Comment from Pastured Life Farm

Comment for Docket FDA-2026-P-1156-0001 Re: Citizen Petition from American Pastured Poultry Producers Association – Alignment of “Pasture-Raised” Standards for Shell Eggs To Whom It May Concern: I am writing on behalf of Pastured Life Farm, an independent family farm in O’Brien, Florida, where we raise chickens on true rotational pasture using regenerative practices. We strongly support the Citizen Petition submitted by the American Pastured Poultry Producers Association (APPPA) requesting that the FDA establish clear, consistent labeling requirements for the “pasture-raised” claim on shell eggs that align with the definition and guidance already used by USDA FSIS for poultry meat and products. At Pastured Life Farm, our hens have meaningful daily access to high-quality, vegetated pasture for the majority of their lives. When we use the term “pasture-raised,” it reflects actual production practices — rotational grazing on living forage with vegetative cover — not just access to bare outdoor yards or minimal doors on a barn. Our customers choose our eggs because they believe in (and are willing to pay for) the superior nutrition, animal welfare, and environmental benefits that come from real pasture-based systems. The current lack of a clear FDA standard for shell eggs creates significant problems. It allows some producers and marketers to use the “pasture-raised” label on products that do not meet consumer expectations or match the practices of farms like ours. This misleads buyers, erodes trust in the marketplace, and puts genuine pastured producers at a competitive disadvantage. Consumers deserve to know that when they see “pasture-raised” on an egg carton, it means the hens actually spent the majority of their time on rooted, vegetated pasture — the same standard that applies to chicken meat. We urge the FDA to adopt a clear and enforceable definition consistent with the FSIS approach: eggs labeled “pasture-raised” should come from hens that spend the majority of their lives on land where the majority is covered in rooted vegetative cover (grass or other plants). This alignment would bring much-needed consistency across poultry products, protect the integrity of the claim, and reward farmers who invest in authentic regenerative practices. Thank you for the opportunity to comment. Pastured Life Farm is happy to provide additional details about our production methods, share customer feedback, or participate in any further discussions on this important issue. Sincerely, David Shields Pastured Life Farm O’Brien, Florida www.pasturedlife.com