The opinion of the Court was delivered by
[145]*145HANDLER, J.
In this appeal the Court is confronted with State consumer protection regulations that incorporate a complex body of religious doctrine and contemplate the assistance by clergy or religious experts in the interpretation and enforcement of that doctrine. Those regulations are challenged under the Religion Clauses of the federal and state constitutions that define and govern the relationship between religion and state.
Under regulations administered by the Division of Consumer Affairs, the State regulates the preparation, maintenance, and sale of kosher products. The regulations state that it is “an unlawful consumer practice” to sell or attempt to sell food “which is falsely represented to be Kosher.” They define “Kosher” as “prepared and maintained in strict compliance with the laws and customs of the Orthodox Jewish religion.” Those regulations were invoked by the Attorney General, who brought an enforcement action charging Ran-Dav’s County Kosher, Inc. (County Kosher) and its principal, Arthur Weisman, with violations. The charged parties denied the allegations and claimed that the regulations violated the Religion Clauses of the federal and state constitutions. The constitutional claims were brought before the Appellate Division while the trial court retained jurisdiction of the enforcement action.
A majority of the Appellate Division upheld the constitutionality of the regulations. Ran-Dav’s County Kosher, Inc. v. State, 243 N.J.Super. 232, 579 A.2d 316 (1990). A dissenting opinion took the position that the regulations were unconstitutional. Id. at 259, 579 A.2d 316. The issue is whether the kosher regulations facially violate the provisions of the federal and state constitutions that prohibit government establishment of religion. The constitutional issue is substantial, and the dissent brings the appeal to this Court as of right. R. 2:2-1.
We hold that the kosher regulations violate the Establishment Clauses of the federal and state constitutions. Our primary ground for that holding is that the regulations impose [146]*146substantive religious standards for the kosher-products industry and authorize civil enforcement of those religious standards with the assistance of clergy, directly and substantially entangling government in religious matters.
I
The difficult and unusual issue presented on this appeal calls first for an explanation of the subject matter of the challenged regulations and an analysis of the regulatory standards and enforcement procedures. That explanation will inform the inquiry into whether the regulatory scheme takes government too far into the religious domain.
Regulations governing the kosher-foods industry were promulgated in 1984 by the Division of Consumer Affairs under the authority of the Consumer Fraud Act, N.J.S.A. 56:8-4. The regulations make it “an unlawful consumer practice” to sell or attempt to sell food “which is falsely represented to be Kosher.” N.J.A.C. 13:45A-21.2.
The word “kosher” (from the Hebrew “kasher”) means “fit” or “ritually correct.” It is used to refer to, among other things, the Jewish dietary laws. The practice of “kashrut” within Judaism serves to attain “kedusha” or holiness and is a fundamental tenet of the religion. The origin of the kosher laws can be traced back to the Torah (the first five books of the Bible), but most of the laws concerning what is kosher have developed through centuries of Talmudic debates (debates regarding the application of the principles contained in the Torah) and rulings by rabbinic scholars. The dietary laws of “kashrut” set forth rules covering “(1) permitted and forbidden animals, (2) forbidden parts of otherwise permitted animals, (3) the methods of slaughtering and preparing permitted animals, (4) forbidden food mixtures, and (5) proportions of food mixtures prohibited ab initio but permitted ex post facto.” 243 N.J.Super. at 241, 579 A.2d 316 (quoting 8 Encyclopedia of Religion 270-71 (1987)). The laws of kashrut are complex and exacting. For [147]*147example, animals must be slaughtered in a prescribed manner by a trained person. Meat must be “koshered” according to specifically defined soaking and salting methods to draw out the blood. Ibid. Central to the doctrine of “kashrut” is the requirement of the “mashgiach,” the religious authority who must supervise kosher butchers and certify compliance with the laws of kashrut. Without proper religious supervision, certain foods are simply non-kosher, even though constituted and prepared in identical fashion to kosher foods.
The court below suggested that there is universal agreement among the branches of Judaism that the standards governing the preparation and sale of food are those of Orthodox Judaism. Ibid. In fact, however, there is considerable disagreement over what precepts or tenets truly represent the laws of kashrut. There are differences of opinion concerning the application and interpretation of the laws of kashrut both within Orthodox Judaism and between Orthodox Judaism and other branches of Judaism. Herman Wouk, This Is My God (1959), reprinted in The Life of Torah 98-99 (Jacob Neusner ed., 1974). See Rabbi Hayim Halevy Donin, To Be a Jew 102-104, 112-119 (1972); Rabbi J. David Bleich, Contemporary Halkhic Problems 84-92 (1977). Some disputes arise in light of new technologies used in the preparation of foods. Bleich, supra, at 86-92. Other disputes arise because many members of the non-Orthodox branches of Judaism take divergent approaches to the adherence to the laws of kashrut, considering certain foods to be kosher even when not prepared in the strictest compliance with certain commonly accepted principles. Wouk, supra, at 99. See Donin, supra, at 103-04, 118-19.
Controversies over kosher products center not only on the nature of the products themselves but on the persons supervising their preparation. Wouk, supra, at 99; Donin, supra, at 112, 115, 118. Disputes constantly arise within Orthodox Judaism over the legitimacy of the various religious authorities purporting to ensure that food is kosher. See, e.g., Kashrus Magazine, September 1990, 26-32 (publishing a “Seven Page [148]*148Guide” of over 100 rabbinically-supervised kosher supervision services worldwide, but withholding endorsement of any particular service with the following disclaimer: “Some of the [supervision services] are not relied upon by most of the kosher world. Consult your rabbi for which symbols you should use.’’).
