To:                  R-CALF USA Members & Affiliates

From:            Bill Bullard, CEO


Background:  On July 15, 2020 the Federal Trade Commission (FTC) issued a proposed rulemaking titled “Made in USA Labeling Rule.” In its rule, the FTC proposes to strengthen its Made in USA labeling requirements to reserve the USA label only for products in which, among other things, all significant processing that goes into the product occurs in the United States and all or virtually all ingredients of the product are made and sourced in the United States.

The FTC is specifically seeking public comments on whether there are any current statutes, rules or policies that may conflict with the FTC’s proposal.

The conflict is this: While the FTC wants to ensure that only products actually made in the USA bear a “Made in USA” label, the Secretary of Agriculture has a policy that says a foreign beef product that enters the USA and is subject to only minor processing, such as being taken out of a big box and packaged in smaller boxes, can bear a “Product of USA” label.

This is the very kind of conflict the FTC needs to hear about. The U.S. Dept. of Agriculture’s (USDA)’s policy that allows a USA label on imported beef deceives consumers and should be considered fraud.

Everyone reading this is encouraged to file comments with the FTC regarding your support of its proposed rule.

The comment deadline is September 14, 2020.

Action: Submit comments on or before September 14. Here’s what you can say: I am a cattle producer or consumer and I support the FTC’s proposal but only beef that is born, raised, and harvested in the United States should be eligible for a “Made in the USA” or “Product of the USA” label.

To submit comments go to and click on the comment box and copy and paste from above ‘Action’ or write your own comment like the FTC comment submitted by Rick Keith, Producers Livestock – Omaha:

“I support the USA Labeling Rule, but only if it includes Beef – Born, Raised, and Harvested (BRH) in the United States. Now processors can bring in foreign beef, they can grind and mix it with actual USA “BRH” beef or do as little as repackaging it and call it a product of the USA. This is wrong, beef processors are slipping by the true intention of the rule. Please put a stop to this, as it hurts our beef industry.”

Good luck and thank you for your support!

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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is the largest producer-only lobbying and trade association representing U.S. cattle producers. It is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. Visit or, call 406-252-2516 for more information.