Farm Legal Series #7: Navigating Requirements and Regulations with Farm Subscriptions

 
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Welcome to the seventh episode in Barn2Door's series in partnership with the Farm to Consumer Legal Defense Fund. FTCLDF is a non-profit organization of lawyers supporting Farmers across the country and helping them navigate the unique legal challenges Farmers face.

In this episode, we focus on the legalaties of CSAs, herd share subscriptions, and meeting local requirements and regulations involved in selling food on a recurring basis.

farmtoconsumer.org
barn2door.com/resources

 
 
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    James Maiocco: Hey, welcome to the Direct Farm Podcast. We've got a great conversation for you today with the Farm-to-Consumer Legal Defense Fund or FTCLDF. One of our favorite partners. The Farm-to-Consumer Legal Defense Fund is a nonprofit organization made up of lawyers, serving Farmers all across the United States by helping them protect, defend, and broaden their rights and the viability of independent Farmers, artisanal food producers and their consumers.

    This is the seventh episode in a series of podcasts that we've done with the Farm-to-Consumer Legal Defense Fund, each highlighting a different farm [00:01:00] product, and some of the legal challenges associated with it. Today, we're gonna be talking about farm food subscriptions, often refer to as CSAs or community supported agriculture and some of the legal nuances that can become associated with these subscriptions.

    I'm delighted to welcome today Alexia Kulwiec. She is the Executive Director of the Farm-to-Consumer Legal Defense Fun, and she's a licensed attorney in Illinois and Wisconsin, having practiced law for over 20 years. Her experience has inspired her interest in US agriculture, promoting small scale Farmers and sustainable farming, and protecting the rights of independent Farm producers all across America.

    Welcome Alexia. It's great to see you again.

    Alexia Kulwiec: Hi James, thanks so much for having me back again, pleased to be here.

    James Maiocco: We're delighted. We hear nothing but great feedback from our Farmers who get a chance to work with you. For those who are new, who've not heard of the Farm-to-Consumer Legal Defense Fund, could you give a quick overview of what you do and what the organization does?

    Alexia Kulwiec: Of course, thank you. [00:02:00] So Farm-to-Consumer Legal Defense Fund is a membership based nonprofit organization. We provide legal representation to our members mostly concerning policies and regulations that make it difficult for small, independent Farm or food producer to be economically sustainable.

    So helping through the regulatory process and working on policy that we hope might support smaller, independent Farms, as opposed to large agricultural operations. A lot of times the regulations really are not intended for smaller players, and we know consumers want this local, these local goods.

    So trying to even the playing field for our small, independent Farms.

    James Maiocco: You guys do great work. And like I said, we hear nothing about positive feedback from our members who are working with you today. And for those of you who are Farmers, I encourage you to listen to many of the podcasts in this series. You'll find a lot of great information and advice in terms of how you might be able to operate your business and perhaps give you better clarity on how you can, again, meet [00:03:00] the local requirements while also servicing your local community.

    Today we're gonna be diving into some contract areas, interestingly enough, dealing with Farm food subscriptions. Subscriptions today are probably one of the most widely used features on Barn2Door. In fact, more than 40% of all sales on Barn2Door this past month were subscriptions to food products.

    So subscriptions generally, many farmers might know them as a CSA. Community supported agriculture, CSAs. So just first off, when you think about subscriptions Alexia, what are some of the big legal factors you might be aware of when selling food on a recurring basis?

    Alexia Kulwiec: Sure. One of the things I think about is, when a Farmer sets this up as a subscription service, it will be a matter of contract and how that contract is set up, I think is really important. So what exactly is the consumer purchasing, right? Is it a share in a particular production of a product?

    Is it a guarantee that they'll get [00:04:00] products every week? Or are they literally purchasing, say a percentage of a crop yield or in the case of dairy, right? Milk production, that kind of thing. So I think that exactly what's being promised and guaranteed and the language of that contract, it can just be vital.

