Investigation · Meat & Seafood

The Counter Doesn't Know Where It Came From

Grocery store meat and fish labeling has three overlapping problems: origin claims that mean less than they sound, quality terms with no legal definition, and a global supply chain so fragmented that even the retailer often can't trace it.

43% of salmon samples mislabeled in Oceana study — most sold as "wild" were farmed Atlantic
2016 year Congress repealed mandatory country-of-origin labeling for beef and pork
2016 year USDA withdrew its official "grass-fed" marketing standard, leaving a gap
Jan 2026 "Product of USA" rule tightened — but still voluntary. No label required without the claim.
Chapter 01 · Origin

Where the Meat Actually Came From

The "Product of USA" label was the most exploited loophole in American food labeling for nearly a decade. Here's exactly what it meant — and what it still doesn't tell you.

Critical
The Loophole · 2016–2025

Brazilian beef could legally say "Product of USA"

In 2015, Congress repealed mandatory country-of-origin labeling (COOL) for beef and pork after Canada and Mexico won a WTO dispute. What followed was a decade-long loophole: meat from animals born, raised, and slaughtered entirely abroad could be labeled "Product of USA" as long as it passed through a USDA-inspected plant for repackaging. Unwrapping and rewrapping a box of Brazilian beef was legally sufficient. Major meatpacking corporations — many foreign-owned — used this extensively to market imported product at domestic price premiums.

The specific example: In 2017, the USDA temporarily banned imports of Brazilian processed beef after 11% of tested shipments were rejected for "public health concerns and sanitary conditions" — the normal rejection rate is under 1%. The ban was lifted in 2020. Imports surged 500% in the two years following the lift. During this entire period, imported Brazilian beef could legally be labeled "Product of USA."
Current
The Fix · Effective January 1, 2026

The rule tightened — but it's still voluntary

In March 2024, the USDA finalized a new rule: "Product of USA" now requires animals to be born, raised, slaughtered, and processed in the United States. This took effect January 1, 2026. It closes the repackaging loophole. But the label remains voluntary. Producers aren't required to tell you where their meat came from at all — they only need to meet the standard if they choose to use the claim. Most grocery store beef and pork carries no country-of-origin information whatsoever, and is not legally required to.

Structural
The Concentration Problem

Four companies process most of America's beef

JBS (Brazilian), Tyson Foods, Cargill, and National Beef process approximately 85% of all U.S. beef. JBS — the largest — is headquartered in São Paulo and has faced federal bribery investigations, food safety violations, and antitrust scrutiny. When your steak came from a large grocery chain with no origin label, the odds are high it passed through one of these four facilities. The butcher counter aesthetic at the store does not reflect the actual supply chain upstream.

How the supply chain actually works

Step 1
Ranch / Farm
Cattle raised — may be in US, Canada, Mexico, Brazil, Australia
Step 2
Feedlot
Grain-finished for 90–120 days
⚑ No label required
Step 3
Slaughter / Processing
Often one of four major processors
⚑ Country of origin lost here
Step 4
Distribution
Cold chain to regional DCs
Step 5
Grocery Case
"Fresh" label applied at store; may have been vacuum-packed weeks prior
Chapter 02 · Labels

What the Label Claims vs. What It Means

Several widely-used terms on meat packaging have no federal legal definition, are self-certified by producers, or have definitions that diverge significantly from consumer expectations.

