By Grace Hermann, ASU sustainable food systems graduate student
The Model USDA 2026 simulation brought together students from states and territories across the country to represent stakeholders and policymakers in various scenarios, one of which focused on label guidance for voluntary claims. Students worked to present the student acting as the U.S. Secretary of Agriculture with a decision to finalize or alter the Food Safety and Inspection Service’s proposed label guidance on voluntary animal-raising and environmental claims.
Representing corporate interests, small farmers, and advocacy groups, students worked to get the attention of agency leadership and make their case.
The simulation began in a spirited discussion between small and large producers about the need for third-party certification to confirm claims such as “cage-free,” “pasture-raised,” and “humanely raised.” While initially small business representatives and lobbyists for large-scale operations agreed on the need for environmental and animal-raising claims to remain voluntary, their coalition began to crack as small-scale producers began to wonder if corporations would abuse the voluntary labeling claims; ultimately devaluing their superior product.
Scenario participants heard from guest speaker Ashley Grabb, Director of Agriculture and Food Systems Support Division at Arizona Department of Agriculture, who explained the struggles the state faces because of its limited processing capacity. With only 17 inspectors in Arizona, producers can face wait times of up to three months before the state can inspect and allow them to process their meat. While processing delays already strain businesses, the separate funding structures and oversight agencies for meat and poultry versus fresh and shelled eggs create additional complications that further slow producers down. Grabb urged students in Model USDA to consider how their recommendations would hypothetically impact already understaffed state inspectors who have to adhere to state statutes while also staying up-to-date on federal regulations.
After the presentation, students representing third-party certifiers began to increasingly talk about public-private partnerships with inspectors. Advocates reminded certifiers and agency leaders not to forget about the disproportionate cost burdens small producers face by requiring third-party certification to make voluntary claims. Equity and access began to enter discussions even as large producers remained adamant that they would be the ones to face greater difficulties and burdens with any changes to the recommendations because of their scale. Small producers effectively advocated for tiered pricing systems and third-party certifiers effectively called for government support to offset costs for small and mid-tier producers.
Not wanting to add confusion for consumers, advocates also began to ask what education consumers might need in order to ensure they understood the claims that producers were making. Small producers worried that additional efforts that were proposed such as using QR codes to label products would add unnecessary costs, and several consumer advocates questioned accessibility of unnecessary tech for older consumers, those without cell phones, and those who do not speak English. These additional concerns brought students role-playing as agency officials and congressional staffers to successfully reroute the conversation to supporting small and medium producers through grants with a tiered pricing system.
Just as negotiations seemed to be coming to an end, a surprise "announcement" by the European Union (EU) created a frenzy amongst agency officials and international trade representatives. Students had to determine the extent to which losing the trade with the EU would harm the United States meat and poultry industry. Interestingly, participants quickly agreed that the cost of implementing the new EU requirements for voluntary label claims would be more detrimental to the producers than losing the trade with the EU.
What initially appeared to be a crisis ended up strengthening support for leaving the proposed recommendations for voluntary claims as is. Smaller producers and large producers alike rallied around tiered pricing systems for trusted third-party certifiers, but the funding structure for supporting producers in obtaining a certification for voluntary labels remained unclear.
In the end, the Secretary student approved the work group recommendation to maintain the existing proposed rule and consider a funding structure for better supporting small and medium producers to obtain third-party certification. Third-party certifiers successfully advocated for a public-private inspection work group and agreed to an ongoing partnership to determine how to align the recommendations for voluntary claims. The Secretary also explained the importance of educational outreach to consumers through existing USDA programs.
As the presentations and speeches wound down in the room, students expressed excitement over reaching a consensus and finishing the scenario. There was also a palpable relief that they no longer had to role play as individuals that they may have disagreed with. Overall, students walked away with valuable lessons in coalition building, negotiation, and compromise, as well as a broader understanding of the complex structures that are at the foundation of the rulemaking process.
This blog is part of a series written by Arizona State University (ASU) graduate students who role-played as journalists in Model USDA 2026, a multi-day simulation hosted by the Swette Center for Sustainable Food Systems at ASU.