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95–344 PDF 2015

HEARING TO REVIEW USDA MARKETING 

PROGRAMS 

HEARING 

BEFORE THE

SUBCOMMITTEE ON 

BIOTECHNOLOGY, HORTICULTURE, AND RESEARCH 

OF THE

COMMITTEE ON AGRICULTURE 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED FOURTEENTH CONGRESS 

FIRST SESSION 

JUNE 25, 2015 

Serial No. 114–19 

( 

Printed for the use of the Committee on Agriculture 

agriculture.house.gov 

COMMITTEE ON AGRICULTURE 

K. MICHAEL CONAWAY, Texas, Chairman 

RANDY NEUGEBAUER, Texas, 

Vice Chairman 

BOB GOODLATTE, Virginia 

FRANK D. LUCAS, Oklahoma 

STEVE KING, Iowa 

MIKE ROGERS, Alabama 

GLENN THOMPSON, Pennsylvania 

BOB GIBBS, Ohio 

AUSTIN SCOTT, Georgia 

ERIC A. ‘‘RICK’’ CRAWFORD, Arkansas 

SCOTT DESJARLAIS, Tennessee 

CHRISTOPHER P. GIBSON, New York 

VICKY HARTZLER, Missouri 

DAN BENISHEK, Michigan 

JEFF DENHAM, California 

DOUG LAMALFA, California 

RODNEY DAVIS, Illinois 

TED S. YOHO, Florida 

JACKIE WALORSKI, Indiana 

RICK W. ALLEN, Georgia 

MIKE BOST, Illinois 

DAVID ROUZER, North Carolina 

RALPH LEE ABRAHAM, Louisiana 

JOHN R. MOOLENAAR, Michigan 

DAN NEWHOUSE, Washington 

TRENT KELLY, Mississippi 

COLLIN C. PETERSON, Minnesota, Ranking 

Minority Member 

DAVID SCOTT, Georgia 

JIM COSTA, California 

TIMOTHY J. WALZ, Minnesota 

MARCIA L. FUDGE, Ohio 

JAMES P. MCGOVERN, Massachusetts 

SUZAN K. DELBENE, Washington 

FILEMON VELA, Texas 

MICHELLE LUJAN GRISHAM, New Mexico 

ANN M. KUSTER, New Hampshire 

RICHARD M. NOLAN, Minnesota 

CHERI BUSTOS, Illinois 

SEAN PATRICK MALONEY, New York 

ANN KIRKPATRICK, Arizona 

PETE AGUILAR, California 

STACEY E. PLASKETT, Virgin Islands 

ALMA S. ADAMS, North Carolina 

GWEN GRAHAM, Florida 

BRAD ASHFORD, Nebraska 

SCOTT C. GRAVES, Staff Director 

ROBERT L. LAREW, Minority Staff Director 

SUBCOMMITTEE ON BIOTECHNOLOGY, HORTICULTURE, AND RESEARCH

RODNEY DAVIS, Illinois, Chairman 

GLENN THOMPSON, Pennsylvania 

AUSTIN SCOTT, Georgia 

CHRISTOPHER P. GIBSON, New York 

JEFF DENHAM, California 

TED S. YOHO, Florida 

JOHN R. MOOLENAAR, Michigan 

DAN NEWHOUSE, Washington 

SUZAN K. DELBENE, Washington, Ranking 

Minority Member 

MARCIA L. FUDGE, Ohio 

JAMES P. MCGOVERN, Massachusetts 

ANN M. KUSTER, New Hampshire 

GWEN GRAHAM, Florida 

(II) 

(III) 

C O N T E N T S 

Page 

Davis, Hon. Rodney, a Representative in Congress from Illinois, opening 

statement .............................................................................................................. 1 

Prepared statement .......................................................................................... 2 

DelBene, Hon. Suzan K., a Representative in Congress from Washington, 

opening statement ................................................................................................ 3 

McGovern, Hon. James P., a Representative in Congress from Massachusetts, 

submitted article .................................................................................................. 21 

Newhouse, Hon. Dan, a Representative in Congress from Washington, submitted article ........................................................................................................ 26 

WITNESS

Morris, Ph.D., Craig, Deputy Administrator, Livestock Poultry and Seed Program, Agricultural Marketing Service, U.S. Department of Agriculture, 

Washington, D.C. ................................................................................................. 4 

Prepared statement .......................................................................................... 6 

Supplementary material .................................................................................. 21 

(1) 

HEARING TO REVIEW USDA MARKETING 

PROGRAMS 

THURSDAY, JUNE 25, 2015 

HOUSE OF REPRESENTATIVES, SUBCOMMITTEE ON BIOTECHNOLOGY, HORTICULTURE, AND

RESEARCH, COMMITTEE ON AGRICULTURE, Washington, D.C. 

The Subcommittee met, pursuant to call, at 1:31 p.m., in Room 

1300, Longworth House Office Building, Hon. Rodney Davis [Chairman of the Subcommittee] presiding. 

Members present: Representatives Davis, Scott, Moolenaar, 

Newhouse, DelBene, McGovern, Kuster, and Graham. 

Staff present: Carly Reedholm, Haley Graves, Jessica Carter, 

John Goldberg, Mary Nowak, Mollie Wilken, Keith Jones, Liz 

Friedlander, and Nicole Scott 

OPENING STATEMENT OF HON. RODNEY DAVIS, A 

REPRESENTATIVE IN CONGRESS FROM ILLINOIS 

The CHAIRMAN. This hearing of the Subcommittee on Biotechnology, Horticulture, and Research to review USDA marketing 

programs, will come to order. 

The chair would like to recognize our guest, Dr. Morris. Thank 

you for being here. 

Thank you to Ranking Member DelBene. 

I will offer my opening statement now. 

Good afternoon. I would like to welcome everyone to the Committee hearing. For the past several months, the Committee has 

evaluated aspects of agricultural marketing as we have observed 

consumers, ourselves included, are becoming increasingly savvy. As 

the number of choices available to us has increased, so has our desire to locate and purchase products that appeal to a broader set 

of criteria. Consumers are seeking more and different food products, not only appealing to price and quality characteristics, but 

now also relating to various production methods such as grass-fed, 

natural, organic, or the use of technology such as genetic engineering. While many farmers and ranchers are in the commodity business, some have been able to achieve market premiums by appealing to this new consumer demand and creating mixed market opportunities for their products. By utilizing a variety of production 

practices, producers are distinguishing their products in order to 

appeal to unique consumer desires. 

Today, we will be hearing from the USDA regarding programs 

that allow the Agricultural Marketing Service to help producers 

2 

and processors address consumer demand through the development 

of voluntarily and unique marketing claims. To distinguish and 

promote their products in the marketplace, USDA can assist producers using a variety of authorities, including the Agricultural 

Marketing Act of 1946, and the Organic Foods Production Act. 

As this Committee has repeatedly observed, the keys to success 

in any marketing venture is voluntary participation, robust, transparent, and meaningful standards and comprehensive enforcement 

to ensure compliance. Most people are aware of the USDA organic 

label but may not be aware of the policies and procedures of the 

National Organic Program. Likewise, I am sure many people have 

heard of and thoroughly enjoy certified Angus beef, but may not 

know where to find the standards that are in place for this program, nor may they be aware of the procedures in place to assure 

that this label claim is truthful and not misleading. 

USDA’s Agricultural Marketing Service has long been in the 

business of assisting producers in developing the programs and 

tools to take advantage of market opportunities. As the Agriculture 

Committee considers proposals to develop other production-based 

marketing claims, we felt it useful to review USDA’s authorities 

and procedures. And it is my hope that this information collected 

today will be of tremendous value as we look for opportunities to 

improve agricultural productivity, profitability, and sustainability. 

Before I turn to the Ranking Member, I want to briefly discuss 

a recent Supreme Court decision on the marketing order within 

this Subcommittee’s jurisdiction. In the ruling on Horne v. U.S. Department of Agriculture case, the Supreme Court held certain aspects of the raisin marketing order to be an unconstitutional taking. As with all marketing orders, these programs are initiated by 

each industry, and they have the opportunity to withdraw a marketing order at any time. Our responsibility is to uphold the integrity of marketing programs as they are a proven useful tool for 

many industries while ensuring our growers are not adversely 

harmed in the process. 

We are beginning to have bipartisan discussions with the USDA 

to determine the impact of this decision and may conduct additional hearings as the situation warrants. 

[The prepared statement of Mr. Davis follows:] 

PREPARED STATEMENT OF HON. RODNEY DAVIS, A REPRESENTATIVE IN CONGRESS

FROM ILLINOIS

Good afternoon. I would like to welcome everyone to the Subcommittee on Biotechnology, Horticulture, and Research. 

For the past several months, the Committee has evaluated aspects of agricultural 

marketing. As we have observed, consumers, ourselves included, are becoming increasingly savvy. As the number of choices available to us have increased, so has 

our desire to locate and purchase products that appeal to a broader set of criteria. 

Consumers are seeking more and different food products, not only appealing to price 

and quality characteristics, but now also relating to various production methods 

such as grass-fed, natural, organic, or the use of technologies such as genetic engineering. 

While many farmers and ranchers are in the commodity business, some have been 

able to achieve market premiums by appealing to this new consumer demand and 

creating niche market opportunities for their products. 

By utilizing a variety of production practices, producers are distinguishing their 

products in order to appeal to unique consumer desires. 

3 

Today we will be hearing from USDA regarding programs that allow the Agricultural Marketing Service to help producers and processors address consumer demand 

through development of voluntary and unique marketing claims. 

