– Dr. Michelle Arnold, DVM- Ruminant Extension Veterinarian (UKVDL)
Figure 1: Homepage of the APHIS Animal Disease Traceability Website.
In a press release issued on April 26, 2024, it was announced that a new rule, entitled “Use of Electronic Identification (EID) Eartags as Official Identification in Cattle and Bison” was finalized. This final rule is an amendment to the animal disease traceability regulations already in place as of January 2013. The new rule requires eartags to be both visually and electronically readable to be recognized as official eartags for interstate travel for cattle and bison covered under the regulations. In addition, the amendment revised the definition of dairy cattle, clarified certain record keeping requirements, and revised requirements for cattle moving to slaughter. This final rule is specifically focused on improving the ability to trace LIVE animals accurately and rapidly to contain disease outbreaks before they can do substantial damage to the cattle industry. The rule will be published in the Federal Register in the coming weeks and will take effect 180 days after its publication. APHIS maintains an Animal Disease Traceability webpage (Figure 1) with direct access to the Final Rule, FAQs, how to obtain free electronic ID tags, and other resources at https://www.aphis.usda.gov/livestock-poultry-disease/traceability . This article will attempt to address some of the less frequently asked questions about important aspects of the new rule. For reference, page numbers are included where these questions are addressed in the final rule.
Has anything changed with this new rule regarding which cattle are required to have “official identification” when moving interstate?
No, the final rule does not change the categories of cattle and bison subject to the official ID requirements for interstate movement (page 2). Cattle and bison that move interstate and fall into specific categories need official, individual eartags that now can be read both visually and electronically. The requirement for individual identification does not include feeder cattle, nor any cattle or bison moving directly to slaughter.
Beef Cattle (and Bison) that currently require official ID:
-All sexually intact beef cattle and bison 18 months of age or over;
– Cattle and bison of any age used for rodeo or recreational events; and
-Cattle and bison of any age used for shows or exhibitions.
Dairy Cattle that currently require official ID:
-All female dairy cattle of any age and all dairy males born after March 11, 2013; the new rule revised the definition of dairy cattle as follows: “All cattle, regardless of age or sex or current use, that are of a breed(s) or offspring of a breed used to produce milk or other dairy products for human consumption, including, but not limited to, Ayrshire, Brown Swiss, Holstein, Jersey, Guernsey, Milking Shorthorn, and Red and Whites.” (page 30)
According to the revised definition of “dairy cattle”, the offspring of a dairy animal requires official ID for interstate movement. Does this include Beef on Dairy calves?
Yes! According to the final rule, “APHIS’ operational guidance has consistently held that beef/dairy cross bred cattle fall under the definition of dairy cattle and are therefore already required to have
Figure 1: Homepage of the APHIS Animal Disease Traceability Website.
official identification; our change to the dairy cattle definition codifies this longstanding guidance regarding how to interpret the regulations” (page 31). “Beef/dairy cross breeds should already be officially identified. We have no indication of noncompliance or controversy surrounding this policy…We acknowledge the possibility that there may be cattle producers that did not consider their beef/dairy cross breeds to be dairy cattle and were alerted to our interpretation of the definition of dairy cattle to encompass beef/dairy cross breeds by this rulemaking” (pages 71-72). In addition, the revision states that the official ID numbers of all dairy cattle, regardless of whether they are sexually intact, must be recorded on the Interstate Certificate of Veterinary Inspection (ICVI or “Health Certificate”). (page 29)
Why would Beef on Dairy calves be at higher risk for disease?
“As stated in the proposed rule, dairy farm management practices, such as pooling colostrum from multiple cows for many calves, commingling calves at different locations during their lifetimes, and movement to many destinations, result in a higher risk of disease transmission. Beef/dairy crosses born on dairy farms are likely to be exposed to these practices, especially in early life; therefore, they are at an increased risk of disease transmission.” (page 31)
The final rule added several recordkeeping requirements for official identification. Currently anyone (State, Tribe, accredited veterinarian, or person) who distributes official ID devices must maintain records of recipient names and addresses for 5 years. How did this change?
The final rule added that the official ID distribution records must be entered by the person distributing the devices into a database designated by APHIS. Any eartags applied by a federally accredited veterinarian must also be recorded in a readily accessible database available to APHIS in the event of a traceback (page 37). However, a producer who applies official ID tags to his or her own animals but does not distribute the tags to anyone else does not fall under the recordkeeping reporting requirement (page 42).
APHIS did add a new paragraph stating that required records must be maintained by the responsible person or entity and “be of sufficient accuracy, quality, and completeness to demonstrate compliance with all conditions and requirements” of the final rule. It further requires that APHIS be allowed access to all records during normal business hours, to include visual inspection and reproduction (e.g., photocopying, digital reproduction), and the responsible person or entity must submit to APHIS all reports and notices containing the information specified within 48 hours of receipt of request for records. (page 37)
Is a PIN still required to acquire and apply EID tags?
Yes. The PIN (premise ID number) is a nationally unique number assigned to a premise, usually issued through the State animal health official, that is a “geographically distinct location”. The PIN is associated with the location the tag was placed on the animal, not the location of the cattle owner. “All currently approved EID eartags (RFID AIN “840”eartags) are associated with a PIN or a State location identification number (LID), inasmuch as a PIN or a LID is required for” acquisition of the tags. “A PIN is the numerical equivalent of a 911 postal address or a GPS number. A LID is the State-managed equivalent for producers who prefer to have the State store their information, rather than the Federal Government” (page 46).
