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Comments Criticize USDA’s COOL Proposal

The American Meat Institute (AMI) has filed comments criticizing the U.S. Department of Agriculture’s (USDA) proposed amendment to mandatory country-of-origin labeling (COOL). The deadline for filing is today on the proposed rule of March 12, 2013 issued by USDA’s Agricultural Marketing Service.

In its letter of April 9, AMI suggests its member companies will be “significantly and adversely affected by the proposal” in that it would “force every supplier and every retailer to change its labeling information and systems.”

If enacted, the proposal would result in the closing of several meat packing plants because of the costs plants would be forced to incur in order to implement the proposal’s requirements.

“In effect, the agency is picking winners and losers in the marketplace in order to provide information to consumers that recent research shows they care little about and do not wish to pay for,” AMI’s letter  emphasizes.

Moreover, it is clear that the proposal will not bring the United States into compliance with the World Trade Organization’s (WTO) Appellate Body (AB) ruling.

The AB ruling stated that the lack of recordkeeping and verification requirements on one hand, and the limited consumer information on retail labeling on the other hand, were of central importance in its overall analysis.

Further, in reaching its finding of detrimental impact, the AB panel indicated the recordkeeping and verification requirements contained in the COOL proposal would “necessitate” segregation and create an incentive for U.S. producers to process exclusively domestic livestock and a disincentive to process imported livestock.

For those reasons, AMI urges AMS to withdrawal its COOL proposal and seek a solution that will not result in a number of meat packers likely going out of business if the current proposal is allowed to be promulgated and placed into effect.

The complete letter can be accessed at

The United States has until May 23 to comply with its WTO obligations.

If the COOL proposal is enforced, Canada has threatened about $1 billion in retaliatory measures on a variety of U.S. goods including beef and pork.




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