0
federal inspectors verify most "grass-fed" claims — producer self-certifies
2016
USDA withdrew its official grass-fed marketing standard, leaving no single national benchmark
100%
of fresh meat qualifies as "natural" under USDA rules — the label means almost nothing
"Natural"
Implies: minimally processed, wholesome
USDA definition: no artificial flavors, colors, or chemical preservatives, and minimally processed (ground, for example). Under this definition, virtually all fresh meat qualifies. A conventionally raised feedlot steer given growth hormones and antibiotics can produce beef labeled "natural."
Tells you nothing about how the animal was raised, what it was fed, or whether it received antibiotics or hormones.
"Grass-Fed"
Implies: pasture-raised on grass for life
USDA (FSIS) guidance: animal consumed solely forage after weaning. But in 2016, USDA's AMS withdrew its official grass-fed marketing standard entirely. Claims are now self-certified by producers with documentation on file — there is no mandatory third-party audit. More critically: "grass-fed" does not mean "grass-finished." An animal can be grass-fed but grain-finished in a feedlot for its last 4–6 months.
Only meaningful with third-party certification (American Grassfed, Animal Welfare Approved). "Grass-fed" alone is not audited at farm level.
"Grass-Finished"
Implies: ate only grass for entire life
More rigorous than "grass-fed" — means the animal ate only grass and forage for its entire life after weaning, and was never put into a feedlot. However, this term also lacks a USDA-enforced standard. A producer can use it with supporting documentation but without mandatory on-farm verification.
More meaningful than "grass-fed" but still best verified via third-party certification from American Grassfed Association or similar.
"Angus" / "Black Angus"
Implies: premium breed, superior quality
USDA requires beef to have at least 51% black pigmentation to carry most "Angus" program labels. Breed identity is not independently verified at the level most consumers assume. The Certified Angus Beef® program (a nonprofit) has stricter specifications including marbling, maturity, and size requirements — but generic "Angus" claims at grocery stores are not the same as CAB certification and carry no audited standard.
The word "Angus" on a grocery package is primarily a marketing signal. Only "Certified Angus Beef®" with the logo reflects a verified program standard.
"USDA Prime"
Implies: highest quality, heavily marbled
This is a real, graded standard. USDA Prime reflects abundant marbling and comes from younger cattle. Only about 2–4% of all beef qualifies. However, grading is voluntary — most commodity beef is ungraded. And high marbling reflects a feedlot, grain-finished diet, not pasture-raised quality. Prime and grass-finished are typically mutually exclusive: the leaner profile of grass-finished beef rarely achieves Prime grades.
Meaningful for marbling/tenderness. Does not indicate origin, diet quality, or welfare standards — and is typically associated with grain-finishing.
"Fresh" (at the fish counter)
Implies: never frozen, caught recently
FDA does not define "fresh" in a way that prevents previously-frozen fish from being thawed and displayed as fresh. Fish can be frozen on a vessel at sea, shipped frozen to a US port, thawed at a processor, and placed in a grocery display case labeled "fresh." "Fresh, never frozen" means something specific — "fresh" alone often does not. Additionally, "previously frozen" disclosure in small print is legally required, but placement and sizing are not strictly regulated.
Ask at the counter: "Has this been previously frozen?" Staff are required to know. "Fresh, never frozen" on the package is the only reliable label claim.
Chapter 03 · Seafood

The Fish Counter Is Worse

Seafood has the most opaque supply chain of any protein category — governed by two different federal agencies under two different sets of rules, with documented mislabeling rates up to 43% for certain species.

43%
salmon samples mislabeled in Oceana study — most "wild" was farmed Atlantic salmon
30%
"sockeye salmon" samples in NY AG investigation were actually farmed Atlantic salmon
$10/kg
price premium for "wild-caught" Pacific salmon over farmed Atlantic — the financial incentive for fraud
Documented
Farmed vs. Wild · The Core Fraud

Farmed Atlantic salmon is routinely sold as wild-caught Pacific salmon

In the US, wild Atlantic salmon is commercially extinct — all Atlantic salmon at your grocery store is farmed. All wild-caught salmon is Pacific (sockeye, king/chinook, coho, pink, chum). This makes substitution easy to execute: a fish counter employee labels farmed Atlantic salmon as "wild" or "Pacific" and charges the premium price. Oceana's 2015 study found 43% of salmon samples mislabeled; 69% of those mislabeled samples were farmed Atlantic sold as wild-caught. A 2018 New York AG investigation found 30% of "sockeye salmon" samples were farmed Atlantic. Even a 2024 Seattle study, a decade after Washington State passed legislation specifically against salmon fraud, still found 13.5% mislabeling at grocery stores.

Structural
The Supply Chain Problem

Wild Alaska salmon is exported to China, processed, and sent back — sometimes mislabeled

The US exports vast quantities of wild Alaskan salmon to China for processing (filleting, portioning, packaging) because labor costs are dramatically lower. In 2013, the US exported approximately 85,000 metric tons of wild salmon to China — but only about 37,000 metric tons returned. What happened to the rest is, in the words of Oceana, "anyone's guess." Once your fish enters the global seafood supply chain, its species identity and origin documentation can be altered at multiple processing points before it returns to a US retail display labeled "wild Pacific salmon."

Governance
The Regulatory Gap

Two agencies, two different definitions of "processed" — neither closes the gap

Seafood origin labeling is split between USDA and US Customs and Border Protection, under different rules. Both require country-of-origin disclosure — but neither requires disclosure of where it was caught or whether it is farmed or wild, unless the product has been "transformed" (Customs) or "processed" (USDA) — and those two agencies define those terms differently. The result: a fish can change hands, cross multiple borders, and arrive at your counter with a country-of-origin label that reflects where it was last processed, not where it was caught.