    James Maiocco: This is really critical. Cuz some Farms, some states, maybe you can elaborate more on this. Some states actually require you by law to have to enter into a herd share agreement effectively, right? Where it is not technically a subscription, but you are entering into agreement for the yield of whatever is being produced, correct?

    Alexia Kulwiec: Yeah. And so that's for dairy. And if you want to sell, for example, raw milk, some states will forbid the sales, but permit herd share arrangements, and then they'll specify terms. And one thing that's I think, when I hear subscription or community supported agriculture, usually it's a shorter timeframe.

    So you're talking like the seasonal yield and you're purchasing some share and the seasonal yield that the Farmer [00:05:00] might be growing. And with dairy, you're actually purchasing a share in the herd or an animal itself. And so while you're entitled to product, it's not like an ending subscription at the end of a season, you're actually owning a share in something which is in fact slightly different than a subscription because now you have that share period.

    James Maiocco: In perpetuity. That's, I actually think that's great. We actually support both those models with what we call seasonal subscriptions. Like you said, which might be for CSA for a particular growing period of the year or what we call Ongoing Subscriptions, where you're making a commitment to purchase and to receive ongoing products from that Farmer as the yield is produced.

    So now you did mention raw milk, great example. Some Farm products like raw milk are regulated, others are unregulated. So let's start with an unregulated product, like vegetables in a state that doesn't have any specific controls or requirements. Let's talk about maybe some of the issues that can surface.

    So even if you're selling an unregulated product like vegetables, right? [00:06:00] What could come to mind in terms of the types of customers you're selling to, for instance, retail versus wholesale. I would presume that consumers are probably generally less of a concern, whereas wholesale might involve some legal ramifications dealing with like traceability or those types of things.

    Cause I know we've had E. Coli scares for some vegetables, those types of things.

    Alexia Kulwiec: So, first I would say when we say they're unregulated, of course, and depending on the size of the farm's production will be regulated, but you're talking about sales on a subscription basis so there's no specific requirements for how that's going to be done. And I would say yes, I think that the issues that can arise with a consumer again are just specific in terms of what exactly you are contracting for.

    I know when I first became aware of community supported agriculture, my understanding was you were sharing the risk, right? So you were entering as a consumer into a contract. And if the tomatoes are great that year, you're gonna get great tomatoes. But if the crop fails, you've lost some money [00:07:00] because you're sharing the risk in that, with that producer. I feel, or at least I've heard, my understanding is that's a little bit less common today and that more CSA agreements are just like a subscription and they're guaranteeing some kind of yield to the consumers today.

    So I think what the nature of that contract is really vital. And then I think the Farmer may still have some concerns in terms of, can they engage in commercial sales or pickups, in which case they may need an additional license, they may need some kind of general liability sort of insurance.

    But otherwise I think I'm not sure you talked about general grocery stores and retail. Yeah. You're gonna need something in terms of traceability, right?

    James Maiocco: Yeah. For wholesale, I know many Farms who have wholesale products or selling through wholesale markets, oftentimes have traceability concerns, right? Particularly in the event of like an E. Coli outbreak, that type of thing. Being able to identify where it came from.

    Alexia Kulwiec: Right.

    James Maiocco: Even if their product itself vegetables, generally, may not be regulated for direct to consumer purchases.

    [00:08:00] You did bring up delivery and pickup, which is weaves into my next topic related to these types of subscriptions. Cuz like you said, many times people are signing up for a subscription to a vegetable box, let's say a produce box. And oftentimes it's for a pickup like a, you know, a local neighborhood school or church or something like that.

    And there could be a couple different things where one is, there might be a delivery fee. There could be some taxation associated on the delivery fee. So even if there's not tax on the products themselves, maybe tax on delivery. Have you seen some of these issues come up before?

