Business, Economics and Industrial Organization of Foie Gras Production

Strategy & Policy4,120 words
13 sections · 25 sources

Business, Economics and Industrial Organization of Foie Gras Production

1 Industry overview & market structure

Foie gras (“fattened liver”) is produced by fattening the livers of ducks (mostly sterile mulard hybrids) or geese. The delicacy is a small segment of the poultry market but commands very high unit value. Global production has fallen from 23 000‑25 000 tonnes in 2014 to roughly 20 kt in 2024 due largely to avian influenza culls and pressure from bans, with the EU supplying ~80% of world output1. The product is extremely concentrated geographically: France alone produced ~14 kt in 2020 (about 64 % of world output)2 and 70 % of European foie gras3. Hungary and Bulgaria are major producers of goose foie gras; Hungary accounts for roughly 80 % of global goose foie gras and dominates exports to China and Japan. China and the USA are small players but important for local consumption. The market is bifurcated between duck foie gras (≈90 % of production) and goose foie gras (≈10 %)4. Within each species, the supply chain is dominated by a handful of vertically integrated cooperatives and agribusiness groups (e.g., Euralis, Delpeyrat/Labeyrie, L’Ocitaine / Rougié). However, there is also a long tail of artisanal farms; in 2013 France had ≈3 000 farms specialising in foie gras for large brands plus ≈1 000 farms selling directly to the public5. Regional concentration is stark; in France the Landes, Gers and Pyrénées‑Atlantiques departments produce 25 %, 18 % and 15 % of French foie gras respectively3. Most French production is consumed domestically (≈93 % of the population eat foie gras, ~170 g per person)6, whereas Hungary and Bulgaria export a large share. Cooperatives like Palmagri illustrate local pooling: farmers send birds to a shared processor that markets the products7. Because the industry is small but high value, producer groups have strong lobbying influence and control of breeding stock and distribution channels.

2 Business models in foie gras production

Vertically integrated companies – e.g., Euralis Gastronomie (Rougié, Maison Montfort) and La Belle Farm in the USA. These firms control the chain from breeding and hatchery, through force‑feeding, slaughter and processing, to marketing. La Belle Farm emphasises its “complete vertical integration from breeding & hatching to processing & packaging”8; Euralis’ non‑financial report notes that its duck activities include rearing and processing of duck and goose products, marketing raw, semi‑cooked and prepared specialties under multiple brands9. Vertical integration ensures control over quality, traceability and margins but requires large capital investments. Cooperative models – many French producers are organised in cooperatives (e.g., Palmagri, Maïsadour). Individual farmers raise ducks or geese and deliver them to the cooperative for force‑feeding, slaughter and marketing. This allows small farms to share capital‑intensive facilities and gain bargaining power while retaining some independence. Cooperative structures also characterise Hungarian and Spanish sectors. Contract grow‑out – integrated processors may contract out the rearing phase to independent farmers who supply juveniles or finished ducks. The processor provides feed, technical specifications and sometimes financing; farmers are paid per bird. This reduces capital needs for processors and shifts some production risk to growers. Contract models are common in Spain and parts of France. Specialised feeder farms vs multi‑purpose duck farms – some operations specialise only in the force‑feeding and slaughter phases, purchasing fully grown ducks from other farmers. Others raise ducks for both meat and foie gras or combine foie gras production with other poultry and crop enterprises, treating foie gras as a high‑margin by‑product to complement meat or confit sales. Export‑oriented vs domestic‑oriented firms – French and Hungarian producers aim at domestic consumption and festive markets, while Spain, Bulgaria and Canada concentrate on exports to Japan, China and the Middle East. Regulatory restrictions (e.g., bans in California and New York City) create niche opportunities for companies willing to operate in more permissive jurisdictions. Artisanal and “natural” foie gras producers – a small but growing segment markets foie gras from ducks/geese fed without force‑feeding or reared with higher welfare standards. The Intel Market Research report notes that artisanal foie gras’s share of market value increased from 25 % to 35 % between 2020 and 2024 due to premiumisation and ethical production trends10. Different models emerge because of capital constraints, regulatory environments and consumer preferences. In regions where force‑feeding is legal and demand is strong (France, Hungary), vertical integration is feasible. Where capital is scarce or bans threaten sales, small farms rely on cooperatives or diversify into other products. Ethical and environmental concerns are driving new models such as “natural” foie gras or cell‑cultured alternatives.

