Comment from The Fertrell Company

To Whom It May Concern, I am submitting this comment as an animal feed nutritionist and agricultural stakeholder regarding the use of the label claim “pasture raised” on eggs regulated under FDA’s jurisdiction. USDA’s Food Safety and Inspection Service (FSIS) already maintains a clear, defined standard for the “pasture raised” label claim for meat and poultry products. This definition provides meaningful guidance to producers, consistency for enforcement, and transparency for consumers. However, because shell eggs fall under dual jurisdiction, this same clarity does not currently apply to eggs regulated by FDA. As a result, identical label claims are being used across products with different regulatory expectations, creating confusion for consumers and uncertainty for farmers. Producers using the “pasture raised” claim on eggs do not have an equivalent, enforceable federal standard to reference, even though one already exists within USDA. I respectfully urge FDA to adopt or align with the existing USDA FSIS definition of “pasture raised” for egg labeling. Applying an established federal standard would: - Improve consistency across agencies and product categories - Provide clearer expectations for farmers and packers - Reduce consumer confusion around label claims - Support fair competition by ensuring uniform use of the term This request does not seek to create a new standard, but rather to apply an existing, well-understood definition to a product category that is closely related and already subject to shared oversight. Regulatory alignment between USDA and FDA in this area would strengthen trust in labeling claims while supporting producers who are trying to comply in good faith. Thank you for the opportunity to comment and for considering this request for consistency and clarity in egg labeling. Respectfully,