Meat + Poultry - May 2008 - 14

COMMENTARY

Prepare for COOL

f you're hoping mandated countryof origin labeling won't go into effect as scheduled on Sept. 30, 2008,
be prepared because like it or not....
COOL is here to stay.
COOL's scope is peculiar, at best.
Language mandating country-of-origin
labeling on fresh muscle cuts of beef,
lamb and pork; ground beef, ground
lamb and ground pork; farm-raised
fish, wild fish, perishable agricultural
commodities and peanuts was included
in the 2002 Farm Bill. It applies only
to fresh, red-meat products sold at retail - and not poultry, foodservice or
processed meat products.
But now there are a number of
proposed amendments in Senate and
House versions to the existing statutory structure in the current proposed
Farm Bill. The Senate version would
amend some of the record-keeping requirements and penalty provisions plus
include chicken - which the chicken
industry actually requested - among
other things.
Opponents say COOL was championed by proponents who believe
products identified as American in
origin will appeal more to American
consumers and hopefully enhance
sales of red-meat products "Made in
America." Some proponents feel it is
also a food-safety issue. Regardless,

the price tag of COOL requirements
will be staggering: it will cost $2.4 billion for meat packers and processors,
according to U.S. Dept. of Agriculture
estimates - but that's only for the firstyear implementation.

COOL requirements
Under COOL, retailers are responsible
for informing consumers about product origins at the point of sale by using a label, stamp, mark or signage
on the product or package or on the
display holding unit or bin containing the product. Companies supplying
each COOL meat commodity to retailers must also provide information as
to the product's country-of-origin. Under the COOL law, a red-meat product
can feature a "Product of the United
States" label only if the animal the
product derives from was born, raised
and slaughtered in this country.
COOL opponents warn that its complicated format will result in cumbersome, confusing labels. Pork from hogs
born in Canada and raised and slaughtered in the United States could feature labeling stating: "From hogs born
in Canada, raised and slaughtered in
the United States." Ground beef from
beef blended during the grinding process would have labeling featuring
the applicable country or countries....

alphabetically. Such a label could read
"Beef from cattle with the following
countries of origin: Born and raised in
Canada and slaughtered in the United States; Born in Mexico, raised and
slaughtered in the United States; Born
in New Zealand; raised and slaughtered in the United States."

Either way, it's here to stay
If the Farm Bill becomes reality, USDA
must re-write parts of the law that will
change due to the adding of certain
amendments plus offer a comment
period, Mark Dopp, AMI senior vice
president, regulatory affairs & general
counsel, told me recently. Even if the
Farm Bill dies, it is likely there will be
attempts to attach current COOL-related amendments proposed in the Farm
Bill to other pieces of legislation that
would likely become law, he adds.
The bottom line: Expect COOL to
come into effect as scheduled as an
interim fi nal rule. A fi nal rule may
come as much as a year later, which
gives USDA time to get comments on
new proposed amendments as well
as to work with retailers and processors to get them up to speed on the
process.
AMI is advising its members to be
prepared to implement COOL as quickly as possible. "Does that mean on Oct.
1 everyone needs COOL labeling on
their products? I don't expect that will
be the case, but the law will go into
effect on Sept. 30," Dopp says.
AMI has also updated its countryof-origin labeling implementation Web
site to help industry move forward on
this process.
How something that should be a
voluntary marketing matter became
mandated is beyond me, but that's water under the bridge. What's important
now for industry is to be prepared for
COOL. It's here to stay.
By Bryan Salvage, Senior Editor
bsalvage@sosland.com

MEAT&POULTRY

May 2008

www.MEATPOULTRY.com

http://www.MEATPOULTRY.com

Meat + Poultry - May 2008

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