For decades, invalid administrative rulemaking has allowed foreign beef to enter our country’s
food system under weak inspection protocols (termed ‘Risk-Based Inspection’). This practice
increases the potential for introduction of foreign animal disease and undermines the confidence the American families place in the U.S. food safety system.
Compounding this, beef is routinely placed in grocery stores as a Product of the United States
when in fact it was raised and slaughtered beyond U.S. borders, having undergone minimal
change but being untruthfully relabeled as U.S. in origin. Internal administrative procedures –
fabricated and deemed only by the agency – provide for such minimal processing to be
reconsidered as ‘Substantial Transformation’. It is this extra-legal loophole which has allowed
foreign-produced and processed beef to require no differentiation from domestically raised and
slaughtered beef.
It has only recently come to light that these administrative procedures which have served as a
pathway for circumvention of U.S. Code were not, in fact, produced through the notice and
comment process as required under the Administrative Procedure Act.
These underhanded administrative practices, taken together, are sufficient to harm U.S.
ranchers, endanger our nation’s food supply, and weaken consumer trust. Relating your
firsthand experience competing with foreign meat markets will play an immediate and
important role in shaping policy improvements currently underway.
