors.  More information can be found at:


Video Transcript

 Casey, It's a pleasure to be here. And I'm excited to talk about label claims on meat and poultry products. This is just a reminder that all of our programs are open to all at MSU Extension and MSU.  So tonight, There's a few questions that I have. You may have more. and like Casey said, go ahead and type those into the chat. But why our label claims used? What are the required parts of labels? What do various label claims mean? And then how do you obtain approval for using a label claim on meat or poultry package? Those are some of the questions I will aim to answer and have questions and discussion at the end as needed. So there's a plethora of label claims on different foods and it can be very overwhelming to the consumer. Label claims are used to convey messages to the consumer and inform the consumer. Before we get started on a bunch of other contents. Here's a short video I'd like you to watch. Marty, terrible news! There's nothing special about the milk I'm putting on the market. It's slightly translucent white liquid like all the rest, but this is a disaster for sales. Marty, are you listening? My milk, Marty! George, calm down. Your milk is GMO free. But all milk is GMO free. You know it. And I know it, but no one else does. So here's the plan. We're going to put a label on it. GMO free. But GMOs are totally safe. George, George, George, so simple. So naive. Come, let me take you to a magical place. Where are we? The grocery store, the most confusing place in the world. That's where I come to relax. GMO free? None of these other milks say that. Me, I'd rather drink milk that's GMO free than milk that's not not GMO free. Okay. You have a great day. I can't believe that worked! Hey, if consumers didn't want us to bend the truth about what's in their food, then they should have. Should have what? Come with me. Oh, no, no, no, no. Let's get these. Say all-natural. That means they're healthy. They're potato chips. We can't be healthy. Read the label. They're not supposed to lie. Technically, it's not lying potatoes are healthy, natural. You simply bombard the consumer with meaningless claims- -until they're too confused and frustrated to make an informed decision. And then, Profit! Contains only the really real good stuff. What is that even mean? This is too confusing, okay, I give up!  But I'm hungry! Hey, want a cookie? They're the new superfood.  Yummy! *laughter* Alright, so that was not meant to pick on anyone label claim or not. I'm a firm believer there's products and options. And consumers should have choice on what they're able to purchase. But just again to point that labels contain an awful lot of information and they can be very overwhelming to consumers. And they are used to convey those messages, often they are marketing messages. But some things are required on the label as well. So labels must be truthful and not misleading. If they are not truthful or, or they are misleading, then that's considered misbranding and product can be recalled for misbranding. Labels are used to market products. And they are also regulated by either the US Department of Agriculture, USDA or by the Food and Drug Administration, FDA. And so the USDA Food Safety Inspection Service inspects and is in charge of label approval for meat, poultry, egg products, not including shelled eggs and catfish. They do have a generic label approval, but special claims must be pre-approved. There's a food safety era, excuse me, a food standards and labeling policy book that requires certain meat products meet the definition of that. So for example, ground beef cannot have more than 30 percent fat, and then the remainder of that 70 percent would be lean. It could be less. You can have extra lean ground beef that 95 percent lean and 5% fat, or a more standard blend of 80 percent lean and 20 percent fat. There are standards for ground beef that comes from the chuck part of a beef carcass. There's standard definitions for hot dogs that they don't contain more than 40% fat or water. There's varying levels of ham quality. Ham, ham with natural juices him with water added, ham in water products. So depending on what that label states indicates the standard of identity of that too. Here's an example of a label that could be found on a meat product. And there are certain requirements, the name of the product. So in this case, center cut chops, pork loin, bone-in. That is required. That weight is required. A storage statement. So if it needs to be Keep refrigerated or keep frozen. The USDA Inspection mark if it is from, if it is manufactured under USDA Inspection. If it's sold direct through retail, for instance, USDA inspected meat would arrive at a grocery store, be cut up in the back room of the grocery store and packaged for retail sales. That USDA Inspection market will not be on the package. If it is a raw product, safe handling instructions have to be included on the package. And the name and address. An address includes city, state, and zip code of who manufactured that product must be on the label. There's some other optional things on the right, such as cooking instructions. Sell buy dates, unit price, and total price. Those are more optional parts of a label. There's