To distinguish and promote their products in the marketplace, USDA can assist 

producers using a variety of authorities including the Agricultural Marketing Act 

of 1946, and the Organic Foods Production Act. 

As this Committee has repeatedly observed, the keys to success in any marketing 

venture are voluntary participation, robust, transparent and meaningful standards, 

and comprehensive enforcement to ensure compliance. 

Most people are aware of the USDA Organic label, but may not be aware of the 

policies and procedures of the National Organic Program. Likewise, I’m sure many 

people have heard of and thoroughly enjoyed Certified Angus Beef, but may not 

know where to find the standards that are in place for this program; nor may they 

be aware of the procedures in place to assure that this label claim is truthful and 

not misleading. 

USDA’s Agricultural Marketing Service has long been in the business of assisting 

producers develop the programs and tools to take advantage of market opportunities. As the Agriculture Committee considers proposals to develop other productionbased marketing claims, we felt it useful to review USDA’s authorities and procedures. It is my hope that the information collected from today’s hearing will be of 

tremendous value as we continue to look for opportunities to improve agricultural 

productivity, profitability and sustainability. 

Before I turn to the Ranking Member, I want to briefly discuss a recent Supreme 

Court decision on a marketing order within this Subcommittee’s jurisdiction. In the 

ruling on the Horne v. U.S. Department of Agriculture case, the Supreme Court held 

certain aspects of the raisin marketing order to be an unconstitutional taking. As 

with all marketing orders, these programs are initiated by each industry and they 

have the opportunity to withdraw a marketing order at any time. Our responsibility 

is to uphold the integrity of marketing programs, as they are a proven useful tool 

for many industries, while ensuring our growers are not adversely harmed in the 

process. We are beginning to have bipartisan discussions with USDA to determine 

the impact of this decision and may conduct additional hearings as the situation 

warrants. 

I now yield to the distinguished Ranking Member, Ms. DelBene. 

The CHAIRMAN. I now yield to my distinguished Ranking Member, Ms. DelBene, for her opening statement. 

OPENING STATEMENT OF HON. SUZAN K. DELBENE, A 

REPRESENTATIVE IN CONGRESS FROM WASHINGTON 

Ms. DELBENE. Thank you, Chairman Davis. 

And thank you, Dr. Morris, for being with us here today. 

In recent years, the way the average consumer thinks about food 

has undergone a remarkable cultural transformation. Within a relatively short period of time, we have witnessed consumers rapidly 

moving from having little interest in products and where their food 

comes from to today’s consumers seeing food as an exciting possibility, and with cooking now part of personal discovery. 

Most importantly, both for the consumer and for agriculture, food 

is no longer something that just appears on grocery shelves. It is 

inspected, scrutinized, and given careful thought. Consumers are 

the real drivers behind today’s individualistic food environment, 

and it is within this newly-developed foodie culture that the U.S. 

production agriculture now finds itself. Like most market evolution, 

there is both good news and not so good news. 

The good news is food entrepreneurs, both producers and processors, have an increasingly diverse consumer base for which to 

tailor their products. The not-so-good news is an ever-growing and 

potentially confusing array of production, processing, and questions. And while more information for the consumer is a good 

thing, we need to ensure that this information is displayed in an 

4 

easy to understand and accurate way. And we also need to ensure 

that the information provided is grounded in sound science. 

I am pleased that the USDA’s Agricultural Marketing Service is 

here today because of their expertise in overseeing these emerging 

labels. We need to know how to best deliver information to the consumer, what is working now, what isn’t, and how we continually 

improve the current system. As the Committee exercises its responsibility in the area of marketing and labeling claims across the 

board, but including labels related to genetically engineered crops, 

it is critical that we all have a full understanding of the expertise 

that exists within AMS should Congress choose to move forward 

with any sort of new label. 

So, Mr. Chairman, I look forward to hearing from our witness 

today on this important matter, and I yield back. 

The CHAIRMAN. Thank you. 

The chair would request that other Members submit their opening statements for the record so that the witness may begin his testimony and to ensure that there is ample time for questions. 

The chair would like to remind Members that they will be recognized for questioning in order of seniority for Members who are 

present at the start of the hearing. After that, Members will be recognized in order of their arrival. I appreciate the Members’ understanding. 

The witness is reminded to limit his oral presentation to 5 minutes. Your written statement will be included in the record. 

I would like to welcome, once again, our witness, Dr. Craig Morris, Deputy Administrator, Livestock Poultry and Seed Program, at 

the Agricultural Marketing Service of the USDA based here in 

Washington, D.C. 

Dr. Morris, please begin when you are ready. 

STATEMENT OF CRAIG MORRIS, PH.D., DEPUTY 

ADMINISTRATOR, LIVESTOCK POULTRY AND SEED 

PROGRAM, AGRICULTURAL MARKETING SERVICE, U.S. 

DEPARTMENT OF AGRICULTURE, WASHINGTON, D.C. 

Dr. MORRIS. Chairman Davis, Ranking Member DelBene, and 

Members of the Subcommittee, thank you for the opportunity to 

testify today. The position that I serve is as the Deputy Administrator of Livestock Poultry and Seed Program for USDA Agricultural Marketing Service, or AMS, whose mission is to facilitate the 

efficient fair marketing of U.S. agricultural products. Within AMS 

the Quality Systems Verification Programs, or QSVPs, offered to 

the agricultural industry, there are a family of user-fee funded, 

audit-based, third-party verification services. There are a number 

of QSVPs, including those known as export verification programs, 

or EV programs, which are negotiated between the United States 

and foreign governments to ensure U.S. products meet the requirements of foreign buyers and keep U.S. products competitive in an 

international marketplace. 

These EV programs are vital to reopening foreign markets to 

U.S. beef after our nation’s first case of bovine spongiform 

encephalopathy. However, the QSVP I wish to focus on today is the 

highly visible USDA Process Verified Progam, or PVP. Currently, 

my program audits 51 different PVP companies, with approxiVerDate Mar 15 2010 10:12 Aug 20, 2015 Jkt 041481 PO 00000 Frm 00008 Fmt 6633 Sfmt 6601 P:\DOCS\114-19\95344.TXT BRIAN
5 

mately 190 different process verified marketing claims. Several 

PVP companies have labels in the marketplace featuring various 

market claims associated with the PVP shield. Examples of these 

marketing claims include use of antibiotics in animal agriculture, 

product availability, product palatability attributes such as tenderness and employee training in areas of animal welfare. Transparency of the standard behind the marketing claim and the 

knowledge that USDA is an independent auditor are the two key 

aspects of the PVP. 

Companies establish their criteria they want verified, write a 

quality management system program manual, then undergo rigorous audits by AMS to ensure that they are adhering to the standards they set for themselves. 

Recently, AMS approved a PVP for a company to verify their 

marketing claim that the food grade corn and soybeans processed 

at one of their facilities are tested to ensure they are at least 99.1 

percent free of traits that would indicate genetic engineering and 

to market their products as non-GMO/GE. 

I also think it is important to point out what the PVP program 

does not do. The PVP program is a Process Verified Progam, and 

not a product verification program. In the example of the nonGMO/GE PVP mentioned above, this means that there is no USDA 

non-GMO/GE marketing claim standard. In other words, USDA 

has not established a standard for what merits a non-GMO/GE 

marketing claim. Instead, the PVP verifies that the standard accompanied established for itself is transparent and being adhered 

to. By transparent, I mean that the standard behind the marketing 

claim is detailed on the USDA website, such as the specific GE 

traits being tested for, what testing methods are being used, the 

competency of those performing the tests, and that the USDA PVP 

website is available to any interested party to learn more about the 

basic of any PVP marketing claim. 

Second, the PVP is not a truth-in-food labeling program. Within 

the U.S. Government, with narrow statutory exception, regulatory 

bodies at the Food and Drug Administration and other agencies, 

such as the Food Safety and Inspection Service for certain commodities and not AMS are charged with ensuring that all food labeling 

claims, regardless of if they are associated with a PVP or not are 

truthful and not misleading. We have seen and heard that there 

is some confusion regarding how this non-GMO/GE PVP relates to 

AMS’s administration of the National Organic Program, or NOP. 

Therefore, I would like to offer some background differentiating 

those two programs. 

The NOP is a regulatory program within AMS that establishes 

national organic standards and protects the integrity of the USDA 

organic label through certification and proper enforcement. As authorized by Congress, under the Organic Foods Production Act, 

these organic standards assure consumers that products with the 

USDA seal meet consistent uniform standards. 

By contrast, USDA has not established standards for non-GMO/ 

GE claims. So, although the non-GMO/GE PVP outlined earlier 

does provide transparency and third-party verification, it is not establishing a national standard for what merits a non-GMO/GE 

6 

claim like we have done for the National Organic Program organic 

claims. 

In conclusion, AMS’s audit-based services such as the USDA PVP 

allow producers to assure customers of their ability to provide consistent quality products, or services, but do not establish national 

standards for marketing claims. Again, thank you for the opportunity to testify today. 

[The prepared statement of Dr. Morris follows:] 

PREPARED STATEMENT OF CRAIG MORRIS, PH.D., DEPUTY ADMINISTRATOR, LIVESTOCK

POULTRY AND SEED PROGRAM, AGRICULTURAL MARKETING SERVICE, U.S. 

DEPARTMENT OF AGRICULTURE, WASHINGTON, D.C. 

