Trusted beef brands have been deceiving consumers by selling meat products under Raised Without Antibiotics (RWA) labels that are not antibiotic-free. Using documents obtained under the U.S. Freedom of Information Act, a Farm Forward investigation revealed that government regulators detected antibiotics in supposedly antibiotic-free beef, including meat sold by three of the four largest meatpacking firms that dominate the American beef market. With deceptive labeling, these three companies—Tyson, Cargill, and JBS—sold RWA products containing antibiotics at a higher cost to consumers than conventionally raised beef, while government regulators have taken no public or punitive actions to stop them.

Simply put, consumers are being scammed by Big Beef, and the United States Department of Agriculture (USDA) is knowingly letting them get away with it.

USDA testing revealed that antibiotic residue was widespread in RWA beef, but USDA did not release the names of offending companies. This investigation uncovered how the meat industry’s largest and most trusted brands drove this deception of consumers and how USDA’s failure to regulate RWA labeling has made it impossible even now for consumers to make conscientious purchasing decisions.

This brief outlines two key findings:

1. Three of the beef industry’s four largest companies deceived the public about claims that their beef is free of antibiotics, and some have continued to mark products RWA even after receiving USDA’s notice that their products contained antibiotics.

2. USDA has deliberately maintained labeling policies that allow meat companies to mislead consumers.

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The rapid spread of highly pathogenic avian flu (HPAI) H5N1 through our agriculture system presents a deep threat to our food supply and a growing risk that the virus will mutate to become the next dangerous human pandemic. Sadly, the U.S. federal government response has not only been insufficient, but has actually worked to encourage the dangerous corporate practices driving this risk. Longtime close ties between federal agricultural regulators and the industry they are supposed to regulate has resulted in taxpayers actually footing the bill for programs that profit the industrial animal sector while making a human H5N1 pandemic more likely.

As of February 27, 2025, there have been 70 confirmed cases of the virus in humans in the U.S., causing one human death. While the virus has not yet been documented to spread between humans, researchers found that the H5N1 variant in dairy herds required only one mutation to spread more easily in humans. Given that H5N1 mutates rapidly, like other forms of influenza, scientists and public health officials are particularly concerned to know that we are just one mutation away from a potentially deadly human pandemic. The World Health Organization reports that, since 2003, 48.6 percent of global H5N1 cases in humans have been fatal.

Farm Forward’s review of current policies and data reveal six essential flaws with USDA’s response to the pandemic at poultry farms:

• USDA compensation payments to poultry farms with infected birds increase pandemic risk.
• USDA compensates repeat offenders.
• Current audits of safety measures are meaningless.
• Huge loopholes in safety requirements allow many farms to take no measures at all.
• Information blackout from the new administration leaves public health officials in the dark.
• Vaccine requirements lag far behind many other countries.

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Executive Summary

One of the most sophisticated greenwashing and corporate welfare schemes ever designed, “manure biogas,” is providing Big Ag cover to use public dollars to fund an expansion of factory farms in the Midwest. The first thing to know about “biogas” is that the term itself is misleading. “Biogas,” also sometimes called “renewable natural gas” or “RNG,” refers to the use of methane digesters (also known as anaerobic digesters) to capture gas emanating from the cesspools of waste that concentrate on factory farms. These digesters process some portion of the waste from factory-farmed animals into fuel while also producing a polluting byproduct called digestate. “Manure biogas” is more accurately described as factory farm gas, or FFG for short.

Industry has touted its use of FFG as a climate solution, but an investigation by Farm Forward released in parallel with this one documents that FFG functions as a net negative by incentivizing the expansion of factory farming and entrenching current factory farms and their worst practices. This Farm Forward report demonstrates how Big Ag is effectively bringing its waste problem to the Midwest by confusing legislators and the public with lofty talk of “biogas” or, as it is alternatively branded, “renewable natural gas” or “RNG.”

With industrial dairy at the helm, a coalition of utility and fossil fuel companies are making plans to entrench and expand factory farming’s most destructive practices: mass confinement of animals and manure cesspools. At the center of this plan is FFG, which industry plans to promote by a combination of deregulating digesters and manipulating clean fuel standards. Industry has already introduced legislation in Michigan to deregulate anaerobic digesters and their waste byproducts, and to establish a new “clean fuels standard,” a credit trading scheme for polluters.

