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IDFA Comments on USDA AMS Organic Livestock Proposed Rule

Dec 11, 2019
Comments on the U.S. Department of Agriculture (USDA) Agricultural Marketing Service (AMS) proposed rule to amend the origin of livestock requirements for dairy animals under the USDA organic regulations were due Dec. 2, 2019. On behalf of members who produce and market organic dairy products, IDFA offered comments.

For several years, IDFA members have raised concerns regarding the inconsistent interpretation and enforcement of the origin of livestock rule. This inconsistency has created an unlevel playing field across the organic dairy industry. IDFA applauds AMS for reopening this rule and join our member dairy companies in supporting a clear rule that adheres to the original intent of the statute.

IDFA, in general, supports the proposed rule and offers the following recommendations:

Replacement Dairy Stock: IDFA supports a rule whereby organic dairies may purchase replacement dairy stock only from animals that are (1) managed organically from the last third of gestation or (2) from certified organic dairy animals that have passed through an initial whole-herd one-time transition.

Whole-herd One-Time Transition: To ensure sufficient access to organic replacement stock, we recommend that the one-time transition be assigned to a “certified dairy operation” rather than a “producer.” IDFA’s members want to ensure that producers can sell their herd without foreclosing the possibility to returning to organic farming in the future. Similarly, producers need the flexibility to bequeath an organic farm and herd to family members and move to a new conventional location with the goal of starting a new organic dairy.

Transitioned Animal: IDFA supports the definition of “transitioned animal” and supports the proposed rule as it relates to the offspring of transitioned animals.

Implementation Timeline: IDFA urges AMS to issue a final rule that includes a timeline to make the new regulations effective immediately. Given the organic dairy market conditions and competitive harm the origin of livestock ambiguity has created, there is no need for a protracted phase-in period of the regulation.

To read IDFA's full comments, click here. 
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