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COOL - Country of Origin Labelling in the United States
Background on COOL
New US legislation requiring
country of origin labelling (COOL) for agricultural commodities was enacted
on May 13, 2002 when the Farm Security and Rural Investment Act of 2002,
more commonly known as the 2002 Farm Bill was signed by President Bush.
The legislation requires mandatory labelling for beef, lamb, pork, fish,
perishable agricultural commodities and peanuts at certain retail outlets.
The stated purpose of the legislation is to enable US consumers to choose
the origin of the food they purchase. Since the discovery of bovine spongiform
encephalopathy in North America, proponents have argued that COOL is also
about food safety. This assertion is false. Both our countries have excellent
food inspection systems. COOL is a retail marketing measure and has nothing
to do with food safety.
On October 11, 2003 an interim voluntary country of origin labelling program
was implemented that is effective until the measure is made mandatory.
The program guidelines are available at: http://www.ams.usda.gov/cool/ls0213.pdf.
A proposed final rule outlining regulations to implement mandatory COOL
was published on October 30, 2003 with a 60 day comment period. The comment
period was subsequently extended a further 60 days until February 27,
2004. In January of 2004, the COOL law was amended to delay its implementation
until September 30, 2006 for all covered commodities except fish and seafood.
COOL will become mandatory for fish and seafood on September 30, 2004.
In the United States, supporters of the legislation advocate COOL because
it promotes US products to consumers. There are many groups, however,
that do not support COOL because there is no possibility of recouping
the heavy costs of implementing the complex requirements. For example,
for meat to qualify for a "product of U.S." label, the animal
from which it was derived must have been born, raised, and slaughtered
entirely in the U.S. For products produced in our integrated North American
market, the country in which each of these production points occurred
must appear on the label. US industry is required to keep verifiable records
to substantiate this level of detail on retail labels. Implementation
costs for the first year alone have been estimated at nearly US$4 billion
by USDA.
Effects on Canada – US Trade
The mandatory COOL legislation will restrict trade, especially for the
red meat sector. US processors, distributors and retailers have indicated
that they will reduce the number of sources of covered commodities in
an effort to reduce their implementation costs for segregating, tracking
and keeping records. Industry, the Government of Canada and the provinces
have been lobbying US politicians and industry stakeholders to have the
law repealed. The delay of COOL until 2006 except for fish is a result
of the US industry opposition that has been generated to oppose the measure.
Comments have been sent to the USDA outlining the Canadian position. Comments
can be viewed on the USDA-AMS website: http://www.ams.usda.gov/cool.
Effects on Canadian Sheep Industry
In our industry, two main positions have been expressed. Most producers
fear that COOL will severely harm the sheep industry, especially in Alberta
where large numbers of live animals are exported to the United States
from feedlots. Conversely, others believe that COOL may create an opportunity
for Canada to expand its processing capacity to provide meat to the US
market because the tracking costs in the US for imported meat could be
substantially less than what is proposed even for domestic animals slaughtered
in the US under this law.
In 2002, before BSE was discovered in Canada, the Canadian sheep industry
exported 121, 197 animals to the United States including slaughter lambs
and feeder sheep and lambs (Agriculture and Agri-Food Canada Red Meat
Section).
The Canadian Sheep Federation has been closely following this issue. In
conjunction with its efforts to have the BSE import bans lifted, it has
been carrying out trade advocacy activities to inform U.S. stakeholders
of our common interests in continuing to integrate our markets.
If you would like to express your concerns or opinions on how this issue
will affect the sheep industry, please email the Executive Director at
cansheep@cansheep.ca or write
to: P.O. Box 5451 Ottawa, ON K2C 3M1.
More information on the US COOL law is available on the Agricultural Marketing
Service (AMS) website: http://www.ams.usda.gov/cool.
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