Country of Origin Labeling

Overview

In March 2009, the U.S. Department of Agriculture final rule for mandatory country of origin labeling (COOL) went into effect, which requires that retailers notify their customers of the country of origin of covered commodities (which includes fresh produce, macadamia nuts; pecans; ginseng; and peanuts). To ensure compliance with this regulation, the USDA conducts in-store COOL reviews.

Country of origin labeling is an industry issue PMA has been involved with for many years. In addition to providing USDA with numerous comments during the COOL rulemaking process, we also developed COOL best practices with Western Growers Association (available in the resources section below) and partnered with USDA on industry education and outreach.

Industry Compliance Opportunities

Based on our participation in USDA COOL training for state-level cooperators (those who conduct compliance checks), here are some areas in fruits and vegetables where USDA has regularly seen COOL non-compliance:

• Conflicting country of origin declarations between signage and Price Look Up stickers is the most prevalent issue seen in supermarket produce departments.
• Ancillary display signage (highlighting department sales or specials) obscuring country of origin declarations is the second most common issue seen in supermarket produce departments.
• Retailers with strong locally grown produce programs should ensure that state or country of origin is included on bills of lading and/or invoices from their local farmers, so as to make the records verification process run more smoothly should documentation be requested for these items.
• Suppliers can avoid COOL noncompliance issues by being mindful of where COO declarations are placed on packaging (e.g. placing a declaration too close to a seam and thereby rendering it partially obscured or otherwise illegible as the packaging is formed). The item may be considered noncompliant if the reviewer cannot reasonably locate and read the declaration.

Additional COOL Resources

If you have questions about country of origin labeling, please let us know. In addition to our staff experts Kathy Means and Lee Mannering, we have strong connections with USDA officials involved in compliance reviews and can readily access their expertise. Additional COOL resources that may be of interest to you are:

• PMA Field to Fork blog: USDA finds improvements in origin labeling of produce - April 18, 2012
• PMA Field to Fork blog: USDA outlines retail review process during COOL Webinar - September 27, 2011
• PMA Field to Fork blog: Report examines USDA’s implementation of country of origin labeling - September 14, 2011
• PMA Field to Fork blog: Reviews underway, five COOL retail compliance tips from PMA - August 16, 2011
• PMA Field to Fork blog: Country of origin update: how we’re doing as an industry - June 23, 2011
• PMA-USDA COOL Webinar presentation - January 2010
• PMA Analysis: Country of Origin Labeling Final Rule - January 29, 2009
• PMA-WG COOL Best Practices - January 16, 2009
• USDA Agricultural Marketing Service: County of Origin Labeling Final Rule
• USDA Agricultural Marketing Service: Country of Origin Labeling Web Site
• USDA AMS: FAQs for COOL
• USDA AMS: Training Materials for State Cooperators
• USDA AMS: Training Materials for Retailers
• USDA AMS: Training Materials for Suppliers

USDA AMS Video on COOL at Grocery Stores