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COOL enters mandatory implementation

by Wyoming Livestock Roundup

Casper – According to a flurry of press releases leading up to and following Oct. 1 – the date County of Origin Labeling (COOL) took effect – many parties with a stake in the debate are concerned the USDA’s interim final rule (IFR) may not be following Congress’ intent.
    “While the IFR shows marked improvement over previously published COOL regulations, a considerable loophole remains within a critical provision of the rule that addresses how a mixed origin label can be applied to beef,” says U.S. Cattlemen’s Association President Jon Wooster of San Lucas, Calif. “A carefully crafted compromise passed by Congress, reached through sensitive negotiations during Congressional debate over the Farm Bill, is very specific about how and when packers could apply a mixed origin label. Currently, the IFR language undermines the entire country of origin labeling program for beef. There is a chasm of difference between the statutory language passed by Congress and that within the rule drafted by USDA.”
    Wooster says that, according to the rule, beef from an animal exclusively born, raised and slaughtered in the U.S. may not be labeled with a multiple countries label because such animals do not meet the criteria in the statute. Meat from these animals must be labeled as U.S. origin under the statute.
    “USDA’s clarification of this provision does not ensure the statute will be faithfully implemented,” continues Wooster. “The clarification states that U.S. origin beef will only be permitted to be labeled with the multiple countries label if U.S. beef is produced on the same day as that of imported product. In this case, packers could circumvent the law by processing at least one imported animal each day and then mislabeling the beef from all U.S. animals processed that day.”
    The American Meat Institute (AMI) says the U.S. meat industry had to work hard to change course on mandatory country of origin label implementation because of USDA’s revision of implementation guidelines four days before the rule took effect.
    AMI President J. Patrick Boyle says the USDA had built needed flexibility into its earlier labeling implementation guidance. “Under the previous guidance, retailers could have opted to sell meat from cattle born in Canada and Mexico but raised and processed in a U.S. meat plant as a product of the U.S., Canada and Mexico,” he says. “This would have helped packers control the costs associated with segregating livestock and meat, and retailers from having to manage multiple labels.”
    He says the flexibility allowed in USDA’s earlier guidance helped reduce first-year implementation costs to $2.5 billion from the estimated $3.9 billion. “USDA’s change four days prior to implementation is likely to drive costs back up to the original $3.9 billion proposal. Those costs will be passed on in the form of higher meat prices. Sadly, this increase comes at a time when consumers can ill afford it,” he comments.
    According to a release from the Wyoming Stock Growers Association (WSGA), during the first six months USDA’s Agriculture Marketing Service will conduct an industry education and outreach program, during which no citations for violations will be issued. Boyle says that with the last-minute changes the industry will need to make extensive changes to procurement, segregation and labeling. “This will require additional time to ensure compliance,” he says.
    Research at grocery stores in Casper reveals varying levels of education on the part of meat department managers. While some have heard nothing of impending labeling requirements from COOL, others, such at the meat department at Albertson’s, changed the labels of their beef and chicken beginning Oct. 1. The Albertson’s meat department manager says the switch wasn’t difficult on their level – merely a matter of adding the additional information to the meat’s label.
    The WSGA says livestock producers should immediately begin to provide proof of origin. The rules provide that an affidavit can serve as proof of origin and USDA has approved several affidavits which WSGA is making available for download from their website, Forms may also be requested in hard copy or by fax by contacting the WSGA office at 307-638-3942.
    Christy Hemken is assistant editor of the Wyoming Livestock Roundup and can be reached at

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