Is the label verified?
Sometimes
Is the meaning of the label consistent?
No
Are the label standards publicly available?
Sometimes
Is information about the organization publicly available?
N/A
Is the organization free from conflict of interest?
N/A
Was the label developed with broad public and industry input?
Partially

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What this label means 

 

Choosing animal products from animals raised without antibiotics is an important step consumers can take to help address the public health crisis of antibiotic resistance.

Meat and poultry. For the “raised without antibiotics” claim on meat and poultry labels, the USDA requires that source animals were not given antibiotics in their feed, water or by injection. This includes ionophores, which are recognized as antibiotics by the USDA (ionophores are antibiotics that are used only in animals, not in human medicine).

Dairy and eggs. For dairy product and egg labels, which are regulated by the Food and Drug Administration (FDA), label approval is not required. The FDA has no regulatory definition for “raised without antibiotics” labels. 

Why it matters 

The U.S. Centers for Disease Control and Prevention (CDC) estimates that every year antibiotic-resistant bacteria cause more than two million infections, killing at least 23,000 people. The rise of antibiotic resistance is driven by the overuse of antibiotics. The overuse of antibiotics can occur in many settings--doctor’s offices and hospitals, for example -- but we cannot save antibiotics without meaningful changes to our food system, especially livestock and poultry production. This is because, in the U.S., the use of antibiotics in livestock and poultry production dwarfs their use in humans: about 80% of these drugs go to food animals.

In recent years, several companies that produce or sell meat and poultry have pledged to reduce or eliminate the use of antibiotics. Consumers can support these livestock and poultry producers by choosing meat and poultry with a “raised without antibiotics” label.

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How meaningful is this label? 

Raising farm animals without antibiotics is an important practice to combat the public health crisis of antibiotic resistance. However, as a label, “raised without antibiotics” on its own is not meaningful on dairy and eggs, and somewhat meaningful on meat and poultry.

On dairy products and eggs, the “raised without antibiotics” claim is not verified and there is no common regulatory definition, so the label is not meaningful on its own.

On meat and poultry products, producers can make the “raised without antibiotics” claim after submitting a one-time label application with the USDA’s Food Safety and Inspection Service (FSIS), which includes required documentation to support the “raised without antibiotics” label claim. However, there is no requirement for on-farm inspections and no requirement for annual review or auditing of the producer’s records to ensure compliance. 

Look for the following additional labels or seals.

There are several meaningful labels that also address antibiotic use in their standards. If you see any of these labels together with the “raised without antibiotics” label, you can have much more trust in the claim.

USDA Process Verified

Producers making a “raised without antibiotics” claim can choose to have this claim verified by the Agricultural Marketing Service (AMS, an agency at the U.S. Department of Agriculture) through its Process Verified Program.

The Process Verified Program conducts a desk audit and an on-site audit for producers wishing to verify a “raised without antibiotics” label claim. For example, if a company wants to verify that they are raising their poultry without antibiotics, AMS auditors verify hatching, feed mill and on farm records and processes to ensure the company is meeting their processes for antibiotic use. Auditors visit the hatcheries to ensure poultry are not administered antibiotics, before hatching or after hatching. Auditors visit feed mills to ensure that feed does not include antibiotics, review ration and testing records and ensure that requirements included in the company’s Quality Manual are followed. Auditors visit the farm where the poultry are raised to determine if there are any antibiotics on-hand or in use. For new programs, initial approval after the desk audit and on-farm audit lasts for one year, with a surveillance audit conducted within six months of the initial on-site audit. After the first year, on-site audits are conducted annually.

Consumers should be careful to look for the USDA Process Verified seal accompanying a meaningful claim such as “raised without antibiotics” or “no antibiotics ever.” However, not all claims with a “USDA Process Verified” seal are equally valuable to consumers. The USDA Process Verified Program is a service that provides verification for claims and standards written by the company, which vary widely. For example, the program also verifies claims such as “no antibiotics used for growth promotion – antibiotics only used for treatment and prevention of disease.”  This claim offers little value to consumers since the use of antibiotics for growth promotion has been nearly entirely phased out.


