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Food Labeling Continues: COOL Regulations

Updated: Jul 9, 2020

By Ashley Ellixson

Bird's eye view of field (Photos by Edwin Remsberg).

Have you looked at the packaging on your meat lately? Have you ever asked the question, “Why is that label there? Why must it say that?” Today, I am going to walk you through what is known as the country-of-origin labeling (COOL) regulations on meat and other covered commodities. Also, if you’re in the business of selling these products, you should make sure you’re in compliance if the regulation applies to your business.


The provisions of the COOL regulations for the mandatory labeling of beef, pork, lamb, chicken, goat meat, wild and farm-raised fish and shellfish, perishable agricultural commodities, peanuts, pecans, ginseng, and macadamia nuts became effective on March 16, 2009. The regulation was published in the Federal Register on January 15, 2009, and requires designated retailers to label covered commodities for country of origin and, in the case of fish and shellfish commodities, method of production. On May 23, 2013, the USDA Agricultural Marketing Service (AMS) issued a final rule that made changes to the labeling portion of COOL to provide consumers with more specific information and revised the definition for “retailer.”

The original COOL regulations for meat derived from animals born, raised, and slaughtered in the United States allowed for the origin to be designated as ‘‘Product of the U.S.’’ Under the new rule, the U.S. country of origin designation for meat would be required to include location information for each of the production steps (i.e., ‘‘Born, Raised, and Slaughtered in the United States’’ or “Born in Brazil, Raised and Slaughtered in the United States”). Additionally, this rule eliminates the allowance for commingling of meat of different origins.

Cows on a field (Photos by Edwin Remsberg).

Further, a retailer is now defined as any person subject to be licensed as a retailer under the Perishable Agricultural Commodities Act of 1930. Retailers (primarily grocery stores and supermarkets) are required to make country of origin information for covered commodities and if applicable, method of production, available to consumers. Food service establishments (cafeterias, restaurants, etc.) are excluded from COOL requirements. Since COOL is solely a U.S. labeling law, exporters and exported commodities are not subject to its requirements.

The full text of the original and amended COOL regulation can be found at:

The World Trade Organization Dispute

On October 20, 2014, the World Trade Organization (WTO) issued its final ruling on the 2013 COOL regulations after Canada and Mexico challenged the treatment of imported cattle and hogs from their respective countries. The WTO found that the 2013 COOL regulations violated an article in the WTO agreement because it treats Canadian and Mexican livestock less favorably than U.S. livestock. The WTO further explained that the 2013 COOL requirements increased the original COOL requirements’ detrimental impact on competitive opportunities of imported livestock into the U.S. market. In short, the WTO panel found the labeling requirement unfair because it gives consumers incentive to chose domestic meat over imported meat creating segregation in the meat market. Further, the WTO also found that there would be an increased burden on recordkeeping and a new potential for label inaccuracy.

Now What?

On November 28, 2014, the United States decided to appeal the WTO’s decision. On December 12, 2014, Canada filed another appeal in the same dispute. What does that mean? Now we wait and see how the appeals go and whether the Appellate Body will decide differently. Until then, retailers continue to support COOL because they argue that their consumers deserve to know where their food comes from and Canada, Mexico and even the U.S. beef industry continue to strongly oppose COOL regulations because they argue it burdens sales and recordkeeping efforts. Keep your eye out for updates here on the blog!

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