• On December 10, 2025, USDA’s Food Safety and Inspection Service (FSIS) announced the availability of updated guidelines for label approval which reflect changes to clarify the conditions under which voluntary U.S. origin claims can be made.
  • By way of background, FSIS published a final rule in March 2024 defining the conditions under which FSIS-regulated products may bear voluntary U.S. origin claims (89 FR 19470) and concurrently updated its labeling guidelines. Under the final rule FSIS will generically approve “Product of USA” and “Made in the USA” claims for multi-ingredient FSIS-regulated products if: (1) all FSIS-regulated products in the multi-ingredient product are derived from animals born, raised, slaughtered, and processed in the United States; (2) all other ingredients, other than spices and flavorings, are of domestic origin; and (3) the preparation and processing steps for the multi-ingredient product have occurred in the United States.
  • The changes to guidelines include clarifying:
    • that the meaning of “raised” is “from birth to slaughter,”
    • that the term “harvested” may be use to mean “slaughtered,”
    • that the U.S. origin requirements do not apply to sub-ingredients,
    • the definitions of “spices” and “flavorings,”
    • that “Product of North America” is permitted if truthful and not misleading,
    • the conditions under which a multi-origin label claim including the U.S. may be made, and
    • that the term “produced” may not be used as a stand-alone label claim.