Despite modification to proposed rules for Proposition 12, the proposed rules are flawed and more time is needed for compliance, argued The North American Meat Institute (NAMI) in comments submitted to the California Department of Food and Agriculture (CDFA) on Dec. 17.
“Several changes in the modified rules are to be applauded because they account for the 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; flaws NAMI identified in its July comments and during the August
public hearing that still need to be addressed,” NAMI said in the comments.
Proposition 12 directed CDFA to promulgate regulations implementing the law by Sept. 1, 2019. The rules are yet to be finalized even though some provisions take effect Jan. 1, 2022.
“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.
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