COOL Clarified

Country-of-origin labeling (COOL) requirements outlined in the 2002 Farm Bill have drawn mixed reviews.

U.S. farm groups generally support the proposal. Food companies and meat packers oppose it, saying it is unnecessary and costly. Canadian commodity groups, likewise, stand in opposition (see related story, below).

As the Sept. 30 Congressional deadline drew near, USDA officials admitted the final regulations for voluntary country-of-origin labels for meat, produce and fish would not be ready until December, at the earliest.

The American Meat Institute (AMI) and Food Marketing Institute have joined forces to call off proposed legislation to mandate labeling on meat products.

AMI President J. Patrick Boyle calls it the most costly, cumbersome and complex labeling proposal in history. He predicts consumers would likely never see the labels USDA described because the program would be impossible to implement. He says the proposal would result in hundreds, maybe thousands, of product labels describing where livestock were raised, fed and slaughtered.

Last March, National Pork Producers Council (NPPC) delegates rejected a resolution drafted in support of the COOL concept. NPPC CEO Neil Dierks explains: “NPPC favors flexibility in the marketplace and opposes mandatory labeling.”

Proposed Guidelines

Key points in COOL's voluntary guidelines affecting pork:

  • Only pork raised and processed in the U.S. can carry a U.S. Country of Origin product label.

  • Initially, labeling is voluntary; USDA must have regulations for a mandatory program ready by Sept. 30, 2004, when all retailers must comply.

  • “Retailer” is defined as any person who buys or sells perishable agricultural products solely for retail sale with a cumulative invoice value of more than $230,000 in a calendar year. Butcher shops and other marketers below that amount are exempt.

  • Restaurants and other foodservice vendors are exempt.

  • “Covered commodities” are defined in the voluntary guidelines as fresh or frozen muscle cuts of pork and ground pork. Covered commodities are excluded if they are an “ingredient in a processed food item” such as fresh pork sausage.

  • Covered commodities must be derived exclusively from animals born, raised and slaughtered in the U.S.

  • Labels from products of “mixed origin” (originating in more than one country) will designate which production processes occurred in the respective countries. And, when a product from two or more countries is blended, the label must indicate, in descending order by weight, the country of origin for each product: for example, U.S., Canadian and Mexican origin.

  • To verify that pork products are properly labeled at the retail level, records must be maintained from birth to retail.

  • Country of origin notification to consumers may be in the form of stamps, labels, placards or other clear and visible signs on the covered commodity or the package, display or bin at the final point of sale.

  • Compliance with the guidelines will not be enforced during the voluntary period; however, choosing to adopt the voluntary guidelines for one or more covered commodities means that all guideline provisions must be followed for the items labeled for country of origin.

More information on the voluntary guidelines is available by contacting William Sessions, Associate Deputy Administrator, Livestock and Seed Program, AMS, USDA, at: Submissions are encouraged until April 2003, when work begins on mandatory labeling.

The full text of the voluntary guidelines is available at

  1. What commodities require a label?

    • Muscle cuts of beef, lamb and pork

    • Ground beef, ground lamb and ground pork

    • Farm-raised and wild fish and shellfish

    • Perishable agricultural commodities (fresh fruits and vegetables as defined by the Perishable Agricultural Commodities Act)

    • Peanuts
  2. Of the meat mentioned above, what qualifies for the label?

    • Meat exclusively from an animal that is born, raised and slaughtered in the U.S.

  3. What must the label include?

    • The name of the country from which the product originated

  4. Besides the traditional definition of a “label,” what else qualifies as a label?

    • Stamps
    • Marks
    • Placards
    • Other clear and visible signs
  5. Where can the label appear?

    • On the commodity
    • On a package
    • On a display
    • On a holding unit containing the commodity
    • On a bin containing the commodity
  6. Who is required to supply the country-of-origin information to the retailer?

    • Participants in the marketing chain.
  7. What happens to retailers who willfully don't comply?

    • USDA may fine them up to $10,000.
  8. Can the secretary of agriculture use a mandatory identification system to verify the country of origin?

    • No, but she can use existing certification programs as a model.