Species most commonly mislabeled at US grocery stores

Salmon
Highest documented fraud rate
Label: "Wild," "Pacific," "Alaskan"
Most commonly substituted with farmed Atlantic salmon. Oceana found 43% mislabeling rate in winter sampling when wild Pacific supply is low. Wild and farmed look nearly identical to the untrained eye after filleting.
Ask for: species name (sockeye, king, coho) + "wild-caught" + season. Off-season "fresh wild salmon" is a red flag.
Red Snapper
Frequently substituted
Label: "Red Snapper" or "Snapper"
Oceana's national seafood fraud study found red snapper was one of the most frequently substituted fish — over 87% of samples nationally were not genuine red snapper. Often replaced with other, cheaper snapper species or unrelated fish.
Ask for: FDA-approved market name. "Snapper" alone is not sufficient — there are 185 species that can be sold as "snapper" under FDA rules.
Shrimp
Origin most commonly misrepresented
Label: "Wild," "Gulf," "Local"
Oceana found over 40% of grocery stores selling misrepresented shrimp. Farmed imported shrimp is frequently labeled "wild" or "Gulf." A 2020 study in North Carolina found 34% of shrimp sold as "local" was actually whiteleg shrimp not even found in NC waters.
Ask for: country of origin + wild vs. farmed. "Gulf shrimp" in a grocery context should specify wild-caught and US waters.
Halibut
Species substitution common
Label: "Pacific Halibut" or "Halibut"
Pacific halibut is a premium fish commanding high prices. It is commonly substituted with less expensive flounder, other flatfish, or farmed turbot — all of which have similar white flesh and flaky texture but different nutritional profiles and sustainability ratings.
Ask for: Alaska or Pacific origin certification. Pacific halibut season runs March–November; year-round "fresh" halibut is suspicious.
Tuna
Less fraud than commonly believed
Label: "Ahi," "Yellowfin," "Bluefin"
Oceana's research found tuna mislabeling relatively rare at retail (compared to sushi restaurants, where escolar is commonly sold as "white tuna"). In grocery stores, pre-packaged tuna tends to be accurately labeled. Fresh-cut "sashimi-grade" tuna at counters carries more risk.
At restaurants: "white tuna" as sushi is almost always escolar, not albacore. At grocery counter: pre-packaged is more reliable than fresh-cut.
Farmed Salmon
Correctly labeled — but still worth knowing
Label: "Atlantic Salmon" or "Farmed"
When correctly labeled, farmed Atlantic salmon is what it says it is. The considerations: farmed salmon's color comes from synthetic astaxanthin (a carotenoid additive) rather than natural diet; omega-3 content varies significantly by farm; and antibiotic use and environmental impact vary by country of origin (Norway has stricter standards than Chile).
Look for: Norwegian, Faroe Islands, or Scottish origin for generally higher farming standards. Chilean farmed salmon has historically had higher antibiotic use rates.
Chapter 04 · What to Do

Questions That Get Real Answers

A butcher or fishmonger who can't answer these questions doesn't have the supply chain visibility to back up their claims. A good one will know immediately.

🥩
"Where was this animal raised?" — Not "where was it processed." Where did it live. A good butcher sources from named farms or ranches and can tell you state, often county. A grocery counter often can't answer this.
🌿
"Is this grass-finished, or just grass-fed?" — The distinction matters. Grass-fed can include grain-finishing in a feedlot. Grass-finished means no grain at any point. If they don't know the difference, the label isn't being verified.
🐟
"Has this fish been previously frozen?" — Staff are required to know. "Fresh" does not mean never-frozen. The only reliable claim is "fresh, never frozen." If they aren't sure, assume it was frozen at some point.
🎣
"What species is this, specifically — and is it wild or farmed?" — "Salmon" is not a sufficient answer. Ask for the species: sockeye, king, coho. Ask: wild-caught or farmed Atlantic. Vague answers correlate with higher mislabeling rates.
📍
"Where was this caught or raised?" — For fish: Alaska, Pacific Coast, Atlantic, imported? For beef: which ranch, which state? The more specific, the better the supply chain visibility. If the answer is "I'm not sure" — the chain is long and opaque.
The Alternative

A butcher who can answer all of these questions already exists.

Independent butchers and fishmongers typically source from a small number of farms and vessels they know by name. The supply chain is short enough that traceability is built in — not marketed onto a label. San Francisco has several.

San Francisco · Verified vendors

Three places where the counter knows the answer

These vendors were verified for sourcing transparency — not just for being independent, but for having the supply chain knowledge to answer the questions above.

Butcher · Outer Sunset
Guerra Quality Meats
490 Taraval St. Family-owned since 1954. Full-service butcher with house-made deli. No chain ownership — Robert and John Guerra, second generation.
guerrameats.com →
Butcher · Noe Valley
Baron's Quality Meats
1706 Church St. Founded 2016 by Niman Ranch alum David Samiljan. No hormones, no antibiotics, humanely raised — sourcing posted and verifiable online.
baronsmeats.com →
Seafood · Noe Valley
Billingsgate
3859 24th St. Founded 2020 by chefs with Four Star Seafood background. Direct relationships with California fishermen. Traceable by design — they know the boat.
billingsgatesf.com →

Keep tracing.

This is one investigation. There are twenty more — covering supplements, protein bars, chocolate, and the conglomerates behind brands you think are independent.

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