But the Natural Choice line was made of the exact same meat used in Hormel\u2019s standard products<\/strong>, like Spam, misleading consumers into thinking their purchases benefited their health, the environment, and animal welfare more than buying other Hormel brands might. So in 2016, we sued. FarmSTAND (formerly the Food Project at Public Justice) brought suit<\/a> with the Animal Legal Defense Fund<\/a> (ALDF) in a Washington, D.C. court contending Hormel\u2019s \u201cnatural\u201d advertising was false and misleading. ALDF, Tracy Rezvani, and the Richman Law Group also acted as counsel in the case. Over the course of the lawsuit, a Hormel official confirmed that when people purchase Natural Choice products, they\u2019re getting animal products that are no different than those that make up other product lines (Exhibit 207<\/a>). <\/p>\n\n\n\n Consumers want to shop in ways that align with their values, but the lack of transparency in labeling and advertising poses a major barrier to doing so. This deep dive introduces revelations\u2014many in Hormel\u2019s own words\u2014about the severity of Hormel\u2019s factory-farm practices and the extent to which Hormel sought to deceive and take advantage of customers in marketing its line. This lawsuit\u2019s discovery process shined a spotlight on previously inaccessible materials that paint a damning picture of industrial meat products like Hormel\u2019s and the branding used to sell them<\/strong>. What follows are key insights about Hormel that showcase these materials, which offer entryways to take on the food industry at large through suits, organizing campaigns, and investigations. <\/p>\n\n\n\n \u201cThere\u2019s no segregation specifically done for Natural Choice Products.\u201d<\/p>\nDeposition of Cory Bollum, Hormel, Exhibit 208<\/em><\/a><\/cite><\/blockquote>\n\n\n\n When you see\u00a0the word \u201cnatural\u201d on a label, the food industry knows the assumptions you make about the food you buy. But that doesn\u2019t guarantee what\u00a0you\u2019re\u00a0buying meets those expectations.\u00a0According to former Natural Choice Brand Manager, Jeremy Zavoral, consumers who see a product with a \u2018natural\u2019 claim \u201cassume that there are other benefits to the product\u201d (Exhibit 218<\/a>).\u00a0Research shows that most consumers who heavily buy \u2018natural\u2019 labeled products believe that \u201cnatural\u201d means that animals raised for food are humanely raised, grown free range, given no added growth hormones, and antibiotic-free<\/strong>\u00a0(Exhibit 51<\/a>). The crux of the suit was that Hormel\u2019s ads \u201ctend to mislead because the animals are born, raised, and killed in unnatural, unsafe, and cruel conditions,\u201d conditions which \u201cdo not comport with reasonable consumers\u2019 perceptions of \u2018natural\u2019 meat.\u201d A fuller accounting of the discrepancy between the Natural Choice campaign and the realities of Hormel\u2019s practices the case sought to prove are outlined in the\u00a0complaint<\/a>.<\/p>\n\n\n\n It is not surprising that corporations invest in consumer behavior and market analysis research to better hawk their products. Entire industries and academic disciplines exist to understand how to prime consumer demand and exploit the beliefs of would-be customers to compel them to purchase one product over another, or a product they wouldn\u2019t otherwise buy.<\/p>\n\n\n\n What is surprising is the extent to which U.S. Department of Agriculture (USDA) regulations allow Hormel and companies like it to create confusion and misunderstandings that lead consumers to believe their products have qualities they do not<\/strong>. Looking at the company\u2019s own documents, Hormel\u2019s Natural Choice product line is tailor-made to take advantage of the popularity and interest in \u201c\u2018Natural\/Green\/Healthy\/Organic\u2019 options\u201d (Exhibit 5<\/a>) by exploiting lax regulations surrounding the term \u201cnatural\u201d to offer a product that was less expensive than one actually raised in \u201cnatural\u201d settings \u2013 like free range versus factory farm conditions \u2013 and possessing the qualities consumers expect a \u201cnatural\u201d product to have (Exhibit 51<\/a>). In response to consumer feedback that nearly 95 percent of consumers wanted natural products accessible during regular shopping trips (Exhibit 1<\/a>), Hormel put resources into changing their branding to green rather than brown, to communicate \u201cnatural\u201d more (Exhibit 212<\/a>). The following sections reveal that Hormel did not put similar resources into putting practices into place to produce food that consumers would reasonably consider to be more natural. <\/p>\n\n\n\n A: We had a brown version and we went with the green because it went better \u2014 it was seen as fitting more with the brand. The deceptive