Final COOL Labeling Regulation Takes Effect

The final country of origin labeling regulation went into effect on March 16, 2009. The most important thing you can do is ensure that your stores identify a country of origin for every covered commodity. To help at the store level, the three departments affected – produce, meat and seafood – are broke down with COOL requirements necessary to be in compliance with United States Department of Agriculture regulations. You should review these guidelines to make sure they reflect the instructions to your store personnel. For example, if all country of origin in your seafood department is displayed on pin tags for bulk displays and scale labels for self-service overwrapped product, it is recommended that you modify the sheets accordingly.

Please note that these requirements do not address recordkeeping. Retailers do have an obligation to keep records (1) to verify the country of origin claim for all covered commodities until they are sold and (2) to be able to identify their suppliers.

Visit any of the links provided at the end of this outline for more information on all country of origin labeling requirements, including recordkeeping, processed foods and frequently asked questions. Contact the Iowa Grocery Industry Association office at 515-270-2628 or info@iowagrocers.com with any questions or concerns.

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Produce Department – Country of Origin Labeling

1. Origin information must be displayed for these products items: Fruits, vegetables, peanuts, pecans, macadamia nuts, ginseng
   • Origin information is not required for produce that is:
   • Processed (i.e. cooked, dried)
   • Combined with other foods (i.e. fruit salad, cole slaw)
   • Origin information is not required for food service (i.e. salad bars)

2. Use country, state or region to identify origin (i.e. Mexico, “California Grown,” Product of US)

3. Check all produce items for origin information
   • No further action is required if:
     • The produce has a label, twist tie, PLU or other sticker with origin informatio
     • The produce is in a consumer package (i.e. clamshell) that identifies origin of the item
   • If no origin on product or consumer package:
     • Check the case in which the produce arrived and post origin from case on shelf tag or sign
   • If no origin shown any where:
     • Check with supervisor

4. Identify all possible origins if you put produce from different places in the same bulk display (i.e. a bin of apples from China and the United States; a bulk display of bananas from Costa Rica and Ecuador)

Meat Department – Country of Origin Labeling

1. Display country of origin information for all fresh: Beef, pork, lamb, chicken and goat meat
   • Country of origin is not required for meat that has been:
     • Processed (i.e. cooked, cured, smoked or restructured)
     • Combined with other foods (i.e. breaded cutlets, marinated steaks, meatloaf, stuffed chicken breasts)

2. Country of origin may be displayed by any of the following means:
   • Overwrap of branded, pre-packaged product; scale label of store-wrapped product; shelf tag; pin tag; single meat case sign (meat case signs must be conspicuous and legible and they must not apply to processed or combined meat in same case)

3. Use the country of origin statement from your supplier (i.e. If plastic overwrap on primal or outer case of multiple primals states “Product of US,” label meat cuts “Product of US.”

4. Only label meat with combination of country of origin statements if the meat that you are combining has different country of origin statements
   • Example 1: All steaks in store labeled “Product of US” by suppliers –  Label all steaks “Product of US” (Not: “Product of US, Canada, Mexico”)
   • Example 2: Steaks from primals labeled “Product of US” placed in same tray as steaks from primals labeled “Product of US and Canada – Label tray “Product of US and Canada

Seafood Department – Country of Origin Labeling

1. Display country of origin for all fresh or frozen fish or shellfish

2. Display method of production for all fresh or frozen fish or shellfish:
   • Method of Products: 1) “Wild” or “Wild Caught” or 2) “Farmed” or “Farm-Raised”

3. Country of origin and method of production not not required for seafood that has been:
   • Processed (i.e. cooked, cured, smoked, restructured)
   • Combined with other foods

4. Display country of origin and method of production by any of the follwing means:
   • Pin tag; shelf tag; scale label for store-wrapped product; outer package of supplier-packaged product

5. Use the origin and production information provided by supplier

6. Seafood with different origins or production methods may be sold in same bulk display or package if all possible origins or production methods are stated

National Grocers Association Special Report on Final COOL Rule (PDF – 44 KB)

Letter from Secretary of Agriculture Tom Vilsack (PDF – 20 KB)

COOL Rules & Regulations (PDF – 304 KB)

COOL Questions and Answers (PDF – 66 KB)