COOL 2.0: Comment Period Extended for “Product of U.S.A.” Labeling

August 24, 2018 04:11 PM
Possible “Product of USA” update seen as a way to bring back Country-of-Origin Labeling (COOL).

The comment period for “Product of U.S.A.” labeling has been extended by USDA’s Food Safety & Inspection Service (FSIS) following support and pushback from several agriculture organizations. The move has been seen as a move to re-establish Country-of-Origin Labeling (COOL) by some industry groups.

A petition was filed by the Organization for Competitive Markets (OCM) and the American Grassfed Association (AGA) on June 12, requesting that FSIS change the “Product of U.S.A.” entry in the FSIS Food Standards and Labeling Policy Book.

FSIS had originally sought to end the comment period on Aug. 17, but the first comment period received “significant interest from stakeholders.” A request was then sent to FSIS to extend the comment period on Aug. 14.

FSIS opted to extend the comment period for an additional 30 days following the original Aug. 17 deadline’s ending. The new comment period ends on Sept. 17.

In the petition letter OCM and AGA claim there is a lack of clarity in the definition of “processing” with regard to the current policy. The groups allege that meat can be imported from other countries and be labeled as a “Product of U.S.A.” if it passes through a USDA inspected plant.

“The ability of consumers to identify U.S. beef and pork products has been greatly hampered by the repeal of the retail mandatory Country of Origin Labeling for those products. Therefore, OCM understands it is imperative when a manufacturer chooses to label its meat products as ‘Product of U.S.A.,’ it should have the right to do so but only if the meat ingredients of the product are of domestic origin,” the petition letter from OCM and AGA states.

There have been more than 2,000 comments made on the petition website as of Aug. 24. Supporting comments have come from two national cattle groups including U.S. Cattlemen’s Association (USCA) and Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America (R-CALF USA).

In a press release R-CALF USA mentions that beef and pork are both outliers to COOL laws that are applied to other products.

“Any policy that does not reserve the USA label for beef exclusively born, raised, and slaughtered in the United States allows meatpackers and importers to steal the good name and reputation of the U.S. cattle producer. The USA label is our trade mark and should not be sold by the USDA,” says R-CALF USA CEO Bill Bullard.

USCA believes there needs to be accurate labeling for beef.

“Producers across the country are demanding accurate labeling of U.S. beef products and USCA will continue its work to secure this needed transparency.  The comments submitted today reflect our ongoing work on this issue and we will continue to push for labels that clearly state and designate those products born, raised, and harvested in the U.S.,” says USCA board of director Maggie Nutter.

The National Cattlemen’s Beef Association (NCBA) is one of the groups that has voiced concern with the possible policy change. Colin Woodall, senior vice president of government affairs at NCBA calls the effort “a misguided attempt to restore mandatory Country-of-Origin Labeling (mCOOL) by circumventing the legislative process.”

“Having failed to achieve success in Congress, OCM and AGA are attempting to advance the mCOOL agenda through regulatory action. NCBA opposes the petition because it would bring economic harm to producers and fail to benefit consumers,” Woodall says.

There is concern from NCBA that the “Product of U.S.A.” has the support of the Humane Society of the United States (HSUS). The animal rights group has asked members to comment on the FSIS petition through the HUSU website and social media channels. In a press release OCM and AGA mentioned that HSUS “a leading animal welfare organization” was supportive of the change.

“It is unfortunate that OCM – an organization that claims to represent producers – continues to advance the agenda of radical animal rights activists. From attacking the Beef Checkoff to partnering with the Humane Society of the United States (HSUS), it is clear that OCM does not have the best interests of cattlemen and cattlewomen at heart,” Woodall adds.

COOL requirements were removed for beef and pork in 2016 following a repeal within the omnibus bill. Previous to the repeal the World Trade Organization (WTO) had said COOL was out of compliance with trade rules. The WTO ruling would have allowed Canada and Mexico to enact retaliatory trade tariffs.

In the petition letter from OCM and AGA it is asserted that research shows consumers want COOL. In a Journal of Food Distribution Research study from 2003 showed 75% of consumers prefer to make purchases on a product with COOL. However, only 19% would pay a premium for a “U.S.A. Guaranteed” steak. Two other studies or surveys were mentioned that had been conducted in 2010 and 2011.

More recent research from Kansas State University has shown that consumers don’t care about COOL, they are worried about price. Data accumulated in 2012 determined only 23% of consumers were even aware of COOL at the time.

“The petition relies on faulty assumptions and debunked theories about the benefits of mCOOL. Many producers have invested time and effort to develop voluntary value-added programs that deliver premiums for their cattle. These voluntary programs have proven much more effective at responding to consumer demand and increasing financial returns for producers than mCOOL,” Woodall says.

To comment on the “Product of U.S.A.” petition go to this website link.

Back to news



Spell Check

Kearney, NE
8/27/2018 07:53 AM

  What is truly a "shame" is NCBA's blatant bias AGAINST American cattlemen. Trade with Canada has given American producers the "black eye" of BSE-a disease that was common in Canada, but never once found in a native American cow. NCBA represents the meat packers first, with actual cattle producers being somewhere down the list.

Jennifer Truby
Durango, CO
8/30/2018 08:36 PM

  It’s not right that US raised beef is sold to other countries at a premium and our US stores can sell meat as “Product of USA”. It’s dishonest and misleading. Cattle producers are being forced out of business at alarming rates and there’s no incentive for people to get into the business. It’s hard damned work and it’s sad that we could end up a 3rd world country because we won’t be able to feed ourselves.

Brewster, KS
8/30/2018 10:32 PM

  NCBA steals our money from the checkoff and wastes it.. I don't know of 1 rancher or feeder HSUS has put out of business but I can show you THOUSANDS NCBA'S POLICIES AND POSITIONS HAVE PUT OUT OF BUSINESS!


Corn College TV Education Series


Get nearly 8 hours of educational video with Farm Journal's top agronomists. Produced in the field and neatly organized by topic, from spring prep to post-harvest. Order now!


Market Data provided by
Brought to you by Beyer