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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