Chairman Davis, Ranking Member DelBene, and Members of the Subcommittee, 

thank you for the opportunity to testify on behalf of the U.S. Department of Agriculture (USDA) at today’s hearing to discuss some of the management system audits 

offered by the Department in support of producer marketing programs. It is our 

hope that the information we provide will offer a better understanding of our current activities and our programs. 

I serve as the Deputy Administrator, Livestock Poultry and Seed Program, for 

USDA’s Agricultural Marketing Service (AMS). AMS’ mission is to facilitate the efficient, fair marketing of U.S. agricultural products, including food, fiber, and specialty crops. Within AMS, there are a family of user-fee-funded, audit based thirdparty verification programs and services available to the agricultural industry under 

its Quality Systems Verification Programs (QSVP). The QSVP are designed to provide suppliers the opportunity to assure customers of their ability to provide consistent quality products or services. Under a QSVP, a supplier’s documented quality 

management system is verified through independent third-party audits conducted 

by qualified AMS staff. There are a few audit programs within the umbrella of 

QSVP that I will cover today. 

Processed Verified Program 

One of these is the Process Verified Program (PVP) which provides agricultural 

businesses with third-party, objective verification of a particular standard or marketing claim. With today’s label-conscious consumers, producers often rely on management system audits to support claims that help distinguish their products in the 

marketplace. USDA’s PVP assures buyers that the producer’s production processes 

that support specific marketing claims have been verified by an independent thirdparty audit conducted by AMS. Process verification based on an audit of company’s 

quality management system is distinct from the testing and certification of a product to a specific standard. Only the latter can guarantee to the consumer that the 

product meets the requirements, such as GE-free or hormone-free. Process 

verification can, however, provide confidence that the company’s management supports such claims. 

Companies with approved USDA PVPs make claims supported by their process 

verified points—these include age, source, feeding practices, or other raising and 

processing claims—and market themselves as ‘‘USDA Process Verified’’ with use of 

the ‘‘USDA Process Verified’’ shield and term. All label claims that are associated 

with a PVP or not, must be approved by the Food Safety and Inspection Service 

(FSIS) to determine if they are truthful and not misleading when associated with 

meat, poultry, or egg products in commerce that were produced under Federal Inspection. Separately, the U.S. Food and Drug Administration (FDA) is responsible 

for ensuring that labels for food under its authority are truthful and not misleading. 

It is the company’s responsibility to ensure labels for foods other than meat, poultry 

and egg products are truthful and not misleading under FDA’s requirements. The 

USDA Process Verified Program does not relieve the company of meeting regulatory 

requirements issued by other Federal Departments or USDA Agencies. 

Currently, AMS audits 51 different companies with PVP programs, which have 

approximately 190 different process verified points. Several companies with PVP 

programs have labels in the marketplace featuring various points with the USDA 

PVP shield. Examples of process points verified include: Perdue brand for cage free, 

tenderness guaranteed, no antibiotics ever, vegetarian fed, no animal byproduct fed 

chicken; Cargill’s Shady Brook brand for ‘‘No antibiotics used for growth promotion—antibiotics only used for treatment and prevention of illness’’ turkey; and 

Tyson’s no antibiotics ever chicken. 

7 

Transparency and the knowledge that AMS is the independent auditor are key 

aspects of the PVP. The company establishes the criteria that they want verified, 

writes a Quality Management System Program Manual, and then undergoes rigorous audits by AMS to ensure they are adhering to the standards they set for 

themselves. Some examples of the marketing claims supported by process 

verification today are ‘‘No antibiotics or hormones being fed or administered to animals’’ and ‘‘Source verified to the farm or ranch of origin’’. The two pillars of the 

PVP are that buyers and any interested party can come to the AMS website, required to be on any PVP consumer packaging, to see the specific details of the quality management system that serves as the basis of any PVP marketing claim and 

know that highly trained and independent employees are conducting the onsite audits of any approved PVP establishment. 

AMS utilizes the International Organization for Standardization (ISO) 19011:2002 

guidelines for quality management systems auditing. These internationally recognized guidelines provide a format for evaluating program documentation to ensure 

consistent auditing practices and ensure confidence in AMS as an independent 

third-party verifier. AMS auditors undergo extensive training in ISO and audit principles, as well as training specific to the industry, process, and/or claims they are 

auditing. AMS is committed to the transparency of its auditing services. AMS posts 

online a list of suppliers and the claims AMS verifies for all Process Verified Programs. 

The claims on food products associated with PVP’s, like all food labeling claims, 

fall under the jurisdiction of either USDA’s Food Safety and Inspection Service 

(FSIS) or the U.S. Food and Drug Administration (FDA). AMS’s sole focus is auditing whether a subject firm followed the process it described in its PVP application. 

AMS approval of a PVP does not mean that the labeling of food produced using the 

process necessarily meets the regulatory requirements for food labeling enforced by 

FSIS and FDA. 

Recently, AMS approved the first PVP for a company wishing to obtain third-part 

verification for its a marketing claim that its products meet its desired standard of 

99.1 percent non-genetically engineered (content, which the company is using as a 

basis for labeling the product as comprised of ‘‘Non-GMO/GE Process Verified’’ material. Under this new program AMS verifies that the processes and procedures are 

in place to support a claim that food grade corn and soybeans sold under the program are at least 99.1 percent free of traits that indicate genetic engineering. This 

means that the company can use the USDA Process Verified Shield, after prior approval by AMS officials, on the product labels or marketing materials that they use 

on the food grade soybeans and corn coming from the approved facility. These foods 

will not themselves be labeled for or sold directly to consumers. 

I think it is important to point out what this program does not do. First, this does 

not establish an approved claim for food safety nor does it establish a standard for 

food safety. Second, this is not a USDA marketing claim standard. USDA has not 

established a standard for what merits a marketing claim concerning the presence 

or absence of genetically engineered components in food regulated by USDA. Moreover, such a food labeling claim for plant-derived foods would fall within the regulatory purview of the FDA. In this case, the company established their own standard, terminology, and logo for the claim they wished to make and AMS simply 

verified that processes were in place and operational such that the firm could meet 

its own established standard. Such verification does not necessarily mean that any 

food labeling associated with the claim meets regulatory requirements enforced by 

FSIS or FDA. Third, the PVP is not a truth in food labeling program. Within the 

U.S. Government, the U.S. Food and Drug Administration (FDA), USDA’s Food 

Safety and Inspection Service, and other agencies, and not AMS, are charged with 

ensuring that all food labeling claims are truthful and not misleading. 

And, finally, AMS did not create a ‘‘Non-GMO/GE’’ logo for this program. Logos 

that may begin to appear in commerce identifying products produced under a PVP 

are those developed by the specific establishments themselves. Those logos are the 

responsibility of the good producer and are subject to copyright by Federal agencies 

other than AMS. The only official, AMS-authorized mark on a product produced 

under any PVP will be the PVP Shield associated with the PVP website associated 

with the specific marketing claim. 

Quality System Assessment Program 

A second audit service provided is the USDA Quality System Assessment (QSA) 

Program which provides companies that supply agricultural products and services 

the opportunity to assure customers of their ability to provide consistent quality 

products or services. It is limited to programs or portions of programs where specified product requirements are supported by a documented quality management sysVerDate Mar 15 2010 10:12 Aug 20, 2015 Jkt 041481 PO 00000 Frm 00011 Fmt 6633 Sfmt 6621 P:\DOCS\114-19\95344.TXT BRIAN
8 

tem. The specified product requirements may be identified by the company or may 

be those outlined in a USDA Export Verification (EV) Program. To operate an approved QSA Program, a company must submit a documented program that meets 

the program requirements as outlined by AMS. 

One such QSA Program is our export verification (EV) program for pork products. 

EV Programs ensure that the specified product requirements are supported by a 

documented quality management system and are verified through independent, 

third-party audits conducted by AMS. For example, our EV Program for Pork to the 

Russian Federation ensures that: 

• Pork is free of tetracycline group antibiotics. 

• Slaughter facilities have implemented a tetracycline group antibiotics testing 

program. 

• Facilities approved for export to the Russian Federation have implemented a 

microbiological testing program for generic Salmonella, Listeria monocytogenes, 

and total plate count testing. 

Certified Responsible Antibiotic Use Standard 

A final example of an AMS audit-based marketing program is the Certified Responsible Antibiotic Use (CRAU) Standard developed by School Food FOCUS 

(FOCUS) and The Pew Charitable Trusts (Pew). FOCUS and Pew sought to minimize the use of veterinary antibiotics that are identical or closely related to drugs 

used in human medicine and to offer schools a viable way to put poultry raised with 

responsible antibiotic use on menus. Poultry producers in conformance with CRAU 

are prohibited from using antibiotics with analogues in human medicine routinely 

or without clear medical justification. Use of antibiotics with analogues in human 

medicine must be rare, well documented, and prescribed by a veterinarian. Antibiotics that do not have analogues in human medicine have no further restrictions 

in this standard. 

The scope of the CRAU verification includes a comprehensive farm-to-package review of relevant processes and facilities that include hatcheries, feed mills, farms/ 

barns and processing/packaging sites. The audit must document systems for proper 

identification and segregation of CRAU product from farm to package. To meet the 

requirements of the CRAU standard, a poultry company must be audited by AMS. 

National Organic Program 

We have seen and heard of some confusion in the press and elsewhere regarding 

these audit-based marketing claims and AMS’ National Organic Program (NOP). 

Therefore, I would like to offer some background differentiating the two programs. 

The NOP is a regulatory program housed within AMS responsible for developing 

national standards for producing agricultural products labeled as ‘‘organic’’. These 

standards assure consumers that the production process for products carrying the 

USDA organic seal meet consistent, uniform standards. NOP regulations do not address food safety, nutrition or health. 