Because the laws of kashrut are so complex, compliance with them is highly labor intensive. Kosher food therefore costs more than non-kosher food. Because of those higher prices, and because most consumers cannot determine whether foods labeled as “kosher” were prepared under “kosher standards,” unscrupulous vendors can reap substantial profits by misleading consumers into believing their products are kosher. 243 N.J.Super. at 251, 579 A.2d 316.
The false promotion of non-kosher foods harms a variety of consumers. Observant Jews may be induced, unwittingly, to break the laws of their religion. Kosher foods are important not only to Jews but to many other persons as well. Adherents to certain other faiths, especially those forbidding the consumption of pork, purchase kosher food to comply with their own religious requirements. People with particular health problems, such as shellfish allergies, buy kosher products to avoid troublesome food. Finally, some members of the general public believe that kosher meat is superior to non-kosher meat because it is prepared under especially close scrutiny. Id. at 247-48, 579 A.2d 316.
Those concerns are reflected in the social impact statement accompanying the initial adoption of the kosher regulations:
The preparation of Kosher foods involves certain slaughtering and sanitary procedures and often results in a more expensive food product. These rules make it illegal to falsely represent food as Kosher or Kosher for Passover and thus protect the consumer who, for reasons of religion, conscience, quality or health, intends to purchase Kosher foods.
[16 N.J.R. 220(a).]
The regulations were substantially amended in 1987. See 19 N.J.R. 1060(a) (statement accompanying 1987 amendments). [149]*149The regulations address the preparation, maintenance and sale of kosher products. Throughout, the regulations refer explicitly to the “Orthodox Jewish religion” and the “laws and customs” of that religion to specify the standards that apply to the kosher food industry. “Kosher” is defined by the regulations to mean “prepared and maintained in strict compliance with the laws and customs of the Orthodox Jewish religion.” N.J.A. C. 13:45a-21.1. The regulations also impose complicated guidelines governing the actual handling of foods. For example, the regulations expressly require that “Kosher meats must be maintained Kosher and must be properly deveined and, with the exception of liver, washed within 72 hours after slaughter, and within each subsequent 72 hours period in accordance with the laws and customs of the Orthodox Jewish religion.” N.J.A.C. 13:45A-21.3(a)(2)(i). Establishments that deal in both kosher and non-kosher food must comply with detailed regulations regarding separation of the former from the latter. Ibid. Reflecting the necessity for religious supervision, establishments that sell only kosher food must advise the Director of Consumer Affairs of their rabbinical supervision. N.J.A.C. 13:45A-21.5.
Violations of the regulations are subject to the penalties of the Consumer Fraud Act, namely, injunctions, N.J.S.A. 56:8-8, and fines, N.J.S.A. 56:8-13 (imposing fines up to $2,000 for first offense, up to $5,000 for subsequent offenses). Civil enforcement of the regulations is undertaken by the Bureau of Kosher Enforcement within the Division of Consumer Affairs, in the State Department of Law and Public Safety, which is under the jurisdiction of the Attorney General. The State Kosher Advisory Committee shares responsibility for the enforcement of the regulations. The Attorney General created that Committee, pursuant to the Consumer Fraud Act and the kosher regulations, by Executive Directive No. 1987-2. The Committee consists of ten rabbis appointed by the Attorney General, nine of whom are orthodox rabbis, the tenth being a conservative rabbi. The Chairman of the Committee is the Chief of the Bureau of [150]*150Kosher Enforcement. The Committee’s function is to “advise the Attorney General on Kosher matters and enforcement of the New Jersey Kosher regulations ... and make recommendations for regulatory changes.” 243 N.J.Super. at 240, 579 A.2d 316.
The record indicates that on five occasions during 1987-89, investigators employed by the Bureau of Kosher Enforcement inspected County Kosher and noted possible violations. First, an inspector noticed calves’ tongues soaking in a full-strength brine solution. Pursuant to N.J.A.C. 13:45A-21.3(a)(2)(i), Kosher meat must be deveined, but those tongues had not been deveined. Next, an inspector found six boxes of Shelat brand chicken breasts in a storage freezer, a brand of chicken that recently had been determined to be non-kosher. The storage of kosher food with non-kosher food is prohibited by N.J.A. C. 13:45A-21.3(a)(l)(ii). Third, inspectors observed blood and a vein in meat that was to be ground for hamburger, contrary to N.J.A.C. 13:45A-21.3(a)(2)(i). Finally, an inspector noted a problem involving the labeling of meat. County Kosher’s operations are supervised by an orthodox rabbi who contended that the establishment’s activities complied with the kosher laws. Nevertheless, the foregoing incidents formed the basis of the consumer fraud charges against appellants.1
II
The First Amendment to the United States Constitution provides that “Congress shall make no law respecting an estab[151]*151lishment of religion, or prohibiting the free exercise thereof.” The United States Supreme Court has explained: “The First Amendment’s Religion Clauses mean that religious beliefs and religious expression are too precious to be either proscribed or prescribed by the State.” Lee v. Weisman, — U.S.-,-, 112 S.Ct. 2649, 2656, 120 L.Ed.2d 467, 482 (1992). The Religion Clauses of the First Amendment have been applied to the states since Cantwell v. Connecticut, 310 U.S. 296, 60 S.Ct. 900, 84 L.Ed. 1213 (1940) (Free Exercise Clause) and Everson v. Board of Education, 330 U.S. 1, 67 S.Ct. 504, 91 L.Ed. 711 (1947) (Establishment Clause).
