What the New “Product of USA” Rule Really Means for Small and Mid-Sized Producers
- Nicole E. Day
- 1 hour ago
- 5 min read
This guidance is written for producers, processors, co-packers, and private label brands navigating the new FSIS requirements for voluntary U.S. origin claims.
Published: December 2025
On March 18, 2024, FSIS issued a final rule redefining the use of voluntary U.S. origin claims on meat and poultry labels. While these claims remain voluntary, the standards for using them have changed. Beginning January 1, 2026, any establishment applying a U.S. origin claim will need records that prove the claim is truthful and meets the criteria set in regulation.
This shift will affect establishments of every size. It will require many producers to strengthen traceability, supplier documentation, and label recordkeeping systems. Understanding the rule now allows producers to prepare without disruption.
The Rule in Plain Language
FSIS now treats the following as voluntary origin claims that require documented support:
• Product of USA
• Made in the USA
• Any alternative U.S. origin statement
These claims remain eligible for generic label approval. This means they do not require LPDS review unless the label contains other special statements. Generic approval does not remove the obligation to maintain full label records, demonstrate compliance, or provide support to FSIS.
Starting January 1, 2026, inspectors will verify that any establishment using these claims maintains documentation that satisfies the new standard.
What Counts as “Product of USA”
Single ingredient products
The establishment must show that animals were:
• Born in the United States
• Raised in the United States
• Slaughtered in the United States
• Processed in the United States
All four steps must occur domestically in order to use “Product of USA” or “Made in the USA.”
Multi-ingredient products
To qualify, the establishment must show:
• All FSIS ingredients meet the full birth-to-processing standard
• All other ingredients, except spices and flavorings, are of domestic origin
• All preparation and processing steps took place in the United States
If even one non-exempt ingredient is imported, the product cannot bear “Product of USA.”
Alternative U.S. Origin Claims
If a product does not meet the full criteria, an establishment may use a more specific claim. Examples include:
• Pork harvested in the USA
• Beef processed in the USA
• Cooked and packaged in the USA
• Sliced and sealed in the USA
These claims must be factual and limited to the exact production steps that occurred domestically. Documentation must match the language of the claim.
A Practical Example
A beef jerky product uses U.S. born, raised, slaughtered beef but includes imported soy sauce as part of its marinade.
• It cannot use “Product of USA.”
• It may use a specific alternative claim such as “Beef sourced and processed in the USA,” provided documentation supports the claim.
This is the type of nuance producers will need to consider as they review their current labels.
What Documentation Must Be Maintained
FSIS does not mandate a single format, but documentation must be sufficient to prove the claim is accurate. Establishments may maintain:
• Written descriptions of controls from birth through packaging
• Signed supplier statements or affidavits
• Ingredient specification sheets showing domestic origin
• Process flow descriptions
• Segregation or traceability records
• Receiving logs, invoices, and purchase records
• Internal descriptions of how the product is prepared
Records must be made available to FSIS within 24 hours upon request.
Important nuance on natural casings
A natural casing processed in another country may still be considered domestic origin if the animal was born, raised, and slaughtered in the United States. This distinction matters for small processors and charcuterie producers who rely on established supply chains.
How Generic Approval Fits Into This
Many producers interpret generic approval to mean they do not need documentation. The rule reaffirms that generic approval only removes the need for LPDS pre-approval. It does not remove the requirement to maintain:
• Mandatory label features
• Complete label records
• Support for voluntary claims
• Proof the label is truthful and not misleading
Generic approval still carries full compliance responsibility.
What Inspectors Will Be Verifying
FSIS inspection program personnel will review:
• Whether the label is eligible for generic approval
• Whether the establishment maintains a complete label record
• Whether documentation supports the U.S. origin claim
• Whether all mandatory labeling features are present
• Whether allergens are properly declared
• Whether the label matches the record in use
NOTE: If support is missing, the product will be retained and noncompliance documented.
FSIS will initially focus enforcement on “Product of USA” and “Made in the USA.” State origin claims will be addressed later.
Note on exported products
The new rule applies only to products sold in the domestic market. For exported products, establishments must continue to follow the labeling requirements of the destination country as outlined in the FSIS Export Library.
Co Packers and Private Labels
This rule applies equally to co-packers and private label brands.
• The establishment applying the claim must maintain documentation.
• Private label clients must align their origin statements with the establishment’s records.
• Co-packers must ensure their incoming ingredients do not conflict with the claim their client wishes to make.
Both parties share responsibility for accuracy. This is an area where misunderstandings commonly occur, and clarity now prevents conflict later.
Addressing Enforcement and Risk
If an establishment uses a claim without support, FSIS may:
• Retain product at the plant
• Issue a Noncompliance Record
• Require relabeling before product enters commerce
• Escalate repeat issues for further review
Misdeclared allergens or major errors may trigger recall actions. Preparing now reduces these risks significantly.
How Producers Can Prepare Now
Steps to take before January 1, 2026:
Review every label that uses U.S. origin language
Confirm whether each product meets the new definitions
Identify labels requiring modification
Strengthen traceability for all FSIS ingredients
Request updated domestic origin statements from suppliers
Standardize documentation for non-FSIS ingredients
Update label records with descriptions of processing steps
Train staff on new recordkeeping expectations
Consider shifting to precise alternative claims when full criteria are not met
Early preparation prevents relabeling delays and supply chain disruptions.
AgriForaging’s Perspective
Origin claims carry history, identity, and responsibility. They reflect a product’s story and the systems behind it. This rule does not limit tradition. It requires that origin statements align with documented fact. For many small and mid-sized producers, this reflects the integrity they already bring to their work.
Transparent origin claims protect consumers and strengthen trust in the domestic supply chain. Clear records protect the producer and prevent avoidable regulatory conflict.
For more federal labeling updates, visit www.agriforaging.com.
Have Questions?
Producers with questions about the new rule or its documentation requirements are welcome to use the AskHACCP Hotline. The service is free and confidential, created to support small and mid-sized food producers navigating regulatory systems.
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845 481 0820
Author
Writer: Nicole E. Day, Founder and CEO, AgriForaging Compliance Services Nicole specializes in regulatory compliance, HACCP systems, facility design, and technical guidance for small and mid-sized producers across the United States.
Reference
Final Rule: Voluntary Labeling of FSIS Regulated Products with U.S. Origin Claims
Federal Register: 89 FR 19470