use of the term \u201cnatural\u201d is not unique to Hormel<\/strong>. In fact, Natural Choice advertising was put on a pedestal in a trade association slideshow as exemplary of the direction in which the entire industry might go. A meat industry slideshow produced by SPINS, a marketing company that specializes in promoting natural products, coined this \u201cpremium-tizing conventional brands,\u201d in which otherwise unremarkable products are labeled in ways that combine trendy concepts (like \u201cgourmet\u201d or \u201cartisanal\u201d) with \u201cclean labeling terminology\u201d to appeal to \u201cthe natural meat customer,\u201d including consumers who specifically want organic foods as well as people who want to eat healthier (Exhibit 37<\/a>).<\/p>\n<\/div>\n\n\n\n The same slide deck plainly says, \u201cthe term \u2018natural\u2019 is practically unregulated and can\/will be used widely\u201d<\/strong> (Exhibit 37<\/span><\/a>). Yet another industry presentation from the Natural Marketing Institute found that \u201cthe high degree of consumer confusion is evident across many perceptions, including one in three who do not see a difference between \u2018Natural\u2019 and \u2018Organic\u2019 and government regulation for these labels\u201d (Exhibit 51<\/span><\/a>). This is especially problematic given that \u201corganic\u201d is a production certification<\/a><\/span> that is regulated by the government and requires businesses to adopt specific practices and undergo inspections to verify the use of those practices.<\/p>\n\n\n\n An internal media guidance document for the rollout of the Natural Choice rebrand spells out the key messages Hormel developed to imply certain characteristics of Natural Choice lunchmeat. Media guidance documents often prepare employees to provide canned answers to frequently asked questions, including ways to address or sidestep controversial issues. In the guidance provided on the topic of \u201cAnimal Care,\u201d Hormel has \u201ca zero-tolerance policy for inhumane treatment of animals,\u201d for example, with no further explanation. The guidance also spells out ways to pivot from questions like \u201cThe campaign emphasizes no preservatives; however, many of the Hormel Foods brands do contain preservatives. What would your response be to questioning consumers?\u201d without addressing whether Natural Choice products contain preservatives (Exhibit 1<\/a>).<\/p>\n<\/div>\n<\/div>\n\n\n\n Hormel\u2019s apparent commitment to training employees to be opaque about Natural Choice products highlights the active role corporations play in creating consumer confusion and exploiting genuine interest in values-based purchasing.<\/strong> Furthermore, the documents uncovered during this lawsuit illustrate the deception of Hormel\u2019s messaging, offering fuller answers to the questions that might appear in a media guidance document. <\/p>\n<\/div>\n\n\n\n The <\/span>way animals were raised for Hormel\u2019s products is<\/span> shocking<\/span><\/span>, even putting aside questions about the use and misuse of the term \u201cnatural.\u201d Because the animals and production practices used in the Natural Choice line were virtually the same as Hormel\u2019s other products \u2013 like canned chili or Spam \u2013 internal documents we uncovered during the lawsuit demonstrate both the deceit of Natural Choice advertising as well as the more general offenses of Hormel suppliers\u2019 meat production.<\/p>\n\n\n\n For example, we discovered that Hormel had food safety violations related to conditions that were anything but what could reasonably be considered natural. Violations included, but were not limited to, contamination of carcasses with \u201cfecal material, ingesta, and milk\u201d (coded \u201cFS-2\u201d by FSIS<\/a>), failure to address bruises, sores, and other unsightly wounds and infections (coded \u201cOCP-3\u201d<\/a>), and failure to wash and sterilize equipment (Exhibit 96<\/a>). <\/p>\n<\/div>\n<\/div>\n\n\n\n Read together, these documents reveal a pattern of violations that pose threats to consumer health and to workers in these plants<\/a>. The following sampling from noncompliance reports uncovered during the lawsuit shows feces on carcasses on their way to being processed into Hormel products. <\/p>\n\n\n\n Each noncompliance report that FarmSTAND uncovered for one facility ends in a similar way and shows how ineffective Hormel was at addressing the presence of fecal matter on the meat<\/strong>. \u201cThe establishment\u2019s preventative measures for controlling fecal material from entering the chiller have not been effective or have not been implemented\u201d (Exhibit 102<\/a>). One month later at the same plant: \u201cThe establishment is not preventing fecal material from entering the chiller\u201d (Exhibit 99<\/a>). Five months later at the same plant: \u201cThe establishment management is not preventing carcasses with fecal material from entering the chiller\u201d (Exhibit 100<\/a>).