    Alexia Kulwiec: You know, what I have seen is in some states, if you're doing direct-to-consumer, you may have regulations in place that require customers to come to the Farm for pickup and you may even have regulatory problems with doing deliveries. I certainly am aware that if the Farm and when I say that, I mean, a Farm employee, is delivering product, then yes that there could in [00:09:00] fact be an obligation on that producer to gather sales tax for the service fee, which is usually not going to be required for the raw agricultural product.

    Another thing that I have come across that I think is interesting is that if you have a Farm employee delivering Farm products, that is no longer agricultural work.

    And so what that means is then the Farm is no longer exempt from the different employment laws, and you might have to worry about wage and hour concerns, workers' compensation concerns, and some kind of liability concerns. So that's one thing I've certainly come across. And then when it comes to some of the work we do like with herd shares, even if it's legal to own part of that herd and to obtain part of that product, there may be further regulation or interpretation by the agency about whether it can be delivered or where you can pick it up.

    And we will often work with people on a contractual basis and help Farms draft a special delivery agreement along with the product that's separate and apart from, say, just [00:10:00] obtaining product, but it's an added service under a delivery agreement.

    James Maiocco: Wow. So let's break this down cuz while it sounds simple, Hey, I signed up for a box to have it just delivered to my local school or church to pick it up. We now have gone from being in the line of Farming in agriculture work, non-taxable unregulated product. You're totally fine selling direct-to-consumer, provided the consumer comes and picks it up on your Farm, to depending on the state you're in.

    The activity of the delivery is what you said could be considered non-farm work. Now, all of a sudden, like you said, subject to all kinds of wage and hour laws. Subject to different employee compensation obligations as well. Cause I know many states have different minimum wage requirements for ag workers versus non-ag workers.

    They may even have different time tracking obligations for those workers. Wow. It's it sounds simple, right? Just say, Hey, sign up for our product, have it delivered. But wow, the nuances here can get pretty sticky. I know Colorado just implemented, literally mid-year beginning in July, [00:11:00] is separate 27 cents tax for every delivery in the state of Colorado.

    Very complicated. It's hard for Farmers to think about how to even keep up with all these things.

    Alexia Kulwiec: There was one other thing I was thinking about, and maybe this is cuz I was just working on some agritourism issues, but the other thing that comes to my mind is the Farmer's income themselves, their own income, tax returns change if they're operating some kind of a business that's not agricultural.

    So not only do you need to maybe collect the sales tax, but when you as the producer are doing your own income taxes, you may now have some business profit and loss that's separate and apart from Farm income. So that's also something to think about.

    James Maiocco: All right. I'm gonna make a quick plug here for you Alexia, because this is just a great example where I would strongly suggest while Alexia and I are both attorneys and we don't represent you listeners who are reaching out, you can get legal representation from the Farm-to-Consumer Legal Defense Fund by simply going to [00:12:00] farmtoconsumer.org.

    And you can sign up to become a member for just $125 a year, and get directed legal advice from a lawyer on that team who is licensed and barred in your state. Which is really important because the subtleties and the variations that we're discussing right now, very dramatically from a state like California, to perhaps like a state like Wisconsin or Virginia, what have you. So wide variation on all these issues, everything from delivery to wage and hour laws to taxation.

    So good point. Let's talk a little bit more about regulated products. Let's talk about perhaps like proteins or milks, right? So you mentioned earlier about some states are okay with on-farm pickup. So you can sign a herd share agreement subscription, what about packaging?

    Cause I know that many of us have been to, you know, gotten meat from a processor and it'll have this big stamp on there. It says not for resale. How does that work? What does that mean if I've got a subscription. Aren't I buying into something that's being resold to me over and over again? Help me understand that.

    Alexia Kulwiec: Yeah, [00:13:00] interesting. So if you are doing as a Farmer, if you're doing a subscription service and you want to include regular provision of meat, for example, what you've touched on is that to sell meat, the meat has to be inspected at a USDA inspection facility or a state licensed facility if it's just being sold intrastate.

