Labeling Regulations
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Sarah Rae, JD’25
Rulemaking petition to amend labeling regulations
During the Fall semester, Sarah drafted a rulemaking petition urging the US Department of Agriculture’s Food Safety and Inspection Service (FSIS) to amend its labeling regulations to prevent misleading claims on meat, poultry, and egg products derived from industrial animal agriculture facilities such as CAFOs (Confined Animal Feeding Operations). The petition requests that FSIS redefine “farm” to clearly exclude CAFOs and require facilities to provide documentation proving they are traditional farms before using labels with terms like “farm-raised” or “pasture-raised,” including associated imagery. The petition is grounded in concerns over consumer deception, animal welfare, environmental harm, and erosion of small-scale farming. It emphasizes that consumers rely heavily on labels to guide purchasing decisions and argues that FSIS must uphold its duty to ensure labels are truthful, in line with its statutory obligations under federal food safety laws. Ultimately, the petition calls for increased regulatory clarity, transparency, and accountability to better inform consumers and reduce litigation driven by misleading marketing.