<\/p>\n\n\n\n As a part of this lawsuit, FarmSTAND collected sworn testimony from Hormel employees to reveal contradictions in the company\u2019s claims to naturalness. In one deposition, Hormel Director of Procurement Cory Bollum confirmed Hormel does not require suppliers to phase out inhumane housing methods or to provide pigs with access to the outdoors or pasture (Exhibit 208<\/a>). An instruction manual for Jennie-O, a Hormel-owned brand, revealed that animal growers were required to stimulate \u201cunnatural\u201d conditions, like forcing turkey hens to live in 24 hours of light a day so they eat more<\/a> and grow faster (Exhibit 142<\/a>). Another Jennie-O slide deck explained how turkeys are raised in \u201call confinement,\u201d as opposed to a free-range setting that consumers are likely to associate with products labeled \u201cnatural\u201d (Exhibit 143<\/a>).<\/p>\n\n\n\n Beyond baseline conditions,\u00a0more acute mistreatment of animals by Hormel and its suppliers\u00a0separated their meat from what most consumers would believe to be natural.\u00a0<\/strong>Examples abound. In one instance, a line stop at a processing plant caused\u00a0150 chickens to suffocate to death<\/a>\u00a0(Exhibit 211<\/a>). And their pregnant and nursing sows are confined in particularly cruel ways. Pregnant sows are confined in tight barred metal stalls called \u201cgestation crates,\u201d which were barely larger than the animal and \u201crestrict \u2018normal\u2019 behavioral expression\u201d (Exhibit 147<\/a>). Once the sows give birth, they could be then forced onto their sides unable to move naturally in barred metal crates called farrowing crates (Exhibit 207<\/a>).<\/p>\n\n\n\n FarmSTAND also uncovered slaughter and surgical practices used on animals in their Natural Choice line. Hormel\u2019s suppliers used manual blunt force trauma \u2013 a deadly blow with a dull object to the head \u2013 to euthanize their suckling pigs (Exhibit 208<\/a>), and chickens were crushed to death as a form of euthanasia (Exhibit 211<\/a>). When asked whether pork used in Natural Choice products could have been sourced from piglets who received no anesthesia when they were castrated and had their tails docked \u2013 cut off supposedly to keep pigs from biting each other\u2019s tails \u2013 a Hormel representative answered that \u201csince that\u2019s a common industry practice, yes\u201d (Exhibit 207<\/a>). <\/p>\n<\/div>\n\n\n\n If you are interested in learning more beyond this litigation, ALDF conducted an undercover investigation of a pig supplier it identified as providing animals to Hormel and you can see coverage of that footage\u00a0at the link below.<\/p>\n\n\n\n In a Natural Marketing Institute slide deck presenting an industry study on consumer beliefs about what \u2018natural\u2019 means, 86 percent of the general population surveyed believed natural foods should have no added growth hormones, and 72 percent believed they would be antibiotics free (Exhibit 51<\/a>).<\/p>\n\n\n\n But documents FarmSTAND obtained from Hormel suggest a wide gap between consumer expectations about the use of potentially harmful chemicals and antibiotics in \u201cnatural\u201d food versus how Natural Choice meat is actually produced<\/strong>. Pigs that became Natural Choice products were not tested for ractopamine, a drug that promotes muscle growth and is associated with broken limbs and a complete inability to walk<\/a> \u2013 and was banned in 160 countries<\/a> as of 2014 (Exhibit 208<\/a>). For the purposes of sanitation, chicken carcasses in at least two facilities that supply Hormel were washed with either chlorine or peracetic acid before being processed (Exhibit 211<\/a>). Termin-8, a feed disinfectant that contains formaldehyde and propionic acid and is used for its antimicrobial properties, was incorporated into feed for turkeys destined for Natural Choice products (Exhibit 213<\/a>). A letter authorizing export of meat to Russia confirmed the allowable use of growth-stimulating antibiotics \u2013 bambermycin and\/or virginiamycin \u2013 in Hormel products (Exhibit 138<\/a>). Guidance material for Jennie-O turkey producers, a subsidiary of Hormel Foods, showed \u201cmixing appropriate water disinfectant or medication for the flock\u201d as a daily chore, and included a picture of cramped conditions (Exhibit 142<\/a>).<\/p>\n\n\n\n A: The USDA has approved the term on our packaging and we extend the \u2014 we extend the use of the word from our packaging to the advertising. Widespread use of antibiotics in raising food animals, standard among Hormel Natural Choice suppliers and across the industry (Exhibit 208<\/a>), \u201ccontributes to the emergence of drug-resistant bacteria\u201d and poses real risks to public health<\/a>. Unsealed documents reveal positive tests for foodborne illness-causing pathogens among products, like Salmonella (Exhibit 86<\/a>, Exhibit 87<\/a>, Exhibit 88<\/a>, Exhibit 111<\/a>, Exhibit 112<\/a>, Exhibit 213<\/a>).