The New Jersey Constitution also contains a Religion Clause. “There shall be no establishment of one religious sect in preference to another.” N.J. Const. art. I, para. 4. In Tudor v. Board of Education of Rutherford, 14 N.J. 31, 45, 100 A.2d 857 (1953), cert. denied, 348 U.S. 816, 75 S.Ct. 25, 99 L.Ed. 644 (1954), Chief Justice Vanderbilt stated that under both the federal and state constitutions, “the state or any instrumentality thereof cannot under any circumstances show a preference for one religion over another.” This Court has observed that New Jersey’s Religion Clause, which contains no reference to the “free exercise” of religion, “is less pervasive, literally, than the Federal provision,” Clayton v. Kervick, 56 N.J. 523, 528, 267 A.2d 503 (1970), vacated on other grounds, 403 U.S. 945, 91 S.Ct. 2274, 29 L.Ed.2d 854 (1971), and therefore the Court has not been impelled to interpret the state constitution more broadly than the federal constitution in cases implicating the establishment of religion. Right to Choose v. Byrne, 91 N.J. 287, 313, 450 A.2d 925 (1982); Marsa v. Wernik, 86 N.J. 232, 239-40 n. 2, 430 A.2d 888, cert. denied, 454 U.S. 958, 102 S.Ct. 495, 70 L.Ed.2d 373 (1981); Resnick v. East Brunswick Township Bd. of Education, 77 N.J. 88, 104, 389 A.2d 944 (1978); Clayton v. Kervick, supra, 56 N.J. at 528, 267 A.2d 503. In any event, interpretation of the state constitutional standard is informed by an understanding of federal constitutional doctrine concerning the establishment of religion.
[152]*152The constitutional strictures on government action concerning religion seek to avoid certain evils. They include discrimination among religions or between religion and nonreligion, symbolic union between government and a given religious faith or religion in general, sponsorship of the religious mission of a group, excessive entanglement between government and religion, and political divisiveness incited by the government’s favoritism of a particular religious faith. See Grand Rapids School Dist. v. Ball, 473 U.S. 373, 390, 392-97, 105 S.Ct. 3216, 3226, 3227-29, 87 L.Ed.2d 267, 281-86 (1985); Committee for Pub. Educ. & Religious Liberty v. Nyquist, 413 U.S. 756, 794-98, 93 S.Ct. 2955, 2976-78, 37 L.Ed.2d 948, 975-77 (1973); Lemon v. Kurtzman, 403 U.S. 602, 611-15, 91 S.Ct. 2105, 2111-12, 29 L.Ed.2d 745, 756-57 (1971); Walz v. Tax Comm’n, 397 U.S. 664, 674, 90 S.Ct. 1409, 1414, 25 L.Ed.2d 697, 704 (1970); Torcaso v. Watkins, 367 U.S. 488, 495, 81 S.Ct. 1680, 1683-84, 6 L.Ed.2d 982, 987 (1961).
The basic standard for determining the proper application of the Establishment Clause is the three-pronged test of Lemon v. Kurtzman, supra, 403 U.S. at 612-13, 91 S.Ct. at 2111, 29 L.Ed.2d at 756-57. However, in cases of state action that patently create denominational preferences, a different analysis controls. A law that creates “explicit and deliberate distinctions between different religious organizations” must be regarded “as suspect and [subject to] strict scrutiny in adjudging its constitutionality.” Larson v. Valente, 456 U.S. 228, 246, 102 S.Ct. 1673, 1684, 72 L.Ed.2d 33, 48-49 (1982); see Hernandez v. Commissioner, 490 U.S. 680, 109 S.Ct. 2136, 104 L.Ed.2d 766 (1989).
The Appellate Division concluded that the regulations did not constitute a per se violation of the Establishment Clause under Larson. It determined that the regulations, by expressly adopting the laws of the “Orthodox Jewish religion,” did not prefer Judaism over other religions, and that the enforcement of kosher standards does not disfavor or denigrate any other [153]*153religion. 243 N.J.Super. at 250, 579 A.2d 316. It also accepted the State’s argument that the regulations do not prefer Orthodox Judaism over other branches because merchants are free to observe dietary laws according to any standard they choose. Id. at 246-47, 579 A.2d 316.
The ruling of the Appellate Division that the regulations do not create a preference within the Jewish religion was based mainly on the assumption that the State’s enforcement policy under the regulations allows merchants to apply their own sincerely held variant interpretations of kashrut. Id. at 246-47 & n. 14, 249, 255, 257-59, 579 A.2d 316. However, the State apparently has abandoned its position that the regulations allow different interpretations of the kosher laws. Rather, it now contends that a uniform standard must be applied. See discussion infra at 159-60. The clear implication of that change of position is that merchants sincerely believing that their products are kosher could nevertheless be prosecuted under the regulations if the State believes that their products do not conform to the standards of Orthodox Judaism as the State defines and applies them.
Despite our doubts surrounding the Appellate Division’s ruling that the regulations are valid under the Larson test, we decline to invoke that standard, primarily because the record suggests uncertainty concerning both the precise meaning and the enforcement standards of the regulations. In any event, we are satisfied that because the kosher regulations directly, clearly, and inescapably violate the standards of Lemon, we need not resolve the issue of whether the regulations constitute a per se violation of the First Amendment under the Larson test.
Three elements must be met under Lemon, viz:
First, the statute must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion, ... finally, the statute must not foster “an excessive government entanglement with religion.” [154]*154[403 U.S. at 612-13, 91 S.Ct. at 2111, 29 L.Ed.2d at 755 (quoting Walz, supra, 397 U.S. at 674, 90 S.Ct. at 1414, 25 L.Ed.2d at 704).]
