FSIS quietly redefined 'grass-fed' in 2024 — here's what actually changed, and what it still doesn't address

For eight years between 2016 and 2024, the United States had no federal definition of the word “grass-fed” on a meat label. The USDA’s Agricultural Marketing Service had withdrawn its own grass-fed marketing claim standard on January 12, 2016 — concluding that AMS didn’t have the statutory authority to define such claims without explicit Congressional grant. The withdrawal left the term in a regulatory vacuum: producers could continue using it, but the federal government wasn’t endorsing any particular meaning behind it.

In August 2024 that changed, partially. The FSIS — the USDA division that actually approves labels on meat and poultry products — published an updated guidance document, FSIS-GD-2024-0006, “FSIS Guideline on Substantiating Animal-Raising or Environment-Related Labeling Claims.” The guideline addresses grass-fed and several adjacent claims (pasture-raised, raised without antibiotics, free-range, etc.). It hasn’t been revised since August 2024 and remains the current substantive guidance.

The headline story is that the federal grass-fed standard is back. The actual story is narrower. Here’s what the guideline does, what it doesn’t, and why third-party certification still does more than the federal floor.

What the guideline actually requires for a grass-fed claim

FSIS-GD-2024-0006 sets out the documentation FSIS reviews when an establishment seeks label approval for a grass-fed claim. The substantive requirements:

• The animals must be fed solely from forage (grass and forage-based feed sources) after being weaned from their mother’s milk.
• No grain or grain by-products are permitted in the diet.
• Animals must have continuous access to pasture during the growing season until slaughter.
• Animals cannot be confined to a feedlot.
• Acceptable forage per FSIS includes grass (annual and perennial), forbs (legumes, Brassica, and other herbaceous broadleaf plants), browse, and cereal grain crops in the vegetative (pre-grain) state. Preserved roughage sources — hay, haylage, baleage, silage, and crop residue without grain — are also acceptable, as is routine mineral and vitamin supplementation.
• Partial-claim labels are permitted if percentages are specified (for example, “85% grass-fed, 15% corn-finished”).

If an animal had any incidental supplementation outside the forage spec — for example, due to a weather emergency that limited pasture access — the producer is expected to provide a signed and dated attestation that the deviation was not routine.

That feeding protocol is meaningfully closer to what consumers think “grass-fed” means than the previous regulatory vacuum allowed. A producer who calls their product “grass-fed” and gets FSIS label approval now does have to substantiate the no-grain, no-feedlot, pasture-access story.

What the guideline doesn’t address

This is where the federal floor falls short of what most consumers paying a grass-fed premium actually expect.

FSIS-GD-2024-0006 is, by its own framing, a feeding-protocol guideline. It doesn’t address:

• Antibiotic use. A 100% grass-fed cow can be routinely dosed with subtherapeutic antibiotics and still qualify for the FSIS feeding-protocol standard. The American Grassfed Association — whose own certification prohibits antibiotic use — pointed this out explicitly in its public comment on the guideline.
• Added growth hormones. Same situation. Hormonal implants used in conventional beef finishing are not addressed by FSIS-GD-2024-0006.
• Animal origin. “Grass-fed beef” sold under a USDA-approved label can be sourced from cattle raised in any country, provided imported product passes USDA inspection. There is no born-and-raised-in-USA requirement in the FSIS guideline.
• Continuous outdoor confinement vs partial. The guideline requires continuous pasture access during the growing season, which technically allows for indoor housing outside the growing season in cold climates. How “growing season” is interpreted is left to producer documentation.
• Animal welfare beyond basic feeding. Stocking density, slaughter practices, and management systems aren’t part of the FSIS substantiation framework.

This isn’t a criticism of FSIS’s specific authority — FSIS’s role under the Federal Meat Inspection Act is narrower than a comprehensive label-claim regulator’s would be. It’s a description of what the federal floor actually covers, which is feeding protocol and not much else.

The regulatory weight question

The most important sentence in the FSIS guideline is in its preamble. The guidance “is not a regulatory document. Therefore, establishments are not required to use the guideline to comply with FSIS regulations.”

In plain language: this is voluntary guidance, not binding regulation. There is no statutory penalty for failing to follow it. What FSIS can do is refuse to approve a label that uses a “grass-fed” claim without adequate substantiation. Since FSIS pre-approval of meat and poultry labels is required before a product enters commerce, the practical effect is that producers who want the label have to substantiate against the guideline. But it’s not the same as a binding rule.

FSIS reviews documentation at label approval. It does not routinely re-audit in the field afterward. There is no equivalent of OSHA’s surprise-inspection regime for animal-raising claims. The structural gap between paper documentation and ongoing field practice is real, and FSIS itself has data on this. The agency’s 2023 Beef Raised Without Antibiotics Exploratory Sampling Program (FSIS Notice 48-23) tested 189 cattle from 79 slaughter establishments across 34 states, all labeled “Raised Without Antibiotics.” Antibiotic residues were detected in 37 of those animals — roughly 20% — originating from 27 different establishments. The agency followed up with letters notifying those establishments that they “may have produced misbranded products.” That’s FSIS’s own data on what an adjacent animal-raising claim looks like when documentation is reviewed at label approval and field practice isn’t continuously audited. It’s the main reason third-party certification continues to matter more than the federal floor.

