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COOL: Still a moving target

00:00AM Sep 24, 2008

By Kim Watson, Beef Today editor

With implementation less than a week away, there are still many questions regarding how the mandatory Country of Origin Labeling law will be implemented. In fact, comments are still being taken on the rule.

In any case, producers, packers and retailers are ramping up to learn more about how to comply with the new law. At a CME Webinar on mandatory COOL today, Derrell Peel, livestock economist at Oklahoma State University said, "Anything that we say will be valid for this moment, but it is still likely to change." While COOL impacts other commodities, the Webinar focused on beef and pork.

This first 6 months under the rule, there will be a grace period in order to educate and help all segments comply with the law. USDA's Agriculture Marketing Service will be conducting 3 informational seminars:

  • September 26 in College Station, Texas.
  • October 7 in Minneapolis-Lakeview, Minn.
  • October 9 in Los Angeles, Calif.

USDA will enforce and require an audit trail from packers to ensure products are in compliance at the retail level. It is expected that those packers impacted by COOL will then require documentation from suppliers. Record keeping requirements are expected to be flexible and records used in the "normal course of business" should suffice. Suppliers must make COOL information available to the purchaser, and the industry has come up with affidavit forms to serve as documentation.

For hog producers, those affidavit forms will most likely come from packers, says Steve Meyer, president of Paragon Economics. For beef producers, sample affidavits are already available on the web through NCBA and some auction barns may start providing those forms as well. Producers also need to remember that animals born or imported before July 15 of this year are considered U.S. origin.

Even with implementation, there are still question over how valuable this information will be to consumers. Some retailers are saying they want product labeled as from the USA. However, Meyer says, that if those same retailers see mixed origin beef or pork at a discount, they may change their minds. Only time will tell how receptive consumers are to this labeling and how retailers will market it.

The CME Webinar will be accessible in the archived section in the Trading Knowledge Center of their Web site by 3 p.m. central time on Thursday, Sept. 25.

Stocker/feeder implications of COOL


  • Request affidavits for purchased animals. Keep a record of seller and/or sale date and location.
  • Provide affidavits for sales groups. Keep a record of buyer and/or sale date and location.
  • Commingled and resorted animals (with same origin) may be sold under a "consolidated affidavit. Animals need to be individually tracked as long as records document a balance between total purchases and sales.
  • Imported and domestic animals best segregated with supporting records unless individual animal ID is used.

During a CME COOL information Webinar, Derrell Peel, livestock economist at Oklahoma State University offered this information.


Cow-calf implications of COOL


  • Be prepared to supply affidavits for animals sold. Keep record of buyer and/or sale date and location.
  • Need records to document normal course of business. These may include: herd and calving records; vaccinations and vaccine purchases; and feed purchases
  • Important to document herd size and composition as of July 15, 2008. Producers may be selling, for several years, brood animals that were grandfathered in on this date.
  • Maintain records on raised cows and bulls.
  • Request affidavits on purchased cows and bulls.

During a CME COOL information Webinar, Derrell Peel, livestock economist at Oklahoma State University offered this information.