How Will COOL Affect You?

Implementation of Country Of Origin Labeling (COOL) was one of the main initiatives of the 2002 Farm Bill and will apply to beef, pork, lamb, fish, perishable agricultural commodities and peanuts. Program implementation of COOL is the responsibility of the United States Department of Agriculture, Agricultural Marketing Service (USDA-AMS).

On Oct. 8, 2002, USDA-AMS published interim voluntary guidelines for COOL and the rule becomes mandatory on Sept. 30, 2004. The guidelines outline standards indicating that COOL will be the primary responsibility of retailers to indicate the country of origin on meat (excluding poultry), perishable agricultural products and peanuts. Food service operators, including restaurants, lunchrooms, cafeterias, food stands, bars and lounges, are exempt from the regulation.

Under the guidelines, a retailer can label a covered commodity with "United States Country of Origin" if certain criteria are met. For beef, the covered commodities must be derived exclusively from animals born, raised and slaughtered in the United States, including animals that were born in Alaska or Hawaii and transported for a period not to exceed 60 days through Canada to the United States and slaughtered in the United States. Fresh and frozen fruits, vegetables and peanut covered commodities must be derived exclusively from produce or peanuts grown, packed and if applicable, processed in the United States.

The law requires retailers to label, at the final point of sale, beef, lamb and pork, fish, shellfish, perishable ag commodities and peanuts as to their country of origin and further label fish as either wild or farm-raised. The law defines retailer as a business that sell fresh or frozen fruit and vegetables with an annual invoice value of more than $230,000. By using this definition, Congress exempts butcher shops, fish markets and small retailers, in addition to the restaurants and other food service establishments the bill specifically exempts from the labeling requirements.

The guidelines also provide guidance for products of mixed origin including products produced both in foreign markets and in the United States as well as labeling for blended or mixed products. Products with an origin that includes production or processing steps that occurred in more than one country could need to bear labels that identify all those countries. There is no "I don't know" classification. Livestock of unknown origin must be sent through the food service sector of the industry.

In compliance with the regulation, retailers will be required to maintain an auditable record system, with a verifiable trail. Records must be kept for at least two years. As such, a person engaged in the business of supplying a covered commodity to a retailer must make information available to the retailer indicating the country of origin.

To find out how COOL will impact your business or farm, the U of M is holding a COOL session on June 24 at the St. Paul campus Earle Brown Continuing Education Center. For more information on COOL or the informational session, contact Deb Roeber at 612-624-2405 or droeber@umn.edu.

If you cannot attend the COOL session at the U of M, or if you have further questions about COOL, the voluntary guidelines or related Farm Bill provisions, go to the COOL Web site.