The Organic Foods Production Act of 1990 provided the authority for USDA to set 

these national standards for the production, handling, and processing of organically 

grown agricultural products. Statutory authority was also provided to enforce compliance with these standards, to accredit certifying agents, and to collect fees for accreditation services. 

NOP regulates the labeling of all organic crops, livestock, and agricultural products certified to USDA organic standards. Organic certification bodies inspect and 

certify that the production, processing and handling practices of farmers, ranchers, 

distributors, processors, and traders comply with the USDA organic regulations. 

USDA conducts audits and otherwise ensures that the more than 90 organic certification bodies operating around the world are properly certifying the production, 

processing and handling of products labeled as organic. In addition, USDA conducts 

investigations and enforcement activities to ensure the integrity of the products 

bearing the organic label. In order to sell, label, or represent their products as organic, operations must follow the specifications set out by the USDA organic regulations. 

Conclusion 

Audit-based services support the ability of producers to make specific claims or 

to assure customers of their ability to provide consistent quality products or services. These claims can cover raising, feeding, handling, processing, labeling practices, or other practices and processes that differentiate a product. They do not establish that the claim is in conformance with applicable labeling requirements, nor 

do they establish any food safety standards. I hope that this testimony and subsequent questions will help this Subcommittee better understand current AMS activiVerDate Mar 15 2010 10:12 Aug 20, 2015 Jkt 041481 PO 00000 Frm 00012 Fmt 6633 Sfmt 6621 P:\DOCS\114-19\95344.TXT BRIAN
9 

ties and the many marketing programs offered by the agency. Again, thank you for 

the opportunity to testify today. 

The CHAIRMAN. Thank you, Dr. Morris. 

Since it is a fly-out day, I am going to reserve my questions for 

the end. 

So I would like to begin by recognizing the gentleman from Georgia, Mr. Scott, for 5 minutes. 

Mr. SCOTT. Thank you, Mr. Chairman. And, Dr. Morris, you hit 

a little bit on the process versus product issue. Could you expand 

on that briefly for us? 

Dr. MORRIS. Absolutely. What the USDA Process Verified 

Progam is about is that when a company establishes for itself a 

standard that it wants to adhere to, we insure that—essentially, 

the internal quality management system within that company is 

operating as intended. It takes on two steps: One, we require a 

company to develop a documented quality management system. 

They submit that to us. We do a desk review of that to make sure 

that as written, that will deliver on the claim that they set for 

themselves. It will consistently produce a product that meets their 

standard. We then do on-site audits to make sure that in-plant, the 

things that they are doing reflect what we saw in the written manual. So it is all about them adhering to their own systems. But it 

is nothing about, at the end of the day, the product meets a certain 

USDA standard. 

Mr. SCOTT. So when the USDA set the standards for organics, for 

example, you are double-checking, if you will, them to make sure 

that they are complying with what they said their process was? Am 

I understanding that correctly? 

Dr. MORRIS. Somewhat, yes. In the case of the National Organic 

Program, Congress provided us express authority to develop national standards for what merits an organic claim. So we actually 

have a standard for what meets an organic claim. Then we have 

specific enforcement powers and investigation powers provided to 

us, again, by Congress, and implemented through regulation, and 

we go out and accredit the certifiers to make sure that they are 

competent as a certification body in performing the certifications on 

farm organic agriculture. 

Mr. SCOTT. Could you speak to the impact of the mandatory labeling in general as compared to the voluntary labeling and the differences in the supply chain and the costs to the consumer of the 

products. 

Dr. MORRIS. The U.S. marketing chain is very dynamic, and 

there is really not a one-size-fits-all approach. Clearly, in the cases 

of the organic program, Congress provided USDA with specific authority to set a single national standard. In many cases, the marketplace works quite well through a process verification where the 

industry sets for itself standards that it basically adheres to. 

So there is not necessarily one specific approach that works best 

in any one situation. We do, obviously, though, look to Congress for 

input in terms of the specific areas that would merit standardization nationally. 

Mr. SCOTT. But if there were no uniform standard, I am from 

Georgia, you could have one standard for Atlanta; you can have another standard for Augusta; one for Tifton; one for Columbus; one 

10 

for Macon, and that would create disruptions in the supply chain, 

I would assume, and maybe the consumer didn’t actually know 

what they were getting. 

Dr. MORRIS. Well, and that gets to exactly the reason the PVP 

was developed. The purpose of the PVP, what it was designed to 

do, is when you see similar claims in commerce, to be able to have 

transparency back to what is the standard behind that claim. So 

what the PVP is trying to do is give consumers that ability to go 

back and see those different standards that are in place in the 

marketplace. But we have many standards oftentimes, and they operate quite well. 

Mr. SCOTT. Without those standards, I would suggest it would be 

inconsistent and confusing. 

Dr. MORRIS. And they can be, yes. 

Mr. SCOTT. I am sorry? 

Dr. MORRIS. And they can be, yes, if there is not transparency 

back to the standards themselves. 

Mr. SCOTT. I am going to yield the remainder of my time, Mr. 

Chairman. But I may come back and ask another question as time 

goes on. 

The CHAIRMAN. The gentleman yields back. 

The chair recognizes Ranking Member DelBene, for 5 minutes. 

Ms. DELBENE. Thank you, Mr. Chairman. 

And thank you again, Dr. Morris, for being here. One of my main 

concerns when we are talking about any potential GMO or nonGMO certification program is that it not conflict in any way with 

the organic regulations or process that is already in place. Many 

in the industry, though certainly not uniformly, view organic certifications as the gold standard. And so I was wondering, in your 

opinion, would the current organic certification be sufficient to be 

labeled as non-GMO? 

Dr. MORRIS. Well, yes. Anything that is USDA organic is, by definition, non-GMO, as genetically engineered crops are not allowed 

to be used in that system. Now, I have to recognize that I do not 

oversee the National Organic Program. I have a peer, Deputy Administrator, Miles McEvoy, and if you would like, we can provide 

you with additional information in written form after I have had 

an opportunity to confer with him that goes into much more detail 

about how the National Organic Program not only controls that 

issue, but allows for the marketing of those products as non-GMO 

or non-GE. 

Ms. DELBENE. I would appreciate that. That would be helpful. 

And in today’s fiscal environment where resources are definitely 

scarce all around, I worry that with the new certification process, 

resources could be diverted away from other important programs, 

not only organic programs but programs across the board. So can 

you comment on how this might be avoided, or are more resources 

needed if we were going to have other programs that were going 

to be available? 

Dr. MORRIS. The PVP that we operate today is fully user-fee 

funded. So we establish a fee rate that is cost recovery. It basically 

pays for the caliber of the employees that we have carrying out the 

activities. So there are no appropriations required for carrying out 

the PVP. 

11 

Ms. DELBENE. And any other particular programs that might be 

put together would probably be user-funded as well then? 

Dr. MORRIS. Yes. The only issues that we would potentially have 

would be the development of standards, or things like that, the 

Subcommittee could be contemplating that we would need some 

source of funds to recover. 

Ms. DELBENE. You also talked earlier about the need for a quality management system. And so I wondered if you could describe 

what that is, and are they used in areas other than agriculture? 

Dr. MORRIS. Yes. Quality management systems are used extensively. They are used extensively in the manufacturing and service 

industries. Essentially, a quality management system is a collection of the business processes that are focused on meeting a customer’s requirements. It is expressed at the organizational structure, the policies, the procedures, the processes and resources needed to implement quality management. There are a number of different quality management system regimes out there, but far and 

away, the ISO 9000 family of standards is the most widely implemented worldwide, and those are the standards that we have chosen to implement as the basis of our Process Verified Program. 

Ms. DELBENE. And you brought out the ISO, International Organization for Standardization. And why do you use their guidelines, 

and so how did you go about using their guidelines, and how did 

they establish them? 

Dr. MORRIS. Without question, the ISO is the world’s largest developer of voluntary international standards. They facilitate worldwide trade by providing that common set of language between nations. They have nearly 20,000 different standards at the ISO that 

cover everything from manufactured products and technology to 

food safety, to agriculture, health care. It basically allows products 

from different markets to be directly compared. When we established the Process Verified Progam, we wanted it to have international recognition. We knew that our audit-based services under 

the broader class of what we call the quality service verification 

programs would need to have recognition from foreign governments 

so that we could keep U.S. agricultural products flowing. That is 

why we chose to use that as the basis of our program. 

Ms. DELBENE. Thank you. 

That completes my questions. I will yield back. 

The CHAIRMAN. Wow. Succinct hearing. We actually have Members yielding back time. 

Mr. Moolenaar is recognized for 5 minutes. 

Mr. MOOLENAAR. Thank you. And my apologies for being late. I 

missed some of your testimony. In general, there has been a lot of 

discussion. And when people meet with me, there is this question 

of voluntary versus mandatory. And you may have addressed that 

already in some of your comments, but do you have any thoughts 

on that? 

Dr. MORRIS. Well, it is very similar to the issue of whether or not 

there needs to be a single national standard for every single marketing claim out there. I think voluntary versus mandatory works 

well in different situations. We have, in AMS, a number of mandatory programs and a number of voluntary programs, both of which 

12 

we believe are doing an outstanding job of facilitating marketing. 

It really depends on the context of the specific issue in play. 

Mr. MOOLENAAR. And just, could you speak a little bit about 

some of your voluntary marketing programs and, again, maybe 

some of those you have already, but how effective are they? 