Why third-party certification still does the heavy lifting

The FSIS guideline itself “strongly encourages” the use of third-party certification — the agency’s own preferred path. When a third-party certification body is involved, FSIS will approve the label only if it carries the certifying entity’s name, website where standards can be found, and logo where one exists. That’s a tighter standard than the producer-self-substantiation path.

The two certifications that matter most in this category:

American Grassfed Association (AGA). Standards require animals to be fed only grass and forage from weaning to harvest, no antibiotics, no added hormones, no animal by-products, raised on pasture without confinement, and born and raised on American family farms. Third-party inspection at least every 15 months. The AGA standards explicitly address the gaps the FSIS guideline leaves open — antibiotics, hormones, origin, ongoing audit.

Certified Grassfed by A Greener World (AGW). Comparable spec, including the antibiotics and hormones prohibitions, requires AGW’s Animal Welfare Approved certification as a prerequisite, and includes specific welfare standards (stocking density, slaughter practices) that the AGA standard handles separately.

Both certifications carry annual fees and require third-party on-farm audits. They are not free for producers. That’s why their presence is signal — a producer who carries one of these badges is opting into a higher cost structure than the federal-floor path requires.

What this means for shoppers right now

Three practical implications.

One: “grass-fed” on a US label means more in May 2026 than it did in May 2023. A producer using a plain “grass-fed” claim has now had to substantiate against the FSIS feeding-protocol standard at label approval. That’s a real improvement over the 2016-2024 regulatory vacuum.

Two: it still doesn’t mean what most people think. If you’re paying a grass-fed premium because you believe the cow was also not given antibiotics or hormones, was raised on a US ranch, and had ongoing third-party verification — the plain “grass-fed” label does not guarantee any of that. Only the third-party certifications do.

Three: the label hierarchy is now clearer. From weakest to strongest signal:

1. No “grass-fed” claim at all. Default conventional beef. Grain-finished.
2. Partial grass-fed claim with percentages disclosed (“85% grass-fed, 15% corn”). Producer was honest about the mixed feeding.
3. Plain “grass-fed” or “100% grass-fed” claim. Producer has substantiated FSIS feeding protocol. Says nothing about antibiotics, hormones, origin, or audit.
4. “Grass-fed and grass-finished” or “100% grass-fed and grass-finished”. Same as above with redundant emphasis signaling that the producer is doing more than the minimum substantiation.
5. AGA Certified or AGW Certified Grassfed. All of the above plus no antibiotics, no added hormones, no animal by-products, American-raised (AGA specifically), and ongoing third-party on-farm audit.

If the certification logo is on the package, it’s the bar. If it isn’t, you have a feeding-protocol claim and nothing more.

What this means for producers

For small and mid-size ranchers selling to local markets and direct-to-consumer, the substantive change is small. Most operations already documenting their feeding protocols for AGA or AGW certification meet or exceed the FSIS feeding standard.

For larger operations or new entrants who want to use a “grass-fed” label without paying for third-party certification, the FSIS guideline now provides a defined documentation pathway: maintain feed records, attestations, and pasture-access logs that match the guideline, submit them at label approval, and the claim can be used. This is faster and cheaper than third-party certification. It’s also less marketable to readers who actually pay attention to certifications.

The market structure that’s emerging looks like this: the smaller producers who differentiate on practices beyond feeding will continue carrying AGA or AGW certification because that’s the only way to substantiate the broader claims to consumers who care. Larger operations will use the FSIS-substantiated plain “grass-fed” path because it’s adequate for shoppers whose differentiation goes no further than feed.

Brands like Force of Nature state their feeding practice explicitly (“100% grass-fed and grass-finished. No grains — ever” for beef and bison) and source from a network of regenerative ranchers, with their own proprietary “Land Steward Index” framework that supplier ranches sign onto. That’s a different model from third-party certification, neither inherently better nor worse — it gives more direct control over the producer-supplier relationship and skips third-party audit costs, at the cost of independent verification. Post-2024 FSIS guidance, the question of which substantiation framework a producer has chosen — federal floor, proprietary, or third-party — is now a more useful piece of label information than the front-of-package claim itself.

What to actually do

For the next 18 months, until the next FSIS revision (if there is one), the practical advice is unchanged from what it was before the August 2024 guideline:

• Buy from brands that name the ranch and publish their feeding protocols by SKU rather than relying on category claims.
• When choosing between two grass-fed products at the same price point, the one with an AGA or AGW certification logo carries the stronger claim.
• The federal “grass-fed” floor is now real but narrow. If antibiotics, hormones, origin, or ongoing audit matter to you, look past the front-of-package claim to the certification badges and the producer’s published practices.

The regulatory floor moved up in 2024. It still sits well below the ceiling. That’s the actual state of grass-fed labeling as of May 2026.