WCMA Calls on USDA for Clarity on Organic Herd Regulations

Mr. Paul Lewis
Standards Division, National Organic Program
U.S. Department of Agriculture
1400 Independence Ave. SW
Room2642-So., Ag Stop 0268
Washington, DC 20250-0268
RE: Proposed Rule USDA-AMS-NOP-11-0009

Dear Sir:

Wisconsin Cheese Makers Association (WCMA) represents manufacturers of cheese, butter, yogurt and whey, as well as companies that process cheese or market and distribute cheese. These 105 member companies and cooperatives operate more than 260 facilities in 22 states.

Several WCMA members are proprietary manufacturers and cooperatives that produce organic dairy products – primarily natural cheeses and butter – for national distribution. These manufacturers work in partnership with more than 450 dairy farms in Wisconsin alone that produce organic milk.

For several years, WCMA members have raised concerns regarding the inconsistent interpretation and enforcement of the origin of livestock rule. This inconsistency has created an unlevel playing field across the organic dairy industry. We applaud AMS for reopening this rule and join our member dairy companies in supporting a clear rule that adheres to the original intent of the statute.

Under current origin of livestock regulations, an organic dairy farmer may be granted a one-time
transition of conventional livestock into organic production under certain prescribed conditions.
However, some producers have a practice of consistently transitioning entire, conventionally raised
herds to organic status when they reach milking age, and therefore consistently bypass the additional
costs of raising a calf from birth to adulthood in compliance with the USDA National Organic Program or NOP. This exploitation of the origin of livestock rule’s one-time exemption has led to a lack of consistency between organic certifiers and uneven interpretation of compliant practice nationwide. This disadvantages Wisconsin organic dairy operations that adhere to the spirit and letter of the USDA NOP.

We ask you to provide a comprehensive solution by issuing clear guidance, as soon as possible, to
ensure all organic certifiers adhere to the same interpretation of the existing origin of livestock standard. Specifically, we are asking the USDA to confirm that the one-time transition exemption can only be used by a producer to initially establish an organic herd, and not to consistently transition conventional herds into a producer's rotation of herds.

In addition, we also request that you move forward with the implementation of the origin of livestock rule as proposed in 2015. Together, these approaches would permanently establish fair and clear standards to promote the success of the organic industry and ensure that Wisconsin's organic farmers are not further disadvantaged.

Thank you for considering these remarks and for your support of meaningful organic standards for farms and processors in the U.S.

Best Regards,
John T. Umhoefer
Executive Director
Wisconsin Cheese Makers Association