Dr. MORRIS. You would be hard-pressed to go to a grocery store 

and not see the product of a lot of our voluntary marketing programs. Everything from USDA choice beef to grade A eggs to certified Angus beef, to a lot of the claims that you would see on particular products related to responsible use of antibiotics, or humanely-raised claim. All of those are voluntary activities. So these 

are companies that have decided to voluntarily differentiate themselves from the marketplace and utilize AMS as their third-party 

auditor, and then also have the transparency behind the standards 

that they have set for themselves, not only available on the USDA 

website, but available to anybody that would seek that information. 

Mr. MOOLENAAR. In terms of the compliance with the standard, 

how does that work? 

Dr. MORRIS. Well it depends on the program. For a number of 

our mandatory programs, we have express authority provided to us 

for investigation and enforcement. In the case of our voluntary programs, companies, especially PVP companies, they have basically 

chosen to differentiate themselves from the broader market. They 

have chosen to hold themselves up as a company that not only has 

transparency but is following through on their standards. In that 

situation, if a company has built a brand around a PVP and then 

loses that PVP, that penalty alone is quite significant to that company in the marketplace. 

Clearly, in the course of our audits, both desk and on-site, we do 

find non-conformance. We have had firms that have lost their process verified status. That impacts their ability to continue to sell 

products as process verified, and really undermines the brand that 

they have developed for themselves. 

Mr. MOOLENAAR. So you have, after conducting an audit, if you 

find irregularities, do you notify them and then give them an opportunity to comply, or is it immediate loss of status? 

Dr. MORRIS. It depends on the severity of the non-conformance. 

We have minor non-conformance that we can deal with in followup audits, we are requesting corrective and preventive action. We 

have significant non-conformance that can render a program immediately unapproved, and we are actually at that point looking back 

in to the product that was produced since the last audit. So it really varies based on the issues at play. We have for-cause audits that 

we will see things occur in the marketplace or have third parties 

bring to us products that they don’t believe to be conforming, and 

that could initiate us coming in and doing an on-site for-cause 

audit, which then, again, can affect their approval. 

Mr. MOOLENAAR. Well, thank you very much. 

And, Mr. Chairman, I yield back. 

The CHAIRMAN. The gentleman yields back. 

The gentleman from Massachusetts, Mr. McGovern, is recognized 

for 5 minutes. 

Mr. MCGOVERN. Thank you, Mr. Chairman. 

13 

And thank you, Dr. Morris, for being here. I appreciate all the 

work that you do. This is an interesting hearing, in the context of 

something that we are beginning to talk about in this Committee, 

and in other committees, about the issue of GMO labeling. Voluntary versus mandatory, or only voluntary non-GMO labeling. 

Quite frankly, I am puzzled by this debate, because I fall on the 

side of the fact that if a majority of people in this country want 

there to be GMO labeling so they know what they are buying, then 

I am for it. I am not making any judgment about the safety or the 

quality of the food. We have all been eating GMOs for a long time, 

but if a majority of people want to know that information, why 

shouldn’t we give it to them? 

There is a recent poll from the Mellman Group that found that 

Americans overwhelmingly favor requiring labels on GMO food: 71 

percent of Americans strongly favor GMO labeling. And I guess the 

argument against the voluntary stuff is that some might do it, 

some might not, but it just makes it more difficult for the consumer 

in my mind. I am not asking you to take a position, but if you are 

going to come up with a standard for what is non-GMO, wouldn’t 

it just be simpler for the consumer to have one label that indicates 

whether something contains GMOs? 

Dr. MORRIS. In AMS, we carry out both kinds of programs, mandatory labeling programs and also our voluntary labeling programs. 

Again, the voluntary labeling programs are carried out on a fee-forservice basis. So these are companies that are choosing to differentiate themselves in the market hoping to command a premium for 

their products because, obviously, they are paying for the 

verification service that we provide. 

So the question is one of is it appropriate for companies to try 

to demand a premium for the product, which is what people obviously use AMS for with our Process Verified Progam and other voluntary marketing programs, or in the mandatory scheme that we 

carry out in other areas where we have been provided authority by 

Congress. 

Mr. MCGOVERN. Right. We have heard a lot of talk that, the 

mandatory route, will cost all this money, it is going to cost the 

consumer money. And yet I am reading from the Washington Post 

Fact Checker that says that people who claim that mandatory labeling is going to cost consumers significantly more in groceries per 

family per year, earned three Pinocchios. Does AMS have any evidence on the cost to consumers on mandatory versus voluntary labeling? 

Dr. MORRIS. No. Again, because the voluntary programs basically 

go where the market wants them. And so we don’t typically sit 

down on our voluntary programs and determine the return on investment, because a company is making that decision when they 

approach us. And so as we dealt with on this particular firm that 

we were discussing during the testimony, they have made a business decision that the investment in AMS auditing is going to help 

them command a premium in the marketplace for their products. 

That is a very different model. So we don’t track the mandatory 

versus voluntary unless we are going into an environment where 

we are given authority by Congress to require labeling. 

14 

Mr. MCGOVERN. So basically at this point, if Congress said to you 

we want mandatory GMO labeling, you would then—— 

Dr. MORRIS.—conduct an economic analysis. 

Mr. MCGOVERN. All right. I thank you and I raise the issue because I have been at a number of briefings where people talked 

about the pros and cons of GMO foods and how they fit into our 

society right now. It just seems to me that the more people resist 

giving the public what they want, the more the public begins to 

suspect maybe there is something wrong with these products. I 

think sunshine and transparency are a good thing. So I would hope 

that Congress would move along the line of greater transparency 

and giving the American people what they want. I thank you very 

much for being here. 

Dr. MORRIS. Thank you. 

The CHAIRMAN. The gentleman yields back. 

Does the gentleman from Massachusetts wish to produce his poll 

or his Pinocchios for the record? 

Mr. MCGOVERN. Absolutely. Thank you. With unanimous consent 

and all the other blessings you would give me. 

The CHAIRMAN. Without objection. 

[The information referred to is located on p. 21.] 

Mr. MCGOVERN. Thank you. 

The CHAIRMAN. Dr. Morris, again, I appreciate you being here. 

I am going to go ahead and ask you a few questions myself. 

I mentioned this in my opening statement about the Supreme 

Court’s decision in the case involving volume control components of 

the raisin marketing order. And the court held the requirement for 

producers to surrender a portion of their crop without just compensation to be an unconstitutional taking. Can you provide, for 

the record, an analysis of this decision, and in particular, what, if 

any, implications this decision has for this or other marketing orders? 

Dr. MORRIS. Absolutely. As I opened with my statement, the efforts of AMS are divided primarily on commodity lines, and I don’t 

actually have marketing orders under my purview. Let me go back 

to the Department and we will work with our Office of the General 

Counsel and Department of Justice and prepare something for you 

in writing. 

The CHAIRMAN. Thank you. Thank you. And for the record 

too—— 

Dr. MORRIS. Yes. 

The CHAIRMAN.—you already oversee a program that is synonymous with non-GMO, that is organic. So can you tell us, for the 

record today, that if one buys an organic product, certified organic 

product, meets all the standards, that it does not include genetically modified seeds? 

Dr. MORRIS. Now, again, I have a peer, Deputy Administrator 

Miles McEvoy. He is the Deputy Administrator of the National Organic Program. Let me go back with him, and we will prepare for 

you, for the record, a much more expansive reply. 

[The information referred to is located on p. 21.] 

The CHAIRMAN. All right. And the organic program sets a single 

standard for organic marketing claims, though? 

Dr. MORRIS. Correct. 

15 

The CHAIRMAN. Can we fairly conclude the establishment of this 

voluntary and transparent standard for organic has helped actually 

build the market for those products? 

Dr. MORRIS. Yes. I think that would be a fair conclusion. 

The CHAIRMAN. Okay. All right. I will reserve the balance of my 

time and recognize Mr. Scott, again, for a second round of questions. 

Mr. SCOTT. Thank you, Mr. Chairman. And one of the things 

that I do think is important to point out is that the certified Angus, 

if you will, that is a voluntary. And I sold Angus cows with my 

grandfather for a long time. We also had a commercial herd. When 

we sold our Angus cows, we didn’t imply that the Limousin Brahman Angus mix cows were unsafe, if you will. 

And some of the, if you will, things that are being said about the 

use of biotechnology in agriculture is confusing, and in the end, 

misleading. We use less fertilizer, less pesticides. Biotechnology has 

been good for the environment, has been good for the producer, and 

has been good for the consumer. But one of the key differences in 

the certified Angus voluntary labeling and what we are facing right 

now is we are facing mandatory labeling from a government, in 

some cases, states, in some cases they are trying to do it at the 

local level. And I guess my question for you is, if somebody passed 

a standard, let’s say, for whatever city we want to call—let’s say 

they want to pass one for Washington, D.C., who would certify 

that? 

Dr. MORRIS. Well, that would be up to the firm that would—well, 

I guess it would be up to the city or the municipality that has 

passed that requirement. So we have not been approached at AMS 

about carrying out any mandatory labeling programs for genetically engineered products. 

Mr. SCOTT. So if a state, for example, we have seen states go 

down this path, who would certify that at the state level? 

Dr. MORRIS. That would have to be determined at the state level. 

Mr. SCOTT. And so the USDA wouldn’t have to? 

Dr. MORRIS. There are a lot of different agencies that relate to 

food labeling. AMS deals, with the exception of those areas, we 

have mandatory labeling programs or specific statutory authority 

to set standards. Most of what we are dealing with, most of what 

I particularly deal with, are these voluntary mandatory claims that 

are used at the national level. We would probably need to go back 

and consider the impacts of some of the state level labeling laws 

and what impact that would have on USDA, or more broadly, the 

Executive Branch. I probably need to follow up with you on that, 

because that gets outside of, really, my scope. 