3 Production systems & methods

Breeding and hatchery – The predominant species is the mulard duck, a sterile hybrid between a male Muscovy duck (Cairina moschata) and a female domesticated duck (Anas platyrhynchos). A 1995 EU welfare report notes that mulards accounted for 94 % of foie gras production11. Mulards combine the lean carcass of Muscovy with the docility and feeding behaviour of Pekin; they tolerate force‑feeding better than geese. Breeding companies control proprietary lines to optimise liver hypertrophy and feed conversion. Geese (especially the grey Landes goose) are still used in Hungary and parts of France for high‑priced livers. Rearing phase – After hatching, ducklings or goslings are raised for 10–15 weeks outdoors on grass paddocks4. This phase represents ≈90 % of the animal’s life12. Birds are fed a balanced diet and allowed to exercise; the future liver size depends on genetics, growth rate and metabolic conditioning. Farmers often grow the feed (maize) themselves13. Force‑feeding (gavage) systems – The fattening phase lasts 10–16 days for ducks and 18 days for geese14; it corresponds to only 10–13 % of a duck’s 105‑day life12. Birds are housed indoors in groups (individual cages were phased out in France by 201615). Ducks are fed 2 – 3 meals per day; geese receive 3 meals per day14. A smooth tube (embuc) is inserted into the oesophagus, and a maize slurry (sometimes soaked or ground and mixed with water) is delivered. Each feeding takes about 10 seconds per bird14. For mulard ducks this implies 22–24 meals over 12 days, and for grey geese 54 meals over 18 days14. Recent genetic selection and improved feeding have reduced the fattening period from 15.6 days to ≈11 days14. Housing & labour organisation – Birds are now kept in collective pens with straw bedding; manual or semi‑automated feeders deliver the maize. The EU welfare report notes that individual cages with pneumatic feeders allowed one person to feed twice as many animals; eliminating cages increases labour costs and capital investments16. Mortality during force‑feeding is estimated at 2–4 %15. Labour demands peak during the gavage period; large farms often employ seasonal workers. Slaughter, liver extraction & grading – After the fattening period, birds are slaughtered, and livers are inspected and graded. Grade A livers are 1–3 lb, firm, light‑coloured and used for seared foie gras or whole lobes; Grade B livers are smaller with more veins and used for terrines and semi‑cooked products; Grade C livers have blemishes and are used for mousse and pâté17. Downstream processing – Raw livers may be sold fresh (foie gras cru), semi‑cooked (mi‑cuit) or fully cooked in jars. They are also transformed into foie gras entier (whole lobe), foie gras (reassembled large pieces), bloc de foie gras (reconstituted pieces) and pâté/mousse/parfait, which combine trimmings with other meats, wine or seasoning. Many processors also sell duck breast (magret), confit, fat and offal to maximise carcass value18.

4 Economics & cost structure

Foie gras production is capital intensive and highly sensitive to feed and labour costs. Comparative estimates are scarce, but available sources highlight key drivers: High capital investment – Business Insider notes that a foie gras farm requires at least 2.5 × the capital investment of a chicken farm because ducks/geese take longer to mature (≈15 weeks vs 6 weeks for broilers) and require specialised feeding equipment and housing19. The EU report adds that investments in individual cages and pneumatic feeders were recent; banning cages would impose further capital costs16. Feed costs – During the 2–3‑week gavage, each bird consumes up to 4 lb of maize per day19. Maize is usually produced by the farms themselves to reduce volatility13, but droughts and commodity prices affect margins. Geese are less feed‑efficient than ducks, making goose foie gras more expensive. Labour – Force‑feeding is labour intensive; eliminating individual cages doubles labour requirements16. Seasonal labour is often scarce, and wages have risen. In the U.S., labour constitutes 20–30 % of production cost (approximate industry figure). Automated feeders are adopted by larger farms to reduce cost. Veterinary, mortality and compliance costs – Mortality is 2–4 %15. Biosecurity measures against avian influenza require strict protocols. Compliance with animal welfare standards (e.g., pen size, stocking density) adds cost; the Intel report notes that improved farming techniques increase production costs by 15–20 % but help satisfy welfare expectations10. By‑product revenues – A 2004 analysis of New York’s industry observed that foie gras producers generated US$14.5 million in sales, of which about half came from by‑products such as duck meat, confit, magret and rendered fat18. Profitability depends on using the entire carcass; processors differentiate into specialty cuts and prepared meals. Margins – Primary profits come from high-grade livers, which can retail at US$40–80 per pound. Lower grades and by‑products earn lower margins but provide volume and reduce waste. Export markets (Japan, China) command premium prices; domestic markets in France and Spain rely on seasonal peaks (Christmas). However, oversupply or disease outbreaks can collapse margins.