other labels that have to be approved by the USDA in order to be put on the label. Special statements and claims, they require a sketch approval first. And there's some examples here. This is a USDA mock label used for example purposes. And we'll show some additional labels. We do not endorse anyone or commercial brands that we're going to show. We're just showing them as examples. The Food and Drug Administration regulates and approves labels for all other foods beyond what the USDA does, including shelled eggs. On the USDA label is required parts as well including the standard of identity or name of the food, the net quantity nutrition facts in many cases are required except for in some instances with very small quantities from small companies not being required. Most of the time, nutrition facts are required. Name and address of the manufacturer and any required allergen labeling. Allergen labels must also being required on if an allergen is president in a meat and poultry product as well. And then the health claims, the Food and Drug Administration has to approve any health claims. And those are usually in the relationship of the food and a reduced risk of disease or health related condition. The FDA also has nutrient content claims such as free, high, and low, or more reduced and light. And often those are based on the quantity of something being present in the regular product of that same brand. And comparatively, so they can have a reduced fat line of, of whatever that is, the product is. And that's comparative within brands. There's also some structure function claims and the role of ingredients or dietary supplements on human functions such as calcium build strong bones or fiber maintains bowel regularity. Those would need to be approved. And then note that dietary supplement claims are not evaluated by the FDA. And they have to have a package disclaimer that indicates they're not evaluated by the FDA. So we have created a series of food label claim infographics, and these are available on the web site, Michigan State University Extension website. If you simply search MSU Extension food label claims, they will come up. And this is just some generic information and talks about where claims originate, they can originate from the government. So sometimes the USDA. Define something for us or FDA. Sometimes it's third-party claims, and then sometimes it's a producer or food manufacturer. But again, all of this extra information on food labels is used to influence consumer, consumer purchasing decisions and convey information about the product to the consumer. This one doesn't relate as much to food label claims, but it is in the series, so I thought I would just mention it. But there are different dates. Sell by dates are common. But the ones that are the most user-friendly are Use by, Best before, or Best if used or frozen by a certain date, as indicated in the middle. There's other dates that indicate when something was made or it may have some sort of expiration date on it that's given in some fashion to allow the companies some traceability and then release from liability. Sometimes it's a pack date that's out there. But those dates that are used on food products are also confusing for consumers. And so we made a infographic about that. So I have a couple of true or false. You can raise your hand or type into the chat if you want. But true or false, food products from animals given supplemental growth hormones contain hormones and food products from animals not given supplemental growth hormones are hormone free. Is that true or false? So that would be false because there is inherent levels of hormones in any type, meat or poultry product that are naturally occurring in the animals, even if they haven't been given a supplemental hormone. Oftentimes, the claims will be raised without added hormones or no hormones administered. But if you find a label that says hormone free, that's false and misleading because you're not going to find meat or dairy products that are absolutely hormone free. They all have some inherent level of naturally occurring hormones. And we've created a hormone label claim fact sheet as well. We note that the FDA has approved any use of hormones in beef, lamb and milk production. And they're thoroughly reviewed and regulated. Pork and poultry products are not allowed to be pork and pigs and poultry are not allowed to be administered hormones. Therefore, the claim no hormones added cannot be used on labels unless it follows a statement that says federal regulations prohibit the use of hormones. And I'll show a few examples of this. Some perspective of what raised about added hormones or no hormones added in beef and lamb. About 97 percent of cattle in the US do receive FDA approved ear implant, which is supplemental testosterone, progesterone, or estrogen that is administered into the ear. It's a slow release. If something were to not work with that, the ear is not an edible part of the animal. So it's not directly in the animal. And there are very little or detectable ways, detectable differences, I should say, in beef that is from cattle not administered additional hormones and those that are administered hormones. They're on the nanogram or 10 to the negative ninth level of