<\/p>\n\n\n\n The documents also point to various loopholes that the industry uses to comply with the letter but not the spirit of the law. One such loophole has to do with the use of celery powder as a preservative that, only after it is added, produces nitrates that then extend the shelf-life of a product. Companies can claim such products have \u201cno added nitrate or nitrite, except for those naturally occurring,\u201d<\/a><\/span> although according to scientists and advocacy groups, there is no evidence that using processed celery ingredients is healthier<\/a><\/span> than other added nitrites. While Hormel claims they use celery juice or powder to get \u201cthat cured color and cultured flavor,\u201d (Exhibit 209<\/span><\/a>), one of their own documents says it \u201cgives a loophole in the naming of ham\u201d (Exhibit 116<\/span><\/a>).<\/p>\n<\/div>\n<\/div>\n\n\n\n This loophole does not just allow the company to skirt a regulation; it allows one more way to mislead consumers, as Hormel\u2019s own Consumer Insights Supervisor stated that many \u201cconsumers think [natural] means that there\u2019s no preservatives in it\u201d (Exhibit 212<\/a>). (FarmSTAND and the Animal Legal Defense Fund submitted a regulatory comment<\/a> to the FDA challenging that loophole.) <\/p>\n\n\n\n To sum up, the practices used to create Hormel\u2019s Natural Choice line of products do not represent the types of practices a consumer might expect from its \u201cnatural\u201d branding<\/strong>. While one might expect Natural Choice products are the result of safer and more humane practices, a Hormel official confirmed that it \u201cwould be true\u201d that there\u2019s no separate manner in which the pigs raised for Hormel Natural Choice are raised versus any of the other Hormel-branded products. (Exhibit 207<\/a>).<\/p>\n<\/div>\n\n\n\n Hormel exploits both the government\u2019s failure to comprehensively regulate use of the term \u201cnatural\u201d in advertising, and rising consumer interest in organic foods (Exhibit 51<\/a>) to generate consumer confusion. In so doing, Hormel brands meat raised with low-quality production methods that don\u2019t meet consumer expectations of what \u201cnatural\u201d means, and sells those products at highly competitive prices. This undercuts producers and companies who are using animal rearing and processing methods that actually meet these consumer expectations who may charge a premium to cover the costs associated with those practices. <\/p>\n\n\n\n For example, a manager of the Natural Choice brand informed multiple senior members of Hormel\u2019s marketing staff that \u201c[c]onsumers assume natural meat is antibiotic free,\u201d even though the exhibits examined above illustrate how antibiotics and other growth-promoting additives were a standard feature of Hormel suppliers\u2019 growing practices (RSUMF<\/a>, para. 84). This deception, and the practices masked by it, reveal a pressing need for reforms that make food systems more transparent in ways that can bolster animal welfare, worker safety, human health, and environmental sustainability. <\/p>\n\n\n\n The uncovered documents also challenge whether<\/strong> existing regulatory frameworks for food safety can or will be effective in grappling with the scope of Hormel\u2019s harms<\/strong>. While a consumer might reasonably expect regulatory agencies like the USDA to confront the problems posed by Hormel, oftentimes its programming perpetuates those same harms.<\/p>\n\n\n\n The Hazard Analysis and Critical Control Points-based Inspection Models Program (HIMP) is a case in point \u2013 a \u201cfood safety program\u201d that sped up line speeds and served to increase processing of pigs for pork. In Hormel\u2019s view, \u201cThe HIMP program is designed to allow the USDA inspectors better perspective and more flexibility to monitor activity and identify any issues. In addition to the USDA inspectors at the facility, there are employees trained to the standards of the UDSA conducting the additional inspections\u201d (Exhibit 109<\/a>).<\/p>\n<\/div>\n\n\n\n The Hazard Analysis and Critical Control Points-based Inspection Models Program (HIMP) is a case in point \u2013 a \u201cfood safety program\u201d that sped up line speeds and served to increase processing of pigs for pork. In Hormel\u2019s view, \u201cThe HIMP program is designed to allow the USDA inspectors better perspective and more flexibility to monitor activity and identify any issues. In addition to the USDA inspectors at the facility, there are employees trained to the standards of the UDSA conducting the additional inspections\u201d (Exhibit 109<\/span><\/a>).