Because the kosher regulations provide both substantive standards prescribing religious practices and procedures for their enforcement, the entanglement prong, which prohibits excessive government involvement in religious matters, is most germane in assessing the constitutional validity of the administrative scheme.
The prohibition against undue government involvement in religion “rests upon the premise that both religion and government can best work to achieve their lofty aims if each is left free from the other within its respective sphere.” People of Illinois ex rel. McCollum v. Board ofEduc., 333 U.S. 203, 212, 68 S.Ct. 461, 465, 92 L.Ed. 649, 659 (1948). This prong most closely connects the Lemon test to Jefferson’s notion of a “wall of separation” between church and state. See Reynolds v. United States, 98 U.S. 145, 164, 25 L.Ed. 244, 249 (1879) (quoting reply from Thomas Jefferson to the Danbury Baptist Association, Jan. 1, 1802). The Supreme Court has stated, “Some limited and incidental entanglement between church and state authority is inevitable in a complex modern society, ... but the concept of a ‘wall’ of separation is a useful signpost.” Larkin v. Grendel’s Den, Inc., 459 U.S. 116, 123, 103 S.Ct. 505, 510, 74 L.Ed.2d 297, 305 (1982).
In considering whether the kosher regulations foster excessive government entanglement with religion, we initially note that they impose substantive religious standards on establishments purporting to be kosher. Specifically, the regulations contain numerous requirements relating to religious practices essential in the preparation and maintenance of kosher foods. Further, those requirements must be met “in strict compliance with the laws and customs of the Orthodox Jewish religion.” Hence, the administrative scheme does more than require that businesses purporting to be under a certain type of rabbinical supervision are in fact under that type of supervision; it requires such establishments to adhere strictly to religious [155]*155kosher standards in the conduct of their business and authorizes the State to monitor the adherence to those standards. As a result, Jewish law prescribing religious ritual and practice is inextricably intertwined with the secular law of the State. Further, the State itself takes on the traditional religious supervisory role, thereby partially supplanting the Jewish organizations and institutions that historically have stood as final judges of religious matters.
The State contends that the regulations control only the false promotion and sale of non-kosher products. It acknowledges that the regulations incorporate a substantive religious standard, but argues that doing so is necessary in order to protect consumers of kosher products from misrepresentation. However, the State’s adoption and enforcement of the substantive standards of the laws of kashrut is precisely what makes the regulations religious, and is fatal to its scheme. The regulations govern the promotion and sale of kosher products by regulating their antecedent preparation and maintenance. They empower the State to establish fraud or misrepresentation in the promotion of the product by demonstrating that the product was not prepared and maintained in “strict compliance” with what the State itself believes to be “the laws and customs of the Orthodox Jewish religion.” In that respect, as pointed out by the appellant, “[t]he regulations do not police the nutritional quality or sanitary purity of kosher food, but only its religious purity.” In doing so, they create an unconstitutional entanglement of government and religion analogous to that recognized in Spacco v. Bridgewater School Dep’t, 722 F.Supp. 834, 844-47 (D.Mass.1989), where a municipality leased a Catholic parish center for use as public elementary school, provided that the town’s use of the center would “at all times be consistent with the teachings of the Roman Catholic Church enunciated by the Holy Father and the Bishops in communion with him.”
[156]*156The regulations thus squarely put the State’s imprimatur behind certain foods that can be lawfully sold as kosher, and plainly punish merchants who, without State approval, insist that other foods are kosher as well. As we explain below, infra at 160-61, we cannot construe the regulations, as the dissent would, as providing a “good faith” defense to enforcement actions by the State. Cf. post at 171-72. We stress, however, that our analysis is based on the Establishment Clause, not the Free Exercise Clause. Under the Establishment Clause, the State can neither impose religious rules nor endorse religious norms.
The State observes that many people purchase kosher products for non-religious reasons and, from that fact, it posits that the concept of “kosher” has assumed a secular as well as a religious meaning. The State confuses the meaning of the law with the motives of consumers. “Kosher” means “ritually correct.” To be sure, the ritual correctness of products preparation may be irrelevant to those consumers who purchase kosher food only in order to avoid pork or shellfish, or because kosher food is said to be prepared in more sanitary fashion than non-kosher foods. Nevertheless, the kosher regulations mandate that food sold as kosher be prepared in ritually correct fashion. The religious indifference of some consumers does not empty those regulations of their fundamentally religious character.
The sectarian nature of the regulations is further evidenced by the religious qualifications of the persons selected to enforce the regulations. The Chief of the Bureau of Enforcement is an orthodox rabbi. The Advisory Committee, which is authorized to advise the enforcement agency about compliance with the kosher regulations, consists entirely of rabbis. The Appellate Division and the dissent both suggest, however, that the religious identity of those persons is not important. 243 N.J.Super. at 254, 579 A.2d 316; post at 180.
[157]*157The employment qualifications of state officials and employees often reflect the nature of their duties. For example, all of the professional boards under the jurisdiction of the Attorney General are composed of persons with special professional qualifications related to their regulatory authority. See generally Title 45, Professions and Occupations, N.J.S.A. 45:1-1 to 25 (prescribing qualifications for boards such as certified public accounts, architects, barbers, dentists, chiropractors, engineers, marriage counselors, nurses, etc.). The expertise of administrative agencies is an important aspect of the authority they exercise and the deference given to their determinations. In re Amendment of N.J.A.C. 8:31B-3:31, 119 N.J. 531, 543, 575 A.2d 481 (1990) (according “substantial deference” to regulations of administrative agencies based on a recognition of their “peculiar competence”). In this case, the existence of an Advisory Committee composed predominantly of orthodox rabbis underscores the theological or religious nature of the State’s regulatory endeavors. See Lee, supra, — U.S. at-, 112 S.Ct. at 2655-56, 120 L.Ed.2d at 480-82 (noting that a public school’s selection of a rabbi to deliver a benediction at a graduation ceremony underscored the religious nature of the benediction).