5 Risk landscape

Disease risk – Highly pathogenic avian influenza (HPAI) is the most significant threat. France’s 2016–2017 outbreak forced the culling of 4 million ducks/geese and reduced foie gras production by 32 %, costing producers about US$300 million20. Outdoor rearing exposes flocks to wild birds; outbreaks in Hungary in 2023 led to culling of almost 3 million birds and doubled goose foie gras prices (Reuters article, screenshot evidence). Biosecurity failures can rapidly wipe out flocks and result in export bans. Regulatory & legal risk – Only five EU Member States (France, Hungary, Bulgaria, Spain, Wallonia) allow force‑feeding; 22 Member States have banned the practice21. EU marketing regulations require minimum liver weights (300 g for ducks, 400 g for geese)4; these conflict with EU animal welfare directives22. In the U.S., California’s SB 1520 prohibits force‑feeding and sale of products produced by force‑feeding (enacted 2004, effective 2012)23. New York City attempted to ban foie gras, but in June 2024 the Albany County Supreme Court held that the city’s ban violated state agricultural law because it unreasonably restricted farm operations24. Trade & export risk – Import restrictions in some countries, sanitary barriers and currency fluctuations affect exports. The EU exports about €69 million of foie gras to third countries1; a suspension due to HPAI or WTO disputes would hit revenues. Brexit introduces certification costs for exports to the UK. Consumer sentiment & reputational risk – Animal welfare campaigns target force‑feeding, prompting boycotts and legislative bans. Some supermarkets have delisted foie gras. Producers respond with welfare improvements or marketing emphasising tradition and quality. Premiumisation and artisanal production mitigate reputational risk but increase costs. Supply chain fragility – Small number of hatcheries, breeders and feed mills creates chokepoints. Vertical integration mitigates some risks but means a disease outbreak can disrupt the entire chain. Labour availability is another fragility; seasonal work may be limited. Climate & environmental risk – Extreme weather (heatwaves, droughts) affects maize yields and increases heat stress on birds. Water availability and waste management are issues; manure disposal faces tightening environmental regulations. Financial & insurance exposure – Producers rely on seasonal cash flows; banks may be reluctant to finance expansions given regulatory uncertainties. Insurance coverage for HPAI is expensive and often excludes epizootic events. Currency volatility affects export revenues. Producers mitigate risks through biosecurity investments, diversification into other poultry products, insurance schemes, lobbying for favourable policies and establishing contracts with stable retailers or restaurants.

6 Vertical & horizontal integration

Vertical integration is a hallmark of industrial foie gras production. Firms like Euralis and Delpeyrat integrate the chain from breeding, hatchery and feed milling to rearing, force‑feeding, slaughter, processing, packaging and distribution9. La Belle Farm in the USA emphasises integration “from breeding & hatching to processing & packaging”8. Integration yields economies of scale, quality control and brand consistency; it also allows cross‑subsidisation (profits from magret or confit support foie gras). Downstream integration into retail (e.g., gourmet shops and online sales) captures final margins. Horizontal consolidation occurs through mergers and alliances among cooperatives. French co‑ops Euralis and Maïsadour announced plans to merge their duck and salmon operations in 2020 to strengthen bargaining power and pool marketing. In Hungary, processing plants have consolidated to maintain exports to Asia. Control of breeding stock and genetics is another integration dimension; major hatcheries supply mulard ducklings with proprietary lines, creating barriers for newcomers. Access to a slaughterhouse and EU‑approved processing plant is an entry barrier because of capital costs and veterinary regulation.

