Tell USDA to Finalize the 2015 Origin of Livestock Rule to Close Organic Dairy Loopholes
NOFA-VT and Vermont Organic Farmers (VOF) are asking all certified organic farmers to stand with U.S. certified organic dairy farmers and submit comments to the USDA in support of a strong final Origin of Livestock Rule (OOL). Not only is this important to dairy farmers—it is important to all organic farmers that rely on a strong organic label that maintains consumer trust.
Family organic dairy farmers across the country have suffered greatly over the past few years, partially because the USDA has failed to close regulatory loopholes that have allowed mega-dairies to skirt the rules (by continually transitioning conventional dairy animals) and have flooded the milk market causing lower prices to farmers. Consumers have caught wind of these mega dairies and have questioned the integrity of the organic label. We cannot let that happen! We must fight for strong standards.
All comments are due to USDA by December 2.
Individual comments to the USDA are best. Form comments will count as one comment. Please take 5 minutes to support organic dairies with a comment using the below template.
OOL Comment Template
INTRO: A short introductory paragraph about you and your farm. What do you grow, how long have you been certified, why organic integrity (strong standards) are important to you.
SUPPORT FOR THE RULE: A statement that clearly puts forward your support for the OOL final rule. You can use the below talking points:
- I strongly support the proposed rule on Origin of Livestock Rule and its immediate implementation.
- The OOL rule is needed to uphold consumers’ expectations about organic dairy by specifying that organic dairy animals must be raised organically from the last third of gestation or be raised organically for one year if transitioning a conventional herd to organic, which is allowed only once.
- Once a distinct herd is transitioned to organic, all animals must be raised organically from last third of gestation
- Cycling of dairy animals in and out of organic production is prohibited.
- USDA should honor farmer-comments and strengthen, not weaken, the proposed rule.
- The delay in issuing a final rule has resulted in economic harm for organic dairy farmers from low pay prices caused by an oversupply of organic enabled and encouraged by loopholes in the rule.
- Rulemaking is critical to bring consistent enforcement, maintain a level playing field to all organic dairy producers, and uphold strong organic integrity for all organic farmers.
CLOSING: A closing statement that reaffirms your support for the 2015 proposed Origin of Livestock Rule and asks for immediate or swift implementation.
- National Organic Program Q&A on the Proposed Rule
- Northeast Organic Dairy Producers Alliance Resource Page - Origin of Livestock
- Organic Trade Association Origin of Livestock Fact Sheet
- Full text of Proposed Rule published on Federal Register
- Notice from USDA to reopen the comment period