Mr. SCOTT. Somebody would have to pay for that labeling. Somebody would have to pay for that standard. The state or whoever 

passed that law would have to contract with somebody to do that. 

And I guess that is where I think that we are headed down a very 

dangerous path here for the consumer where, if something is not 

done here, then you are going to see more inconsistency and more 

confusing scenarios for the consumer. The USDA is the standard 

for guaranteeing that we are getting what we purchase when we 

go to the store. 

16 

Mr. Chairman, there is a lot that needs to be done here to protect the consumer to make sure the consumer understands actually 

what they are getting, and there is a uniform standard. 

Thank you for your testimony. 

Dr. MORRIS. Thank you. 

The CHAIRMAN. The gentleman yields back. 

The gentleman from Michigan is recognized, Mr. Moolenaar, for 

5 minutes. 

Mr. MOOLENAAR. Thank you, Mr. Chairman. And, again, thank 

you for your testimony, Dr. Morris. 

I wonder if you can help me with some of the definitions that you 

hear a lot. There is genetically engineered, genetically modified. Are 

those synonymous terms? 

Dr. MORRIS. Well, genetic engineering is really the method used 

to arrive at the claim. In the case of genetically modified, genetically modified organism, GMO, those are terms that consumers 

rightly or wrongly are associating with a class of products that they 

are wanting to seek more information about or have an opinion 

about one way or another. So genetically engineered is the technology that is arriving at this class of foods that are often labeled 

as non-GMO, there is a lot of Federal guidance in this area. But 

there are different kinds of genetic—it is very complicated. We can 

get back to you with a little bit more in writing if you want in 

terms of some of the different technologies and how they are applied. But genetic engineering is clearly the proper term for this 

class of foods that we are discussing. 

Mr. MOOLENAAR. So it is the means of genetic modification that 

is the genetic engineering? 

Dr. MORRIS. Correct. 

Mr. MOOLENAAR. Some of the modifications occur in nature, do 

they not? 

Dr. MORRIS. Absolutely. 

Mr. MOOLENAAR. Could you speak to that? 

Dr. MORRIS. Yes. In the case of the non-GMO/GE PVP that we 

have approved, we are specifically looking for those traits that indicate genetic engineering. So an example, and let’s say livestock, 

where you can naturally select cattle that are pulled without horns. 

Or you can go with gene editing and kind of preordain that you 

have decided that this is going to be a pulled animal more efficiently than if you went through natural selection. Those are very 

different things. 

So in the case of our non-GMO/GE program, we are really looking for those traits that wouldn’t be arrived at through natural selection that are much more genetic engineering as opposed to some 

of the gene editing and some of those other things. 

Mr. MOOLENAAR. And how do you handle that with respect to 

natural. Because if certain things are being genetically modified 

naturally, how do you approach that? 

Dr. MORRIS. AMS doesn’t regulate the term natural for meat, 

poultry, and egg products, our sister agency, the Food Safety and 

Inspection Service, and for all of the commodities, the Food and 

Drug Administration. So natural claims fall in a whole different 

area that are somewhat independent or on a separate stream from 

the debate we are having on non-GMO/GE. 

17 

Mr. MOOLENAAR. Okay. Thank you. I appreciate it. 

I yield back. 

The CHAIRMAN. The gentleman yields back. 

The gentleman from Washington, Mr. Newhouse, is recognized 

for—I haven’t figured out how long yet, because he is late—for 5 

minutes. 

Mr. NEWHOUSE. So I will make up some time a little bit there. 

Thank you, Mr. Chairman, I appreciate that. I apologize for my 

lateness, but I can assure you, I was doing good work. 

I appreciate you being here, Dr. Morris. I don’t really have a 

question as such, so I won’t take much time. But I just wanted to 

expound on what I understand my colleague from the State of 

Washington and our Ranking Member, Ms. DelBene, was asking, 

if I could. 

Under current USDA regulation, is, in fact, the case that biotech 

products are not allowed to be certified organic? I would like to 

read an excerpt from the USDA blog from a post titled Organic 

101, Can GMOs Be Used in Organic Products? And that was dated 

May 17, 2013. So if I may, just to enter it into the record. 

‘‘The use of genetic engineering, or genetically modified organisms (GMOs), is prohibited in organic products. This means an organic farmer can’t plant GMO seeds, an organic cow can’t eat GMO 

alfalfa or corn, and an organic soup producer can’t use any GMO 

ingredients.’’ 

The reason, Mr. Chairman, that I raise this point is because it 

is frustrating to me that USDA already has this, what I would call 

a great voluntary tool for consumers to know what is in the food 

and products that they purchase, but that some jurisdictions feel 

compelled to impose duplicative, costly, and mandatory burdens on 

consumers and producers that, as far as can be seen from the 

USDA’s own blog, add no additional benefit. So ultimately, I believe this Congress and this Committee will likely have to consider 

legislation to ensure that our farmers, ranchers, growers, producers, and families aren’t harmed by these costly unworkable 

rules. And that is not necessarily a question, but just a statement, 

and I wanted to make sure I got that in the record. 

And with that, Mr. Chairman, I would yield back. 

The CHAIRMAN. Let the record show the gentleman yielded back 

3 minutes of time. 

Thank you, Mr. Newhouse. 

And I want to go ahead and get into a few more questions with 

you, Dr. Morris. And we are waiting on possibly another Member 

to get here to ask a few questions. 

Obviously, there has been a lot of discussion about H.R. 1599, 

and I would like to know, has the USDA taken a look at the 

USDA-related portions of H.R. 1599, the Pompeo-Butterfield bill? 

Dr. MORRIS. Yes. We have looked at the legislation. We have 

worked with technical assistance with the Subcommittee, absolutely. 

The CHAIRMAN. All right. If the non-GE certification provisions 

included in the Pompeo-Butterfield bill were enacted, would that 

give the USDA the authority to establish a standard for non-GE 

food labeling programs? 

18 

Dr. MORRIS. We are familiar—as I stated, we are familiar with 

the legislation as introduced. Our read of the bill is aimed at providing authority to establish a standard, but certainly there are 

many aspects of the legislation, and we continue to analyze its impact if it is enacted in its current form. It does affect many agencies in the Department, so we are working through that. 

The CHAIRMAN. All right. Under the bill, the USDA is instructed 

to promulgate regulations establishing a non-GE labeling program. 

When the agency promulgates regulations to implement such programs as they did with the National Organic Program, what kind 

of opportunity is typically available for the public to comment and 

influence the rulemaking process? 

Dr. MORRIS. Again, without final legislation explicitly directing 

us on what to do, there are several processes that we could use. 

With our standard rulemaking process, we typically, we always do 

provide the public with multiple opportunities to comment. Again, 

we don’t have the final legislation or our regulatory guidance at 

this time. 

The CHAIRMAN. And we don’t have the final legislation either, 

hopefully you can come back and we can have further discussion. 

But my last question, some observers assert that because some 

consumers desire information concerning the use or nonuse of genetic engineering, all consumers should pay the price through mandatory labeling schemes. I know that some other Members mentioned this process with you, but it seems to me that USDA’s voluntary labeling programs provide additional information to consumers about how their food was raised or produced, and they do 

so in a manner that adds value to the agricultural production, marketing claim. 

Would you agree that the USDA’s labeling programs provide 

value? 

Dr. MORRIS. In short, yes. As we stated, these services are provided for a fee. So the private-sector is very smart, that they are 

making a decision that there is a value in paying for the service 

that we provide. 

The CHAIRMAN. So you agree these labels provide useful information to consumers who actually desire it? 

Dr. MORRIS. Yes. 

The CHAIRMAN. Okay. Well, I have no further questions. 

I will yield to the Ranking Member for any last questions or closing statement. 

Ms. DELBENE. I have no further questions. I want to thank you, 

again, for being here and appreciate your follow-up on the earlier 

information from your colleague. 

Dr. MORRIS. You bet. 

Ms. DELBENE. Thank you. 

The CHAIRMAN. Today, the Subcommittee examined the tools and 

capabilities of USDA’s Agricultural Marketing Service to assist food 

producers to market their products. As we look more closely at the 

types of products consumers are demanding, we need to have the 

programs in place to ensure that the claims made on product labels 

are truthful and not misleading. 

The farmers want and need to provide consumers with the products they desire. And as we have just heard, the Agricultural MarVerDate Mar 15 2010 10:12 Aug 20, 2015 Jkt 041481 PO 00000 Frm 00022 Fmt 6633 Sfmt 6601 P:\DOCS\114-19\95344.TXT BRIAN
19 

keting Service has the tools and expertise to provide consumers 

with the information they want in a manner that supports interstate commerce. 

We will soon consider a substitute amendment to H.R. 1599, the 

Safe and Accurate Food Labeling Act, which seeks to put in place 

the policy to make this work. That substitute is circulating in draft 

form and will continue to go through refinement as we near Committee consideration. Consumers are now being exposed to arbitrary and inconsistent label claims, some for non-GE products such 

as salt, where there is obviously no genetically engineered salt. 

Consumers will benefit from legislation under consideration, which 

would establish a national uniform and voluntary marketing approach to these label claims. The House Committee on Agriculture 

has a long history of involvement in developing policies to further 

the advancement of agricultural biotechnology. We are aware of the 

incredible potential this technology brings to food and fiber production. With biotechnology, the careful and precise addition of one or 

a few genes to a plant may make it more productive and nutritious, 

more tolerant to environmental stresses such as drought, and more 

resistant to disease and pests. 

