Revealing the Truth Around Some of the Most Common Food Labels in America
Sinclair, Cambria. “Greenwashing”. 2020, JPEG file.
The year is 2013. The location, Los Angeles, California. It’s my first day of my first year of college at UCLA and the first period of my life living on the west coast. Excited to meet new people and make friends, I walk around my dormitory floor to see if anyone wanted to grab dinner at one of the dining halls. The first person is from LA. Great, a local to show me the ropes! But they can only go to one dining hall because they eat vegan except for on Wednesdays or when they have a craving for ice cream. Also, their preferred spot is closed. The next one is a pescatarian, and they’ve got their mini fridge stocked with take out sushi because they don’t trust the fish on campus because it’s farm raised and not wild caught. Third person, finally a meat eater. THANK GOD. But wait, they won’t eat on campus yet because their body can only handle free range, organic, grass-fed meat and they aren’t sure the dining halls are up to snuff. Feeling defeated and in fear of judgement, I decide to go eat by myself and reflect on the fact that on day one of college, I couldn’t even understand half the the words out of my classmates mouths. Maybe California was going to be too much for me.
OK, so maybe that’s a bit of an embellishment, but my time out west definitely introduced me to some dietary restraints that I was not used to back home in the Washington, D.C. area. And during my time at school I really began to wonder what all these prestigious food labels even meant. If I was going to eat meat, did it have to be organic or hormone free or from free range livestock raised on pastures?
As it turns out, these labels, loaded with the upper echelon of food buzzword superiority, are often conflated with best quality, healthiest, or most environmentally friendly. The truth is that most of them do not hold much moral, nutritional or environmental highground compared to their alternatives. And while I could probably write an entire book about the true meaning of all food labels, this post is going to break down some of the most common ones that you’re used to seeing on animal based food items and then walk you through what they mean in relation to what their impact on the food system really is, with a focus on environmental impact, animal welfare and food safety.
The two primary agencies involved in food regulation, and thus labeling, are the Food and Drug Administration (FDA) and the U.S. Department of Agriculture (USDA). I’ll probably confuse you even more if I try to explain how their authorities breakdown for every food group, so take a look at the regulatory oversight visual below to try and absorb some of the complexity we’re dealing with here.
Marchand, Gabrielle. “USDA vs. FDA”. 2020, JPEG file.
Given that the line for oversight can remain blurry and that both organizations have authority in regulating animal food products, both of their inputs and supervision will be included throughout to help better define what some of the food labels that they enforce mean. The most important differentiation to keep in mind for this article will be the divergence between meat, dairy and eggs.
Organic foods are labeled as such due to a certification from the National Organic Program within the USDA’s Agricultural Marketing Service (AMS). The purpose of the organic program is to utilize methods that “integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.”
Per the USDA, for livestock to be considered organic, they need to be fed 100% organic feed (aside from supplementary nutrients), raised on organically maintained land and have year round access to the outdoors. They also cannot receive antibiotics or growth hormones as well as other banned feed ingredients. Some drugs such as vaccines are approved, as well as pain medication or dewormers when preventative measures do not work, although animal selection and management practices are the primary means by which organic livestock farming must utilize to prevent diseases and parasites. A full list of approved chemicals can be found here.
According to the Organic Produce Network this includes growing feed crops with:
- NO synthetic fertilizers, synthetic pesticides, sewage sludge, irradiation, or genetic engineering may be used.
- Establishment of a buffer space between any nearby conventional farms.
- Ensurance of the long term viability of soil and water quality and conserve wetlands, woodlands and wildlife.
- No use of artificial coloring, flavors or preservatives.
- Compliance with federal, state and local food safety standards.
- Proper use of manure under specific composting guidelines.
So these standards probably sound pretty good when taken at face value, nobody wants unnecessary chemicals on their food, so what’s the catch? Why doesn’t every farmer employ these parameters? Well that’s probably because although the program was designed to improve environmental protection, the data shows that’s not always the case (depending on the metric used to compare).
