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Country of Origin Labelling is the next step to an entirely open marketplace for the US. In an ideal supermarket, consumers can understand as well as see the product that they are purchasing and they can monitor the system of production which has brought it to their aisles. But what are the real issues that follow this dream, asks Adam Anson, reporting for TheFishSite, and what implications does COOL bring back to the producer?

The long awaited Country of Origin Labeling rules - widely abbreviated to COOL - came into effect in America on the 30th of September. The belief is that by tracking food items from farm to fork the department of agriculture will be better equipped to monitor where the food chain safety precautions break down when things go wrong. Diseases could theoretically be tracked and stopped before they reach consumer's plates, but the implications of COOL hold further promises for the consumer.

In this age of variety and choice, consumers want to know where their food comes from. A Consumer Reports poll last year found that 92 per cent of Americans agree that imported foods should be labelled by their country of origin. Not only do they want that assurance that they are buying a safe product from a reliable producer but they also want to know what industries and communities they are supporting or boycotting with their money; be they local, deprived, ethical, or eco-friendly.

For a long time these things have been in the hands of big businesses, but now the control is sliding back to the buyer. Public relations are the political campaigns of the marketplace and without it, big businesses are powerless.

COOL will undoubtedly put pressure - the kind producers actually feel and listen to - on countries to prioritize food quality. This, in turn, is a real incentive for the entire food sector to to make sure they are putting out a reliable product, for any error will tar each and every producer, no matter how scrupulous they are. Whether this is a detrimental link for the producer or not, we are yet to find out.

The Reality of a Label

A Summary of the Detail

The rule covers muscle cuts and ground beef (including veal), lamb, chicken, goat, and pork; perishable agricultural commodities (fresh and frozen fruits and vegetables); macadamia nuts; pecans; ginseng; and peanuts -- as required by the 2002 and 2008 Farm Bills. USDA implemented the COOL program for fish and shellfish covered commodities in October 2004.

According to the USDA, commodities covered under COOL must be labeled at retail to indicate their country of origin. However, they are excluded from mandatory COOL if they are an ingredient in a processed food item.

USDA has also revised the definition of a processed food item so that items derived from a covered commodity that has undergone a physical or chemical change (e.g., cooking, curing, smoking) or that has been combined with other covered commodities or other substantive food components (e.g., chocolate, breading, tomato sauce) are excluded from COOL labeling.

Food service establishments, such as restaurants, lunchrooms, cafeterias, food stands, bars, lounges, and similar enterprises are exempt from the mandatory country of origin labeling requirements.

The rule outlines the requirements for labeling covered commodities. It reduces the record keeping retention requirements for suppliers and centrally-located retail records to one year and removes the requirement to maintain records at the retail store. The law provides for penalties for both suppliers and retailers found in violation of the law of up to $1,000 per violation.

The rule prescribes specific criteria that must be met for a covered commodity to bear a "United States country of origin" declaration. In addition, the rule also contains provisions for labeling covered commodities of foreign origin, meat products from multiple origins, ground meat products, as well as commingled covered commodities.

So what are the requirements of COOL? According to the United States Department of Agriculture, items that do not need to be labelled are "Meat, poultry, and fish purchased in annual amounts under $230,000; organ meats; processed foods; mixtures; and restaurant and cafeteria food, which includes salad bars, even supermarket salad bars."

Most smaller butcher shops and fish markets won't exceed the $230,000. It is estimated that maybe 15 percent of all the meat sold in Nebraska will be exempted

The USDA predicts little economic benefit from the new labels and says their biggest impact will be additional cost. Analysts have concluded that the labels will cost 1.2 million farmers and food businesses a combined $2.5 billion to implement in the first year. The estimate includes new paperwork requirements and possible changes to plant operations, line processing, product handling and storage.

USDA analysts say the higher costs will bump food prices up, although by less than 1 cent per pound for affected products.
Probably the most extensive changes will affect meat. About 10 percent of hogs and cattle slaughtered each year in U.S. packinghouses -- about 10 million hogs and 2.5 million cattle -- were born in Mexico or Canada.

But USDA officials say the new labels are no guarantee of food quality. The change is being implemented by the marketing arm of the USDA, not its Food Safety and Inspection Service.

In many ways it is not a food safety provision at all, but purely a marketing provision. Both imported and domestic food will continue to be subject to existing food safety standards

Trouble Ahead?

The National Farmers' Union of the Unites States has been a steadfast supporter of the labeling law and played a key role in negotiating the compromise that allowed for the provision to be included in the 2008 Farm Bill. However, NFU President Tom Buis expressed several concerns with USDA’s interpretation.

Although the feeders selling cattle to the meatpackers will provide documentation about where their animals were born, some meatpackers say it will be difficult and expensive to maintain separate identification of foreign-born and native-born animals as they move through the packinghouse.

Some packers may opt to label their meat as products of the U.S., Canada and Mexico, rather than attempt to claim an exclusively U.S. origin for only part of their production. Farm groups have criticized that strategy, saying it would defeat the purpose of labeling .

The Government of Canada is disappointed the U.S. is moving forward with the COOL legislation. Minister Ritz said: "The possibility that this may discriminate against Canadian products is a concern, therefore, the Government of Canada is working with industry and the provinces and territories to minimize any impact on Canadian farmers and ranchers."

Further Reading

- You can view the Interim Final Rule by clicking here.
- You can view the 2004 Interim Rule for Fish and Shellfish by clicking here.

October 2008

the Fish Site Editor

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