    So if there's a sale involved and a subscription is a sale, it needs to come from an inspected facility. There are ways to do meat through a custom slaughter facility. That's something we help members with all the time. And that's where the stamp comes in, if it's gone to a custom slaughter facility instead of a federal or state facility, that means that the consumer, the owner of the animal, is the only one that can consume those products. Well they're families but that they can't resell it. A producer can't just use custom slaughter in a subscription series and provide meat. They're really better off to use a USDA facility for that.

    James Maiocco: So not crossing any [00:14:00] borders, staying within your state. Okay, good.

    So let's, this touches on the other topic I wanted to hit on, which was this notion of mixed bundles then, right? Cause just like you said, many times we'll see a producer who is, hey, they've got a great group of buyers who regularly buy their produce and their vegetables from them.

    And they've got, maybe they've got a hundred, maybe 200 members to their CSA and like, hey, I've got a captive audience. I've got a great group of people. I've got a neighbor whose got, processing 10 head of cattle every month. And guess what, you know, it'd be really easy for me just to tack that on as an add on sale, right?

    Or maybe it's a value added product, like jam or something else. Like how should the Farmer be thinking about this, all of a sudden taking an unregulate unregulated product for sale to consumers and all of a sudden, perhaps mixing in some of these other products?

    Alexia Kulwiec: Yeah, it gets tricky depending on what you're talking about. So first and foremost, a lot of times if the producer is going to be selling things that are [00:15:00] in addition to what they have grown themselves, then the regulations will be different. And what I mean by that is if you are selling, for example, meat from your neighbor first and foremost, you can only do that if it's been inspected.

    And second of all, you may need a food establishment license. For example, you may need to make sure that you're in a retail establishment zoned area and get appropriate permits because a lot of the exemptions are ways that Farms can sell directly to consumers. A lot of those rules have to do with Farmers producing their own goods and then selling their own goods.

    And so that would be a big concern of mine is, and we have this, we see a lot of Farms want to then sell neighbors items as well. And where folks run into trouble is, they didn't need a license to sell their own produce from their own Farm to their consumers. But they do if they're going to be reselling goods for someone else.

    James Maiocco: Are there some variations on that from in state this date, cuz you know I think about myself, whether I'm at my home in [00:16:00] Washington or at my place down in Tennessee, anytime I'm out and about going for a drive in the country, I'm always looking for those Farm stands. And I'm trying to think of a single time that I've been to a Farm stand where there wasn't some value added product, oftentimes honey, from some of the local Farm that's being sold as an add-on.

    So what I'm hearing from you is that the Farmers selling their own produce at their little local Farm is probably fine in many cases, but the second they add in that neighbor's honey or some other neighbor's beef, now all of a sudden it might look like they're operating, like you said, a retail establishment, is that correct?

    Alexia Kulwiec: So first off, if they're selling their own value added products such as honey, jam, et cetera, a lot of times that will still be covered under a local cottage food regulation, and they won't need additional licensing of any kind. Meaning they don't need a commercial kitchen license.

    If they're reselling from somebody else, then in many places I have seen now it's a resale, so you're considered retail or some kind of food establishment and you would need a license to be doing that.[00:17:00]

    James Maiocco: And potentially even zoning issues, correct?

    Alexia Kulwiec: Yeah, there can be zoning issues. We've certainly had cases where you may be agriculturally zoned.

    That doesn't mean that you're zoned for commercial sales and once you're reselling or selling from somebody else by local definition, they might consider it to be quote, "a commercial sale".

    James Maiocco: Wow. It just, again, subtle, but very important nuances that could really get a Farmer into some serious trouble, just when they're trying to do the right thing. They're just trying to feed the local community and maybe their neighbor's incapacitated, maybe they're elderly and they're having a health issue and they're just trying to help them sell some honey or sell some beef.

    But watch out, contact your local member, the Farm-to-Consumer Legal Defense Fund to make sure that you got your bases covered.