Synthetic pesticides, herbicides and fertilizers work to ensure unwanted plants and animals are kept away from crops and that they receive the proper nutrients to grow. Similarly, genetically modified crops have boasted significant increases in yields for many plant species. Without them, the efficacy of the select organic-approved pesticides, herbicides and fertilizers causes organic farming to struggle to produce comparable yields to conventional agriculture. What this means is that more land is required to produce the same amount of food under an organic scenario versus conventional. This has led to concerns about the increased the risk of deforestation, and general ecosystem destruction resulting in biodiversity loss.
So does this mean that organic farming is always worse for the environment? NO. What it means is that it is not the silver bullet to address sustainability in the food system both in production and relative to its environmental impact. With a growing population and demand for food, increased land usage means a complete transition to organic farming across the globe is likely not feasible. Differences between food type, farming methods and location all have an effect on the long term sustainability of an agricultural operation and the efficacy of a transition to organic farming. Despite the label, some organic farmers may also go beyond the organic standards, while others do not. So when you purchase organic foods, just know that it alone does not equate to a guaranteed environmental benefit relative to unlabeled alternatives.
Let’s talk about those hormones that organic farming guarantees not to add to animals. To start, all animals have hormones. They wouldn’t grow without them. Consequently, “Hormone Free” is likely a misnomer for what should be “No Hormones Added”. On top of that, by law, pork and poultry cannot be raised with added hormones under any circumstances in the U.S.
Hormones can be used when raising cattle, but farmers must adhere to a “withdrawal period”, where the synthetic hormones can exit the animal, before slaughtering. For dairy products, no hormones added does not make sense, because the milk itself would never have hormones added to it. The synthetic hormones used in dairy cattle are known as rBST or rBGH, and you should look for the labels, “rBGH-free Milk” or “rBST-free Milk” or “From Cows not Supplemented with rBST/rBGH” if you are not comfortable purchasing dairy products that came from cows treated with synthetic hormones.
For pork and poultry, this label has no impact because there is no difference between foods with a label of “No Hormones Added” and foods without it. For products that come from cattle, specific labels about synthetic hormones may be utilized for personal preference.
This is primarily a concern with dairy products and as a result, the FDA has conducted comprehensive reviews of multiple reports related to the topic. Candidly, much of the concern relates to the belief that rBGH treatment increases cows’ level of Insulin-like Growth Factor – 1 (IGF-1). While IGF-1 occurs naturally in humans, at high levels, it can be cancerous. The most recent FDA review concluded that the use of rBGH did not increase IGF-1 levels to a dangerous quantity in people who consumed milk from cattle treated with the synthetic hormone. While not a governing body regulating food safety or on farm practices, it should be noted that the American Cancer Society would like to see more research before comfortably stating there is zero risk to human health from synthetic hormone usage in cows.
So why even use hormones? Their purpose is to increase milk production. This can cause issues in cows such as mastitis, which may lead to concerns about both animal welfare and antibiotic use for treatment of the issue. The FDA also concluded that the risk to human health relative to the antibiotic use was not of concern (we’ll get to that later).
Additionally, due to the improvements in milk production efficiency per cow, use of rBST has been shown to correlate with reduced feedstuff and water use, cropland area, Nitrogen and Phosphorus excretion, greenhouse gas emissions, and fossil fuel use compared to conventional milk production. What this means is that if you can get more milk over the course of a life cycle of a cow, the environmental impact per serving of end product is lower than if less food was produced.
While you should make your own conclusions about whether you are comfortable with consuming products from animals treated with synthetic hormones, most dairy products in stores no longer contain them anyway. “Hormone Free” is not an accurate term for describing animal based foods at all and you should look for more specific phrasing such as “rBGH Free” or “rBST Free” if you feel the need to ensure that you are purchasing dairy products that come from cows who were never given synthetic hormones.
When a food label makes certain claims, The Federal Food, Drug and Cosmetic Act gives the FDA authority to regulate labels on packaged foods to “not be false or misleading”. This jurisdiction means that the FDA assures that antibiotics are not present if a dairy product is labeled “Antibiotic Free“. The FDA also has the Grade A Milk Safety Program, which goes further to ensure that milk with that label cannot contain trace amounts of any drug, antibiotics included.
