Agriculture, Rural Development, Food and Drug Administration - Member Day

House Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies

2025-04-29

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Source: Congress.gov

Participants

Transcript

Chairman Harris, Ranking Member Bishop, thank you for the opportunity to testify before you today.  As you begin the fiscal year 2026 appropriations process, I encourage you to block the USDA from enforcing its recent regulation mandating electronic identification   or EID ear tags on cattle and bison moving interstate.  Ending this unlawful mandate and destructive policy is one of my constituents' top priorities, along with thousands of ranchers and cattlemen across America, especially those independent and family-owned operations that make up the heart of the American West and our nation's food supply.   On November 5th, 2024, the Animal and Plant Health Inspection Service's final rule, use of electronic identification ear tags as official identification in cattle and bison went into effect.  The rule amends the 2013 Animal Disease Traceability Rule to mandate EID ear tags   for cattle and bison that move across state lines.  Not only does USDA lack the authority to enforce such a mandate, but it ignored the devastating repercussions of this flawed policy and failed to follow the proper regulatory process.  Such repercussions include the destruction of thousands of small businesses and accelerated vertical integration of our food supply.   For states like Wyoming that lack major meat processing facilities, most livestock will be moved across state lines at some point during the life cycle to access the market.  This subjects my constituents to this rule while arbitrarily excluding their competitors in those states with packing operations.   In its 2013 ADT rule, the USDA estimated that the cost of a nationwide RFID system would be between $1.2 and $1.9 billion.  Yet, USDA estimates that the current rule would cost just $26.1 million annually.  This sleight of hand was achieved by considering only the cost of the eurotags themselves, ignoring all related compliance costs, including for wands,
software, hardware, retrofitting of infrastructure, and labor to implement a functioning EID system.  They also included only 11% of the regulated community, thereby nullifying their claim that this rule is about disease traceability, with USDA itself admitting that it must have 70% compliance for it to work for that purpose.   I appreciate that over the last two years, this subcommittee has sought to shield U.S. ranchers from the cost burden of this rule by providing $15 million to the agency for implementation.  Unfortunately, those efforts have not protected the rancher by no fault of this subcommittee.  The underlying policy itself is flawed, and there is simply no means to match the end to its purported   achievements.  In November, as the regulated community was preparing for the rule to take effect, state veterinarians were already reporting a shortage of EID tags.  This shortage continues to plague the system, forcing ranchers to buy more expensive tags or be non-compliant with the rule.  Throughout the rulemaking process, including in response to comments received about the proposed rule, USDA assured the regulated community that the ear tag manufacturers   were prepared to meet this mandate.  Yet the shortage persists, with states as recently as last week running out of tags and having to create backorder lists for producers who are now in violation.  Government mandates never result in decreasing the cost or increasing the supply of the mandated product, and the EID situation is no exception.  Tag prices have skyrocketed, meaning the faulty $26.1 million cost estimate is even more absurd as compared to the true cost.   If all this weren't bad enough, I reiterate that the USDA does not possess the authority for such a rule.  The EID final rule cites the Animal Health Protection Act.  Congress, however, did not empower USDA to use the AHPA to impose such a mandate.   The law also includes no provision allowing the USDA to impose criminal or civil penalties regarding violations of AHPA regulations, meaning it does not have the authority to implement the rule other than through the most extreme form of enforcement possible, which is denying access to the interstate cattle and bison markets.

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