December 2, 2019
The Honorable Sonny Perdue
Secretary
U.S. Department of Agriculture
1400 Independence Avenue SW
Washington, D.C. 20250

Dear Secretary Perdue,

The undersigned organizations are unified in our support for the proposed Origin of Livestock Rule. Rulemaking is critical to bring consistent enforcement, maintain a level playing field to all organic dairy producers, and uphold strong organic integrity for all organic farmers. We urge you to quickly review submitted comments and move towards immediate implementation of the Rule.

The Origin of Livestock Rule is needed to uphold consumers’ expectations about organic dairy by specifying that organic dairy animals must be raised organically from the last third of gestation or be raised organically for one year if transitioning a conventional herd to organic, which is allowed only once. Once a distinct herd is transitioned to organic, all animals must be raised organically from the last third of gestation. It must be prohibited to cycle dairy animals in and out of organic production.

The delay in issuing a final Rule has resulted in economic harm for organic dairy farmers from low pay prices caused by an oversupply of organic milk enabled and encouraged by loopholes in the current rule. As you are aware, 99% of the original comments to the 2015 Origin of Livestock Rule supported making these same changes. We urge you to ensure the final rule reflects the much-needed clarity requested by the organic dairy producer community and upholds a strong sense of organic integrity.

Both the House and Senate responded to the requests of the organic industry by including bill language in the Fiscal Year 2020 Agriculture, Rural Development, Food and Drug Administration and Related Agency Appropriations Bill requiring USDA to issue a final Origin of Livestock rule within 180 days from the date of enactment. The current rule is inhibiting the National Organic Program’s ability to provide consistent and fair enforcement; leaving our nation’s organic animal standards unfair and inconsistent.

The strong public-private partnership between USDA and the organic industry has created a foundation that has allowed the industry to grow into a $50 billion market. This provides economic opportunities for U.S. farmers and businesses and produces one of the most highly trusted labels by consumers.

We respectfully ask you to move quickly to end the five-year wait for legal clarity and consistent implementation of origin of livestock regulations. Organic dairy farmers are suffering, and we have the solution to level the playing field and uphold consumers’ expectations with strong regulations. We know you share a desire for strong enforcement and integrity and trust you will act quickly to issue and implement a Final Rule.

Sincerely,

National Organic Coalition
Organic Farmers Association
Organic Trade Association
Accredited Certifiers Association, Inc.

Be A Blessing Farm
Beretta Dairy
Beyond Pesticides
California Cloverleaf Farms
CCOF
Center for Environmental Health
Cuatro Puertas
Dr. Bronner’s
ETKO
FairShare CSA Coalition
Farm Aid
Food & Water Watch
Food Animal Concerns Trust (FACT)
Food Democracy Now!
FoodChain ID
Friends of the Earth
Hanover Co-op Food Stores
Hoosier Organic Marketing Education
IFOAM North America
Iowa Organic Association
Kanalani Ohana Farm
Lancaster Farm Fresh Co-op
LSAdderson, Inc.
Maine Organic Farmers and Gardeners Association
McClelland’s Dairy
Mensonides LLC Providence Farms
Midwest Organic and Sustainable Education Service (MOSES)
Midwest Organic Dairy Producers Alliance
MOFGA Certification Services, LLC
Montana Organic Association
MOSA Certified Organic
National Family Farm Coalition
National Farmers Organization
Natural Resources Defense Council
Nature’s International Certification Services
New England Farmers Union
NOFA-NY Certified Organic LLC
Northeast Farming Association of New Jersey (NOFA-NJ)
Northeast Organic Dairy Farmers Alliance
Northeast Organic Farming Association – Interstate Council
Northeast Organic Farming Association of Connecticut
Northeast Organic Farming Association of New York (NOFA-NY)
Northeast Organic Farming Association of Vermont
Northeast Organic Farming Association/Massachusetts Chapter (NOFA/Mass)
Northwest Center for Alternatives to Pesticides
OFARM Organic Farmers Agency for Relationship Marketing
Ohio Ecological Food and Farm Association
OneCert, Inc.

Oregon Tilth
Organic Crop Improvement Association Research & Education, Inc.
Organic Seed Alliance
Organic Seed Growers and Trade Assn (OSGATA)
OrganicEye
Pennsylvania Association for Sustainable Agriculture (PASA)
Pennsylvania Certified Organic (PCO)
Pesticide Action Network of North America
Primus Auditing Ops.
Quality Certification Services
Real Organic Project
Rocky Mountain Farmers Union
Rodale Institute
Sonoma County Department of Agriculture/Weights & Measures
Sonoma County Farm Bureau
Straus Family Creamery
Straus Organic Dairy Farm
The Cornucopia Institute
The Land Connection
Upstate Niagara Cooperative, Inc.
Vermont Organic Farmers (VOF)
Virginia Association for Biological Farming
Wesen Farms Inc
Western Organic Dairy Producers Alliance
Wild Farm Alliance