Sunday, September 7, 2008

Are you ready for COOL?

COOL is the country of origin labeling law that was enacted in 2002, but delayed repeatedly, until the 2008 Farm Bill expanded the categories of food that needed to be labeled. The final date was set for mandatory implementation on September 30th of this year. From NewswireToday.com:
The Country of Origin Labeling law (COOL) will become effective on September 30, 2008. All Cool covered commodity, livestock, produce, fowl, fish, shellfish, nuts and peanuts will have a means of traceability records for the AMS USDA COOL Law. Retailers have to provide to consumers the country of origin, by a label on the package or be fined $1000.00 per item. These retail markets will not purchase products which are not compliant with the COOL law, and they can audit your records if you are producer/grower or a packer-shipper. Any person engaged in the business of supplying a covered commodity to a retailer, whether directly or indirectly, must maintain records to establish and identify the immediate previous source in the food chain.
If you weren't confused already, they also just threw in one more rule. Meat AMI explains:

The U.S. Department of Agriculture's Food Safety and Inspection Service (FSIS) has issued an interim final rule (IFR) allowing for generic approval of changes to meat and poultry product labeling necessitated by mandatory country of origin labeling (COOL). To be consistent with the COOL statute and the Agricultural Marketing Service (AMS) IFR published on August 1, 2008, the FSIS IFR also will become effective on September 30, 2008, and its provisions do not apply to covered commodities produced or packaged before September 30, 2008.

Because many meat and chicken products are covered commodities under COOL, FSIS is amending its regulations to 1) provide that adding country of origin labeling statements to comply with the AMS IFR will be considered to be generically approved and 2) require that a country of origin statement on the label of a meat or poultry product that is a covered commodity to be sold by a retailer must comply with the AMS’ interim final rule.

So how do you know if you need to be COOL ready, or if you are buying from a COOL compliant company? Where do you start? I suggest begenning at the scource: the AMS has very comprehensive training materials you can download directly from their site by clicking here, including training presentations, exams, and quizzes. They also have a lengthy but informative pdf of questions and answers you can find here.

Also in the works in a new site called countryoforiginlabel.org. While they do not have all of their information up yet, look to this site in the coming weeks for information and help understanding and implementing COOL.

Finally, The Cattle Network has a breakdown of the changes from the 2002 Farm Bill that will be part of the 2008 COOL program, including that differences in foods that are covered.

Further Reading:

Wisconsin Ag Connection on the Interin Final COOL rule.

Americans For Country of Origin Labeling

The Beef Association overview of COOL, including a timeline.