Michiganders are increasingly waking up to the industry’s plans, and concerned citizens are resisting and opposing the growth of CAFOs in their states.1 However, industry misinformation has led to considerable confusion about FFG, even among policymakers and some environmentalists. This report demonstrates that FFG is a clear case of egregious greenwashing. FFG threatens a massive misappropriation of public funds to expand a polluting industry deeper into America’s heartland.

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Executive Summary

“Manure Biogas” (also known as factory-farmed gas, or FFG) is rapidly expanding, and industry has structured it to produce a reverse Robin Hood effect: the increasing subsidies for FFG are supposed to incentivize green practices but instead fund greenwashing that promotes the growth and entrenchment of the largest factory farms at the expense of the surrounding communities, the climate, and public health.

“Biogas” is how Big Ag refers to the use of methane digesters—large sealed tanks with no oxygen—to capture gas emanating from the cesspools of waste that concentrate on factory farms. These costly and inefficient digesters process some portion of the waste from factory-farmed animals into fuel while also producing a polluting byproduct called digestate. “Biogas” is more accurately described as factory farm gas or FFG for short.

FFG functions to pump billions of dollars into propping up industrial animal production. In places where data is available like Wisconsin and Iowa, FFG growth has meant the growth of factory farms. In 2023, federal subsidies for biogas began rapidly expanding and exceeded $150 million. In one federal grant program alone, there was an over 2,600 percent year-over-year increase in federal grants for biogas. These public funds have attracted private investments that further exacerbate the problem.

Farm Forward’s analysis reveals that these subsidies flow almost exclusively to factory farm interests and disproportionately to the biggest, most destructive farms—rewarding the ones that do the most environmental damage. In addition to grants, low-interest loans, tax deductions, and other free monies from public coffers, the justification of FFG involves a blatant overvaluation of environmental credits. Despite these obvious problems being flagged by 15 members of the U.S. Senate and House,1 the federal government has doubled down on support for FFG.

Greenwashing gas from factory farms is not a climate solution. It’s climate gaslighting. The real solutions to the problems of factory farming are well known: reducing our overall dependence on animal products and raising the remaining animals on farms that combine the best of traditional and modern models to reduce the many public health and environmental costs of large-scale animal agriculture.

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See our parallel report, “The ‘Biogas’ Plot: Fueling Factory Farms in the Midwest.”

Executive Summary

This report details the results of a consumer fraud investigation conducted by Farm Forward, with the help of rancher whistleblowers, that uncovered systemic deception, cruelty, and animal abuse by arguably the leading higher welfare, Organic, Certified Humane, and “regenerative” dairy operation: Alexandre Family Farm, LLC. Our own eyewitness experiences in investigating this report, coupled with extensive documentation—including video footage, photographic evidence, ownership documents, a veterinary evaluation from a large animal veterinarian who works in the dairy industry, and a review by leading animal welfare scientist Gail Hanson, DVM—together provide damning evidence that Alexandre, in contrast to their public claims and certifications, practices a business model that ensures that cows routinely suffer egregiously and that diseased animals are sold into the human food supply chain. Given Alexandre’s leading reputation in the industry, Alexandre’s failures suggest that decades of industrialization make it nearly impossible for modern dairies to produce their products in line with public expectations.

The enormous scale of preventable animal disease and suffering documented at Alexandre reveal loopholes in its certifications that function to deceive consumers, so-called humanewashing. Perversely, Organic certifications frequently function to incentivize farmers to withhold needed medical treatment from diseased animals and, polling shows,1 aid in humanewashing by giving the public the false sense that these certification standards align with their values. Many manufacturers that incorporate Alexandre’s dairy into their own products—including toddler formula—highlight Alexandre’s welfare claims to increase their own sales, expanding the humanewashing (and such products may not identify Alexandre by name and so are hard for consumers to avoid).

One of the most dramatic findings of our investigation is that in more than a hundred videos and photos Farm Forward has documented dozens of cases of serious violations of even the relatively weak Organic, Certified Humane, and other certifications that Alexandre touts in its advertising, yet Alexandre retains those certifications.