This final rule does not require producers to purchase and affix EID eartags to their cattle as the only acceptable official identification device or method to meet the official identification requirements for interstate movement (page 3); the regulations continue to list eartags as one of several forms of authorized official identification, which also include tattoos and brands when accepted by State officials in the sending and receiving States. (see Frequently Asked Questions at the APHIS website for further information).
Given that a major reason for this new official ID rule is to keep transcription errors to a minimum, why does APHIS still require a visually-readable tag?
The 15-digit identification number currently used for all approved EID eartags begins with the same 6 digits: 840003. The first 3 digits are the country code, which is 840 for the United States. The following 3 digits, 003, signify a sequential numbering system from a start number of 003,000,000,000. Therefore, an individual visually reading an EID tag would only read 9 unique characters (the characters following 840003). These characters are only numbers, with readability standards including larger font size and color contrast. A transcription error “is not likely to significantly increase from the current state when relying on visual read of the eartag; if anything, several factors should make it easier, not harder, to transcribe the tag number. However, the use of EID tags would allow for an electronic read of the tag if a transcription error were believed to have occurred.” (page 43) This final rule does not require producers or livestock markets to have electronic reading equipment or additional data management systems, because the official EID tags must be readable visually as well as electronically.
RFID tags were previously categorized as either “Low Frequency” (LF) or “Ultra-High Frequency” (UHF). This final rule refers to RFID tags as “HDX” or “FDX”. Are these terms similar?
The RFID tag technology can be categorized by the radio frequency range it uses to communicate, either low (LF) or ultrahigh frequency (UHF)—whichever the State, producer or industry sector prefers. Low frequency tags have a shorter read range and only one tag can be read at a time. UHF has an extended read range of up to 30 feet, faster data transfer, and is better suited to capturing load lots of cattle.
However, RFID can also be categorized by the way information is transferred between the tag and reader, either “Half Duplex (HDX) or “Full Duplex” (FDX). HDX tags are heavier, they transmit information one way at a time and are better able to transmit through interference such as metal objects, and they have the strongest read range. FDX eartags are lighter in weight, they transmit information continuously but are more susceptible to interference from metal objects and fluorescent lights. Regardless of type, all RFID tags must be approved by USDA and meet standards for quality and performance, be tamper proof, contain a unique ID, and display the U.S. official ear tag shield.
Figure 2: National Uniform Eartagging System (NUES) Metal Tag (“Silver” or “Brite” Tag).
What if the animal already has “official identification” such as the NUES Metal Tag or a visual-only tag? Does it have to be removed or will it be required to apply an additional electronically-readable tag?
No, all visual-only official ID tags applied prior to the date the rule is effective will be considered official identification for the animal’s lifetime including the metal NUES tags (Figure 2), commonly referred to as “silver” or “brite” tags, and the Brucellosis Vaccination metal tag, an orange metal tag that indicates the animal was calfhood vaccinated for Brucellosis (Bangs Disease). However, a visually and electronically readable official eartag may be applied to animals currently identified with non-EID official eartags or Brucellosis vaccination tags, even though this results in more than one official eartag in an individual animal (page 102).
Figure 3: Example of an Official Tag
What must be on an official ear tag?
USDA Official Ear tags (Figure 3) are designed for one-time use (tamper evident) and imprinted with:
– A unique animal identification number or “AIN” which is a 15-digit number starting with 840003;
– Official Ear tag Shield
– The words “Unlawful to Remove”;
– Manufacturer’s Logo or Trademark (printed or impression of)
– The placement of official RFID tags is recommended in the left ear, but there is no such regulatory requirement, and the tags may be placed in either ear at the owner’s discretion.
Buyer beware: Tags containing numbers with the prefix “USA” or a numeric manufacturer code such as 982 are not considered official identification but these tags are still available for purchase and, in many cases, cannot be returned or exchanged for the correct tags. APHIS only recognizes tags beginning with numeric country codes (“840” for the United States) as official (page 49). Bear in mind that there are 840 visual panel tags available that do not contain RFID technology that will not be accepted as official after the final rule becomes effective.
Have the rules regarding movement within slaughter channels changed?
The existing regulations allow cattle to move interstate to an approved livestock market and then to slaughter or directly to slaughter without official identification (typically travel on a backtag) unless held up for more than 3 days. This final rule clarifies that animals may only move to another slaughter establishment or approved feedlot, with appropriate documentation and identification, but must remain in a terminal market and can only be sold/re-sold as slaughter cattle. (page 101)
Will EID tags increase food safety? Will EID tags be used to identify beef imported into the US?
Since animal identification programs end at the time of slaughter, EID tags on cattle will not directly increase food safety. Within the USDA, food safety of meat and meat food products falls under the Food Safety and Inspection Service (FSIS). Although APHIS does not provide oversight of the slaughter or processing operations, APHIS conducts slaughter surveillance for domestic animal diseases, such as brucellosis and TB, and some foreign animal diseases.
Similarly, COOL (Country of Origin Labeling) is not related to APHIS’ animal disease traceability program but is under the purview of the Agricultural Marketing Service (AMS). (page 19)