COOL has arrived, after 6 years of debate over implementation of the 2002 Farm Bill, and more than 10 years of debate over whether or not to have mandatory country of origin labeling on food products. September 30 starts the process, although the USDA says there will be a six month grace period for affected livestock producers and sellers to learn the requirements without fear of prosecution. So what requirements should be learned in the next six months?

Hog and cattle producers can watch an Internet based presentation from Iowa State University. If technical issues will not allow you to view that, the Iowa Beef Center provides a numerous other resources.

Country of origin labeling (COOL) initially became law in 2002, but implementation was delayed for many commodities covered by the legislation. It was re-adopted in the 2008 Farm Bill and USDA developed the regulations. In addition to fruits, vegetables, and nuts, COOL covers muscle cuts of beef, pork, lamb, chicken, and goat meat, as well as ground meats, and both wild and farm-raised fish. Exempt are processed meats and food products, and products produced before Sept. 30. Although there is a grace period, retailers are being urged to adopt the program immediately. Since the retailer is responsible for labeling the product, they can require suppliers and their suppliers to provide information on the origin of the product, and that goes all the way back to the farmgate.

Any animal that is born, raised, and slaughtered in the US would be a “product of the US;” however ground beef could come from several geographical sources, and would be labeled as such. To verify the origin at the demand of the retailer, the meat packer must have legal documentation, and will require a producer to provide satisfactory paperwork. Identification for individual animals is not required, but producers may find that to be easier to handle. Also, paperwork must be kept for 1 year from the date of the transaction. Any animal born or imported before July 15, 2008 is considered US origin.

The primary paperwork that producers will likely handle is an affidavit, which is a legal document that, when signed, certifies the authenticity of the information. Anyone signing an affidavit is required to have first hand knowledge of the origin of the animal. Along with the legal requirements come verification audits, which can be conducted to trace an animal. Acceptable papers which can be used in an audit include: birth records, receiving records, purchase records, animal health papers, sales receipts, inventory documents, feeding records, segregation plans, branding records, breeding stock information, etc. To comply with the requirements, producers will have to be able to trace animal movement one step back and one step forward.

The affidavit does not have to be written by your attorney, since a variety of them are available without charge. They only have to be completed and either kept on file or submitted to a livestock purchaser when requested.

Iowa Beef Association affidavit
National Cattlemen’s Beef Association affidavit
Chicago Mercantile Exchange affidavit

USDA’s COOL website

Within the USDA’s COOL website, a lengthy question and answer section addresses several issues that will be pertinent to a livestock producer about the affidavit process:
1) It should contain “Evidence that identifies the animal(s) unique to a transaction can include a tag ID system, information such as the type and sex of the animal(s), number of head involved, the date of the transaction, and the name of the buyer.”
2) When an animal may be transferred from one producer to another, such as a farrowing operation to a feeder pig finisher, the finisher can rely upon the affidavit from the farrowing operation.
3) There are also “continuous affidavits” that can follow the animal until cancelled.

Summary:
The country of origin labeling system is now being implemented by USDA to indicate the national origin of meats, fruits, vegetables, sea foods and other non-processed products. The Cornbelt livestock operator will have an integral involvement in the process by certifying the US origin of livestock that will eventually be slaughtered. Most of the certification process will be accomplished through legal documents that can be transferred between buyer and seller and remain with the animal.