    All right. Well, let's talk a little bit. You mentioned the word, "intrastate" a couple times earlier, and you were very slow when you said it. Let me say that again, "intrastate". Can you explain what the word, "intrastate" means just for those who might be a little bit challenged when it comes to their own vocabulary and really help [00:18:00] them unpack also maybe some illegal issues when you sell interstate versus intrastate?

    Alexia Kulwiec: Sure. So interstate means you're crossing state lines, right? You're in more than one state, right? intrastate means you're within one state line. You're within that state and you stay within the borders of that state or in that state. So when it comes to certain sales, such as raw dairy, in some states, is allowed to have direct from the Farm sales or even in retail stores, but only if it is quote, "intrastate", or within that state. Similarly you had talked about state inspection, meat processing facilities that meat can only be sold within the state lines.

    That's essentially the difference, is that if you're going to cross state lines, federal laws are going to kick in. If it's intrastate, it's much more likely to be a state law governing exactly what's happening within that state and the producer needs to know those limitations.

    James Maiocco: So a real key understanding for [00:19:00] those people who wanna understand the legal basis of this, is that the federal government under the Constitution under the commerce clause, has the power to regulate commerce between the states. That's why we keep on talking about the term interstate. The second commerce across occurs across state lines, then immediately the federal government has jurisdiction and they can regulate your activities.

    So that's why there's oftentimes some exceptions in intrastate sales that stay within state lines where the federal government doesn't have authority or express authority.

    Alexia Kulwiec: Thank you. Correct.

    James Maiocco: Okay. Well, we're getting a lot of nuances cuz verbiage in the law is very important.

    It can be very impactful, right? So when it comes to subscriptions to Farm food, Is there any implications, in terms of thinking about the terms of a Farm product subscription versus a CSA or herd share? Is there an obligation, for instance, if I'm in a state that requires me to enter into a herd share agreement that I have to call it a herd share, or can I still call it a subscription?

    What are the things that a [00:20:00] Farmer need to think about here?

    Alexia Kulwiec: Yeah. So what I would say, I'd say a couple of things. I think first and foremost, if you're doing a subscription, I think it's really important to say it's a product subscription, right? So you're making it clear. I have heard people use the terminology Farm share, for example, I presume most of our producers don't wanna sell a share of their Farm, and so I think that kind of language matters.

    I think in terms of our dairy herd share agreements, in the states where there are specific statutes that allow it, it depends on the state. And so what I mean by that is some states specifically allow herd share agreements and they call them that.

    And I would much prefer that we label them as such to be similarly situated under that state law. Although I don't necessarily know that in all those states that it's required.

    James Maiocco: From a marketing perspective, like you could still market it's a Farm product subscription, but underneath of it, it's actually a herd share agreement.

    Alexia Kulwiec: Yeah. Although I would be careful with dairy, like I said [00:21:00] earlier. It's not, you're not just subscribing to the product, you actually have an ownership share in the herd. So somewhere along the line, that needs to be clear. And then in some states for the herd share in dairy, I'm speaking specifically to be lawful, there's very explicit requirements.

    And so in some states, you know, you have to be very clear that you're purchasing a share in the herd. You have to be clear that you're paying money for maintenance and boarding of the animals. You have to be super clear on some kind of a warning under state law about that state's opinion on the health of raw milk.

    So there may be some very specific requirements.

    James Maiocco: So again, for those of you who didn't hear the website earlier, go to farmtoconsumer.org, and you can see there that Alexia and her team have assembled some maps that will give you a little bit of an overview based on product types, where what the generalities may be state by state, and then more importantly, to get specific legal guidance and advice from one of their attorneys.

    You can simply sign up and join as a member for just [00:22:00] $125 a year, and you'll get access to somebody like Alexia on her team that can assist you with again, doing this evaluation for your jurisdiction, for your products, in specific to the language that you'd be required under your state.

