Close the COOL Loophole

Comments due by September 30, 2008

   The 2002 and the 2008 Farm Bills require retailers to disclose the country of origin of beef, lamb, pork, chicken, wild and farm raised fish and shellfish,  perishable fruits and vegetables, peanuts and other commodities on their labels.  USDA has issued an interim final rule implementing Country of Origin Labeling (COOL), available here: The rule will become effective on September 30, 2008 which is also the deadline for comments.

     COOL is an important tool for consumers. It allows consumers to choose U.S. produced meats, produce and nuts.  The COOL rule, however, provides a vast loophole.  It specifically exempts covered commodities found in “processed” food items. The processing loophole is available for foods that have been cooked or marinated or cured or simply when they have been combined with other covered commodities. Excluded, for example, are roasted peanuts, marinated pork loin, salad mixes, fresh fruit cups, dried fruits and
vegetables, smoked or cured ham and bacon.

     This exemption excludes a significant portion of the foods consumers bring home from their grocery stores on a daily basis and it compromises a consumer’s right to know the origin of the foods
they are buying and consuming.

Tell USDA to close the COOL loophole.

There are several ways to submit your comment:

*         You can submit your comment directly from the Food and
Water Watch website:,  or

*         You can submit your comment directly to USDA at their
(Check the box: “Select to find documents accepting comments or
submissions” and search for “country of origin labeling”, or

*         You can fax your comment to USDA at (202)354-4693, or

*         You can mail your comment to the address below.

Comments should be addressed to:

Country of Origin Labeling Program
Room 2607-S
Agricultural Marketing Service, USDA
Stop 024
1400 Independence Ave. SW
Washington, DC 20250-0254

(Received via the Slow Food DC listserv, a highly informative source of food news!)

~Laurie O’Neill


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