USDA Organic

The USDA organic regulations prohibit the use of antibiotics in organic animal agriculture, with the exception of poultry prior to the second day of life (in hatcheries). But if a producer makes a “raised without antibiotics” claim on a certified organic poultry product, it means that the producer has submitted documentation to the USDA that antibiotics are not used at any point, including in the hatcheries. Other than in the hatcheries, the USDA Organic label signifies that a USDA-accredited certifier has verified the prohibition on antibiotic use after day 2. 

USDA Organic label review.

Animal Welfare Approved

The Animal Welfare Approved standards prohibit routine antibiotic use (antibiotics can only be used to treat sick animals). The label is verified.

Animal Welfare Approved label review.

Certified Humane by Humane Farm Animal Care (HFAC)

The Humane Farm Animal Care standards for the Certified Humane label prohibit the use of antibiotics for growth promotion and disease prevention (antibiotics can be used to treat sick animals) for beef and pork. For poultry, the label standards prohibit the use of antibiotics for growth promotion and disease prevention, except in hatcheries. Certified Humane does not have standards for hatcheries, so antibiotics such as gentamicin could be injected in eggs and day-old chicks. The label is verified.

American Grassfed

The American Grassfed label standards prohibit the use of antibiotics. The label is verified.

American Grassfed label review.

GAP Step 1-5+

For beef, pork, turkey, sheep, goat and bison, the use of antibiotics is prohibited. For chicken, the sub-therapeutic use of antibiotics is prohibited, but standards do not specify that antibiotics at therapeutic levels are prohibited for routine disease prevention and control. The label is verified.

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Is the label verified?

U.S. Department of Agriculture (USDA) regulations require that labels on meat and poultry with a “raised without antibiotics” claim have to be approved by USDA staff. Companies submit a label application with supporting documentation that supports the “raised without antibiotics” claim. Supporting documentation that is needed includes:

  1. A detailed written description explaining controls for ensuring that the animals are not given antibiotics from birth to harvest or the period of raising being referenced by the claim;
  1. A signed and dated document describing how the animals are raised to support that the claims are not false or misleading;
  1. A written description of the product tracing and segregation mechanism from time of slaughter or further processing through packaging and wholesale or retail distribution; and
  1. A written description for the identification, control, and segregation of nonconforming animals/product (e.g., if beef raised without the use of antibiotics

need to be treated with antibiotics due to illness).

For poultry, the USDA requires a company making a “raised without antibiotics” labeling claim to submit a letter answering questions about whether eggs are injected with antibiotics prior to hatching. The USDA guidelines do not, however, state that this practice is prohibited.

USDA staff only conducts a one-time desk audit (reviewing paperwork submitted by the company) but does not conduct annual audits or on-farm inspections. Third-party certification of the claim is not required. As noted above, companies may choose to be verified through the USDA Process Verified Program, or can obtain other certification that addresses antibiotic use.

On eggs and dairy, the FDA requires that labeling be truthful and not misleading, but the agency does not require that the label be approved or verified and does not have a regulatory definition of the claim that companies have to meet. 


Is the meaning of the label consistent?

No.

On meat and poultry, the USDA allows variations of the claim, such as “raised without antibiotics the last 120 days” or “raised without subtherapeutic antibiotics.” The agency requires that the variation be indicated on the label but does not set a standard or define these variations.

The label can have different meanings on meat and poultry products, when it is regulated by the U.S. Department of Agriculture, than on dairy and eggs, when the label is regulated by the Food and Drug Administration and not defined. 

Are the label standards publicly available?

Sometimes.

For the label on meat and poultry, the USDA has a document with labeling guidelines, which is publicly available.

The FDA does not have a formal rule or publicly available guidelines for the label on dairy and eggs. 

Is information about the organization publicly available?

N/A. There is no single program or government agency behind the “raised without antibiotics” label.

Is the organization free from conflict of interest?

N/A. There is no single program or government agency behind the “raised without antibiotics” label.

Was the label developed with broad public and industry input?

Partially for meat and poultry; the USDA accepts comments from the public on its labeling guidelines, which include guidelines for the “raised without antibiotics” labeling claim. However, the USDA allows variations of the claim, such as “raised without subtherapeutic antibiotics” which were not developed with broad public and industry input.

No for dairy and eggs; the FDA has no regulatory definition for the “raised without antibiotics” label on dairy and eggs.