The 30-day comment period for the Agricultural Marketing Service (AMS) of USDA proposed revised rules for country-of-origin labeling (COOL) for meat ended on April 14. AMS will review the comments received with a focus on May 23 for implementation of new rules required by a WTO ruling that the current regulations disadvantage imported animals. The Canadian government has already indicated that it considers the revised rules more discriminatory against meat from imported animals that the current ones found at fault in the WTO case.

The issues at hand are fairly narrow – do the rules put Canadian and Mexican live animals at a competitive disadvantage and do the labels provide adequate information to consumers?  The issue is not about labeling laws; the U.S. government has the right to require labels stating sources of origin and the WTO ruling reconfirmed that.  Whether or not consumers read the labels is also not an issue.  The cost of COOL for the U.S. livestock production and meat processing industries is not up for debate.  Congress passed the law as part of the 2002 and 2008 farm bills and the President signed them; changing the law is up to them.

The Canadian and Mexican governments filed cases at the WTO claiming their animals were disadvantaged by treatment not consistent with commitments of the U.S. government as a member of the WTO.  In June 2012, the WTO Appellate Body affirmed a previous WTO Panel’s finding that record keeping and verification result in processors segregating animals and create incentives to process exclusively domestic livestock and disincentives to process imported ones.  The least costly way of complying is to rely exclusively on domestic livestock and thus has a detrimental impact on the competitive opportunities of imported livestock.


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The AMS proposed rule addresses only the labels for muscle cut covered commodities and information for consumers.  Muscle cut covered commodities derived from animals slaughtered in the U.S. would be required to have origin designations and specify the country location of production steps of birth, raising, and slaughter of the animal from which the meat is derived.  Under the current regulations, muscle cuts from animals that were born, raised, and slaughtered in the U.S. are simply designated as ‘‘Product of the U.S.’’ Muscle cuts of animals raised in Canada and only slaughtered in the U.S. are now labeled “Product of Canada and the U.S.”  Muscle cuts from animals born and partially raised in Canada and finished and slaughtered in the U.S. would be labeled “Born in Canada, raised and slaughtered in the U.S.”  These labels are designed to more closely align the information collected with the information actually provided consumers and justify the record-keeping and verification requirements of the law.