ISU livestock specialist discuss COOL’s impact on industry

By Jean Caspers-Simmet

AMES, Iowa —Mandatory Country of Origin Labeling, which became law in 2002, will be implemented Sept. 30.

The law covers beef, lamb, chicken, goat and pork; wild and farm-raised fish and shellfish; fresh and frozen fruits and vegetables; ginseng and raw peanuts, pecans and macadamia nuts.

Iowa State University’s Iowa Beef Center and the Iowa Pork Industry Center recently hosted a webcast outlining steps producers need to take to comply with the regulations. An archive of the webcast as well as additional information on COOL is available at


"There’s no need for producers to panic about COOL," said John Lawrence, Iowa Beef Center director. "They should pay attention and know what is going to be expected of them."

During the webcast, Lawrence and Iowa Swine Industry Center associate director James McKean said hog and cattle producers should communicate with packers and buyers to know exactly what will be required. There will be six-month grace period for full compliance.

Lawrence said the COOL legislation applies to retailers, who in turn, pass requirements down the supply chain to packers and producers. Food service and retailers with invoice cost of perishable agricultural commodities of less than $230,000 per year are exempt.

The law specifies four categories of product. Category one, animals born, raised and slaughtered in the Untied states, will be labeled, "Product of the U.S." Category two is multiple countries of origin and will be labeled "Product of U.S. and country X and/or country Y." Ground meat in this category will be labeled, "May include product of (list of countries)." Category three is animals imported for immediate slaughter and will be labeled, "Product of Country X and U.S." Category 4 is meat imported as finished product to sell at the retail level. This will be labeled, "Product of country X."

Congress limited record-keeping requirements to documents used in the normal conduct of business for producers, Lawrence said. Animals born or imported before July 15 are "grandfathered" in as U.S. origin. Records must be maintained to establish the origin of a covered commodity for one year from the date of a transaction.

"Individual animal I.D. is not required, but it may be easier, particularly for operations that co-mingle animals which may be of foreign origin," Lawrence said. "Some livestock buyers may require individual animal ID."

USDA rules allow a producer affidavit as acceptable evidence if it is made by someone having first-hand knowledge of the origin of the animals and identifies the animals unique to the transaction.

The Iowa Beef Center worked with livestock and farm groups to develop an affidavit. Nationally, farm groups also developed an affidavit. The IBC affidavit requires date, seller’s name, address, phone number, a description of the animals, the number, where the animals were born and raised and the seller’s signature.


Examples of cattle records that may be used in a COOL verification audit are birth, receiving or purchase records, animal health papers, sales receipts, animal inventory documents, feeding records, APHIS VS forms, segregation plans, State brand requirements, breeding stock information or other similar documents, Lawrence said. Participation in USDA Quality System Verification programs such as PVP or QSA are acceptable evidence to substantiate COOL claims.

McKean said swine records include breeding records to establish location of birth, transfer records within a production system, sales and purchase records from the supplier that give origin, interstate and intrastate movement records, premises inventory records and breeding stock purchase documents.

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