Additionally, the USDA FSIS (Food Safety and Inspection Service) must validate any claim of “Raised without Antibiotics” before authorization for use on food packaging. Should it be corroborated, this label would ensure that the animals were not administered antibiotics via feed, water or injection at any point during their life. Trace levels of antibiotics are tested for among all USDA regulated animal based food products and must adhere to defined standards.
You might be wondering why I was so cagey with these definitions and that’s because there’s the governance overlap and technical definition relative to products without the label is a bit enigmatic. Outside of food, the FDA is in charge of clearing all drugs for legal use on all animals. Inclusive of livestock, this means that the FDA both approves the drugs to be used by veterinarians and establishes standards for medication withdrawal periods when veterinarians administer antibiotics to sick animals. This is so that no amount of the drug is left by the time the animal is slaughtered or milked. Taking it a step further, they also develop the tests that are used to ensure that milk does not contain trace amounts of antibiotics before being available to consumers. Despite what a lack of “Antibiotic Free” labeling might imply, U.S. Dairy reported in 2017, that zero dairy products headed to market had tested positive from the FDA for trace amounts of antibiotics since 2010 anyway. So, while the FDA technically does ensure the validity of this label under their legal discretion, it does not indicate that dairy products without the label have antibiotics present because, by law, they can’t.
These same withdrawal periods occur for non-dairy foods in relation to antibiotics. Animal products are tested for after slaughter and those with harmful residue amounts, in accordance with USDA FSIS compliance, are not allowed to enter the market. In 2017, the FSIS found residue violations in less than 1% of routinely scheduled domestic samples. “Raised Without the use of Antibiotics” is validated to mean explicitly what it states, but you should remember that all food products intended for consumption are cleared from containing any illegal antibiotic residues before entering the food supply regardless of prior use.
While there is a dearth of research on the topic, one study indicated that cows treated with antibiotics produced manure with increased levels of greenhouse gas emissions. Keep in mind that antibiotics are meant to treat sick animals. The argument could likely be made that antibiotics decrease the mortality of animals and therefore their use could ensure that total farm emissions and resource use relative to the amount of food being produced could help decrease overall greenhouse gas emissions. Nevertheless, antibiotic use is not intended directly for the purpose of reducing emissions, though this limited research is worth mentioning if your primary motivation to use food labels is for environmental reasons.
If you are not comfortable consuming animal products that have ever been in contact antibiotics, despite the standards set for usage by the FDA and the testing performed by the FDA and USDA FSIS, search for foods labeled, “Raised Without the use of Antibiotics” rather than “Antibiotic Free“.
Cage Free, Free Range and Pasture Raised (Eggs)
The USDA defines “Cage Free” to mean:
“Eggs packed in USDA grademarked consumer packages labeled as cage free must be produced by hens housed in a building, room, or enclosed area that allows for unlimited access to food, water, and provides the freedom to roam within the area during the laying cycle.”
And “Free Range” to be:
“Eggs packed in USDA grademarked consumer packages labeled as free range must be produced by hens housed in a building, room, or area that allows for unlimited access to food, water, and continuous access to the outdoors during their laying cycle. The outdoor area may be fenced and/or covered with netting-like material.”
“Pasture Raised” is a newer term and one not defined or regulated by the USDA, but should it be paired with the third party, “Certified Humane” label, it means that each hen has 108 square feet of outdoor space covered with vegetation in addition to a barn or shaded area for protection during roosting.
At the bare minimum, this could be an idea of the areas defined by each label:
Marchand, Gabrielle. “Egg Labels”. 2020, JPEG files.
For clarification, the graphic above does not mean that these are exactly what each farm categorized under these labels will look like. What it does mean is that they could legally differentiate from a standard caged practice solely by removing cages and adding a small, fenced-in, outdoor opening and still label themselves as cage free or free range, respectively. Be careful not to conflate cage free or free range with pasture raised and do some research on the specific farm that your eggs come from for more accurate information about what the set up looks like because the USDA labels really only validate the minimum standards.