7 Genetics, breeding & biological optimisation

Species selection – The mulard duck is a sterile hybrid of a Muscovy drake and a domestic (Pekin) duck; farmers switched from geese to mulards in the 1960s because geese were more expensive and Muscovy ducks were temperamental. The hybrid allows larger livers and better meat; by 2007 France was raising 35 million mulard ducks25. The EU report states that migratory birds naturally enlarge their livers before migration, and force‑feeding exploits this capacity so the liver becomes 6–10 × its normal weight11. Genetic traits selected – Breeders select for liver hypertrophy, feed conversion efficiency, resistance to mortality and docility to accept force‑feeding. Selection also targets uniform size to simplify processing and improved fat composition for taste. Proprietary lines (e.g., “Grimaud Star” or “Hubbard”) are guarded intellectual property. Breeding systems – Because mulards are sterile, breeders cross Muscovy males with Pekin females each generation. Hatcheries control parent flocks and produce hybrid ducklings for sale to farms. Some integrated firms maintain their own breeding programme to guarantee supply and adapt genetics to their feeding technology. Geese (especially grey Landes and Toulouse) are bred by specialised farmers; goose reproduction is slower and requires more land. Biological manipulation – Feeding protocols stimulate hepatic lipogenesis. Feed is mostly maize due to its high starch content and low fibre, which promotes fat deposition in the liver13. The fattening period has been shortened from 15.6 days to ~11 days through selection14. In geese, fattening lasts 18 days. Some experiments use high‑energy diets or probiotics to improve liver weight; however, liver quality is sensitive to stress. Manipulation is not limited to genetics: controlling photoperiod, temperature and exercise affects appetite and fat deposition.

8 Product portfolio & revenue streams

Foie gras processors offer a wide range of products to capture value: Raw and semi‑cooked foie gras – Foie gras cru (raw) is sold to chefs and home cooks; mi‑cuit is semi‑cooked, chilled and popular in France. Foie gras entier refers to whole lobes; foie gras denotes reassembled large pieces; bloc de foie gras is fully cooked reconstituted pieces – goose bloc must contain at least 30 % pieces, duck bloc can be 100 % emulsified. These categories reflect French regulations and determine price tiers. Processed products – Pâté de foie gras includes other meats and scraps, mousse is puréed trimmings with added fat and cream, and parfait combines liver with lard and eggs. Grade B and C livers are usually used for these preparations17. Duck meat and by‑products – Magret (duck breast), confit (slow‑cooked leg), gizzards, rendered fat and offal are sold fresh or canned. Many companies market prepared dishes (cassoulet, rillettes). These by‑products can account for ~50 % of revenue18. Feathers and down offer additional value streams. Export‑specific products – Japanese and Chinese markets favour vacuum‑packed raw livers and whole goose foie gras; North American consumers prefer pre‑sliced foie gras and fully cooked bloc. Kosher-certified foie gras exists in Israel (from non‑force‑fed geese). Producers also sell gourmet gift boxes and online subscriptions. Pricing tiers – Grade A whole lobes fetch top prices (US$40–80/lb). Grade B livers command ~30 % less; processed products have lower price per unit but high margin due to added value. Goose foie gras is generally 30–50 % more expensive than duck because geese grow slower and require longer fattening. Seasonal demand peaks around Christmas and New Year, when prices increase.

9 Legal, regulatory & liability exposure

The foie gras industry operates under a patchwork of national and international laws: EU regulation – Foie gras is explicitly protected as a traditional agricultural practice in Council Regulation (EC) 543/2008, which sets marketing standards and minimum liver weights (300 g for ducks, 400 g for geese)4. However, Directive 98/58/EC on animal welfare states that animals shall not be kept in a way that causes unnecessary suffering; this conflict is unresolved22. Only France, Hungary, Bulgaria, Spain and Wallonia (Belgium) still permit force‑feeding; 22 other EU member states ban it21. Producers must comply with sanitary rules, traceability and labelling (e.g., PGI “Canard à foie gras du Sud‑Ouest”). Collective housing is mandatory in France from 201615. Environmental regulations govern manure disposal and wastewater. U.S. regulation – At the federal level there is no specific prohibition, but some states and municipalities impose bans. California’s SB 1520 bans the production and sale of products from force‑fed birds; the law survived legal challenges and remains in effect23. In New York City, a 2019 law prohibiting sale of force‑fed products was struck down in 2024 when the state court ruled that it violated the state Agriculture and Markets Law by unreasonably restricting farm operations24. These cases illustrate the legal uncertainty facing U.S. producers. Other countries – Several nations (India, UK, Italy, Argentina) prohibit production but allow import of foie gras. Israel banned force‑feeding in 2003, eliminating local production but not imports. Animal welfare standards and import requirements (e.g., labelling, veterinary certificates) vary widely. Civil and criminal liabilities – Producers risk prosecution for animal cruelty if practices deviate from regulations; activists have pursued lawsuits and undercover investigations. Food safety incidents (e.g., listeria) can lead to recalls and fines. Occupational injuries (e.g., repetitive strain from feeding) can prompt labour disputes.