    Alexia Kulwiec: Right. And all of these nuances are state law and it can get really confusing fast. And then in zoning, in some other areas, you'll have townships or municipalities or counties. So it's really important that folks take an individual approach.

    James Maiocco: Big time. Well, let's hit on the last topic related to subscriptions. One of the biggest reasons why Farmers enter into these types of arrangements is to ensure they can start building recurring revenue, right? And candidly, it's a lot easier for buyers. It's not like you and I are gonna choose to stop eating next week.

    I'm gonna continue to eat proteins, produce, and dairy. It's not going to end. It's never ending. And guess what? Farmers would love to also be able to tap into that never ending commitment in terms of cash, to help support their Farm. It's a great [00:23:00] business outcome for Farmers when they can put these subscriptions in place. But payments sometime can also take a couple different forms, right?

    It's one thing if you have a dairy where it's never ending, like you said, where, hey, I'm just making a recurring agreement to pay you every single month to be a part of this herd share. But sometimes you have people who have a seasonal or a subscription for a set period of time. We call that a seasonal subscription, might go from, you know, April through August.

    And maybe I get a box of produce every week on my doorstep, or what have you. And oftentimes Farmers will allow people to pay up front or pay as they go. So as a buyer, I obviously I might choose one or the other. Many times Farmers might give a little bit of discount if I pay up front, or if I pay as I go, and maybe a lot of people who live paycheck to paycheck, maybe that fits better with their food budget.

    Let's talk about what Farmers need to think about on that, because what happens if the Farmer's getting all this money up front and the buyer signing up to a commitment, you [00:24:00] mentioned earlier, sometimes something can happen. There could be some risk. Maybe there's a hail storm. Maybe there's Japanese beetle come through, you know, eat up all the crops.

    What's the Farmer's liability there with their buyers? Do they have to make certain disclosures? Do they have to repay people? Like how have you seen Farmers handle this before with their CSAs?

    Alexia Kulwiec: Yeah. I mean, I think if a Farmer's going to do the upfront version, which I know is often really much better for the Farmer, because they use that money to get the inputs they need to then produce the product. But something could happen, and I think that the best way to really handle that is to include language that someone is investing in a share of the crop as opposed to a dedicated guarantee of what they will receive each week.

    And I say that because a Farm's gonna use the money for their inputs and that money's gonna be gone regardless of what happens. And if they don't set it up as a share of the crop yield, for example, and then something [00:25:00] does happen and then beetle comes in and they, their crop is ruined. Could they be responsible for repaying some of that subscription paid up front?

    If you're investing in the crop, then not necessarily. You shared the risk. But if it's truly a subscription, which is more of a guarantee, what I'm getting biweekly, for example, then the producer may need to return that money if they can't deliver.

    Cause it's a regular sales contract. And if they can't fulfill their end of it, they'll have to refund that money.

    James Maiocco: Do you see Farmers taking out insurance in those types of scenarios where they could have coverage for those types of investments?

    Alexia Kulwiec: Sure. I have seen plenty of producers have Farm insurance that will provide them with resources if the crop fails. Absolutely. And they can use that money then for refunds back to the consumers.

    James Maiocco: That's not a bad idea. I know we see a lot of Farms take commitments for crops up front, even after the season's over, just because there's always such demand for many of these local producers. There's a lot of FOMO that if I don't sign up now for next season, I'm [00:26:00] not going to, I'm gonna miss out on next season, so I better sign up today.

    I know for a fact that I'm in one of those types of subscriptions where I would give my right arm to not give up that subscription to my pork producer here in Seattle. They produce fantastic pork. But my point is, I sign up and I'm willing to pay that money and take that risk. But it seems that, like you said, that's a really great outcome for the Farmer, because like you said, they can invest it from an input standpoint.

    What about transparency or notice obligations? What if, many of us are used to something like, Netflix, where you just sign up for a subscription, you pay as you go, and hey, if I wanna cancel it one month, I just cancel it and I don't get billed next month.

