As set forth verbatim in the Statement of Relevant Facts above, the PPIA’ preemption clause invalidates any “ingredient requirements” that are “in addition to, or different than, those made under” the PPIA if “imposed by any State … with respect to articles prepared at any official establishment in accordance with the requirements of” the PPIA. 21 U.S.C. § 467e. Here, every single one of Hudson Valley’s and the Canadian Farmers’ products is prepared, as it is required to be, at an official establishment.

And contrary to what Defendant suggests, regardless of how “cruel” a State may believe some poultry products to be, Congress has clearly stated that “ingredient requirements … in addition to, or different than, those made under this chapter may not be imposed by any State … with respect to articles prepared at any official establishment in accordance with the requirements under” the PPIA. 21 U.S.C. § 467e. Where, as here, Congress’s manifest intention was to create uniform requirements in the field of poultry products, the purported motivation of a state law that imposes an “additional” or “different” requirement — or that otherwise stands as an obstacle — is of no moment.

To Plaintiffs’ Partial MSJ Re Federal Preemption (CV-12-05735-SVW-RZ) requirement or taking other action, consistent with this chapter, with respect to any other matters regulated under this chapter.” 21 U.S.C. § 467e. This savings clause expressly disclaims any Congressional intent to occupy the field beyond the marking, labeling, or ingredient requirements.