Structural conditions in the dairy industry, and particularly in Organic certification programs, may make socially unacceptable forms of animal suffering— like failure to adequately treat obvious injuries and illnesses—the rule rather than the exception. Given that these welfare problems are occurring in “best of the best” operations that, as of the release of this report, remain in good standing with their certifications, it is our recommendation that for the foreseeable future, consumers who wish to avoid animal cruelty steer clear of products made from cows’ milk.

Introduction

The Historical Moment

When the country’s most diverse, lactose-intolerant, and environmentally conscious generation, Gen Z, turned its back on cows’ milk, it put industrial dairy’s back up against a wall. Americans’ annual cow milk consumption had already fallen by two-thirds between 1945 and 2022, from 45 gallons per person to 15.2 Members of Gen Z drink even less than the rest of the public, in 2022 buying 20 percent less cows’ milk than the national average.3 “We lost almost an entire generation of milk drinkers,” noted U.S. Representative Glenn Thompson (R-PA), leader of the House Committee on Agriculture.4 Meanwhile, in 2022 just over 40 percent of U.S. households purchased plant milks5 like oat, soy, and almond, which occupy ever-increasing footage of grocery store shelves: their global revenue of $15 billion in 2015 is expected to grow to more than $35 billion by the end of 2028.6

The Labels

As the dairy industry tries to convince Gen Z that it offers a humane, desirable, relevant, and climate-friendly product, dairies apply appealing labels to milk cartons: “pasture-raised,” “grass-fed,” “eco-friendly,” even “carbon neutral,” and the recently introduced “regenerative.” Most of these labels are meant to convey in part—as phrased by Alexandre Family Farms, LLC (Alexandre)—“These are some happy grass grazed cows,”7 “I am one happy cow,”8 and “Life on our pastures is a happy one!”9 But how can consumers know that these marketing labels and statements fairly represent the actual conditions on the farm, and aren’t simply more humanewashing?10

The Certifications

Enter third-party certifications like “Certified Humane by Humane Farm Animal Care,” to persuade consumers that on-farm conditions are as humane and environmentally sound as the labels purport. And it’s working, at least for the dairies. Alexandre’s customers likely believe that they are supporting “happy cows.”11 Well-intentioned consumers buy into both the label claims and certifications, paying a hefty premium for cows’ milk from the dairies that sell to “ethical” retailers like Whole Foods Market, which markets their partnership with Alexandre as “Restarting Dairy.”12 Alexandre boasts a number of premium animal welfare certifications and was named a Whole Foods Market Supplier of the Year in 2021.13 But given the evidence that we uncovered, Alexandre’s welfare claims appear designed to deceive.

The Animal Welfare Violations

In more than 15 years of advocacy Farm Forward has seen the worst of the worst on factory farms. Yet our own eyewitness experiences combined with the videos, photographs, and research the rancher whistleblowers provided to us documenting Alexandre’s practices shocked even us.

Dozens of videos and photos depict Alexandre’s numerous indefensible animal welfare violations. Far from indicating isolated incidents, or physical abuse of a few cows by “a few bad apples” among Alexandre staff, the footage points to routine management practices, driven from the top, that lead to systemic, egregious suffering. In addition to what the videos depict, whistleblowers working with and around Alexandre provided photographic evidence of more than a dozen calves who were kept isolated from their mothers and died; whistleblowers also described serious lapses in management that resulted in, for example, the extreme suffering of hundreds of cows and the violent deaths of dozens of cows.

The Report

The report’s first section, “Animal Abuse at Alexandre,” documents the condition of cattle videoed, photographed and/or witnessed by the whistleblowers or by Farm Forward staff, as well an assessment of video evidence from a large farmed animal veterinarian specializing in dairy. Their evaluations, along with an independent evaluation by farmed animal welfare expert Gail Hansen, DVM, all point to dismal welfare conditions at Alexandre.

