LaVidaLocalvore has some interesting discussion, with links to further reading, on the new Country Of Origin Labeling (COOL) that is supposed to start this month. COOL is good in and of itself, it should be used to label foods coming into our country so consumers know if their infant formula, milk, dog food, etc came from China in whole or in part. The recent food poisonings coming out of that country emphasis how important it is to know where your food comes from and what is in it. Sadly COOL is filled with exemptions for processed foods making it virtually useless.
A major concern is that COOL will be used to push the USDA’s invasive proposed National Animal Identification System (NAIS) down our throats. The USDA may claim they need 100% voluntary compliance with NAIS to implement COOL.
The FSIS/USDA, which handles labeling issues, is not too clear on exactly what is required for COOL. For example, our pastured pork label gives our address and says “Pastured Pigs Bred, Born & Raised on Our Vermont Farm”. Our label also has our address on it. One would think that meets the COOL requirements very clearly. The pigs are from our farm. They were born here. Our farm is in Vermont. Everyone in the USA knows that Vermont is in the United States - at least they should know so after going through the government’s indoctrination program, er, I mean public education. Ergo, our label quite clearly states the country of origin as being the USA.
But, all is not so clear to people at FSIS/USDA. I asked, “is our label in compliance with COOL” and was told no.
Thank you for your question regarding the country of origin labeling program (COOL). Based on your description, your label is not sufficient to comply with the COOL regulation. This response provides some context which may help determine whether the products derived from your animals are required to bear COOL declarations.
COOL is a consumer right-to-know labeling law that requires retailers to notify their customers of the country of origin of covered commodities. The law defines a retailer as a firm that purchases an invoice amount of perishable agricultural commodities (fresh and frozen fruits and vegetables) in excess of $230,000 per year. In essence, that means most grocery stores and supermarkets. To the extent your products are sold in such regulated retail establishments, those retailers are required to provide country of origin information on products derived from your animals. Sales through a farm stand, farmer’s market, direct sales to consumers or other sales to institutions or food service establishments are exempt from this labeling law.
The law allows the use of state, regional or locality labeling in lieu of the country of origin declaration for perishable agricultural commodities, peanuts, pecans, macadamia nuts and ginseng, only. State, regional or locality designations are not acceptable in lieu of country of origin labeling for meat products. If your products are sold by a retailer subject to this labeling law, the products derived from your animals will have to indicate they are a product of the U.S.
email communications with:
Kenneth M. Becker
Marketing Specialist - Country of Origin Labeling
USDA-AMS, Livestock and Seed Program
Interestingly, I got exactly the opposite answer from another USDA/FSIS supervisor saying our label is fine and Vermont is sufficient on the label since Vermont is in the USA. Logically one would think that this second answer is correct. Not to be snobby but since we sell in Vermont I’m sure all of our customers know that Vermont is within the USA.
I’m not too happy with the idea of throwing away 15,000 labels just because somebody at the USDA who makes regulations doesn’t know their geography. At this point I have asked the butcher if he can print “Made in USA” on the labels when applying the weight and product names to the packages. Maybe that will work as a stop gap measure.
There are the strange clauses in COOL that allow processed foods to be exempted from the labeling. So our hot dogs, which contain our pork, maple syrup, milk and salt are not be required to have a COOL label. Our smoked bacon and hams aren’t required to have COOL labels. Apparently a bag of mixed peas and carrots is exempt from the rules. This exemption seems nonsensical and specifically designed for big producers to sneak around the COOL regulations. After all, the consumer as a right to know, according to Mr. Becker above.
I like the idea of COOL but it should be applied to incoming foods. All foods should be covered, processed or not. State, local and regional designations should obviously be accepted for all foods just as they are for ginseng. COOL appears to be going to be used as a wedge to bring NAIS in our back door - an unpleasant prospect. The USDA calls NAIS voluntary but they’re doing everything they can to force it down our throats and make it mandatory in reality.
COOL is just an interim rule so we’ll see what happens with this flawed implementation of Country Of Origin Labeling. COOL definitely has the flavor of one step forward, a step to the side and two steps backward.