Origin of Livestock Letter to Sonny Perdue

 Organic Farmers Association submits letter to Sonny Perdue, Secretary of Agriculture, expressing concerns with the Origin of Livestock. Read the full letter below.


November 26, 2018

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

Dear Secretary Perdue,

The Organic Farmers Association is concerned that the current Origin of Livestock standards are creating unfair and inconsistent interpretations of the standards and inconsistent implementation by certifiers across the country. We respectfully ask that USDA prioritizes implementation of an Origin of Livestock Rule. To accomplish this goal, w

The current rule is inhibiting the National Organic Program’s ability to provide sufficient enforcement to ensure that our nation’s organic animal standards are fair and consistent. The effect of this is market instability which could lead to a lack of consumer confidence in the domestic organic dairy industry.

Our members, efficient domestic organic dairy producers, have seen inequities in the enforcement of regulation for dairies around the issue of the Origin of Livestock. They believe they can compete with the most efficient organic dairy producers if they are treated equitably. The Office of Inspector General (OIG) report supports their fears and concerns. The organic dairy industry lacks a clear uniform national standard for Origin of Livestock, a concept that is at the core of the creation of the Organic Food Production Act and the National Organic Program.

As you well understand, regulations must be enforced in a uniform and consistent manner to ensure all industry participants are competing on a level playing field. That is not the case of the current organic dairy industry.

USDA’s Office of Inspector General audit confirmed that certain segments of the organic dairy industry are being treated differently than other segments and that certifiers are interpreting the standards for origin of livestock very differently.

We ask that USDA fix those inequities by implementing the attached Organic Farmers Association Origin of Livestock suggestions (Attachment A). We base the policies on the OIC’s audit. We ask the Secretary to work with the National Organic Program to immediately issue Guidance on the interpretation of the one–time transition provision.

Our policy would clearly state that the provision for transitioning conventional cows to organic in one year is a one-time allowance and continuous transition of conventional livestock is not permitted. This language is not controversial and mirrors language first published in the 2015 Proposed Rule. It also mirrors the language in the preamble of the rule further supporting this interpretation. This would put organic dairy on the same level as all other organic commodities, would stop the fraud and confusion existing within the organic dairy industry, would stop continual transition of non-organic dairy heifers, would open the market for certified organic replacement animals, and would ensure that all US-based and international-based certifiers are using the same standards. Please see the Attachment B for more details on our proposal.

Detailed data needed to make sound policy decisions is difficult to find for the organic dairy industry. Despite the lack of macro level information, our members understand the daily impact of regulation failure (See Attachment B). Creating sound dairy policies and regulations needs sound data.

The organic industry is a $50 billion industry. We ask that USDA give serious consideration to providing more economic capabilities to collect the data and help the industry better understand the impact of proposed policies on the industry. The Organic Farmers Association is ready to work with USDA and Congress to build support for that request.

Founded in 2016, Organic Farmers Association is a national, grassroots, membership organization that provides a strong and unified national voice for domestic certified organic producers. Organic Farmers Associations works to build and support a farmer-led national organic farmer movement and national policy platform by: developing and advocating policies that benefit organic farmers; strengthening and supporting the capacity of organic farmers and farm organizations; and supporting collaboration and leadership among state, regional and national organic farmer organizations. Only certified organic farmers drive our policy positions. Our membership and network of certified organic farmers is diverse and spans all 50 states and U.S. territories.

We would be happy to talk with you and your leadership within Agricultural Marketing Service more about origin of livestock. We urge you to move swiftly as family organic dairy farmers are suffering because of the lack of uniform and strict enforcement. We know you share this priority for strong enforcement and integrity and look forward to hearing from you.


David Colson
President, Organic Farmers Association

Cc: Gregory Ibach, Under Secretary for Marketing and Regulatory Programs, Jennifer Tucker, Director, National Organic Program