difference. And they're very, very minute. If there is any additional hormones in the meat, it would all be digested in the stomach and not absorbed by humans when they consume it. Just like there's hormones naturally occurring in vegetables and another food products. So as I mentioned, hormones cannot be added and used in swine or poultry raising. So the statement is often found on labels. No added hormones or steroids with a little footnote. And then it says that no added hormones or steroids, federal regulations prohibit the use of hormones or steroids in poultry. That has to be on the label. Consumers may or may not read that. Rbst is an absence, claim is added. There can be synthetic BST given to cows. Most of that is not used based on retailer actual retailer objection. When that process or practice was being used. But it would allow cows to give more milk. And on the label, it says, no artificial growth or growth hormones might be the label claim. But they have to have a, the statement if they use that. That no significant difference has been shown in milk from cows treated with the artificial growth hormone rBST and non rBST treated cows. So we also have some infographics on Dairy Milk label claims and non-dairy beverage label claims. And won't go into detail since the focus of this is on meat and poultry. So true or false, the government clearly defines humanely raised. If you said false, you would be correct. But for these, humanely raised or humanely handled are examples of third-party label claims that are developed by the producer and/or processor. And the standards are followed and audited by a third party company, such as certified humane or the animal welfare approved. There are other humanely raised programs out there, but these are two of the more popular ones. And those third-party standards are defined by those groups, And then the producers have to follow and provide documentation and audit results through third-party audits, that they're following those practices in the way they say they are. So true or false? Food products from animals given antibiotics always have antibiotic residue in them. That would be false. Many times if an antibiotic has been administered, there is no residue. If there is some sort of residue, it has to be below a threshold that is approved by the FDA. And that's why withdrawal periods are given before animals can be used for meat or milk purposes. Here are some of the claims that you see on products raised without antibiotics. No antibiotics administered, and we see that listed in a different plethora of different ways, also often with other label claims. So we also have a antibiotic label claim fact sheet that explains what antibiotics are and what the claim raised without antibiotics or no antibiotics added or no antibiotics ever means. That means that from birth through slaughter, those animals would never have been given antibiotics. Sometimes the claim is no sub-therapeutic antibiotics. And that's given to allow consumers to understand that the animals were not given antibiotics on a daily basis, but may have been given antibiotics in the case of an illness. We talked about the antibiotic use and judicious use of antibiotics with farmers. True or false? Moving on to another segment. Free-range poultry have access to an indoor and outdoor area during production. And this would be true. So free range, have room to roam in open pastures and such. And this is a living condition, not necessarily a diet claim about the animals it just is referring to their housing. So we have an animal raising label claim infographic as well. So we talked about free range and free roaming having to be required by, by USDA definition, to have access to the outdoor area during production. In some cases there's days that they cannot have it if there's extreme weather or something. But in general, it has to be for at least a 120 days or more of the the growing season and good weather. Cage-free or create free. is another label claim associated mostly with eggs. And that indicates that the animals have the ability to move around in a building enclosure, or on a pasture and have unrestricted access to food and freshwater throughout that. There's we already talked about third party certifications like humanely raised, pasture raised would be another animal raising claim. It's similar to free range in poultry. But we would see this more with red meat type animals, beef, even swine, lamb. It is not defined by USDA. That's so that's different than free range and free roaming, which are defined by USDA. Pasture raised is not defined by USDA. And then naturally raised also refers to the live production practices. But it cannot be used on packaging because it's easily confused with natural. And we'll talk about natural coming up. But natural typically indicates that the production practices, such as the antibiotics or growth promoting hormones were not administered to the animal if it's in a naturally raised environment. So oftentimes if this is what practice you're doing and you're not able to put it on the label. That information is included at point of sale or through other marketing methods beyond the label. So that was some cage-free labeling in poultry and egg products. True or False? Farmers