Cattle Producers Should Prepare For Mandatory COOL
The long-delayed mandatory Country of Origin Labeling (COOL) law appears to be likely to take effect on or before the scheduled date of September 30, 2008. Although nothing is final yet, full implementation may affect some or all of the 2007 calf crop and certainly will affect the 2008 calf crop. USDA has reopened the comment period to allow interested parties to have input into the final rule for COOL implementation. Producers have until August 20, 2007 to submit comments on the proposed final rule for COOL.
Producers should also start thinking about how they will comply with the law. Some details may change with the final rule but the general requirements of the law are clear. The proposed final rule states “Any person in the business of supplying a covered commodity to a retailer, whether directly or indirectly, must maintain records to establish and identify the immediate previous source (if applicable) and immediate subsequent recipient of a covered commodity, is such a way that identifies the product unique to that transaction by means of lot number or other unique identifier, for a period of 1 year from the date of the transaction.” Producers should think about whether they have records that will meet these requirements, whether new records are needed and how those records must be organized and maintained to be available as required.
It is likely that many cow-calf producers already have the majority of records needed to prove the origin of the calves they sell although some reorganization of those records may be needed. Stocker producers, however, face a greater challenge to be able to trace animals from a variety purchasing sources to subsequent marketing groups after the commingling that is so typical and necessary for stocker production. Some sort of individual animal ID, although not mandated by this law, is likely to be the only feasible way for many stocker operations to be able to maintain records of animal origin. Feedlots and packing plants will likewise need detailed records to maintain a complete chain of identification through the marketing system, especially during meat fabrication when pieces of animals are commingled in boxes of beef. Although the details are not finalized yet, it is time for producers to begin planning for implementation of mandatory COOL.
Source: Derrell S. Peel, OSU Extension Livestock Marketing Specialist
http://www.cattlenetwork.com/cattle_identification_Content.asp?ContentID=141735
The long-delayed mandatory Country of Origin Labeling (COOL) law appears to be likely to take effect on or before the scheduled date of September 30, 2008. Although nothing is final yet, full implementation may affect some or all of the 2007 calf crop and certainly will affect the 2008 calf crop. USDA has reopened the comment period to allow interested parties to have input into the final rule for COOL implementation. Producers have until August 20, 2007 to submit comments on the proposed final rule for COOL.
Producers should also start thinking about how they will comply with the law. Some details may change with the final rule but the general requirements of the law are clear. The proposed final rule states “Any person in the business of supplying a covered commodity to a retailer, whether directly or indirectly, must maintain records to establish and identify the immediate previous source (if applicable) and immediate subsequent recipient of a covered commodity, is such a way that identifies the product unique to that transaction by means of lot number or other unique identifier, for a period of 1 year from the date of the transaction.” Producers should think about whether they have records that will meet these requirements, whether new records are needed and how those records must be organized and maintained to be available as required.
It is likely that many cow-calf producers already have the majority of records needed to prove the origin of the calves they sell although some reorganization of those records may be needed. Stocker producers, however, face a greater challenge to be able to trace animals from a variety purchasing sources to subsequent marketing groups after the commingling that is so typical and necessary for stocker production. Some sort of individual animal ID, although not mandated by this law, is likely to be the only feasible way for many stocker operations to be able to maintain records of animal origin. Feedlots and packing plants will likewise need detailed records to maintain a complete chain of identification through the marketing system, especially during meat fabrication when pieces of animals are commingled in boxes of beef. Although the details are not finalized yet, it is time for producers to begin planning for implementation of mandatory COOL.
Source: Derrell S. Peel, OSU Extension Livestock Marketing Specialist
http://www.cattlenetwork.com/cattle_identification_Content.asp?ContentID=141735