August 24, 2020
The Honorable Sonny Perdue
Secretary of Agriculture
U.S. Department of Agriculture
1400 Independence Drive S.W.
Washington, DC 20250
Dear Secretary Perdue;
As the U.S. Department of Agriculture (USDA) considers its third round of Farmers to Families Food Box Program purchases, the undersigned organizations respectfully request that preference be given to applicants that demonstrate a commitment to procuring truly American-raised and grown products.
With U.S. Senators and members of the U.S. House of Representatives calling into question USDA’s $28 billion Market Facilitation Program expenditures in response to the trade war with China, it is imperative the funds expended through the Farmers to Families Food Box Program are beyond reproach.1
Though the terms “Agricultural Commodity/Product” or “USDA Food” are explicitly defined in the solicitation provided by USDA as “products grown, processed, and otherwise prepared for sale or distribution exclusively in the United States”, due to the repeal of mandatory country-of-origin labeling requirements for U.S. beef and pork products in 2015, it is nearly impossible for an applicant to certify that their products match the USDA definition unless those products are procured directly from an independent meat processor.
Further, the solicitation provides for an exemption to the “U.S. Origin Product” contract requirements that appears to target ground meat products:
“For commodities that the Department has determined to be generally commingled, a commingled
product shall be considered to be a product of the United States if the offeror can establish that
the offeror has in inventory at the time…a sufficient quantity of the commodity or product that was produced in the United States to fulfill the contract being awarded…”
Due to the current regulatory loophole which USDA Food Safety and Inspection Service acknowledged2 allows for imported beef to be labeled “Product of the U.S.A.”, the undersigned organizations are concerned that the current regulations governing beef and pork products could allow for the misspending of federal aid dollars to be spent on imported, foreign goods.
1 The New York Times, “U.S. Watchdog to Investigate Trump’s Farm Bailout Program”, (February 14, 2020), https://www.nytimes.com/2020/02/14/us/politics/trump-farm-bailout-investigation.html
2 USDA Food Safety Inspection Service, “FSIS Final Response to Petition”, (March 26, 2020), https://www.fsis.usda.gov/wps/wcm/connect/dba58453-e931-4c1d-9b4e-fb36417049ce/19-05-fsis-final-response-032620.pdf?MOD=AJPERES
Therefore, we ask that USDA prioritize applicants who have demonstrated established relationships with independent regional meat processors to fill their order.
Applicants are already required to complete a written narrative describing their role in support of American agriculture and how they intend to engage small farmers (e.g those farms and processors servicing local and region interests and farmers markets). This would be an excellent opportunity for USDA to identify and rank applications based on their ability to source beef and pork products that were born, raised, and harvested in the U.S.
The third round of Farmers to Families Food Box program purchases will spend the balance of the $3 billion authorized for the program. We encourage USDA to make certain that this federal funding will support American agricultural producers and distributors.
Thank you for your consideration of this matter.
American Grassfed Association
Family Farm Action Alliance
Independent Cattlemen of Nebraska/ICON
Independent Beef Association of North Dakota
Independent Cattlemen’s Association of Texas
Kansas Cattlemen’s Association
Montana Cattlemen’s Association
Rocky Mountain Farmers Union
Rural & Agriculture Council of America
U.S. Cattlemen’s Association
Women Involved in Farm Economics