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COOL

Mandatory labeling for retail meat products begins September 30, 2008. The original law passed in 2002 was not implemented for meats due to Congressional delays. This law was amended as part of the 2007 Farm Bill recently passed by the US Congress. Now that the law is final, USDA must promulgate appropriate rules for implementation. Although there remains some degree of uncertain for the specific requirements, the industry is readying for implementation. The information below provides some guidance for producers and processors. AgInfoLink has the ability to provide both live animal and in plant traceability solutions to meet COOL requirements. For more information on AgInfoLink solutions, contact 800.287.8787 or email info@AgInfoLink.com.

References:
Iowa Beef Center
National Cattlemen’s Beef Assn
USDA Country of Origin Labeling
www.ams.usda.gov
www.countryoforiginlabel.org

COOL Considerations For Cow-Calf & Stocker Cattle Producers. Dr. Derrell S. Peel, Oklahoma State University Extension Livestock Marketing Specialist. August 8, 2008

COOL Is Back…Again. Dr. Derrell S. Peel, Oklahoma State University Extension Livestock Marketing Specialist. May 23, 2008

What Will Be Required Of Cow Calf Producers Under The COOL Rules This September? Dr. Jack C. Whittier, Colorado State University May 14, 2008

COOL Considerations For Cow-Calf & Stocker Cattle Producers
Dr. Derrell S. Peel, Oklahoma State University Extension Livestock Marketing Specialist. August 8, 2008

Mandatory Country of Origin Labeling will take effect on September 30, 2008. There are specific rules on the definition of retailers and on processed foods (which are exempted) and on food service establishments (which are also exempted) but in general, beef sold in retail markets must bear a label or notice to consumers about the origin of the beef. Only beef from animals born, raised and slaughtered in the U.S. may be labeled Product of U.S.A. Other product must identify the country or countries of origin, which might include the U.S. and other countries. USDA-AMS has indicated that they will use the first six months to help retailers and suppliers come into compliance with the law.

Meat packers are considered the originators of the origin claim but the interim final rule indicates that the slaughter facility “must possess or have legal access to records that are necessary to substantiate the origin claim.” “A producer affidavit shall be considered acceptable evidence provided it is made by someone having first-hand knowledge of the origin of the animals and identifies the animals unique to the transaction.” Records maintained in the course of normal conduct of business may serve as verification. Animals that are part of a NAIS compliant or other recognized official identification system may use the animal ID to verify origin claims.

Cow-calf producers can use a wide variety of herd or calving records, feed purchases, animal health or vaccine purchases to document the normal level of production that would verify the origin of calves they sell. Producers should be prepared to provide an affidavit to the buyer stating the origin and the existence of such records. Producers should keep a copy of the affidavit noting the buyer and/or the date and location of the sale. COOL also covers meat from breeding animals which means that producers should keep records of raised animals used for breeding and should request an affidavit for any purchased cows or bulls.

All animals in the U.S. as of July 15, 2008 are considered to be U.S. origin. It is important for cow-calf producers to document herd size and composition for these animals that are “grandfathered” in under this date. Young cows that may not be sold for several years may need this documentation to verify the status as of July 15, 2008.

Stocker producers, like other suppliers, must “maintain records to establish and identify the immediate previous source and the immediate subsequent recipient.” Commingling of animals creates a challenge but AMS has indicated that as long as a producer has records of purchases and sales that reasonably account for total animal sales, individual animals or subsets of animals need not be traced back to specific purchase group(s). Thus, animals purchased from a variety of sources arriving with affidavits that show that animals all have the same origin, can be commingled into different sales groups and sold with affidavits that verify the origin of the animals.

Depending on the flow of animals into and out of an operation, producers may find it advantageous to use a more detailed tracking system to account for sources and destinations of cattle. Of course, if a producer has animals with different origins, those animals should be segregated by origin group with appropriate records to account for each origin group unless they are part of a NAIS compliant or other individual animal ID program to track animals. As noted above, NAIS compliant animals may use the animal ID as verification of origin. Animals on hand as of July 15, 2008 are covered under the previously mentioned grandfather clause.

Source: Derrell S. Peel, OSU Livestock Marketing Specialist

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Cattle Update: COOL Is Back…Again
Derrell S. Peel, OSU Extension Livestock Marketing Specialist May 23, 2008

Now that the Farm Bill process is finally over, cattle producers should be ready for the long delayed implementation of Country of Origin Labeling (COOL). The new Farm Bill has some language that modifies the previous COOL legislation and that has a couple of implications for producers. First, the new language simplifies the meat labels and the records requirements for COOL. This should make it easier for some producers to meet COOL requirements although the legislation applies to the requirements for meat retailers and it will be up to them to decide exactly what records to request from packers, feedlots, stocker and cow-calf producers. The second implication is that the legislative changes mean that the Agricultural Marketing Service (AMS) must change the implementation rules to conform to the new language. This means that the final rules are not yet spelled out and there is some uncertainty about the dates of implementation. It is anticipated that AMS will move quickly to implement interim rules while going through the process of finalizing the rules.

The new language emphasizes the use of existing business records whenever possible to minimize the burden on producers. For many cow-calf producers, existing business records are likely sufficient and producers may simply have to offer an affidavit that they have the records to document the origin of the calves they sell. Documenting cull breeding animals could be problematic and producers should give some thought to keeping records for later years when cull animals are sold. Current animals will likely be grandfathered in as of a date to be determined.