We readily acknowledge that the religious persuasion of State employees usually imparts no religious cast to the functions they perform. In this case, however, it is plain that the Committee was constituted as it was precisely because rabbis have the expertise, education, training, and religious authority to interpret, apply, and enforce the regulations. We do not construe the State’s regulatory scheme as imposing a religious qualification on its enforcement personnel, and we certainly do not suggest that it ever would be appropriate to exclude adherents to particular religions from any state body, but we cannot disregard or discount the manner in which the enforcement entities have been constituted. In this case, as in many others, the manner in which a law has been administered is a strong indicator of the government’s understanding of its rules, which can aid our own understanding of their meaning. See, [158]*158e.g., Cedar Cove, Inc. v. Stanzione, 122 N.J. 202, 212, 584 A.2d 784 (1991); Peper v. Princeton Univ. Bd. of Trustees, 77 N.J. 55, 69-71, 389 A.2d 465 (1976). Contrary to the assertion in the dissent that we determine the validity of those rules as applied, see Post at 180, we simply observe that the appointment by the State of enforcement officials with religious qualifications confirms that the regulations themselves have a principally religious meaning.
In some ways, this case presents an interrelationship between government and religion reminiscent of those found in Larkin, supra, and State v. Celmer, 80 N.J. 405, 404 A.2d 1 (1979) (partially overruling Schaad v. Ocean Grove Camp Meeting Ass’n, 72 N.J. 237, 370 A.2d 449 (1977)). In Larkin, the challenged statute vested in churches and schools the power to veto applications for liquor licenses within five hundred feet of the church or school. The Supreme Court concluded that the statute enmeshed the churches in the exercise of government powers, violating the entanglement prong of the Lemon Establishment Clause test. 459 U.S. at 127, 103 S.Ct. at 512, 74 L.Ed.2d at 297. In Celmer, the challenged ordinance ceded all municipal law enforcement authority to the United Methodist Church. There we voided a conviction for traffic violations obtained pursuant to the ordinance because it entrusted a religious entity with civil authority. 80 N.J. at 420, 404 A.2d 1. In contrast to those two cases, which involved the enforcement by religious bodies of secular or civil law, here we have enforcement by religious personnel of a sectarian or religious law. Thus, in this case the entanglement between religion and state is even more apparent.
The entanglement test under the Establishment Clauses of our constitutions forbids government adoption and enforcement of religious law. That test also forbids government resolution of religious disputes. The government may not “lend its power to one or the other side in controversies over religious authority or dogma.” Employment Div., Dep’t of [159]*159Human Resources v. Smith, 494 U.S. 872, 877, 110 S.Ct. 1595, 1599, 108 L.Ed.2d 876, 884 (1990) (citing Presbyterian Church v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393 U.S. 440, 445-52, 89 S.Ct. 601, 604-08, 21 L.Ed.2d 658, 663-67 (1969)); Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696, 708-25, 96 S.Ct. 2372, 2380-88, 49 L.Ed.2d 151, 162-71 (1976); Kedroff v. St. Nicholas Cathedral, 344 U.S. 94, 95-119, 73 S.Ct. 143, 143-56, 97 L.Ed. 120, 126-38 (1952).
The Appellate Division majority concluded that the State would not be involved in doctrinal disputes under the regulations. It apparently believed that disputes would be infrequent and inconsequential because, as stated by the Attorney General, “all branches of Judaism recognize and agree that there is ‘a single historical standard of kosher determination.’ ” The dissent expresses a similar view, suggesting that the regulations will not give rise to many disputes because they impose a “uniform, objective, and therefore secular standard.” Post at 172.
Our examination of the record and secondary sources reveals that differences of opinion do exist with respect to the laws of kashrut and that disputes do arise. See supra at 146-48. Because of varying doctrinal interpretations, varying degrees of trust that members of some sects place in the food supervisors of other sects, and varying “shades of observance” undertaken by individual Jews, no one practice can be called “the only true Judaism.” Wouk, supra, at 99. Disputes may occur infrequently, but when they do, they are ineluctably religious in tenor and content. The dissent criticizes those conclusions as based on information taken from secondary sources. Post at 182-83. That criticism must be tempered. We would note that the dissent itself relies on information hardly distinguishable from secondary materials, namely, the beliefs of four rabbis who happen to be associated with the State, to support its assertion that there is unanimity concerning the Jewish dietary laws. Indeed, the authority on which the dissent relies suggests a lack of unanimity. One of the rabbis cited by the [160]*160dissent concedes that the laws of kashrut evolve as they are “interpreted and construed by authoritative rabbis in each generation.” He and another rabbi acknowledge that individual Jews take different approaches with respect to the observance of the laws of kashrut. In addition, many of the cases cited in the dissent for the proposition that the laws of kashrut are “uniform” actually concede that disagreements exist. See, e.g. Hygrade Provision Co. v. Sherman, 266 U.S. 497, 45 S. Ct. 141, 69 L.Ed. 402 (1925); Barghout v. Mayor & City Council, 325 Md. 311, 600 A.2d 841 (1992); National Foods, Inc. v. Rubin, 727 F.Supp. 104 (S.D.N.Y.1989). In any event, we must point out that reliance on secondary materials is entirely proper in cases like this one. As the Supreme Court noted in County of Allegheny v. Greater Pittsburgh ACLU, 492 U.S. 573, 614-15 n. 60, 109 S.Ct. 3086, 3112 n. 60, 106 L.Ed.2d 472, 507-08 n. 60 (1989), courts should not hesitate to refer “to secondary sources in aid of their Establishment Clause analysis.” To ignore secondary sources, said the Court, is to write a judicial “prescription for ignorance.” Ibid.
