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"Naturally raised" label deficient and misleading

January 22, 2008

Naturally Raised Marketing Claim
Room 2607-S
AMS, USDA
1400 Independence Ave. SW
Washington, D.C. 20250-0254

Dear AMS,

As the largest consumer-owned grocery retailer in the United States, we're writing to say that the USDA's proposed "naturally raised" label is deficient and misleading and should be abandoned. It would deceive consumers and undermine the integrity of the products we sell.

If USDA's proposal were to be approved, livestock producers could label their meat as being USDA verified "naturally raised" - without any concern for animal welfare, environmental stewardship, or even access to natural living conditions or feed (pasture grasses) suitable to their species. This appears to be intentionally misleading and would undermine seriously the USDA's grass-fed and certified organic labels.

The USDA's proposal, as it stands, fails to give consumers accurate information and fails to support their expectations in what such a label should mean. It also would fail to support farmers who deserve to earn a premium for best practices. It would allow cloned animals and their offspring, and livestock raised in confinement without pasture. It would allow young animals to be weaned on blood products and fed a diet of genetically engineered grains.

The USDA should distinguish and credit producers that do not employ antibiotics, artificial hormones or animal by-products in livestock feed. Labels designating "No synthetic hormones," "No antibiotics" or "No animal byproducts allowed in feed" should be approved and verified by independent, third-party inspectors.

We support labels that are accurate and help consumers make informed decisions. This label, as proposed, is not acceptable.

We encourage the USDA to address our concerns and incorporate stronger standards that would enhance marketing foods that are truly "naturally raised."

Sincerely,

Tracy Wolpert
Chief Executive Officer

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