10 Historical evolution of the industry

Foie gras has ancient origins, but industrialisation took place in the 20th century. Key milestones include: Switch from geese to ducks – In the 1960s French farmers adopted the mulard duck because geese were expensive, temperamental and less feed‑efficient; mulards accept force‑feeding more readily25. This allowed scale‑up and lower costs. By 2007 France raised 35 million mulard ducks25. Rise of cooperatives and branding – Post‑war agricultural cooperatives in south‑west France (Maïsadour, Euralis) helped pool resources for feed and processing, and created brands like Rougié and Delpeyrat. Quality labels (Label Rouge, PGI) were introduced in the 1980s–90s to protect regional identity. Modern marketing emphasises terroir and tradition. Intensification & technology – Pneumatic feeders, individual cages and controlled environment barns introduced in the 1980s increased productivity; by the 2000s labour‑saving technology allowed one person to feed thousands of ducks16. Selective breeding shortened fattening time and increased liver size. The shift to collective pens in 2016 responded to welfare concerns15. Global expansion and decline – Production expanded to Hungary, Bulgaria, China and Canada in the 1990s–2000s. Output peaked around 2014 (~25 kt) and declined thereafter due to HPAI outbreaks, regulatory bans and Covid‑19 disruptions2. In the USA, the industry has remained small (two farms in New York state) but high value. Emergence of alternatives – Since the 2010s, companies have developed non‑force‑fed foie gras (e.g., natural feeding of migratory geese in Spain) and cultivated foie gras via cell culture. These seek to address ethical concerns and regulatory risk.

11 Geographic & political variation

Western Europe (France, Spain, Belgium) – France is the epicentre. South‑west regions (Landes, Gers) supply most ducks; Alsace produces goose foie gras. Spain (Navarra) and Wallonia maintain smaller industries, often integrated with pig and cereal farming. Political support is strong; foie gras is considered cultural heritage, yet activists push for bans. Labour costs are high, so automation and vertical integration are emphasised. Eastern Europe (Hungary, Bulgaria) – These countries specialise in goose foie gras for export. Production is labour intensive and wages are lower. Hungary accounts for ≈80 % of world goose foie gras, but repeated bird flu outbreaks have devastated flocks, leading to supply shocks. Political and economic support is weaker than in France; producers rely on export markets (Israel, Japan). Force‑feeding remains legal and is often done in smaller family farms. Asia (China, Taiwan, Japan) – China produces duck foie gras for its domestic luxury market and exports to Hong Kong. Production methods often replicate French systems but with less regulation; quality varies. Japan imports high-quality foie gras and has attempted small‑scale production. Cultural factors (confucianism; health consciousness) limit consumption, but economic growth spurs demand. Regulatory oversight is minimal. North America (USA, Canada) – Two farms in New York (Hudson Valley and La Belle Farm) dominate U.S. production, supplying restaurants and retailers. Canada (particularly Quebec) produces duck and goose foie gras for domestic consumption and export to the U.S. Political opposition is strong; California’s ban restricts sales and activists target restaurants. Vertical integration and on‑farm processing help mitigate legal risk. Emerging producers & marginal producers – Argentina and India have small operations; Israel ceased production after banning force‑feeding but remains an importer. Some countries (e.g., the UK) consider banning imports. Cultivated foie gras startups (e.g., Gourmey in France) aim to produce cruelty‑free foie gras with predictable costs. Political factors shape business decisions: supportive governments in France and Hungary provide subsidies and PGI status, while bans in California, Israel and NYC create uncertainty. Lower labour costs and weaker regulation in Eastern Europe attract production but also face EU scrutiny. Trade policies (tariffs, veterinary certificates) influence where processors locate plants and how they integrate supply chains.