The Attorney General concedes that it is neither realistic nor accurate to view the laws of kashrut as being immune from dispute. At one point in the litigation, he took the position that government involvement in disputes over meaning could be avoided by the simple expedient of not deciding them. “[Wjhere Orthodox Jewish authorities dispute the force or requirement of a particular definition of kosher, the State is precluded from choosing one interpretation over the other”; the bureau would not enforce the regulations against a purveyor who had adopted a variant interpretation of kashrut based on sincerely held beliefs. 243 N.J.Super. at 246 & n. 14, 579 A.2d 316. However, the State’s current position is that “because of consumer expectations, a merchant’s or his supervising rabbi’s variant, albeit good faith, religious belief that under Orthodox Jewish law pork is kosher, may be regulated by the State.”
The Attorney General’s current understanding of kosher regulations comports with the actual text of the regulations, [161]*161which refers to the kosher laws as those being in “strict compliance” with Orthodox Jewish doctrine. N.J.A.C. 13:45A-21.2. The enforcement position of strict compliance also appears to be consistent with prevailing state policy. See generally N.J.A.C. 13:45A-21 and -22 (as amended, 1987) (current kosher regulations calling for strict compliance and expanding prior regulations by requiring more exacting procedures for preparation and maintenance of kosher foods, for identification of products, and for inspections). See also N.J.S.A. 2C:21-7.4 (amended, L.1988, c. 154) (imposing disorderly persons sanctions for misrepresentation of non-kosher products as kosher, which is defined as strict compliance with Orthodox Judaism).
The Attorney General has acknowledged that the Bureau of Enforcement would be obligated under the kosher regulations to obtain injunctions against merchants adhering to their own understandings of Jewish law in general or Jewish Orthodoxy in particular. The conclusion is inescapable that if a merchant did not adhere to Jewish Orthodoxy, as perceived by the Bureau of Enforcement, and the State legally challenged the merchant’s right to sell his or her products as “kosher,” a court would have to resolve whether the merchant’s view of kashrut diverged from the State’s definition of Jewish Orthodoxy. It is difficult to envision a civil controversy stamped more indelibly with religious doctrine.
The laws of kashrut are intrinsically religious, whether they are ambiguous or not and whether they are disputed or not. Religious doctrines cannot be recast as secular principles simply because they are clear. See, e.g., Spacco, supra, 722 F.Supp. at 844-47 (recognizing inherent religious character of “the teachings of the Roman Catholic Church enunciated by the Holy Father and the Bishops in communion with him”). Nor do religious doctrines become neutral simply because they are widely or even universally held. Lee, supra, — U.S. at-, 112 S. Ct. at 2655-56, 120 L.Ed.2d at 480-82. Neutral principles are “wholly secular legal rules whose application to religious parties or disputes does not entail theological or doctrinal [162]*162evaluations.” Elmora Hebrew Center v. Fishman, 125 N.J. 404, 414-15, 593 A.2d 725 (1989).
We recognized in Elmora Hebrew Center that civil courts may resolve controversies involving religious groups if resolution can be achieved by reference to neutral principles of law, but that they may not resolve such controversies if resolution requires the interpretation of religious doctrine. See, e.g., Jones v. Wolf, 443 U.S. 595, 602, 99 S.Ct. 3020, 3024, 61 L.Ed.2d 775, 783 (1979); Presbyterian Church, supra, 393 U.S. at 449, 89 S.Ct. at 606, 21 L.Ed.2d at 665; Minkin v. Minkin, 180 N.J.Super. 260, 266, 434 A.2d 665 (Ch.Div.1981); Avitzur v. Avitzur, 459 N.Y.S.2d 572, 574, 58 N.Y.2d 108, 114-15, 446 N.E.2d 136, 138, cert. denied, 464 U.S. 817, 104 S.Ct. 76, 78 L.Ed.2d 88 (1983). Neutral principles may be particularly suited for adjudications of property disputes, Presbyterian Church, supra, 393 U.S. at 449, 89 S.Ct. at 606, 21 L.Ed.2d at 665; see Eldership v. Church of God at Sharpsburg, 396 U.S. 367, 90 S.Ct. 499, 24 L.Ed.2d 582 (1970) (Brennan, J., concurring), or civil contract actions, Welter v. Seton Hall Univ., 128 N.J. 279, 608 A.2d 206 (1992); Elmora Hebrew Center, supra, 125 N.J. at 420, 593 A.2d 725; Jewish Center of Sussex County v. Whale, 86 N.J. 619, 432 A 2d 521 (1981); see Christian Science Bd. of Directors v. Evans, 105 N.J. 297, 306, 520 A.2d 1347 (1987), but not where disputes involve interpretations of religious doctrine itself. Elmora Hebrew Center, supra, 125 N.J. at 420, 593 A.2d 725 (holding that only religious authorities can determine scope of duties of “orthodox rabbi”); Chavis v. Rowe, 93 N.J. 103, 112, 459 A.2d 674 (1983); see Alicea v. New Brunswick Theological Seminary, 244 N.J.Super. 119, 581 A.2d 900 (1990), aff'd on other grounds, 128 N.J. 303, 608 A.2d 218 (1992). Here, the disputes that would arise under the kosher laws would call inescapably on the State to assume a religious role. The State itself invariably would be one of the disputants, seeking to impose and enforce its own interpretation of Orthodox Jewish doctrine, and any adjudication by a [163]*163court of such disputes inevitably would entail the application and interpretation of Jewish law.
