The American Pastured Poultry Producers Association (APPPA) has formally petitioned the U.S. Food and Drug Administration (FDA) to establish a clear, enforceable regulatory definition for the term "pasture-raised" on shell egg cartons.
The move aims to close a persistent regulatory gap that currently allows producers using standard "free-range" systems to market their eggs as "pasture-raised," a practice the association warns is misleading to consumers and detrimental to ethical farming operations.
The Regulatory Gap: FDA vs. USDA Jurisdiction
The core of the issue lies in the overlapping but distinct jurisdictions of federal food regulators. Following a 2023 petition that garnered over 16,000 supporting comments, the USDA’s Food Safety and Inspection Service (FSIS) formally adopted a definition distinguishing "pasture-raised" from "free-range" for poultry meat. The USDA standard dictates that pasture-raised poultry must spend a majority (51%) of its life on rooted, vegetative cover.
However, because the FDA maintains jurisdiction over shell eggs, the USDA guidelines have not been uniformly applied to egg cartons. Consequently, current FDA rules allow the "pasture-raised" claim to be used for "free-range" systems, which only require outdoor access without any mandate for vegetation.
"Most shoppers believe 'pasture-raised' means hens spend their days outdoors on real pasture," said Christian Alexandre, President of APPPA and owner of Alexandre Family Farms. "Right now, most supermarket eggs don't match that expectation."
Combating 'Greenwashing' in the Egg Aisle
For the B2B supply chain, including retailers and foodservice operators, the lack of a standardised definition creates an uneven playing field. Pasture-based farmers invest heavily in land stewardship, rotational grazing management, and higher animal welfare standards. Allowing industrial barn operations with basic outdoor access to utilise the same premium labelling undercuts these investments.
Ginger Shields, Director of APPPA, highlighted the market distortion caused by this discrepancy: "When eggs produced in industrial barns with outdoor access are marketed using the same language and imagery as pasture-raised, it undermines consumer trust and disadvantages farmers who are raising birds on pasture. Clear, consistent labelling benefits everyone, helping consumers make informed choices and ensuring that farmers who are doing the right thing are not undercut by misleading claims."
The Proposed Solution: Regulatory Alignment
Rather than requesting the creation of entirely new regulatory frameworks, APPPA’s petition—submitted in January 2026 to the Department of Health and Human Services and the FDA—requests the simple application of the existing, well-understood USDA FSIS definition to FDA-regulated egg labels.
By defining "pasture-raised" shell eggs as coming from hens that spend the majority of their laying life on pasture with a majority rooted vegetative cover, the APPPA argues the FDA can immediately improve market transparency, eliminate greenwashing, and build consumer confidence across multiple product categories.
APPPA is currently encouraging consumers, retailers, and industry stakeholders to submit public comments in support of consistent, cross-agency labelling standards.
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