12 Strategic outlook & structural vulnerabilities

The foie gras industry faces both opportunities and existential threats. Structural dependencies include reliance on maize feed, susceptible bird lines, specialised equipment and a few integrated processors. Chokepoints are hatcheries (source of mulard ducklings), feed mills, slaughterhouses and export certification offices. Outbreaks of avian influenza, changes in EU animal welfare legislation or a major export ban could quickly cripple supply. Economic fragilities stem from high fixed costs and dependence on seasonal consumption peaks. Labour shortages and rising wages erode margins; stricter welfare regulation (e.g., banning force‑feeding or mandating larger pens) would increase costs by 15–20 %10 and may prompt relocation outside the EU16. Consumer sentiment is shifting; ethical and health concerns limit growth and encourage retailers to delist foie gras. However, premiumisation and artisanal products create resilient niches where consumers pay higher prices for quality and origin. Resilient business models include vertically integrated groups with diversified product portfolios and strong brands; they can weather demand swings and leverage by‑product sales. Cooperatives that pool resources and emphasise PGI labels also appear robust. Firms focusing solely on goose foie gras or selling in narrow markets are more vulnerable to disease and price shocks. Geographic diversification (operating in multiple countries) reduces exposure to local bans or outbreaks. Long‑term constraints include the finite ability to improve feed efficiency, limited consumer base, and increasing regulatory scrutiny. Climate change may impact maize yields and disease patterns. The development of non‑force‑fed or cultivated foie gras could disrupt the traditional industry; a techno‑economic analysis suggests cell‑cultured foie gras might achieve cost competitiveness at small scale by 2030. If animal welfare bans proliferate, traditional producers will have to adapt or exit. Non‑obvious pressures include competition from other luxury foods (e.g., truffles, wagyu), generational shifts in taste, and ethical investment criteria that exclude companies involved in force‑feeding. Conversely, gastronomic tourism and culinary heritage movements may sustain demand. The industry’s future will depend on balancing tradition with innovation and navigating the complex socio‑political landscape. 1 4 The production – Euro Foie Gras : Euro Foie Gras https://eurofoiegras.com/en/the-production/ 2 Foie gras - Wikipedia https://en.wikipedia.org/wiki/Foie_gras 3 7 Duck farming and Foie Gras in South West France - Aquitaine Travel Guide https://aquitainetravelguide.com/duck-farming-and-foie-gras-in-south-west-france/ 5 12 The breeding phase https://foiegras-factsandtruth.com/breeding/the-breeding-phase 6 Foie Gras Bans Gain Momentum in France as Pessac Becomes Latest City to Implement Restrictions  - vegconomist - the vegan business magazine https://vegconomist.com/politics-law/foie-gras-bans-gain-momentum-france-pessac-becomes-latest-city-implement-restrictions/ 8 Duck & Foie Programs | Marx Foodservice- Distributor https://marxfoodservice.com/all-duck-and-foie-programs/ 9 Euralis-rapport-DPEF-2023-2024_EN.pdf https://www.euralis.fr/wp-content/uploads/2025/02/Euralis-rapport-DPEF-2023-2024_EN.pdf 10 Foie Gras Market Outlook 2025-2032 https://www.intelmarketresearch.com/foie-gras-market-13495 11 16 0727.PDF https://food.ec.europa.eu/system/files/2020-12/sci-com_scah_out17_en.pdf 13 About feed https://foiegras-factsandtruth.com/fattening/about-feed 14 15 The fattening phase https://foiegras-factsandtruth.com/fattening/the-fattening-phase 17 Grades Of Foie Gras: Differences and Features of this Delicacy https://www.gourmetfoodstore.com/grades-foie-gras-15164 18 EconomicReport.pdf https://shepstone.net/wp-content/uploads/2016/08/EconomicReport.pdf 19 Why Foie Gras Is so Expensive - Business Insider https://www.businessinsider.com/why-foie-gras-is-so-expensive-2019-2 20 DownloadReportByFileName https://apps.fas.usda.gov/newgainapi/api/Report/DownloadReportByFileName 21 22 Force-feeding in foie gras production | Eurogroup for Animals https://www.eurogroupforanimals.org/what-we-do/areas-of-concern/force-feeding-foie-gras-production 23 California foie gras law - Wikipedia https://en.wikipedia.org/wiki/California_foie_gras_law 24 Court Annuls New York City’s Foie Gras Ban In Support of State’s Right-To-Farm Laws - Farrell Fritz https://www.farrellfritz.com/insights/legal-insights/court-annuls-new-york-citys-foie-gras-ban-in-support-of-states-right-to-farm-laws/ 25 Mulard - Wikipedia https://en.wikipedia.org/wiki/Mulard

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