While FDA’s January 2026 traceability compliance date draws ever closer, USDA-regulated cattle and bison operations are nearly upon their November 5, 2024, compliance date for eartag requirements of an Animal Disease Traceability Rule amendment.
With the May 2024 passage of the final rule, Use of Electronic Identification Eartags as Official Identification in Cattle and Bison, the industry was given 180 days to begin applying official Electronic Identification Eartags or EID eartags that are both electronically and visually readable on any covered animal to be moved across state lines. As an amendment to the 2013 Animal Disease Traceability (ADT) Rule, the EID Rule comes at a particularly applicable time as H5N1 cases continue to be reported in dairy cattle.
Historically this has been a tough space for the cattle industry. Years back when we were all facing the impact of Bovine Spongiform Encephalopathy (BSE), the lack of knowing exactly which cattle were moving where created some logistical, economic, and potentially public health challenges. While H5N1 in cattle has not so far turned out to be all that significant with regard to animal health, there are situations such as foot and mouth disease where the movement of cattle can be very impactful on the agriculture business.
With the rule also clarifying certain record retention and record access requirements and revising some slaughter cattle requirements, the goal is to accelerate the speed of response to high-impact animal diseases of both U.S. and foreign origin that threaten the viability of the U.S. cattle and bison industries. Knowing where diseased and at-risk animals are and have been, and when, is critical in emergency response and ongoing disease control and eradication programs.
Since the enactment of the ADT Rule in 2013, the industry has been required to use the official Animal Identification Number (AIN) system for covered livestock that is moved interstate. The number was to appear on an ID tag approved by APHIS and had to be tamper-resistant with a high retention rate in the animal. The tag was to be visually or electronically readable. Then, in 2017, USDA APHIS published a report finding that there were gaps in animal tracing due to the challenges of reading and recording numbers from non-EID eartags and in collecting AINs at slaughter and removing those ID numbers from future tracing efforts. As the report stated, “Eliminating this gap was determined not to be feasible with visual-only eartags, but could be achieved with EID eartags.”
Thus, the birth of the EID final rule as an amendment to the ADT rule, requiring that the tags of covered cattle and bison that are moved interstate be both visually and electronically readable. While an original 2020 notice referred to RFID tags specifically, the final rule was broadened to EID tags in general to allow for other technologies that may become available.
As noted in the rule, to be fully prepared for a possible incursion of a high-risk foreign animal disease, an estimated 70% of each species/sector would need to be traceable “to the source of the disease and exposed animals within the time window of the particular disease’s exposure and transmission parameters.” APHIS sees the rule as furthering that goal by enhancing the ability of the U.S. to regionalize and compartmentalize animal health issues. By separating subpopulations of animals to maintain a specific health status within disease-free regions or zones, adverse impacts can be mitigated and costs minimized. Additionally, the use of EID eartags can significantly reduce the amount of time it takes animal health officials to complete a tracing investigation and help enable the reestablishment of foreign and domestic market access with minimum delay following an event.
While there has been some industry concern about privacy, APHIS has stated that while the EID tag identifies the animal, it does not hold any owner-specific information, so if the animal is sold or otherwise changes hands, it continues to retain its original tag. Additionally, the databases storing the animal disease traceability information are not public; they are accessible only to specific Federal and state officials.
A few caveats to the rule are that it applies only to animals being moved interstate and exempts direct-to-slaughter cattle and sexually intact cattle and bison under 18 months of age. Additionally, eartags applied before November 5, whether visual or EID, will be recognized as official throughout the life of the animal. Thus, visual tags applied before November 5 will not need to be replaced with EID tags.
With both USDA and FDA focused on enhanced traceability for animal/product protection and consumer health, and encouraging, if not actively requiring, the use of electronic systems, it behooves all in any segment of the food industry to take a new look at your internal and supplier traceability systems. This assessment should not only ensure that you are complying with whatever regulation applies to your product and processes, but should consider any potential improvements that could be made to enhance detection, mitigate contamination/disease, and accelerate the speed of outbreak response and recall.