The factors that entangle government in religion through the kosher regulations also implicate the effects prong of the Lemon test, which dictates that the principal or primary effect of government action neither advance nor inhibit religion. The Appellate Division, untroubled by that prong, stated simply that “[t]he parties and amici have not urged a violation of this prong of the test.” 243 N.J.Super. at 252, 579 A.2d 316. The Appellate Division erred in concluding that a violation of the effects prong was not an issue in this case. County Kosher contended that the kosher regulations violate the effects prong because their religious impact cannot be separated from their secular impact. The State countered by asserting that “the primary effect of the Regulations is the advancement of consumerism.” In our view, County Kosher was correct.
According to the State, the regulations work as one element of the Consumer Fraud Act and affect only the commercial activities of selling and advertising merchandise. The State asserts that the regulations do not influence religious concerns; rather, kosher food has overcome its purely religious significance and has taken on a secular significance to the general public. See County of Allegheny, supra, 492 U.S. 573, 109 S.Ct. 3086, 106 L.Ed.2d 472 (upholding menorah display adjacent to Christmas tree in park on basis of secular connotations associated with both holidays). The Appellate Division agreed, apparently finding relevant that New York’s experience with its kosher statute “has shown no unwarranted effect.” 243 N.J.Super. at 259, 579 A.2d 316.
We remain unpersuaded by the repeated contention that the laws of kashrut have become secular norms. We are not here confronted with legislation that is religious only in its historical origins but non-religious in its current applications. E.g., McGowan v. Maryland, 366 U.S. 420, 81 S.Ct. 1101, 6 L.Ed.2d 393 (1961) (stating that Sunday closing laws, although religious [164]*164in origin, are applied without reference to religious purpose or principles); Vomado, Inc. v. Hyland, 77 N.J. 347, 390 A.2d 606 (1978), appeal dismissed, 439 U.S. 1123, 99 S.Ct. 1037, 59 L.Ed.2d 84 (1979) (same). The kosher regulations rely expressly on religious tenets concerning what is kosher and who should be trusted to supervise kosher food preparation. Because they work both as a constraint and as an inducement on merchants who must abide by them and on consumers who cannot avoid them, the primary, if not exclusive, effect of the regulatory process necessarily is to advance particular religious tenets.
State action that engenders identification of the government with a religion, or religions in general, constitutes the unconstitutional establishment of religion, for it always will advance at least one religion and, depending on the nature of the governmental activity, it often will inhibit other religions as well. In Grand Rapids School Dist., supra, 473 U.S. at 389, 105 S.Ct. at 3225, 87 L.Ed.2d at 281, the Supreme Court stated that the effects prong is violated “when the government fosters a close identification of its powers and responsibilities with those of any — or all — religious denominations.” Such a close identification plainly is fostered by the enforcement of the kosher regulations, for the State adopts religious law as its own. In addition, as earlier noted, the Chief of the Bureau of Kosher Enforcement and the entire Advisory Committee are rabbis, individuals qualified under Judaic law to interpret the laws of kashrut. Because those individuals are being used by and for the State in their religious capacity to interpret and enforce state law, the religious and civil authority possessed by them is virtually indistinguishable.
Even a symbolic union between government and religion would contravene the effects prong of the Establishment Clause. Grand Rapids School Dist., supra, 473 U.S. at 389, 105 S.Ct. at 3225, 87 L.Ed.2d at 284. Government practices may not “have the effect of communicating a message of government endorsement or disapproval of religion.” Lynch v. [165]*165Donnelly, supra, 465 U.S. at 692, 104 S.Ct. at 1367, 79 L.Ed.2d at 622 (O’Connor, J., concurring). In Larkin v. Grendel’s Den, supra, the Supreme Court observed that “the mere appearance of a joint exercise of legislative authority by Church and State provides a significant symbolic benefit to religion in the minds of some by reason of the power conferred.” Id. at 125-26, 103 S. Ct. at 511, 74 L.Ed.2d at 306. The Court concluded that state action promoting such an image violates the Establishment Clause, for it has “a ‘primary’ and ‘principal’ effect of advancing religion.” Ibid. Here, the symbolism is especially graphic and the benefit to religion more than symbolic: the State is calling on religious personnel to enforce and certify religious compliance.
The dissent intimates that the regulations may have been designed to “accommodate consumers who purchase kosher food for religious reasons,” but that they do not actually advance a particular religious view. Post at 178. However, “an accommodation of religion, in order to be permitted under the Establishment Clause, must lift ‘an identifiable burden on the exercise of religion.’ ” County of Allegheny, supra, 492 U.S. at 613 n. 59, 109 S.Ct. at 3111 n. 59, 106 L.Ed.2d at 507 n. 59 (quoting Corporation of Presiding Bishop of Church of Jesus Christ of Latter-Day Saints v. Amos, 483 U.S. 327, 348, 107 S.Ct. 2862, 2875, 97 L.Ed.2d 273, 291 (1987) (O’Connor, J., concurring). In general, accommodation takes the form of exempting religious groups from laws of general applicability. County of Allegheny, supra, 492 U.S. at 613 n. 59, 109 S. Ct. at 3111 n. 59, 106 L.Ed.2d at 507 n. 59; see Jones v. Butz, 374 F.Supp. 1284, 1292-93 (S.D.N.Y.1974), aff'd, 419 U.S. 806, 95 S.Ct. 22, 42 L.Ed.2d 36 (1974) (holding that the Humane Slaughter Act, 7 U.S. C. §§ 1901 et seq. (1970), permissibly accommodates the free exercise of religion by exempting persons of Jewish faith from generally applicable statutory guidelines that proscribe practices mandated by the laws of kashrut).
