Pac Foods had a representative in Los Angeles, CA for the October 9th Country of Origin Labeling Informational Session. About 35 people attended the conference, and many were eager to have their questions answered by Craig Morris, USDA Deputy Administrator. Here is a breakdown of some of the questions that were on everyone's mind:
- Anything produced before Sept. 30th does not need COOL labeling. One attendee noted that her customer was asking for the information on product prior to the cut off date, to which the speaker replied that a business will have to work with the customer to give them what they require. Dr. Morris also mentioned that the customer has a right to ask for more than is required by C.O.O.L law- meaning just because suppliers are stamping boxes with the country of origin, doesn't mean customers cannot requesrt it also show up on the recieving paperwork.
- Speaking of that receiving paperwork, if only the boxes for your product come stamped, be prepared to get out the camera or call your supplier; simply writing down what you see on the box is not sufficient recording for C.O.O.L. You need to keep either the box, photo, or paperwork from the supplier for at least a year.
- Beyond the customer requiring more paperwork, some at the session reported that they were being contacted for 3rd party audits to ensure they were complying with C.O.O.L. Dr. Morris stated that the USDA does not train 3rd party audit agencies, but that the customer has the right to request the audits.
- What you tell your customer has to match what your supplier told you. You can't simply list a dozen countries on your sign or invoice and hope you included the right country of origin for that product. Also, if you are listing something of mixed origin, and you know the product has only come from one country for over 60 days, you are in violation of C.O.O.L law.
- There was a lot of discussion on what "significantly altering" meat to make it exempt means. The speaker gave an example that just placing salmon on ceder does not change it, but blackening it with spices would exempt it from C.O.O.L. We also learned that simply injecting meats with sodium phosphates, even though they are called marinated, does not make them exempt.
- C.O.O.L is a marketing law- not a food safety law.
- After three years of the C.O.O.L fish & shellfish program being active, they have never issued a fine.
Overall, the people from the USDA were very helpful in answering questions, although it was clear that some people are very frustrated with the new laws. In a few weeks, PacFoods will post audio from the session so readers can hear the presentation in its entirety.
Something the AMS representatives wanted to emphasize was that the next six months are a learning time for everyone, and that there is no "play book" for the auditers yet. If you have questions or need guidance, writing to cool@usda.gov will get you a prompt response and some help. They also encouraged sending in PDF files with examples pertaining to your questions.
You can read more about the C.O.O.L program at the AMS website.
