Protect the meaning of “pasture raised” for farmers who actually raise birds on pasture.
What is happening?
The label “pasture raised” carries a clear meaning for many farmers and consumers: hens living and foraging on real pasture.
But today that same label can appear on eggs produced in very different systems.
Because eggs fall under a different federal agency than poultry meat, the term “pasture raised” is not consistently defined across egg products. This gap has allowed the label to expand far beyond the pasture-based systems that originally defined it.
For farmers who truly raise birds on pasture, that dilution of the term creates confusion for customers and makes it harder to distinguish real pasture-based farming in the marketplace.
APPPA has submitted two petitions asking federal regulators to align egg labeling with the existing USDA definition already used for poultry products.
The goal is simple: when consumers see the words “pasture raised,” the label should mean the same thing everywhere.
Why it matters
Consumers deserve clear and trustworthy food labels
Farmers raising birds on real pasture deserve fair competition
The meaning of “pasture raised” should not be diluted
Understanding the Two Petitions
FDA Petition
Applies to shell eggs regulated by the FDA.
Because shell eggs fall under FDA jurisdiction, the USDA definition of “pasture raised” does not currently apply to egg cartons.
This petition asks the FDA to adopt a clear definition so that the claim “pasture raised” has the same meaning for eggs as it does for other poultry products.
1,578 comments as of 5/5
USDA Petition
Applies to egg products regulated by USDA FSIS.
This petition asks the USDA/FSIS to formally recognize and apply the existing USDA definition of “pasture raised” to egg products under its jurisdiction.
The goal is to ensure consistency in how the claim is interpreted across USDA-regulated poultry products.
June 5, 2026
June 6, 2026
Shell eggs: Whole eggs sold in their natural shell for direct consumer use, such as cartons of eggs sold in grocery stores or at farms.
Egg products: Eggs that have been removed from the shell and processed into liquid, frozen, or dried forms for use in food manufacturing or food service.
How to Submit Public Comments
Submit a comment to both petitions so regulators in both agencies hear consistent feedback.
USDA Petition (Egg Products)
Submit your comment by email.
Email address: fsispetitions@usda.gov
Subject line: RE: Petition: 26-01
Steps:
Write a short comment explaining why clear pasture-raised labeling matters to you.
Email your comment to the address above.
Use the subject line exactly as written so the comment is attached to the correct docket.
FDA Petition (Shell Eggs)
Submit your comment through the federal docket website.
Link to the petition page:
https://www.regulations.gov/document/FDA-2026-P-1156-0001
Steps:
Click the link above.
Locate the comment box under the petition title.
Paste your comment and submit it through the site.
How APPPA Members Can Help
Public comments matter. The biggest impact happens when farmers help their customers and communities participate.
If even a small number of pasture-based farms invite their customers to comment, participation can increase quickly.
Many customers who support pasture-raised farms are happy to help when they know there is an opportunity.
Ways Members Can Help
Submit your own comments:
Farmers and producers should submit comments to both petitions explaining why pasture-raised labeling matters for their farm and their customers.
Invite your customers to participate:
A simple mention at your farm stand, CSA pickup, or online can encourage customers to leave a short public comment.
Share a simple explanation:
Explain that the goal is to make sure the label “pasture raised” reflects real pasture-based farming.
Use the resources below:
Example emails, talking points, and outreach materials are provided to make it easy to share this initiative with your customers.
APPPA Member Resources
The resources below are designed to help APPPA members explain the initiative and encourage customers to submit public comments. Use these materials to communicate with your customers, community, and networks.
Email Templates for USDA/FSIS Petition
Prewritten emails you can send to your customers explaining the initiative and encouraging them to submit comments.
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To: fsispetitions@usda.gov
Subject: RE: Petition: 26-01To Whom It May Concern,
My name is [Name], and I am a poultry farmer raising birds in a pasture-based system.
Farms like mine invest significant time and labor into raising hens on real pasture using mobile housing that is regularly moved to fresh ground. This system allows birds continual access to living vegetation and reflects what most consumers expect when they see the term “pasture raised.”
Currently, the term “pasture raised” is not consistently defined across egg products. Because shell eggs fall under FDA jurisdiction while poultry meat and egg products are regulated by USDA, the same label claim can be used for very different production systems.
This lack of consistency creates confusion for consumers and makes it harder for farmers using true pasture-based systems to distinguish their products in the marketplace.
Aligning labeling standards across agencies and applying the existing USDA definition of “pasture raised” consistently across egg products would help ensure that the label reflects real pasture-based farming practices.
Clear, consistent labeling supports transparency for consumers and fair competition for farmers who are raising birds on pasture.
Thank you for the opportunity to submit this comment.