You also might be wondering why the USDA establishes these standards while the FDA is in charge of eggs? There is a lot of overlap with eggs because they come from chickens whose raising conditions are under USDA jurisdiction, but then the eggs themselves are within the purview of the FDA. Look, I don’t think that split makes any sense either, but that’s just the way things are at the moment.
It’s also important to recognize that phrases like, “Animal friendly”, “Happy Hens” and “Naturally Raised in a Natural Environment” are all not defined by the USDA or FDA and are classified as misleading and subjective and should therefore not be used. Additionally, the claim “Best Eggs in the World” cannot be used without scientific evidence to back it up.
These labels are clearly indicative of animal welfare, but their influence on environmental impact is not necessarily correlated. One study found cage free housing to contain more dust and ammonia than caged housing and to be less efficient with land, feed and energy and therefore produced a greater carbon footprint. Another analysis from Australia found free range systems produced 23% more greenhouse gas emissions than cage free systems. The data is still limited, but don’t just assume that chickens raised under more ethical conditions are also more sustainable.
While, not quantified widely with pasture raised chickens yet, a beef farm has been able to use regenerative grazing tactics on their pasture raised cattle to retain more carbon in their soil than released by the agricultural production processes. A “Pasture Raised” label certainly does not guarantee this level of environmental mitigation for chickens and thus eggs, but it is hopefully encouraging evidence that this method of farming could one day become a sustainable route for raising all livestock.
The USDA can certify small and very small producers of ruminant animals as a part of their Grass Fed Program. After submitting and receiving approval on an application detailing their farm’s or ranch’s methodology, this means that they can market their sheep and cattle as “USDA Certified Grass Fed“.
This label means ruminants can only be fed grass and forage aside from milk when they are young, and that they cannot consume grain or grain by-products. They must also be continually allowed access to pasture during the growing season.
It’s important to note that efficacy of the USDA’s ability to ensure that livestock are 100% grass-fed, and thus that of this label, has been called into question. Sometimes claims like “Grass Fed, Grain Finished” can be used to trick consumers into thinking their meat is grass fed, when the reality is that most ruminants will eat some level of grass during their life and could actually be fed grains for the majority of it.
Grain fed beef can cause issues in livestock health, such as liver abscesses. This then increases the likelihood that they are treated with antibiotics. This would be the primary food safety concern, but as we now know, this is a highly regulated process in itself.
With the risk of abscesses in mind, although grain-based feed will not kill cattle, grass fed beef could be seen an improvement for animal welfare. That said, this is only one metric for ethical treatment and not an implication that traditional feedlot style farms have worse standards for welfare across the board or that all small, pasture style systems always have optimal welfare standards either.
The environmental impact is highly contested. Grass fed animals take longer to grow, meaning that they are more resource intensive throughout their lives to produce a comparable amount of food to grain fed ones. But, as mentioned earlier, a small pasture raised, grass fed beef farm in Georgia was able to implement regenerative agricultural practices so that they stored more carbon in their soil than they released from their animals. What this means is that “USDA Certified Grass Fed” alone is not a good indicator for environmental impact.
So What Should I Do?
You may be more frustrated after reading this article because I just made these labels even more confusing. While it sounds like all of them guarantee a certain set of processes, very few ensure both a positive environmental and welfare related impact. Additionally, all food in America goes through food safety regulations, so these labels should not be an indication of that metric whatsoever. I think the main takeaways are these two points:
1. Define your own level of comfort with any of these agricultural processes and labels relative to your own values
2. Research the farms that your food comes from – or even better – find a local farmer or producer that you can trust
The examined labels are often vague or convey a message that is not very different from any alternative choices you could find at the grocery store. They are usually more confirmation of what one farm does rather than an indication of what others do not. The moral of the story is that if you want to consume animal products from livestock treated in a way that aligns with your own food values, you’re going to have to look beyond the label.
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