AskHACCP: USDA Labeling Rules – What It Takes to Use ‘Pasture-Raised,’ ‘Grass-Fed,’ and ‘Free-Range’

Consumers are paying closer attention than ever to how animals are raised. Labels like “pasture-raised,” “grass-fed,” and “free-range” influence purchasing decisions and build brand identity. But under USDA regulation, these claims are far from casual. They must be well-documented, clearly defined, and fully supported through records, protocols, and often third-party validation.

In this AskHACCP post, we break down what it really takes to get these claims approved by the USDA Food Safety and Inspection Service (FSIS), how to avoid common pitfalls, and how AgriForaging Compliance Services supports producers every step of the way.

‘Grass-Fed’: More Than Just a Diet

“Grass-fed” refers to ruminant animals, such as cattle, and is evaluated using the former Agricultural Marketing Service (AMS) standard. Although AMS no longer certifies this claim, FSIS continues to approve it based on internal documentation and third-party support.

Key criteria include:

• Diet Requirements – Animals must consume only forage (grasses and other green plants) post-weaning. No grain, grain byproducts, or non-forage supplements allowed.

• Access to Pasture – Animals must have continuous access to pasture during the growing season.

• Records and Protocols – Producers must maintain feed plans, pasture management documentation, and animal movement logs.

• Third-Party Support – FSIS may request third-party certification in addition to internal records.

Note: Claims like “grass-finished” or “grain-finished” are distinct and must be defined and supported with accurate documentation. For detailed expectations, producers should align with FSIS’s updated 2024 compliance guideline, which specifies acceptable documentation for animal-raising claims, including photos, affidavits, and written protocols.

‘Pasture-Raised’: Open Space, Backed by Records

“Pasture-raised” is not formally defined by the USDA, which places the full burden of proof on the producer. FSIS will evaluate the claim based on the submitted materials, which describe what the term means in practice and how it is implemented.

Documentation should show:

• Substantial Outdoor Access – Animals must be raised on pasture for a meaningful portion of their lives.

• Space to Move – Animals must have enough outdoor space to express natural behaviors.

• Supporting Evidence – Typical submissions include farm maps, time-on-pasture logs, animal welfare protocols, and photographs.

FSIS typically requires qualifying label language such as: “Raised on pasture with access to shelter.”

As of March 2025, USDA now formally defines “pasture-raised” as animals that spend the majority of their lives on rooted vegetative cover. This definition may help producers better position their claims moving forward.

‘Free-Range’: Common for Poultry, Closely Scrutinized

“Free-range” is most often used in reference to poultry and carries specific USDA FSIS expectations.

To qualify, producers must show:

• Outdoor Access – Birds must have meaningful and continuous access to the outdoors.

• Shelter Access – Indoor shelter must be available, but outdoor access must be genuine and not limited to a small door or brief window.

• Verification Materials – FSIS reviews facility layouts, daily logs, photos, and written protocols to verify the claim

For egg producers participating in the USDA Grade Shield program, labeling approval must be submitted to the AMS.

Producers are encouraged to consult the USDA Meat and Poultry Labeling Terms glossary, which provides additional guidance on “free-range” and other animal-raising terminology used in FSIS-regulated products.

These Claims Apply Beyond Raw Cuts

Animal raising claims are not limited to carcasses or raw meat. They also apply to products such as ground meat, sausages, bacon, bone broth, soups, and charcuterie. Any FSIS-regulated label that includes “grass-fed,” “pasture-raised,” or “free-range” language must be supported by documentation, regardless of the product’s form or packaging.

Note for Multi-Ingredient Products

If your product contains multiple components, such as meat in a soup, sandwich, or frozen entrée, any animal-raising claim applied to that ingredient must also be fully substantiated. FSIS evaluates these claims regardless of where they appear on the label.

The Approval Process: What to Submit

FSIS categorizes animal raising claims as “special statements,” which require full sketch label approval. These claims cannot go through the generic label pathway.

Producers must submit:

• Detailed animal raising protocols.

• Signed producer affidavits.

• Time-stamped photographs and facility maps.

• Third-party certifications, if applicable.

• A sample label featuring qualifying language.

Third-Party Certification Claims If your label includes a third-party animal-raising certification (such as Certified Humane or Animal Welfare Approved), FSIS may require additional language to clarify the scope. This often includes a statement such as: “Certified by [Program Name]; standards are not defined or reviewed by USDA.” FSIS's 2024 guidance also recommends that the certifier’s name and a link to their published standards appear near the claim. This helps prevent consumer confusion and avoids implying USDA endorsement.

FSIS Labeling and Program Delivery Staff (LPDS) reviews all submitted materials before a claim may be approved for use.

Not All Claims Are Created Equal

USDA approval of a label claim confirms that the statement is documented and not misleading. It does not evaluate the ethics, sustainability, or overall animal welfare behind the practice. If your brand wants to tell a deeper story, AgriForaging can help you develop clear, compliant language that reflects your values and practices.

Common Mistakes to Avoid

Many producers unknowingly jeopardize their label approval or compliance status by overlooking key requirements. Here are some of the most common issues we see:

• Submitting labels with animal raising claims but no supporting documentation.

• Using “pasture-raised” to describe limited or seasonal outdoor access.

• Assuming third-party certifications alone are enough for FSIS approval.

• Using claims on processed products without verifying eligibility.

• Applying through the generic label pathways instead of sketch approval.

AgriForaging helps clients avoid these missteps through a hands-on, detail-oriented approach grounded in real experience.

Why It Matters

Submitting animal raising claims without full documentation can result in label rejection, product recalls, and enforcement action. Misleading or unsupported claims can also erode consumer trust. On the other hand, a thoroughly vetted and clearly supported claim can build brand credibility, increase consumer confidence, and open the door to premium pricing and new market channels.

AgriForaging’s Role: Technical Support with Integrity

At AgriForaging Compliance Services, we help producers develop strong, transparent label claims that are rooted in their actual practices. Our support spans every phase of the process, from protocol development and affidavit drafting to document review and communication with FSIS. We’re your partner in label accuracy and regulatory success.

Start with AskHACCP

The AskHACCP Hotline is a free and confidential service designed to help producers navigate regulatory questions, label claims, and food safety challenges. We offer guidance, clarity, and direction, but we do not perform consulting work through the Hotline.

Additional Resources For more information on claim substantiation, visit: FSIS Guideline on Animal-Raising Claims (2024) FSIS Labeling Guidance Index

If deeper support is needed, AgriForaging Compliance Services provides full technical consulting, including:

• USDA FSIS Label Submission and Approval Support

• Grass-Fed and Free-Range Claim Validation

• Animal Raising Protocol Development

• Third-Party Certification Coordination

• On-Site Compliance Audits
  

Have a question about your label claim? Submit it to the AskHACCP Hotline team, your trusted resource for food safety, compliance, documentation, and regulatory clarity.

Visit our Resources page for helpful training materials, infographics, FSIS guidance, step-by-step guides, and SOP references to support your food compliance needs.

And check out our newest federally approved offering: Nutrition Facts Labeling Analysis Services. Ready to move from questions to clarity? Whether you're refining a label or launching a new product, we’re here to support every phase of your compliance journey.