Idaho Potato Commission Rulemaking
The IPC received a petition from an Idaho grower and shipper requesting that the IPC amend its administrative rules to remove the variety labeling requirements for all varieties of potatoes grown in Idaho. The proposal included a recommendation to label all russet varieties grown in Idaho as "Idaho Russet". As a result, labeling the variety of potato on packaging would become optional.
The purpose of the negotiated rulemaking process is to determine whether it is beneficial to the Idaho potato industry, Idaho potato customers, and consumers to Idaho potatoes for the IPC to remove the labeling requirement on all varieties of potatoes.
I am currently opposed to the proposed rule change on variety labeling. While I understand it may simplify and streamline the process on the shipper end I feel it is certainly detrimental from a marketing and branding standpoint. The consumer will not benefit. I agree that many people don't know/pay attention to the lables differentiating Burbanks from Norkotas, for example, but for those who do I feel they deserve the right know what they are purchasing. I also wonder if the rule change would allow for mixing of varieties. That too will be detrimental. There will be no consistency iin the product and consumers will loose confidence in what they have been accustomed to expect. Thank you for your consideration.
Dwight Little
Shawn, Sam, & Travis,
First, I want to thank all of you for putting together the industry meetings regarding this proposed rulemaking. I thought it was a great discussion and would honestly like to see more meetings like that in the future.
As for the proposed rule itself, I struggle to understand what actual benefit this provides to the Idaho potato industry overall. From my perspective, this feels a bit like an “if it ain’t broke, don’t fix it” situation.
Removing varietal labeling creates less transparency in the marketplace. Customers and consumers do recognize varieties like Burbank and Norkotah, and there is value in clearly identifying what is actually being sold versus simply labeling everything as a generic “Idaho Russet.”
The industry is also moving toward more traceability and standardized labeling, not less. Even though potatoes are exempt from portions of FSMA 204, many large customers still require PTI-style labeling that includes commodity, variety, GTIN, and other traceability information for consistency across their supply chains. Removing varieties would likely create additional GTIN and labeling complications while also removing an extra layer of product identification during recalls or market withdrawals.
Another concern I have is that this proposal was discussed as being optional rather than an industry-wide standard. To me, that creates even more confusion if some Idaho shippers include varieties on labels while others do not. Our industry constantly works together to help fulfill customer demand, share PO coverage, and pack for one another depending on contracts and product availability. At times, multiple shippers may even be packing orders for the same customer out of the same facility. Having inconsistent labeling practices across Idaho product makes the industry appear less organized and standardized.
Associations like IPC and IGSA exist in part to help protect and standardize the Idaho potato brand and reputation. If a change like this were ever implemented, I believe it should be all-or-nothing across the industry — not optional by shipper or commodity type. Personally, I do not support the change for russets, reds, or golds.
I also disagree with the statement made during discussions that consumers do not care about potato varieties. In my role, I handle consumer inquiries directly and regularly hear from consumers specifically looking for Idaho Burbank russets. Consumers absolutely do recognize and ask about varieties.
The same concern applies to reds and mini potatoes as well. Certain red potato varieties have different skin and flesh color combinations, such as red/white flesh versus red/yellow flesh, and consumers often prefer specific varieties for certain recipes like soups or potato salads because of flavor, texture, or cooking performance. If all product simply becomes labeled as “red potatoes,” consumers lose the ability to distinguish what they are purchasing and it becomes more of a guessing game. I strongly believe consumer inquiries and complaints would increase significantly as people try to determine what variety they are actually buying.
Overall, I do not believe removing varietal labeling adds value for the industry, customers, or consumers, and I believe many retail and foodservice customers would push back on moving toward less product transparency.
Quick summary of concerns:
• Reduces product transparency and traceability
• Creates confusion between potato varieties
• Optional labeling would create inconsistent standards across Idaho shippers
• Conflicts with increasing PTI and traceability expectations
• Could create additional GTIN and labeling complications
• Removes an additional layer of identification during recalls or withdrawals
• Consumers do recognize and seek specific Idaho potato varieties
• Variety differences can impact recipe use, cooking performance, and consumer preference
• Unclear what overall benefit this provides to the industry
Thank you for the opportunity to provide feedback.
Stephanie Anderson
Good morning Sam. I’ve thought a lot about this proposal. It’s not the first time that it’s been suggested that Idaho remove the variety labeling requirement. If this effort were coming from fresh shippers trying to help new, fresh market varieties gain traction in the fresh industry, I might feel differently than I do, but the reality is that this push is being made by process growers who want to be able to more easily market their process contract overages on the fresh market. They want to be able to sell process varieties like Alturas, Clearwater, Ranger, Reveille, etc. on the fresh market without having to explain to their customers what they’re sending them. How can this help the fresh industry? Processors already use the fresh market as a dumping ground for their overages. Why would we want to remove one of the only barriers we have that keeps them from over-contracting high yield, primarily process, varieties? The fresh market is already oversupplied. I realize that the IPC has to represent all of the potato industry in the state. A healthy processing sector is good for the fresh and vice versa. The fresh market is currently enduring the worst market in history from a grower profitability standpoint. It has been severely oversupplied this season. I fail to see how allowing an even greater supply of potatoes access to our fresh market will be beneficial to fresh growers. I think it will severely harm those growers who grow solely for the fresh market.
I spoke with one of our largest customers about this proposal. His feedback was that it would further reduce Idaho’s standing in the fresh industry. No other states require variety labeling. Customers have no idea what the variety is that they’re buying. Foodservice accounts overwhelmingly prefer Idaho. The labeling requirement is a big reason why. This customer was very much against removing the labeling requirement.