These technologies can likewise improve the efficiency and therefore, the productivity of agriculture, while at the same time, reducing detrimental effects on the environment. These and other advances have enabled us to enjoy the safest highest quality, most 

abundant and affordable supply of food and fiber in mankind’s history. As our knowledge has increased, so has the speed and precision in which we are able to harness natural capabilities to improve the plants that we cultivate. 

We just heard from the USDA that they have the capability and 

resources to provide the valuable oversight of these voluntary marketing claims. We know from previous hearings in this Committee 

as well as the Energy and Commerce Committee that we have a 

robust regulatory review process to ensure human, plant, and animal health as well as environmental health. We look forward to everyone’s thoughtful review and constructive suggestions. And with 

that, I want to thank the witness for his time here today. I look 

forward to having you back in front of this Subcommittee to discuss 

this legislation further. 

And with that, under the rules of the Committee, a record of today’s hearing will remain open for 10 calendar days to receive additional material and supplementary written responses from the witness to any questions posed by a Member. This Subcommittee on 

Biotechnology, Horticulture, and Research hearing is now adjourned. 

[Whereupon, at 2:16 p.m., the Subcommittee was adjourned.] 

[Material submitted for inclusion in the record follows:] 

21 

SUPPLEMENTARY MATERIAL SUBMITTED BY CRAIG MORRIS, PH.D., DEPUTY

ADMINISTRATOR, LIVESTOCK POULTRY AND SEED PROGRAM, AGRICULTURAL

MARKETING SERVICE, U.S. DEPARTMENT OF AGRICULTURE

Insert 

The CHAIRMAN. Thank you. Thank you. And for the record too—— 

Dr. MORRIS. Yes. 

The CHAIRMAN.—you already oversee a program that is synonymous with 

non-GMO, that is organic. So can you tell us, for the record today, that if one 

buys an organic product, certified organic product, meets all the standards, that 

it does not include genetically modified seeds? 

Dr. MORRIS. Now, again, I have a peer, Deputy Administrator Miles McEvoy. 

He is the Deputy Administrator of the National Organic Program. Let me go 

back with him, and we will prepare for you, for the record, a much more expansive reply. 

The use of GMO seeds is prohibited with no exceptions. The USDA organic regulations at 7 CFR § 205.204 require that organic producers use organic seeds, annual 

seedlings, and planting stock. The regulations allow producers to utilize non-organic 

seeds and planting stock when equivalent organic varieties are not commercially 

available, however this allowance does not extend to the allowance of GMO seeds. 

SUBMITTED ARTICLE BY HON. JAMES P. MCGOVERN, A REPRESENTATIVE IN CONGRESS

FROM MASSACHUSETTS

WASHINGTON POST

Fact Checker 

Would GMO labeling requirement cost $500 more in groceries per family a 

year? 

By MICHELLE YE HEE LEE

April 6, 2015 

(Erich Schlegel/AP Images for GMO Answers) 

‘‘Having a series of different and conflicting state and local GMO labeling 

mandates will increase grocery prices for consumers by hundreds of dollars per 


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year. Grocery costs for a family could increase by an average of $500 per year 

under GMO labeling mandates, according to a Cornell University study.’’—Coalition for Safe Affordable Food, news release on website (http:// 

coalitionforsafeaffordablefood.org/news/2015/03/25/coalition-safe-affordablefood-hails-introduction-federal-food-labeling-legislation), March 25, 2015 

There’s a lot of buzz over ‘‘GMO labeling,’’ though polls consistently have shown 

that consumers don’t know much about it. Genetically modified organisms, also 

called GMO, genetically modified food, genetically engineered food, are crops whose 

genes are altered using biotechnical techniques. Plants are bred to have certain 

characteristics, such as being more resistant to herbicides or pests, or to better withstand drought. Food and food ingredients made from such crops have been in the 

food supply since the 1990s (http://www.fda.gov/Food/FoodScienceResearch/Biotechnology/ucm346030.htm). 

A huge portion of commonly grown crops in the United States are modified this 

way, especially corn, soybeans and cotton. For the most part, genetically modified 

crops are considered safe. But the debate is over whether food products should be 

required to be labeled as genetically modified. 

Last year, Vermont became the first state to require food makers to label products 

that include GMOs. The requirement goes into effect in July 2016. There are efforts 

in more than 20 states to require GMO labels. The debate is picking up steam on 

a national level as Congress debates a bill that would trump states’ decisions to 

mandate GMO labeling. 

The Coalition for Safe Affordable Food is one of the bill’s proponents, which include many food industry groups, who want to see a voluntary labeling system. Would mandating GMO labels really cost an additional $500 per year for a family 

of four? 

The Facts 

A bipartisan bill, (http://www.washingtonpost.com/blogs/wonkblog/wp/2015/ 

03/25/is-your-food-genetically-modified-if-congress-moves-on-this-you-may-neverknow/) proposed by Reps. Mike Pompeo (R-Kan.) and G.K. Butterfield (D-N.C.), 

would block states from requiring GMO labeling. Instead, it would set up a voluntary labeling program that would certify foods that do not contain GMOs. 

Those who want labeling say they want a nonjudgmental, back-of-package wording. The point, advocates say, is to allow consumers to make informed decisions, if 

they care about whether foods contain GMOs. Just as people look for the amount 

of transfats, sodium, sugar or any other ingredient they care about, consumers 

would be able to see that the product may contain GMO ingredients. 

Both sides largely agree that simply adding the wording would not drive up consumer costs. Companies regularly update their food packaging as they come up with 

new designs or marketing strategies. But those who oppose mandatory labeling say 

the requirement would drive up costs because it would change manufacturers’ and 

consumers’ behaviors. 

A study by Cornell University Professor William Lesser found that if GMO labeling is required in New York, a family of four would pay $500 more (http:// 

dyson.cornell.edu/people/profiles/docs/LabelingNY.pdf) each year. Lesser uses consumer surveys to project the demand for products that contain, and are labeled as 

containing, GMO ingredients. Demand for non-GMO products will grow in part because the labeling is perceived as a warning. To remain competitive, companies then 

would need to create new products without GMO ingredients. Non-GMO ingredients, especially corn and soybean, tend to be more expensive. 

Companies would, therefore, spend more money on ingredients and on producing, 

warehousing and stocking these new non-GMO products in supermarkets. The study 

assumes that all cost increases will be passed along to food consumers, as opposed 

to being absorbed by the companies or supermarkets. 

Lesser said he used these assumptions because polls show that consumers would 

be less likely to buy consumer products labeled as containing GMO. Competition 

would drive companies to switch to non-GMO ingredients, he wrote to The Fact 

Checker. 

A December 2014 Associated Press—GfK poll (http://ap-gfkpoll.com/main/ 

wp-content/uploads/2015/01/AP-GfK_Poll_December_2014_.pdf) found 66 percent 

of Americans favor ‘‘requiring food manufacturers to put labels on products indicating if they contain genetically modified ingredients.’’ Among those polled, 42 percent said knowing whether food was genetically modified was extremely or very important in judging whether it’s a healthy choice, while 28 percent said it was moderately important. 

An August 2014 Pew Research survey (http://www.pewinternet.org/2015/01/ 

29/public-and-scientists-views-on-science-and-society/) found 57 percent of AmeriVerDate Mar 15 2010 10:12 Aug 20, 2015 Jkt 041481 PO 00000 Frm 00026 Fmt 6621 Sfmt 6621 P:\DOCS\114-19\95344.TXT BRIAN
23 

cans said it was ‘‘generally unsafe’’ to eat genetically modified foods, while 37 percent said it was safe. A parallel survey of scientists showed this was the single largest disagreement between scientists and the general American population; 88 percent of scientists said it was safe to eat GMO foods. Just 28 percent of the public 

perceived scientists had a clear understanding of the health effects of GMOs. (Hat 

tip to The Washington Post poll analyst Scott Clement for combing through the 

data.) 

Labeling advocates say Lesser’s study makes unrealistic assumptions. 

There are many factors other than ingredient costs that affect retail price, according to a study commissioned by Just Label It! (http://www.justlabelit.org/wpcontent/uploads/2013/09/Kai-Roberston-Food-Labeling-Study-2013.pdf) A food 

processor’s costs fluctuate, but several factors deter companies from raising or lowering their retail or wholesale prices because of ‘‘price stickiness,’’ the study says. 

That means prices tend to remain constant despite changes in supply and demand, 

in part because companies are not willing to risk losing long-term customers by raising prices. Plus, setting and advertising new prices is costly on its own. 

Consumers Union, which supports mandatory labeling, estimates the median cost 

of designing and labeling a product as containing GMOs would be just $2.30 per 

person per year. (https://consumersunion.org/wp-content/uploads/2014/09/ 

GMO_labeling_cost_findings_Exe_Summ.pdf) But these costs may not necessarily be 

passed on to consumers, they say. 

A 2011 study by the USDA looked at the impact of labeling on consumer behavior 

and market prices in countries that mandated GMO labels. Even large warning labels on the front of packages are not guaranteed to attract consumer attention, the 

study says. 

Evidence suggests that consumers are just as likely to overlook GMO labels as 

other labels, according to USDA researchers. This is in part because food labels contain a lot of information, and consumers tend to look for labels that matter to them. 

Even if they do look at every single piece of information on a label, they have a 

hard time prioritizing what matters the most. 