verify that animals have only been given certain types of feed ingredients for label claims such as grass-fed and all vegetarian diet. And that would be true. So these are farmer defined and verified claims. And there's a host of different grass-fed grass finished type of of labeling. It implies that the animal has been on forage for the animal's lifetime with the exception of milk consumed prior to weaning. And there's different definitions or certifications of it. These are some examples American grass-fed, certified grass-fed. And there's others as well. But USDA does not define grass fed from an FSIS standpoint. The ag marketing service leg of USDA would verify these grass-fed claims. The same is true with Not fed animal by-products or Fed all vegetarian diet. That would be that all the feed stuffs are what they claim to be. And the Food Safety Inspection Service part of USDA, must be given supporting documentation to verify that claim is truthful and not misleading. But FDA or excuse me, FSIS does not define that. True or false. Farmers can use pesticides when growing organic foods. This would be true. They just have to be naturally occurring pesticides. We have a natural and organic label claims. Fact infographic as well. You will often see on many food products, natural, all natural or a 100 percent natural. There's a slightly different definition for USDA compared to FDA. Um, and I have those in bigger font on the next slide, so I'll talk about them there. Organic needs to be certified. There is a National Organic Program and that's administered by the USDA. If all of the ingredients in a food product, 100 percent of them are organic then the USDA organic seal can be used and they can be listed at, the product can be listed as a 100 percent organic. If 95% or more of the ingredients in the product are organic, that, that same seal of USDA organic can be used. And organic would be used instead of 100 percent organic. If it's at least 70 percent of all of the ingredients in the product that are organic, certified organic, then the statement can be made with organic. And any remaining products are not required to be organically produced, but must be produced without excluded methods that, that would be required of the National Organic Program. And there's non-agricultural product list that must be specifically allowed on the national list of made with organics. So these are on-farm production practices and they would be verified and certified through the National Organic Program. Here's those definitions are natural from USDA. And it simply is a product containing no artificial ingredients or added color and it's only minimally processed. Minimal processing means that the product was processed in a manner that does not fundamentally alter the product. The label must include a statement explaining the meaning of the term natural, such as no artificial ingredients or minimally processed. And from an FDA standpoint, foods regulated by FDA, nothing artificial or synthetic, including all color additives, regardless of source, has been included in or has been added to a food that would not normally be expected to be in that food. These are very general definitions and you will find natural, all-natural or a 100 percent natural on many, many, many food products, including meat and poultry products. Again, the difference between natural, which is the processing end of it on a food, and the naturally raised, in which, the naturally raised, in which the animal was raised, naturally raised cannot be allowed on meat and poultry labels. There have been different petitions to change the definition of natural for meat and poultry products. But that hasn't come to fruition and, and and that's been in the process of being petitioned for for many years. We also have a GMO label claim infographic and indicate the the new bio engineered label symbol that which needs to be used in products that are bio engineered. And the currently 11 approved GMO crops for sale in the US, including corn, soybeans, cotton, alfalfa, sugar beets, canola, papaya, summer squash, Innate potatoes, pink pineapple and non browning Arctic apples. If you are looking to add a food label claim to your meat or poultry product that you're marketing. The guidance on the left is just is the overall label approval process through the USDA. And there is now years ago, every label had to be sent to FSIS, within USDA for approval. Now only only ones that have a food label claim have to be approved after the first generic label is approved for the facility. And we talked in the very beginning of the presentation about the requirements of the product name manufacturer, safe handling, storage, and those type of requirements. The guidance on the right is from FSIS for specific labeling guidelines on documentation and additional information needed to have a animal raising claim or other legal claim that's allowed on meat and poultry products approved. So those have to be submitted with a sketch and additional documentation and then FSIS will approve those. Sometimes they send them back for revision before final approval. So both of these guidances are available to anyone on the internet from FSIS. So in summary, for label claims, consumers need choices. And labels