<\/p>\n\n\n\n While corporate actors like Hormel claim that the HIMP program gave \u201cmore oversight, not less,\u201d food safety advocates including federal meat inspector whistleblowers have argued that the program poses real risks to public health<\/a> and is \u201cUSDA\u2019s way of catering to the industry instead of the consumer.\u201d<\/strong> Despite this, HIMP was the basis for the USDA\u2019s New Swine Inspection System (NSIS), which has received similar flack. The line speed increases authorized under NSIS were then struck down by a court, but USDA is still authorizing plants to operate at increased speed. (Public Justice represented members of Congress who detailed their qualms with NSIS in an amicus brief<\/a>.)<\/p>\n\n\n\n Q: And nothing in your contract actually requires lifecycle auditing from cow-calf through slaughter? FarmSTAND and ALDF\u2019s suit showcases the need for consumers to have transparent and accurate information about where their food comes from and how it is made so they can opt for products genuinely developed in line with their values regarding human health and safety, animal welfare, and environmental impact. It also makes clear the limitations of consumer awareness as a driver for change when companies are permitted to use advertising to create confusion and manipulate customers into believing their products are something they are not.<\/p>\n\n\n\n Lastly, it underscores the importance of holding corporations accountable for their active exploitation of the regulatory gaps that perpetuate harm to humans, animals, and the environment at a massive scale. Litigation is one tool among many that can be used in service of and in solidarity with frontline communities who are transforming the food system. We hope that materials revealed through discovery offer important data for further efforts to increase transparency and accountability in the food system.<\/p>\n\n\n\n\n
![\"\"](\"https:\/\/farmstand.org\/wp-content\/uploads\/2022\/11\/Green-Pig-Transparent-771x1024.png\"){kind=spacer}
<\/figure>\n\n\n\nThe extent to which Hormel researched, analyzed, and exploited consumer perception was more manipulative than previously understood.<\/h4>\n\n\n\n
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Q: So communicating natural more?
A: Communicating Natural Choice more, yes.<\/p>\nDeposition of Karen Kraft, Hormel Foods, discussing label and advertisement presentation, Exhibit 212<\/a><\/em><\/cite><\/blockquote>\n\n\n\n![\"A](\"https:\/\/farmstand.org\/wp-content\/uploads\/2026\/08\/exhibit-37-edited.png\")
![\"A](\"https:\/\/farmstand.org\/wp-content\/uploads\/2026\/08\/exhibit-51-edited.png\")
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<\/figure>\n<\/div>\n<\/div>\n\n\n\nThe animal agriculture practices throughout Hormel\u2019s supply chain and their effects on animals and workers \u2013 in Hormel\u2019s own words \u2013 are grislier than previously understood.<\/h4>\n\n\n\n
Hormel had food safety violations related to conditions that were anything but what could reasonably be considered natural.<\/h3>\n<\/div>\n\n\n\n
![\"\"](\"https:\/\/farmstand.org\/wp-content\/uploads\/2022\/11\/exhibit-102-edited-1024x454.png\")
![\"\"](\"https:\/\/farmstand.org\/wp-content\/uploads\/2022\/11\/exhibit-99-edited-1024x357_v2.png\")
![\"A](\"https:\/\/farmstand.org\/wp-content\/uploads\/2026\/08\/exhibit-100-edited.png\")
![\"\"](\"https:\/\/farmstand.org\/wp-content\/uploads\/2022\/11\/exhibit-142-edited-1024x706.png\")
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<\/figure>\n<\/div>\n<\/div>\n\n\n\nThe lack of regulation in advertising \u2013 coupled with regulatory loopholes \u2013 create false consumer expectations regarding chemical and additive use in \u201cnatural\u201d foods.<\/h4>\n\n\n\n
\n
Q: Why choose to advertise the products in that way?
A: We advertise it with \u201cnatural\u201d because we believe that\u2019s what consumers are looking for\u2026 we found that \u201cnatural\u201d is a way to differentiate our products versus some of our competitors, so it stands out.<\/p>\nRule 30(b)(6) Deposition of Jeremy Zavoral, speaking as Hormel Foods, Exhibit 217<\/a><\/em><\/cite><\/blockquote>\n\n\n\n![\"An](\"https:\/\/farmstand.org\/wp-content\/uploads\/2026\/08\/exhibit-116-edited.png\")
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<\/figure>\n<\/div>\n<\/div>\n\n\n\nThese business-as-usual practices\u2014the factory farming and the lying about it\u2014raise serious concerns about traceability and transparency.<\/h4>\n\n\n\n
![\"Proceedings](\"https:\/\/farmstand.org\/wp-content\/uploads\/2026\/08\/exhibit-96-edited.png\")
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A: Correct.<\/p>\nRule 30(b)(6) Deposition of John Hilgers, speaking as Hormel Foods, Exhibit 211<\/a><\/em><\/cite><\/blockquote>\n\n\n\n