I am strongly against removing the labeling requirement Sam. I realize that I am just one of many voices. Hopefully the majority agree with me. The labeling requirement has both protected and elevated the Idaho Fresh Industry for decades. It would be a self-inflicted wound to remove it.
Sincerely,
Ryan Wahlen
Sam,
I am against changing the existing rule. I feel that labeling all russets an Idaho Russet, reduces the quality of the brand. I am a proponent of the Burbanks versatility and uniqueness in the russet category and lumping it together with a norkotah or perhaps a processing variety, only weakens this view amongst our consumers. Thank you.
Nick Blanksma
Travis - I went to the meeting yesterday that the IPC hosted to discuss labeling requirements. Below are my comments.
- As it relates to labeling for all non-russett varieties, based on the comments at the Idaho Falls meeting, there is no real need to change the rule right now because technology has caught up to the demand of labeling for the specific varieties. Before it was an issue because the bags and ties were all pre-printed. Now, the industry has changed to the point that it is a blank bag or tie that is printed while everything is running which eliminates the stocking and manpower issues that were raised a few years ago.
- As it relates to labeling for all russett varieties, there should not be a change in the labeling requirements because growers and shippers would like to protect the burbank and norkotah variety. I believe that the common sentiment was that if a new variety is going to come into play, then it will have to come through organically, similar to the norkotah. Growers and sales desks will have to slowly introduce it to the buyers and they will have to allow the buyers the opportunity to try it out themselves. In addition, we don't want to hurt the Idaho brand by packing a sub-par russett.
- Also, it would be prudent for the IPC to conduct a survey to buyers and see what they do and don't like about Idaho potatoes and if a change in labeling requirements would be beneficial or detrimental to them.
In conclusion, my comments are that there should not be any changes to the labeling requirements for varieties and russet potatoes and that the IPC should survey the buyers to see what they want.
Thanks,
Mike Huskinson
Sam, I’m a no vote on the Russet proposal of Idaho Russet labeling.
I’m a yes vote on the colored variety labeling .
Thank you
Eric Wahlen
To the Commissioners of the Idaho Potato Commission,
I am writing in response to the petition that was brought before the IPC to discontinue the
labeling of varieties of potatoes in Idaho. I attended both meetings that were held to discuss this
topic and the meetings held a few years ago on the same subject. I come to you with 26 years
of experience sitting on the sales desk selling Idaho Potatoes. Below are the advantages and
disadvantages that I have heard at the meeting and that I feel need to be expressed.
Advantages:
1: Not labeling varieties allows grower/shippers to move product between the fry, process, and
fresh market to take advantage of whichever market is the highest without concern for what they
are delivering to their customers or damage they are doing to the sector of the industry they are
moving product into.
2: It will allow the grower/shipper to mix varieties in the pack to meet the size requirement of the
most profitable markets with no concern of how this will affect the customer, the reputation of
Idaho or the overall market price.
Disadvantages:
1: Idaho has spent years and tens of millions building trust in the Idaho seal. Why would we
want to dissolve that trust by confusing our customers and not letting them know what they are
buying.
2: No other state labels varieties. Why would we want Idaho to be like everyone else and be
generic.
3: Idaho does not give the consumer enough credit. They know varieties and what they are
good for. Why do you think Washington labels apple varieties.
4: Other states will take advantage of our non-labeling and market the fact that Idaho does not
label varieties anymore because they have changed their potatoes.
5: Idaho is the foodservice king. Foodservice want to know what variety they are getting. If start
shipping different varieties to them on a consistent basis, they will learn not to trust Idaho.
6: This is a self-serving attempt from a small amount of the shipping community to take
advantage of markets and potentially destroy the Idaho reputation.
7: it was stated in the meetings that some varieties are not well accepted and receivers ask not
to ship them that variety. With out variety labeling, the trust that receivers are getting what they
want will be taken away.
8: There will be a large temptation to mix varieties in the same box or bag. That would be very
detrimental to the shipper and Idaho.
I highly recommend the IPC not remove the Variety Labeling requirement that has helped build
the states great reputation.
Thank you,
Ryan Bybee
As a participant in Idaho’s potato industry—grower, packer, or both— I support removing mandatory Idaho potato varietal labeling requirements to provide greater flexibility in marketing Idaho-grown potatoes.
This issue has been discussed within the industry for several years as new potato varieties continue to be developed for fresh, processing, and foodservice markets. Updating Idaho’s labeling requirements would provide greater flexibility for growers and packers while continuing to support the strength of the Idaho potato brand.
I support:
Simplifying fresh-pack russet labeling under a unified “Idaho Russet” designation by removing mandatory varietal labels such as Russet Burbank and Russet Norkotah. Removing mandatory varietal labeling requirements for red, yellow, and other specialty Idaho varieties. Allowing an optional sub-designation of “Idaho Russet Burbank” to accommodate specific market preferences.
Signatories:
- Tanner
- Brian Hansen
- Corey Griwsold
- Craig Swensen
- Derek Jentzsch
- Duane Grant
- Kenneth Koompin
- Kent Hansen
- Mike Larsen
- Mike Telford
- Nate McBride
- Paul Duncan
- Stephen Hurst
- Taylor Duncan
- Taylor Grant
Additional Comments or Questions:
Contact:Sam Eaton
VP Legal & Government Affairs
Idaho Potato Commission
208.859.7836
[email protected]
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