|
 |
 |
Country of Origin Labeling (COL)
USDA Posts Q & A
(9.12.08) The U.S. Department of Agriculture has posted a question and answer report that memorializes many of the
Agency's recent interpretations of the interim final rule. To download the question and answer report, click here.
On the meat side, USDA requires retailers to use "and" or a comma when
indicating that product comes from multiple countries (and not to use
"or" or "and/or"). In addition, USDA clearly states that retailers can
designate Category A product as Category B (e.g., Product of US +
Product of US, Canada, Mexico can be labeled "Product of US, Canada,
Mexico) and permits the use of Category B and Category C with a single
declaration (Product of US, Canada, Mexico + Product of Canada, US can
be labeled "Product of Canada, US and Mexico.")
The next question will be how to translate this for purposes
of a single sign -- those issues are not addressed here. This document does
also formalize the Agency's non-controversial decision to reference the
Institutional Meat Processing Standards (IMPS) to distinguish between
whole muscle cuts and variety meats (such as cheek or heart meat), which
are not subject to COL when displayed on their own but whose country of
origin must be indicated when used in ground product.
On the produce side, USDA confirms that it will use grade standards to
determine whether a combination of multiple covered commodities
constitutes a processed product. Specifically, if the items each have
separate grade standards (as honeydews, canteloupes, and watermelons
do), then a combination of the products will be considered "processed"
and not subject to COL.
Although grade standards will seem esoteric,
ultimately, they provide a "bright line" standard and the produce that
common sense suggests would be different are supported by the grade
standard approach. The link to the grade standards is here. (If it
doesn't work, go to www.ams.usda.gov, click on Grading, Standards and
Certification on the left hand side, and keep following the "Standards"
links until you reach the ones for produce.)
|
On May 13, 2002, the Farm Security and Rural Investment Act of 2002, more commonly known as the 2002 Farm Bill, became law. One of its many provisions requires country of origin labeling (COOL) for beef, lamb, pork, fish, perishable agricultural commodities, and peanuts. On January 27, 2004, Public Law 108-199 delayed implementation of mandatory COOL for all covered commodities except wild and farm-raised fish and shellfish until September 30, 2006.
On November 10, 2005, Public Law 109-97 delayed implementation of mandatory COOL for all covered commodities except wild and farm-raised fish and shellfish until September 30, 2008. As described in the legislation, program implementation is the responsibility of USDA’s Agricultural Marketing Service.
The recently enacted Food, Conservation and Energy Act of 2008 (2008 Farm Bill) expands the list of covered commodities to include chicken, goat meat, ginseng, pecans and macadamia nuts.
COOL Update (7.24.2009)
The Food Marketing Institute has released updated information regarding COOL and frozen fruits and vegetables. To read the update, click here.
Listed below are links to various COL websites to help retailers/suppliers.
2008 Farm Bill Side-By-Side Comparison - U.S. Department of Agriculture
U.S. Department of Agriculture - COL Interim Final Rule
U.S. Department of Agriculture - USDA Country of Origin Labeling homepage
National Grocers Association - Special Report. This NGA Special Report summarizes for retailers and wholesalers the requirements of the new interim rule for meat and produce.
Customer Question and Answer - Answers to commonly asked consumer questions regarding COL
Food Marketing Institute
American Meat Institute
|
|
|