For many stocker producers, COOL may require some new recordkeeping efforts. Producers will likely need to request affidavits of origin for cattle they buy and maintain records sufficient to link those buying groups to commingled and sorted selling groups. It is not necessarily the case that producers must use individual animal ID to meet COOL requirements.

It may be possible to verify multiple purchase groups of animals that all have the same origin (i.e. born and raised in the USA) which are subsequently sorted and commingled into different selling groups but can be shown to all be covered by the same label, for which the stocker producer can offer an affidavit as seller.

In other cases, it may well be that the easiest and least costly way for the stocker producer to meet COOL requirements is to use individual animal ID to track animals through the stocker operation.

Producers should watch for additional information as the details are finalized in the coming weeks and months.

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What Will Be Required Of Cow Calf Producers Under The COOL Rules This September?
Source: Jack C. Whittier, Colorado State University May 14, 2008

The title of this article asks a question that is not yet totally answered. However, the answer is beginning to be clearer and soon may be finalized. As you likely know, in 2002, the US Congress passed a law requiring certain “covered commodities” to be verified and labeled as to their county of origin. The acronym used commonly for this law is COOL, denoting County of Orgin Labeling. Final rules for COOL will be written following final passage of the 2007 Farm Bill which has passed the Senate and House Conference Committee and will likely be sent to the President’s desk soon. If the President signs the Farm Bill, final rules will then be written. As of now, the following definitions and requirements are likely to become rules. Let’s examine some of these as they apply to cow-calf producers in Colorado:

Beef as a Covered Commodity: Meat cuts and ground product from beef are defined as a “covered commodity”. More specifically, under the current rules, “a meat product from beef (including veal), pork, and lamb must bear a COOL label or is subject to labeling providing COOL information if: 1. It is sold at retail, AND, 2. It is a muscle cut, or 3. It is a ground product. The product is EXEMPT from COOL labeling requirements if: 1. The meat product is sold at foodservice (e.g., restaurants, institutions, etc.), OR, 2. The meat product is an ingredient in a processed product or, in effect, is processed.” (Source: www.countryoforiginlabel.org, link to DOES A MEAT PRODUCT NEED A LABEL?, accessed 13 May 2008).

Jack’s Comment: From this we can assume that home-raised and harvested beef that is not sold at retail will not be required to be COOL labeled. Beef served on a menu at a restaurant will be exempt, as will beef served in a cafeteria or other food service institutions.

Recordkeeping Requirements: The current language states: “Any person engaged in the business of supplying a covered commodity to a retailer, directly or indirectly, must maintain records to establish and identify the immediate previous source (if applicable) and immediate subsequent recipient of the product. The record must identify the product unique to that transaction by means of a lot number or other unique identifier, for a period of one (1) year from the date of the transaction.

“Establishments that slaughter livestock are considered initiating suppliers of a covered commodity. The Agricultural Marketing Service (AMS) has indicated that the initiating supplier (packer) either must have the records in its possession or have access to records of the livestock supplier that substantiate the country of origin of the meat product at issue.” (Source: www.countryoforiginlabel.org, link to Recordkeeping Requirements, accessed 13 May 2008.).

Jack’s Comment: Since cow-calf producers indirectly supply beef to packers, I interpret this to mean that cow-calf producers will be responsible to have records to substantiate the country of origin of their calves, cull cows and bulls. While these records may not be required at time of sale, it is likely that there will be an increasing demand for such record verification at the time of sale.

Seed Stock / Cow Calf Responsibility: “Provide enough information for an auditor to verify the origin and ownership of the animals identified and to verify the stated designation. Properly identify and record all animals according to the designation.” (Source: www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3103374, accessed 13 May 2008.).

Jack’s Comment: I interpret this to mean that a rancher must have sufficient documentation so that in the event of an audit from USDA, they can verify the country of origin of the cattle they sold into the marketplace.

Examples of records and activities that may be useful. The following record examples are listed in the 2002 version of COOL. “Birth records, receiving records, purchase records, cow/calf tag ID system, sales receipts, feed bills, feeding records, animal inventory, acreage inventory, site maps, APHIS VS forms, production estimates, health records, ownership records, segregation plan, state brand requirements, replacement activities, beef quality program (BQA), breeding stock information.” (Source: www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3103374, accessed 13 May 2008.).

Jack’s Comment: In reality, it will likely be a combination of information that will be used to substantiate the origin of cattle. Records such as brand inspections, bangs vaccination records, sales receipts, etc. will be used to verify that the cattle did in fact originate at the ranch, or were purchased from a qualifying location.

“In the Normal Conduct of Business” clause: The National Cattlemen’s Beef Association (NCBA) website explains recent revisions language in the current Farm Bill legislation as follows: “Language in both the Senate and House bills helps alleviate the paperwork burden on producers requiring only documents used “in the normal conduct of business” to verify origin.… While the current law is far from perfect, the compromise language in the Farm Bill is an improvement for cattle producers. Mandatory country-of-origin labeling is scheduled to take effect on September 30, 2008.” (Source: ,www.beefusa.org/goveFarmBill.aspx accessed 13 May 2008.).

Jack’s Comment: In my opinion the implementation of COOL should not be viewed in a panic mode for cow-calf producers. Most, if not all, of the documentation needed to meet the COOL requirements is likely already part of your normal cow-calf production system. However, I suggest that we all do a better job as record-keepers and make certain that the history of our cattle can be substantiated. I also foresee that such records will enhance the value of cattle when they leave the farm of origin. One of the great principles of our market-driven system is the reward for value and the discount for absence of value. As we look back in 10 years, my prediction is that COOL will add value at the ranch level for those who document and market country of origin information.

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