[166]*166The regulations at issue in this case do not constitute permissible accommodation of Orthodox Judaism. The Attorney General has not pointed to any state-imposed burdens under which Orthodox Jews currently suffer. If the regulations did not exist, observance of the laws of kashrut would go on, free of state intervention, as it has for thousands of years. The regulations merely serve to advance the form of Orthodox Judaism that the State enforces. “The principle that government may accommodate the free exercise of religion does not supersede the fundamental limitations imposed by the Establishment Clause.” Lee, supra, — US. at-, 112 S.Ct. at 2655, 120 L.Ed.2d at 480.
Finally, to survive an Establishment Clause challenge under the purpose prong of Lemon, the regulations also must have a valid secular purpose. State action is invalid under that prong only when there is “no question that the statute or activity was motivated wholly by religious considerations.” Lynch v. Donnelly, supra, 465 U.S. at 680, 104 S. Ct. at 1362, 79 L.Ed.2d at 614.
The State argues that the “secular legislative purpose” of the regulations is to protect consumers against misrepresentation in the sale of food. The focus of the regulations is on the purchase and sale of kosher food, which “is nothing more than a commercial transaction between the merchant and the consumer” carrying no religious significance. The majority of the Appellate Division concurred in the State’s position, concluding that the regulations had a valid secular purpose, viz, “the protection against intentional and negligent misrepresentation in the sale of Kosher food.” 243 N.J.Super. at 251, 579 A.2d 316.
The conceptual difficulty with that' conclusion is that although the objective of the regulation is to protect against fraudulent sales, the focus of the enforcement provisions is not so limited. That focus is directed to the preparation and maintenance of products in strict compliance with Orthodox [167]*167Jewish doctrine. The regulations authorize a consumer fraud action founded on the fact that the product itself was prepared or maintained in ritually incorrect fashion, in violation of the laws of kashrut. In that respect, the regulations are, as characterized by appellants, “quintessentially and unavoidably religious in character.” The regulations may have been designed to assure truth in marketing, but the truths being marketed are, in essence, religious truths. Troubled though we are by the Appellate Division’s holding, we see no need to delve further into the purpose issue in light of our conclusion that the regulations involve the State excessively in religious matters and generate significant effects serving to advance religious interests.
We thus conclude that the kosher regulations as presently formulated violate the Establishment Clauses of the federal and state constitutions.
Ill
Our decision invalidating the current regulations does not mandate “that the government show a callous indifference to religious groups,” Zorach v. Clauson, 343 U.S. 306, 314, 72 S.Ct. 679, 684, 96 L.Ed. 954, 962 (1952), nor does it leave consumers of kosher products bereft of protections against fraudulent and unscrupulous practices. The State unquestionably has a valid interest in preventing fraud in the sale of any foods, including kosher foods. There are effective ways to achieve that end that will not offend constitutional strictures against state involvement in religion. The State can regulate the advertising and labeling of kosher products. The key to such a regulatory approach would be the religious supervision of the preparation and maintenance of products. The regulation could require those who advertise food products as “kosher” to disclose the basis on which the use of that characterization rests. Many kosher food purveyors would comply by imprinting the symbol of one of the recognized private agencies [168]*168that supervise kosher compliance (e.g., “U” for the Union of Orthodox Jewish Congregations of America). Other kosher establishments could comply with a disclosure requirement by indicating other forms of rabbinical supervision. Such an approach would thus make use of the kosher foods industry’s existing scheme of self-regulation. See, e.g., 243 N.J.Super. at 248 n. 15, 579 A.2d 316.
The enforceability of such regulations would inhere in the notion that they simply would “compel [the merchant] to perform a secular obligation to which he contractually bound himself” by virtue of the fact that merchant represents food as being kosher. Avitzur, supra, 459 N.Y.S.2d at 575, 446 N.E.2d at 138. Just as the State may bar promotion of products as having been tested by a certain testing laboratory when they have not been so tested, and just as the State may bar promotion of products as having been endorsed by a certain consumer magazine when they have not been so endorsed, so may the State bar promotion of products as having been prepared under the supervision of a particular rabbi or group of rabbis when they have not been so prepared. Such a consumer protection law would be based on neutral, secular principles, and would be perfectly compatible with the constitutional strictures against governmental establishment of religion.
The regulations at issue, unfortunately, are not limited to such less intrusive means to protect consumers of kosher foods. As they now stand, the regulations plainly violate constitutional standards. We therefore invalidate those portions of the regulations that impose substantive religious standards for the actual preparation and maintenance of kosher food. We do not invalidate the regulations to the extent that they may require the full and accurate disclosure by kosher establishments of the basis on which they advertise and sell their products as “kosher.”
We reverse the judgment of the Appellate Division and remand the matter to the trial court for the dismissal of the [169]*169State’s consumer fraud complaint. We also remand to the Division of Consumer Affairs for the expeditious reformulation of the regulations in a manner consistent with this opinion. See Texter v. Department of Human Servs., 88 N.J. 376, 443 A.2d 178 (1982).