Sincerely,
[Name]
[Farm Name]
[City, State] -
To: fsispetitions@usda.gov
Subject: RE: Petition: 26-01To Whom It May Concern,
I am submitting this comment as a consumer who intentionally seeks out eggs from farms that raise hens on real pasture.
When I see eggs labeled “pasture raised,” I expect that the hens are actually living on pasture with access to living vegetation where they can forage. Right now that term is not consistently defined across egg products, which makes it difficult for consumers to understand how eggs are produced.
Aligning egg labeling with the existing USDA definition of “pasture raised” would help ensure the label reflects real pasture-based farming and reduce confusion for consumers.
Clear labeling helps consumers make informed choices and supports farmers who are raising hens on pasture.
Sincerely,
[Your Name]
[City, State]
Example Public Comments for FDA
Example comments to help farmers and consumers understand what a public comment might look like.
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My name is [Name], and I raise poultry in a pasture-based system. When consumers see eggs labeled “pasture raised,” they expect that hens are actually living on pasture. Aligning egg labeling with the existing USDA definition would help ensure the label reflects real pasture-based farming and reduce confusion for consumers.
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I am a poultry farmer who raises birds on pasture using mobile housing that is regularly moved to fresh ground. The term “pasture raised” should clearly reflect that production system. Aligning egg labeling with the existing USDA definition would help maintain transparency and consistency.
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Pasture-based farms invest significant labor and land management into raising hens on living pasture. Applying the existing USDA definition of “pasture raised” to egg labeling would help ensure the term accurately reflects those practices and supports farmers who are raising birds on pasture.
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When I see eggs labeled “pasture raised,” I expect that the hens are actually living on pasture and foraging on living vegetation. Aligning egg labeling with the existing USDA definition would help ensure the label reflects real pasture-based farming and reduce confusion for consumers.
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I support aligning egg labeling with the existing USDA definition of “pasture raised.” Consumers expect pasture-raised hens to actually live on pasture, not just have limited outdoor access.
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Consumers expect food labels to reflect how animals are actually raised. Applying the existing USDA definition of “pasture raised” to egg labeling would improve transparency and trust in the marketplace.
Talking Points
Simple explanations to help farmers describe the issue quickly and clearly.
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You do not need to give a speech or explain federal policy. Just mention it.
Most customers who support pasture-raised farms already understand the idea. They simply need to know there is an opportunity to help.
Example:
“There are two federal petitions open right now to make sure the term ‘pasture raised’ actually reflects real pasture. If you have a minute later, you can leave a quick comment to support it.”
That is enough. If someone is interested, point them to the link.
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Farm Stand
“We’re working with other pasture-based farms to help protect the meaning of the term ‘pasture raised.’ Two federal petitions are open asking regulators to make sure the label reflects how hens are actually raised. If you have a minute later, you can leave a short comment.”CSA or Egg Pickup
“APPPA has filed two petitions asking federal regulators to align the definition of ‘pasture raised’ for eggs with the same standard used for poultry. If you care about clear labeling, you can submit a short public comment.”Social Media
“We’re supporting a national effort to protect the meaning of ‘pasture raised.’ Two federal petitions are open for public comment right now. If you support pasture-based farms, you can leave a short comment here.” -
On most pasture-based farms, hens live outdoors on real pasture with living vegetation. Farmers typically use mobile shelters that are moved regularly to fresh ground so birds always have access to forage and new pasture.
This is the system many consumers expect when they see the term “pasture raised.”
The petitions ask federal regulators to apply the same understanding of pasture-raised used for poultry products to egg labeling.
Other Resources:
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FOR IMMEDIATE RELEASE
Local Farm Joins National Effort to Protect "Pasture Raised" Egg Labeling
[City, State] — [Date] — [Farm Name] is joining a national campaign led by the American Pastured Poultry Producers Association (APPPA) to establish consistent federal standards for "pasture raised" egg labeling.
Currently, the term "pasture raised" lacks a uniform definition for eggs, allowing products from hens with minimal outdoor access to carry the same label as eggs from farms where hens live on open pasture. APPPA has submitted petitions to USDA and FDA asking both agencies to align egg labeling with clear, enforceable standards.
"When people buy pasture-raised eggs, they expect those hens to actually be living on pasture," said [Farmer Name] of [Farm Name]. "Right now, that expectation isn't always matched by labeling, and that makes it harder for farms like ours to stand out."
Public comments carry real weight in this process, and the deadline is coming fast. Even a brief comment helps regulators understand what consumers and farmers expect from transparent food labeling.
How to submit a public comment: farmmarketingsolutions.com/action
Comment deadlines: USDA Petition — June 5, 2026 FDA Petition — June 6, 2026
About [Farm Name] [1–2 sentence description]
Media Contact: [Farmer Name] | [Farm Name] | [Email] | [Phone]
Content from the Community
Remember, we’re all in this together!
Portraits by Mike Marques, 2020 APPPPA National conference