help guide consumers towards what informs consumers of what they're purchasing. But recognize that labels can be very confusing and overwhelming for consumers. There's lots of fine print. on labels, much of which may not be read by the consumer. And that point of sale material can be used in many ways to also market products. So if you are direct marketing meat and poultry products and you don't want to go through the process of having your label approved with the food label claim on it. You can still provide factual point of sale material, brochures, posters, pictures, things of that nature. Websites to the consumer at that point of sale or during marketing. Remember that food labels are regulated by either the FDA or the USDA depending on which government regulatory agency oversees that type of food and that they must be truthful and not misleading. Again, if you search food label claims and MSU Extension, you will find all of these infographics available for download and use. And we are also in the process of translating many of them to Spanish. I think we have five that are already translated to Spanish. And the rest of them are, are in the works for translation. We have other resources available related to meet marketing and processing on the website. And we also have a poultry processing resource that is popular and used. So with that, I think there are several questions in the chat and I'll try to work through those, Casey. Yeah. Thank you, Janine. I know I learned something from that presentation. Again, just a reminder, if you have any more questions, feel free to add them in the chat. I did insert a Qualtrics survey through MSU Extension to the chat as well. If you guys have a few minutes, we would appreciate your feedback. There were a few comments. One of them was right after your video. The comment was, that would be funny if it weren't true. This film should have been shown in high school economics and nutrition class. And another comment was, I know a lot of people who think Best by date means your food turns poisonous next day and they throw things out. Yes. And in fact, there's been different discussion at the the federal level to change requirements for using Use by or Freeze by dates or Best by dates instead of an expires or, or even a Best by, right. So I have I have a new gallon of milk that's dated March 22nd that I'm just opening today. I'm not I'm not going to drink all of that, our family's not going to drink all of that today. I'm just opening it today. It's marked from a quality standpoint to be Best by tomorrow. I'm just opening it today. It will still be plenty safe to consume in the days following. And yes, there are talks about changing some of those requirements from a dating standpoint to help reduce food waste, but nothing hence has formally been changed yet. Are there any other questions or things that you were hoping was covered in this presentation that was not? There is a question. Are there any state food label requirements in addition to federal rules? Yeah. So there are different requirements from a state standpoint. Michigan specifically does not have a state meat inspection, but they do have state licensing through the retail exempt or custom exempt exemptions from from federal standards. So if the live animal and carcass is not inspected by the USDA Food Safety Inspection Service. If it's done at a custom exempt processor, then the owner of the live animal or owners of the live animal can only use that meat or poultry for their own use. Their families use, their non-paying guests use. And each package of that meat or poultry needs to be marked not for sale. And then there are other state labeling requirements through the food code. They're similar to the USDA requirements, but sometimes the language that's required is a little bit different. But in Michigan, operating under the Michigan modified food code, which is based on the FDA 2009 food code. At some point, I would expect that to be updated to one of the more recent FDA food codes. I think the most recent FDA one is 2017. But within that food code and the Michigan food law, there are legal requirements. Any other questions for Janine? Alright. Janine, do you have any closing thoughts before we finish this session? Now just make sure that you're reading labels to fully understand what the meanings are or find out what those meanings are. Um, and if you're using them for a marketing purpose, make sure that they're truthful and not misleading. And that everything that's required to be on a label is. One of the most common recalls, reasons for recalls in the meat and poultry industry is for inaccurate labeling of allergens. So a meat or poultry product that might contain soy or wheat or egg or milk. There's other allergens as well. That's not declared on the label. So either the wrong label was applied to the product and it didn't include the allergen or the allergen is included as an ingredient but didn't get on the ingredient statement. And then all of that product has to be recalled and destroyed. So it can be very costly to the industry. So if you're applying labels on products, make sure that you're reviewing them and working with your ingredients suppliers regularly. Thank you very much for your participation.