North American Meat Institute calls for moratorium on the application of Proposition 12
WASHINGTON, DC – With California’s Proposition 12 (Prop 12) January 1, 2022, the effective date for impending pork and law enforcement rules nearly two years late and nowhere near be final, the North American Meat Institute (Meat Institute) today called for a moratorium on enforcement to allow time for those subject to the law to comply.
“Until the publication of the final rules, the companies concerned are ‘on hold’ of what they need to do to comply with Proposition 12 in order to avoid the risk of criminal prosecution,” said Mark Dopp, director of the operation of the Meat Institute. “For this reason alone, fairness requires that the California Department of Food and Agriculture (CDFA) promulgate an enforcement moratorium lasting at least 28 months after the publication of the final rules. “
Dopp made the remarks during a public hearing on the proposed rules associated with Proposition 12 held by the CDFA and the California Department of Public Health.
Proposition 12 ordered the CDFA to promulgate regulations implementing the law by September 1, 2019.
“If the CDFA had met its legal deadline, there would have been regulatory certainty and the industry would have had 28 months to prepare for Proposal 12. But as I read this statement, the comment period regarding the proposed regulation with its many flaws is still open and the publication of the final regulations will likely remain in months, ”said Dopp.
“Those who argue that the industry has had sufficient time to comply with Prop 12 do not understand or ignore, perhaps willfully, the complexity of the pork supply chain and the segregation and costs other than Prop 12 will impose on conditioners / processors and other players in this chain.
In June, the Meat Institute submitted 12 pages of comments, found here, indicating that the rules, if finalized, would create a bureaucratic maze of regulations:
· Require an almost impossible annual certification of production facilities for calves and breeding pigs (sows);
· Create an accreditation process that is too complex for the entities authorized to certify these installations;
· Impose detailed record keeping requirements on producers and throughout the supply chain;
· Impose problematic labeling provisions; and
· Grant a legally contestable power of execution.
The text of the proposed rules is available here.
The North American Meat Institute is the premier voice for the meat and poultry industry. Members of the Meat Institute process the vast majority of beef, pork, lamb and poultry in the United States, and manufacture the equipment and ingredients necessary to produce the safest meat and poultry products and of the highest quality.