The report’s second section, “Animal Welfare Certifications Failed to Prevent Suffering,” demonstrates that the certifications supposedly verifying Alexandre’s welfare practices—USDA Organic, Certified Humane by Humane Farm Animal Care, and Regenerative Organic Certified—did not prevent, or apparently even detect, the abuses at Alexandre. In fact, documentary evidence indicates that the Organic program and Organic certifiers were notified of abuses and potential violations of Organic standards and yet the issues persisted. Sadly, when combined with the market pressures in the dairy industry, a requirement of the Organic program—the prohibition of the use of antibiotic treatment of animals marketed with the label—may have perpetuated and even worsened systemic animal suffering at Alexandre.

Third, in “Ripples of Humanewashing,” this report shows that Alexandre’s claims of ethical production expand through the market through food manufacturers who purchase its dairy products, including a company producing toddler formula. These “ethical dairy” companies spread Alexandre’s deception far beyond the products that Alexandre sells directly to consumers.

When the certifications with the highest animal welfare standards don’t prevent appalling animal suffering even at the leading higher welfare regenerative dairy, we are left to wonder what is happening at other big dairies, and whether higher welfare dairy is possible for today’s grocery markets. Given current market dynamics, big dairy may be a welfare problem that cannot be solved.

Widening the focus from just Alexandre, the appendix “Structural Suffering” explores how the organizational structure of large scale organic and conventional dairies depresses animal welfare and leads to the staggeringly high annual death rate for cows used for dairy, and suggests directions for future research.

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Introduction

This report provides an analysis of the opportunities for alignment between the Regenerative Agriculture (RA) movement and the Farmed Animal Protection movement (FAPM). Farm Forward was commissioned to create this report by a client in the funding community. It has been condensed and edited for a larger, but still targeted, audience: funders and advocates who work, or who are interested in working, at the intersection of farmed animal protection and regenerative agriculture. In particular, our imagined reader is someone who already shares certain values with the FAPM—a concern for the suffering of farmed animals, for example—but is unfamiliar with the history, politics, structures, and ideologies that have driven farmed animal protection work in certain directions. We hope this report will facilitate greater investment and participation in farmed animal protection work— and in strategies that involve the RA movement—by helping interested parties identify entry-points for engagement with advocacy groups.

This project was conducted over several months and was motivated by our client’s interest in understanding:

• The broad landscape of the RA movement.
• How RA actors incorporate farmed animal welfare into their models or understand farmed animal welfare as central to their missions.
• Barriers to scaling RA.
• Opportunities for scaling RA.

We limited the scope of our research to activities taking place in the US. Our methodology included conducting interviews with people working within the RA space, consulting scientific and expert research, and referring to publicly available 990s and nonprofit websites. We also draw upon the direct experience of our team.

Farm Forward is a mission-driven nonprofit advocacy organization that both conducts direct advocacy campaigns against factory farming and provides strategic consultation to advocacy groups, funders, and businesses around farmed animal protection issues. We do not claim to be disinterested parties— rather, a strength we bring to this project is our team’s deep experience as FAPM insiders, including the relationships, insights and intuitions won over years of direct engagement with farmers, companies, and advocacy groups. We also assume certain values on the part of our reader: that the welfare and well-being of farmed animals matters, and that advocacy work which centers farmed animals merits more robust funding and support.

This report is not meant to provide a comprehensive or definitive description of all RA activities. It has focused, instead, on answering certain questions that are of especial interest to our client, whose central aim is to advance farmed animal welfare. Because we conducted this project with the assumption of certain shared values with our reader, we were able to leave out some more granular analysis and data that would be expected in a report claiming academic objectivity.

We have attempted to be transparent when we are expressing Farm Forward’s informed opinions as well as observations based on our own experience rather than outside research or interviews (usually through footnotes). We have also attempted to provide data that is accurate and included citations so that readers can conduct their own research.

One thing to note is that we conducted most of this research prior to the global outbreak of COVID-19, which has dramatically altered the economic landscape in which regenerative agriculture operates. Economic and political decisions being made now and in the near future will play an important role in determining which models of agriculture grow or shrink in the US, and we may face a different regulatory climate for agriculture in the US than we have in the past. While we have incorporated new data into this report wherever possible, we cannot predict the state of regenerative agriculture in the years to come, and we think it is highly worthwhile to revisit many of the questions in this report again in the future to see how their answers may have changed in post COVID-19 America.