C.O.O.L.
Country Of Origin Labeling

By Gretchen Morfogen

The mandatory country of origin labeling law requires many, but not all, retailers to ensure that country of origin information is provided for certain beef, lamb, and pork products (covered commodities). The law also directs the Secretary of Agriculture to issue regulations to implement these labeling requirements. USDA is expected to publish an interim final rule implementing the law. Because that publication is not a final rule, some aspects of the regulation could still be subject to change.

Packers and processors that supply covered commodities to their retail customers must provide COOL information to the retailers. That information can be provided to retailers in a number of ways, including providing the labels to the retailer or labeling the product directly.

Work through this set of questions and you should be able to determine whether COOL applies to the products you buy. A meat product from beef (including veal), pork, lamb, chicken or goat must bear a COOL label or is subject to labeling providing COOL information if:
1. It is sold at retail, AND
2. It is a muscle cut, or
3. It is a ground product
The product is EXEMPT from COOL labeling requirements if:
1. The meat product is sold at foodservice (e.g., restaurants, institutions, etc.),
2. The meat product has undergone specific processing resulting in a change of character (e.g. cooking, curing, smoking or restructuring) or has been combined with at least one other covered commodity or other substantive food component. The exemption includes, for example, the following:
a. Hot dogs and sausages
b. Lunch meat
c. Cooked products
d. Breaded products
e. Cured products
f. Products in which the meat is an ingredient (e.g., spaghetti sauce with meat)
g. Fabricated steak
h. Meatloaf
i. Marinated pork tenderloin

FAQ regarding the COOL law


Will country-of-origin labels raise the cost of meat?
USDA estimated the cost to implement mandatory country-of-origin labeling in the first year alone will be about $2.5 billion. Given the costs associated with record-keeping and the necessary segregation of livestock and meat in plants based on their origin that will be critical in ensuring label accuracy, that number could be too low. How these costs will be spread across meat products and how much prices will rise is yet to be determined.

How do these labels benefit consumers?
Congress has determined that country-of-origin labels are important to consumers. Whether consumers will pay more and if so how much more they will pay at a time when prices are hitting record levels due to spiking livestock feed prices remains in question.

Don't these labels already exist?
Currently, finished products in consumer packaging that are imported from other countries, such as Danish hams or Canadian pork loins, for example, say "Product of Denmark" or "Product of Canada." Before September 30, 2008, if meat was processed in the U.S., it was considered a U.S. product and no labeling was required detailing its geographic history.

Why doesn't this labeling rule apply to foodservice or processed meat products?
Congress determined that products intended for foodservice and processed meat products should be exempt from the law.

How much meat is imported from Mexico?
Very little. However, many young cattle are imported from Mexico and are subsequently raised and processed in the U.S. If you see a beef product bearing the label "Product of U.S. and Mexico," that label reflects the fact that the animal was born in Mexico, but raised from an early age in the U.S. and then processed.
Are imported meat products as safe as U.S. products?

Exporting meat products to the U.S. is not easy because the U.S. government requires that these products meet the same high standards as U.S. products. To be eligible to export to the U.S., a foreign country's inspection system has to be found by USDA to be equivalent to the U.S. system. In addition, meat plants in other countries that wish to export must document that they are following U.S. food safety standards or standards that are equivalent to U.S. standards. These plants must be certified by the USDA. When the meat products arrive at the U.S. border, they are subject to more safety inspections. Finally, if the imported meat is further processed in the U.S., it is subject again to the inspection requirements administered by USDA. Only a limited number of plants within a limited number of nations meet these tough standards. U.S. meat companies wouldn't buy these products, use them in production, and apply the U.S. company label if they weren't confident in the imported product's safety.

This information has been provided to you in order for you to be more informed about the changes in our food safety laws and how it might affect you, the consumer.

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