Why We’re Asking FDA to Align “Pasture Raised” Standards for Eggs

APPPA has submitted a dual petition with both the USDA FSIS and the FDA urging the FDA to align egg labeling requirements for the “pasture raised” claim with the existing USDA FSIS definition already used for meat and poultry.

This effort is not about creating new standards or debating production science. It is about regulatory consistency, fair competition, and protecting the integrity of real pasture-based farming.

Same Label, Very Different Systems

USDA already maintains a clear, enforceable definition for “pasture raised” when the claim is used on meat and poultry products. That definition reflects meaningful outdoor access to actual pasture and provides clarity for both producers and consumers.

Eggs, however, fall under dual jurisdiction. Because FDA does not currently apply the same definition to shell eggs, the “pasture raised” claim can be used far more loosely. This regulatory gap allows large egg companies to market eggs from industrial or “free-range” systems — where birds may spend most of their lives indoors with limited outdoor access — using language and imagery that implies a truly pastured model.

The result is widespread consumer confusion and an uneven playing field.

Why This Matters for Pastured Producers

For farmers who genuinely raise birds on pasture, this lack of clarity has real consequences:

• Undermined price premiums: Consumers willing to pay more for real pasture-raised eggs cannot reliably distinguish them from industrial alternatives using similar claims.

• Unfair competition: Large-scale operations benefit from marketing language that implies pasture-based practices without meeting the same expectations.

• Eroded consumer trust: When labels don’t mean what shoppers think they mean, trust in all producers — including the ones doing it right suffers.

Our Ask: Apply an Existing Standard to Eggs

We are urging FDA to adopt or align with the existing USDA FSIS definition of “pasture raised” for egg labeling. This approach:

• Uses a standard that already exists and is well understood

• Improves consistency across agencies and product categories

• Clarifies the difference between limited outdoor access and true pasture-based systems

• Protects farmers who invest in genuine pasture management
  
  

This is a practical, achievable request focused on alignment — not expansion of regulation.

Why This Is a Win for the Pastured Poultry Community

Clear, consistent labeling helps ensure that when consumers choose “pasture raised,” they are supporting farms that actually raise birds on pasture. It reinforces the value of the production systems our members use and helps prevent industrial models from diluting the meaning of the term.

Ultimately, this effort supports:

• Fair markets

• Honest labeling

• Consumer confidence

• The long-term viability of pasture-based poultry farms
  
  

We encourage members to stay engaged, submit comments when possible, and help educate consumers about what truly pasture-raised production looks like.

USDA FSIS Petition Link: 

https://www.fsis.usda.gov/policy/petitions/petition-submitted-american-pastured-poultry-producers-association-apppa

Email comments to: fsispetitions@usda.gov

Subject: RE: Petition: 26-01 

FDA Petition Link:

https://www.regulations.gov/document/FDA-2026-P-1156-0001

Use the Comment Box under the Petition title.