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Cattle producers continue to urge Peterson to implement COOL by September 30

On Tuesday, R-CALF USA representatives personally delivered a letter to House Agriculture Committee Chairman Collin Peterson, D-Minn., to request his assistance to make certain that country-of-origin labeling (COOL) is implemented without further delay.

The letter thanks Peterson for his leadership in 2003 when he worked to ensure that the U.S. Department of Agriculture (USDA) would verify country of origin on the basis of existing books and records kept in the ordinary course of business, without imposing undue administrative, financial or legal burdens on producers.

"Unfortunately, shortly after Representative Peterson's efforts in 2003, USDA published a draft COOL rule that would've imposed onerous and unnecessary record-keeping requirements on producers, suppliers and retailers," said R-CALF USA National Membership Co-Chair Joel Gill, who talked with Peterson's staff on Tuesday. "Opponents of COOL have seized on the draft rule's unnecessarily draconian approach to argue that there is no workable way to implement the COOL law as currently written. In making those arguments, COOL opponents have blurred the distinction between what the COOL law actually requires and what USDA regulators chose to impose through the draft rule. It's time to clear up this confusion."

Gill explained that the approach in the 2003 draft rule can - and should be - abandoned for an approach that more closely reflects the outlines of Peterson's 2003 proposal.

"USDA can take this simplified regulatory approach today - without further delay," said Gill. "The current COOL law gives USDA all the authority it needs to adopt this simplified regulatory approach. There is absolutely no need to amend the current COOL law in order for USDA to issue a set of common-sense rules for implement COOL - rules that reduce administrative burdens, allow reliance on existing books and records, and prevent the shifting of legal and financial burdens to producers.

"This approach is possible because, in September 2004, USDA adopted precisely this approach using the existing COOL law when the agency published the rule for labeling fish and shellfish," Gill continued. "The law is the same for fish and for beef, and USDA has demonstrated with its fish and shellfish rules that it knows how to simplify the implementation rules for COOL."

The letter stated that the same simplified regulatory approach already in place for fish and shellfish can be easily applied to beef without any changes to the current COOL law.

This approach will:

1) allow packers to indicate beef has come from imported animals without having to specify each further production step that may have occurred in the United States;

2) allow packers to label blended products with a list of the countries of origin that may be contained in the product, rather than a definitive list of each country;

3) allow retailers to rely on pre-labeled products for origin claims;

4) allow packers to rely on country markings that already are applied to cattle imports in order to determine origin;

5) eliminate unnecessary and duplicative record-keeping requirements regarding chain of custody and separate tracking during the production process to allow packers and retailers to rely on documents they already keep in the ordinary course of business; and,

6) reduce the record retention requirement from two years to one year.

"Furthermore, under the current law, a new rule could specify that producers and retailers do not need to demand affidavits or third-party verification audits of suppliers in order to adequately substantiate origin claims," Gill pointed out.

"These changes would address any legitimate concerns about the costs of the labeling program, while preserving the full benefits of mandatory COOL and ensuring that consumers are informed of the origins of their beef purchases," he emphasized. "Moving toward simplified implementation as quickly as possible under the current law will have enormous benefits for U.S. cattle producers and their customers."

R-CALF USA CEO Bill Bullard attended the congressional meeting with Gill and said that cattle producers and consumers already have waited more than five years for COOL's implementation.

"We are urging Congress to immediately implement COOL despite the intense lobbying efforts of the nation's meatpackers," Bullard said. "The marketplace cannot be competitive until consumers can tell the difference between domestic beef and imported beef with a country-of-origin label."

Note: To request a copy of the letter to Peterson, contact R-CALF USA Communications Coordinator Shae Dodson at the e-mail address or phone number above. Also available is a paper titled "COOL Myths and Facts" and another titled "Country-of-Origin Labeling for Beef." Additional information on COOL can be found at the "Country-of-Origin Labeling" link at

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