Researchers did not find significant retail price increases resulted from labeling 

requirements in other countries. Advocates on both sides point to Ben & Jerry’s, 

which switched to non-GMO products. The premium for non-GMO ingredients 

ranged from 5 to 20 percent, The Wall Street Journal reported. (http:// 

www.wsj.com/articles/the-gmo-fight-ripples-down-the-food-chain-1407465378) But 

Ben & Jerry’s planned to absorb the costs rather than pass them on to customers. 

Yet it is impossible to know how many companies will act as Ben & Jerry’s did, 

said Claire Parker, spokeswoman for the Coalition for Safe Affordable Food, which 

opposes mandatory labeling. Smaller companies, in particular, would not be able to 

do so, she said. 

It is important to consider how consumer behavior would change, and supporters 

of mandatory labeling are downplaying the costs, according to Parker: ‘‘The validity 

of the (Consumers Union) study is also brought into doubt by Consumers Union’s 

admission that they dismissed potential changes in consumer behavior. When the 

leaders of the movement are admitting the aim of labeling is to change consumer 

behavior and remove GMOs from the marketplace, I think that tells you how central 

consumer behavior is to the debate.’’ 

The Pinocchio Test 

The $500 figure assumes that companies will switch to more expensive, non-genetically modified ingredients, and then pass all the incurred costs to consumers. 

It also assumes that all extra costs to stock, warehouse and produce new, non-genetically modified products will translate to higher prices at the cash register. It is 

difficult to imagine all of these assumptions will materialize for every company. 

However, it also is difficult to imagine that consumers or companies will not be 

affected at all. Not every company may be in the position to absorb all extra costs, 

if they decide to switch ingredients. Given that consumers overwhelmingly want 

GMO labeling—even though they largely don’t understand GMOs—consumers could 

decide not to buy products labeled as such. If the demand for such products decreases significantly, companies will have to act accordingly. Ultimately, that could 

result in costs trickling down to consumers—even if it’s not as high as $500 per 

year. 

It is an exaggeration to use the $500-per-family figure from the New York labeling bill in the national GMO debate. Those who oppose mandatory labeling are making the assumption that companies will switch out all GMO ingredients, produce 

completely new products, and then pass on all the costs of stocking, warehousing 

and producing those products to consumers. There may, indeed, be increased comVerDate Mar 15 2010 10:12 Aug 20, 2015 Jkt 041481 PO 00000 Frm 00027 Fmt 6621 Sfmt 6621 P:\DOCS\114-19\95344.TXT BRIAN
24 

petition for companies to switch to non-GMO ingredients. But there are many other 

factors that affect wholesale or retail prices than just the cost of ingredients. 

Three Pinocchios 

(About our rating scale (http://www.washingtonpost.com/blogs/factchecker/about-the-fact-checker/)) 

Update: William Lesser, who conducted the Cornell study, provided the following 

response to this fact check. 

April as we know brings showers, leading to May flowers. As of late though April 

is also bringing a host of state-based bills to require labeling of many foods containing GMO ingredients. There are many issues involved in such discussions, but 

those receiving special attention are ‘the right to know’ v. labeling costs. The polar 

points of the cost debate are the $2.30 annual per capita from Consumers Union 

and my estimate for N.Y. of $125 [Note: Lesser said he reduced his $500 estimate 

for a family of four to $125 per capital to compare to the Consumers Union estimate.], which estimate received a triple ding from The Fact Checker (Would GMO 

labeling requirement cost $500 more in groceries per family a year?, (http:// 

www.washingtonpost.com/blogs/fact-checker/wp/2015/04/06/would-gmo-labelingrequirement-cost-500-more-in-groceries-per-family-a-year/) April 6). 

The huge distinction is not over the cost of placing a ‘‘May contain GMO ingredients’’ on a package, but rather what the associated costs are. Those proposing low 

costs, according to The Fact Checker, assume few consumers will switch to products 

with the more costly non-GMO ingredients and/or manufacturers will absorb the 

higher costs. The example given is for Ben & Jerry’s which did not raise prices when 

it switched to non-GMO flavoring ingredients like brownies. But flavorings are only 

a small part of ice cream ingredient costs so, that example is not very illustrative. 

For my part, I assume based on survey data that, post-labeling, products will realign to 50% labeled GMO-containing, 40% unlabeled non-GMO containing and 10% 

organic. Unfortunately The Fact Checker got that fact incorrect, stating my work 

‘‘assumes that companies will switch out of all GMO ingredients.’’ I did not assume 

that, and the difference is enormous: about 10,000–12,000 individual food items. It 

is true that no one really knows how consumers will respond to labeling. The Fact 

Checker references a USDA study which notes that consumers may ignore GMO labels as they seem to ignore many other labels. But then other food products are not 

stigmatized by being called ‘‘Frankenfoods,’’ certain to cause concern among a population admittedly uninformed about GMOs. 

The Fact Checker serves a highly valuable function when checking the accuracy 

of politicians’ quotes and identifying references to data sources. Critiquing an individual study on an unfamiliar industry is though a different task which should perhaps be approached with more care. 

W. LESSER, 

Dyson School of Applied Economics and Management, 

Cornell University. 


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Support For Requiring Labels On GMO Foods Is Overwhelming Across All 

Segments 

Nearly Nine-In-Ten Believe Labels Are Important, and a Majority Believe 

They Are Very Much So 


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SUBMITTED ARTICLE BY HON. DAN NEWHOUSE, A REPRESENTATIVE IN CONGRESS

FROM WASHINGTON

Organic 101: Can GMOs Be Used in Organic Products? 

Posted by MILES MCEVOY, National Organic Program Deputy Administrator, on May 17, 2013 at 1:20 p.m. 

This is the thirteenth installment of the Organic 101 (http://blogs.usda.gov/tag/organic-101/) series that explores different aspects of the USDA organic regulations 

(http://www.ams.usda.gov/nop). 

The use of genetic engineering, or genetically modified organisms (GMOs), is prohibited (http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=3e8c8892691edb8b69 

8bb72196aafed3&rgn=div5&view=text&node=7:3.1.1.9.32&idno=7) in organic products. This means an organic farmer can’t plant GMO seeds, an organic cow can’t 

eat GMO alfalfa or corn, and an organic soup producer can’t use any GMO ingredients. To meet the USDA organic regulations, farmers and processors must show 

they aren’t using GMOs and that they are protecting their products from contact 

with prohibited substances, (http://www.ecfr.gov/cgi-bin/textidx?c=ecfr&SID=3e8c8892691edb8b698bb72196aafed3&rgn=div5&view=text&node= 

7:3.1.1.9.32&idno=7) such as GMOs, from farm to table. 

Organic operations implement preventive practices based on site-specific risk factors, such as neighboring conventional farms or shared farm equipment or processing facilities. For example, some farmers plant their seeds early or late to avoid 

organic and GMO crops flowering at the same time (which can cause cross-pollination). Others harvest crops prior to flowering or sign cooperative agreements with 

neighboring farms to avoid planting GMO crops next to organic ones. Farmers also 

designate the edges of their land as a buffer zone where the land is managed organically, but the crops aren’t sold as organic. Any shared farm or processing equipment 

must be thoroughly cleaned to prevent unintended exposure to GMOs or prohibited 

substances. 

All of these measures are documented in the organic farmer’s organic system 

plan (http://blogs.usda.gov/2012/10/10/organic-101-five-steps-to-organic-certification/). This written plan describes the substances and practices to be used, including physical barriers to prevent contact of organic crops with prohibited substances or the products of ‘‘excluded methods’’ such as GMOs. On-site inspections 

and records verify that farmers are following their organic system plan. Additionally, certifying agents conduct residue testing (http://blogs.usda.gov/2013/02/ 

20/organic-101-strengthening-organic-integrity-through-increased-residue-testing/) to 

determine if these preventive practices are adequate to avoid contact with substances such as prohibited pesticides, antibiotics, and GMOs. 

Any certified organic operation found to use prohibited substances or GMOs may 

face enforcement actions, including loss of certification and financial penalties. However, unlike many pesticides, there aren’t specific tolerance levels in the USDA organic regulations for GMOs. As such, National Organic Program policy (http:// 

www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5090396) states that 

trace amounts of GMOs don’t automatically mean the farm is in violation of the 

USDA organic regulations. In these cases, the certifying agent will investigate how 

the inadvertent presence occurred and recommend how it can be better prevented 

in the future. For example, they may require a larger buffer zone or more thorough 

cleaning of a shared grain mill. 

USDA supports all methods of agriculture production, including organic, conventional, and biotechnology. To help these different methods coexist better, USDA has 

convened an Advisory Committee on Biotechnology and 21st Century Agriculture (http://www.usda.gov/wps/portal/usda/usdahome?contentidonly=true& 

contentid=AC21Main.xml) (‘‘AC21’’). Organic stakeholders are well-represented on 

AC21. Recent recommendations from the Advisory Committee are currently being 

implemented (http://www.usda.gov/documents/usda-factsheet-ac21-final-recommendations.pdf) by USDA agencies. 

Consumers purchase organic products expecting that they maintain their organic 

integrity from farm to market (http://blogs.usda.gov/2012/04/26/organic-101- 

the-lifecycle-of-organic-food-production/), and USDA is committed to meeting these 

expectations. No matter where it was grown, if a product has the USDA Organic 

label on it, it wasn’t produced with GMOs. 

See more at: http://blogs.usda.gov/2013/05/17/organic-101-can-gmos-be-used-inorganic-products/#sthash.eFzcMOFW.dpuf 

Æ