Week 6: Decoding the USDA organic label

Taste of India…the plate included paneer butter masala, garlic naan, onion pakora, aloo gobi, chana dal, and masala chai. This was the best meal I’ve had in weeks.

I possess the skills to cook, but lack the will. On average I subsist on a mixture of yogurt, cereal, fruit, and crudités. Taking this class however has inspired me to try to eat “better” (i.e., combining foods in a way beyond pouring milk over shredded wheats) and more consciously (i.e., organic, sustainable sourced, local, etc.).

The two are hard to tackle at once, but I’ve discovered two magical ingredients. . I’ve relied heavily on Trader Joes and their affordable organic frozen vegetables and microwave-able rice. But after paying an extra $2 or $3 for the organic versions, I wanted to know more about what that meant and what I was actually paying for.


The most common organic certification that I see is through the USDA. There are four categories of organic products in the US: crops, livestock, processed products, and wild crops.

The National Organic Program (NOP) develops rules and regulations for the “production, handling, labeling, and enforcement of all USDA organic products.” The NOP receives input from the National Organic Standards Board which is made up of 15 members of the public.

In the many regulations that the NOP has in their handbook, they also define what “organic” means. I was surprised by their definition, “a labeling term that refers to an agricultural product produced in accordance with the Act and the regulations in this part.” I expected more details in regards to how the products are planted, cared for, and harvested. However, after looking through the hundreds of specific regulations the USDA label dictates, I was less surprised.

Since I’ve been contemplating removing dairy from my diet, I looked more specifically into the regulations for dairy.


The feed for animals must be organic, and include some pasture. The rest can be purchased from certified organic livestock feed suppliers or “grown-on farm” sources.


A dairy animal has to be under “continuous organic management” for a least one year before their milk can be labeled organic. I wonder how much of a financial cost that means to dairy farmers; if they receive significantly more for organic milk and if that is enough to make up for the extra costs in feed and meeting regulations.

But wait, there’s an exception to the organic management rule. In 7 CFR §205.236(a)(2)(i), it dictates that a producer is allowed to transition both land and animals at the same time over a three-year period. It goes further to say “with animals consuming third-year transitional feed grown on land that is managed organically as part of the operation’s organic system plan.” The last sentence makes very little sense to me, and gives me the utmost sympathy for a farmer trying to figure this out. Is there a subset of lawyers which deal with USDA certification?


This is what I’m probably most interested in; how are the animals treated and what their living conditions look, smell, and feel like.

To be USDA organic certified dairy farmers have to ensure several things:

  • minimization of pain and stress for approved physical alterations
  • preventative health-care practices
  • year-round access to outdoors with fresh air, clean water, sun, shade, and exercise areas
  • shelter that provides for natural maintenance, comfort behaviors, exercise, and reduction of potential for injuries
  • documentation of temporary confinement

The “physical alterations” can apparently include ear notching hot iron branding, castration, and dehorning.  Year-round access to the outdoors does not include specific regulations on how long the access is for and what quality of the outdoors is available. Additionally, appropriate shelter is rather vague.

The lack of detail makes me feel as if farmers are capable of skirting many of the regulations, and reinforces the idea that further research is needed to ensure your dairy is coming from a humane source.







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