    But if I'm a Farmer, like I've made a commitment to produce this food for you. And maybe you're on a chicken subscription and I'm growing broilers for you every six weeks, right? And I've got them on a rotation. Can Farmers put some terms in here to protect themselves to make sure that buyers just don't walk away a week before the boilers are supposed to be processed?

    Alexia Kulwiec: Yeah. I think the notice is key and I would absolutely recommend that Farmers have some kind of language that protects them. I have [00:27:00] seen, like I say, I've seen arrangements where once you're in the subscription for the season, you've made a commitment whether it's upfront money or it's every single time to pay that money and you're invoiced regardless of whether you pick up because the farmer's committed to produce a certain amount.

    I've also seen arrangements where a consumer can give, say 30 days notice or something. I think you guys might even work with folks with much shorter notice periods. The longer notice periods allows the producer then to find other customers for the produce or for what, whatever it is that it's trying to distribute in that season.

    James Maiocco: I would say at least just based on the data we see across the Farms, and granted we have thousands of Farms we service, but it varies quite dramatically. Very large Farms that are servicing larger metropolitan markets where there's an abundance of buyers, oftentimes will allow people to just cancel, you know, ad hoc, like literally with a week's notice or less even.

    Cancel anytime. Skip anytime. That's not a [00:28:00] hard thing to do if, again, if you're in the market where for instance, we have some of our Farmers that have thousands of members, like literally they're doing a thousand deliveries a day or a week, you know, in very big metro markets. On the flip side of it, we tend to see Farmers who are servicing smaller audiences or first time Farmers or people who are just starting to try to enter into this side of the business who may only have 50 to a hundred members and they can't afford to lose a single member.

    And those cases, oftentimes we see them not allow buyers to cancel or even skip at all. It's like, hey, if you're out of town on vacation during these, you know, 10 weeks, that's not my issue. We'll donate your box to, you know, to the food shelter. And so I think Farmers should choose to do what's best for their Farm, but also to ensure they can protect their income, while also being transparent with the buyers in terms of what they should expect if they sign up.

    Alexia Kulwiec: Yeah. And I have seen that on a number of occasions, the idea that if I'm committing to the year, I'm committing to the season and if I can't pick it up, either they [00:29:00] donate it or I have to have someone else pick it up and donate it. Just donate it to your members, to your neighborhood. That's what I've done.

    James Maiocco: Yeah, the chickens aren't gonna stop laying and the tomatoes aren't gonna keep growing, right? It's just someone's gotta eat the food, right?

    Well, Alexia, thanks so much for that conversation. Where can Farmers go to learn more about topics like this, as well as get more information on the Farm-to-Consumer Legal Defense Fund? Can you remind the audience again of your website?

    Alexia Kulwiec: Yeah, thank you so much. We are just at farmtoconsumer.org. You can email us at info@farmtoconsumer.org. Or we actually will answer an old fashioned telephone at (703) 208-3276.

    But our website really is a great place to start. We've got maps, we've got some resources. Information about us and what kind of things we're up to. And so we will have some member only events at times and the kind of services that you can expect to get from us. So farmtoconsumer.org.

    James Maiocco: Thank you so much. I wanna extend my thanks to Alexia and everyone at Farm-to-Consumer Legal [00:30:00] Defense Fund, who are just doing a stellar job supporting many of the Farms that we work with at Barn2Door, as well as serving all kinds of Farms all across the country. We encourage you to tune in next time to the next Direct Farm Podcast with Alexia as well, where we'll dive into the nuances, laws, and costs associated with being a Direct to Consumer Farmer.

    For more information, again, go to farmtoconsumer.org. To learn more about Barn2Door, including access to this and other free resources and best practices for your Farm, go to barn2door.com/resources.

    Thank you for tuning in today and we look forward to seeing you next time. Take care and have a great day.

    [00:31:00]

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