In comments submitted to the California Department of Food and Agriculture (CDFA), The North American Meat Institute (NAMI) said, despite modification to proposed rules for Proposition 12 (Prop 12 or the law), the proposed rules remain flawed and more time is needed for compliance.
“Until CDFA publishes final rules, no one can adequately prepare to comply with a law with criminal sanctions and that authorizes civil litigation,” said Mark Dopp, General Counsel and Chief Operating Officer at NAMI. “Rather than apply ‘band aids’ to address some challenges, NAMI suggests CDFA go further and afford everyone in the supply chain, from hog producers all the way to foodservice and retail entities, the 28-month preparation time the law, and the voters, contemplated before enforcing any aspect of Prop 12 or its regulations.”
For the text of the comments, go here.
Although CDFA modified the proposed rules and are to be applauded because they account for complexities in the supply chain or they bring the proposal more in line with the law, unfortunately, many parts of the May 2021 proposed rules remain intact and flawed. NAMI identified these flaws in its July comments and during the August public hearing.
Prop 12 directed CDFA to promulgate regulations implementing the law by September 1, 2019. The rules are yet to be finalized even though some provisions take effect January 1, 2022.
About North American Meat Institute
The North American Meat Institute is a leading voice for the meat and poultry industry. The Meat Institute’s members process the vast majority of U.S. beef, pork, lamb, and poultry, as well as manufactures the equipment and ingredients needed to produce safe, high quality meat and poultry products.