CFA submitted the following comments in response to the United States Department of Agriculture’s (USDA) Agricultural Marketing Service (AMS) proposed rule on organic livestock and poultry production requirements. Twenty years ago, USDA allowed unscrupulous producers to certify as “organic” eggs laid by hens without outdoor access. Under the rules, organic producers must provide “year-round access for all animals to the outdoors, shade, shelter, exercise areas, fresh air, clean water for drinking, and direct sunlight,” but USDA has allowed large producers to satisfy this requirement with enclosed, concrete “porch” type structures. These facilities have come to dominate the organic egg market, accounting for over half of the organic eggs sold each year, according to one estimate. Although the proposed rule would close the loophole, it suggests the agency might give companies as long as 15 years to comply. CFA’s comments urge the agency to implement the new rules within a maximum of three years, and to take into account alternative labeling claims, such as “100% organic diet” or “produced with organic feed,” that affected producers may use to offset any lost revenue that results from the rulemaking.