PORKER
Well-known member
USCA urges producers to file comments on COOL final policy rule by Sept. 30
Friday, September 12, 2008 12:26 PM MDT
The U.S. Department of Agriculture (USDA) published its Interim Final Rule for Country of Origin Labeling (COOL) in the Aug. 1 Federal Register. The agency is accepting public comment until Sept. 30.
The U.S. Cattlemen's Association (USCA) COOL Committee Chair, Danni Beer, South Dakota is urging livestock producers and producer groups across the country to file comments.
"It is crucial for livestock producers to be engaged in shaping the Final Rule for COOL. We have an opportunity with the public comment period to close some loopholes in the agency's proposed rule," said Beer. "Producers can do so by filing comments including suggested changes in the rule as well as stating their appreciation for provisions they support.
During a meeting with USDA officials U.S. Cattlemen's Association leadership learned that it is just as important to tell the agency what we like about the rule as well as what we want to see changed."
USCA found the following provisions of the Interim Final Rule beneficial for cattle producers and beef consumers:
1. Ground beef and hamburger will have to be labeled by its country of origin (COO). All possible countries must be listed. Under the Interim Final Rule, USDA actually expanded the products requiring labeling.
2. The Chain of Custody requirement was removed. In the first COOL rule USDA required that retailers keep records regarding the "chain of custody" for all covered commodities.
3. Retailers can rely on manufac-turer/first handler's labels to establish the product's origin.
4. A producer affidavit shall be considered acceptable evidence on which the slaughter facility may rely to initiate the origin claim, provided it is made by someone having first-hand knowledge of the origin of the animal(s) and identifies the animals unique to the transaction.
5. The rule doesn't preempt state laws on foods not covered under this law; i.e., Alaskan salmon.
6. The rule does NOT require a mandatory animal identification system.
USCA also found areas that could be problematic for cattle producers and consumers:
1. Under the multiple countries of origin portion of the law it is specific that the multiple country label can only be used for meat that is NOT exclusively born, raised and slaughtered in the U.S. The regulations do not contain this specific instruction.
This may allow packers to list meat exclusively born, raised and processed in the U.S. to be labeled "product of the U.S., county "X" and country "Y".
Writing the rule this way allows the beef production chain to continue processing beef without separation of beef by country of origin. For cost reasons plants that process beef from more than one country will benefit.
USCA leadership was told this decision was made on the basis that rules are written to be the least restrictive to business. On a positive note, consumers will have more information than they do now about the origin of their beef if this provision is not altered.
"Will retailers and consumers ask for more information about the products involved under this provision," asked Beer. "We certainly hope they will ask for USA-born and raised beef after they are given this additional information.
Part of our job as producers is to promote our product, and that's a responsibility we must assume through our beef checkoff or other means, if necessary."
2. The "processed food" provision is too broad. This part of the rule doesn't affect beef as much as some of the other covered commodities. For example, 95% of peanuts will not be labeled under the Interim Final Rule because USDA considers "roasted" peanuts as a processed food item. This provision in the rule is far too inclusive to be of much benefit to consumers who want to make informed purchasing decisions.
View the 233 page Final Interim Rule at www.uscattlemen.org. On the page, click on the COOL Library and then click on the Rules button in the upper left hand corner.
Comments on the rule should be sent to USDA COOL Program, Docket No. AMS-LS-07-0081, Room 2607-S, AMS USDA Stop 0254, 1400 Independence Ave. SW, Washington, DC 20250-0254 or comments can be faxed to 202/354-3693 referencing Docket No. AMS-LS-07-0081.
Friday, September 12, 2008 12:26 PM MDT
The U.S. Department of Agriculture (USDA) published its Interim Final Rule for Country of Origin Labeling (COOL) in the Aug. 1 Federal Register. The agency is accepting public comment until Sept. 30.
The U.S. Cattlemen's Association (USCA) COOL Committee Chair, Danni Beer, South Dakota is urging livestock producers and producer groups across the country to file comments.
"It is crucial for livestock producers to be engaged in shaping the Final Rule for COOL. We have an opportunity with the public comment period to close some loopholes in the agency's proposed rule," said Beer. "Producers can do so by filing comments including suggested changes in the rule as well as stating their appreciation for provisions they support.
During a meeting with USDA officials U.S. Cattlemen's Association leadership learned that it is just as important to tell the agency what we like about the rule as well as what we want to see changed."
USCA found the following provisions of the Interim Final Rule beneficial for cattle producers and beef consumers:
1. Ground beef and hamburger will have to be labeled by its country of origin (COO). All possible countries must be listed. Under the Interim Final Rule, USDA actually expanded the products requiring labeling.
2. The Chain of Custody requirement was removed. In the first COOL rule USDA required that retailers keep records regarding the "chain of custody" for all covered commodities.
3. Retailers can rely on manufac-turer/first handler's labels to establish the product's origin.
4. A producer affidavit shall be considered acceptable evidence on which the slaughter facility may rely to initiate the origin claim, provided it is made by someone having first-hand knowledge of the origin of the animal(s) and identifies the animals unique to the transaction.
5. The rule doesn't preempt state laws on foods not covered under this law; i.e., Alaskan salmon.
6. The rule does NOT require a mandatory animal identification system.
USCA also found areas that could be problematic for cattle producers and consumers:
1. Under the multiple countries of origin portion of the law it is specific that the multiple country label can only be used for meat that is NOT exclusively born, raised and slaughtered in the U.S. The regulations do not contain this specific instruction.
This may allow packers to list meat exclusively born, raised and processed in the U.S. to be labeled "product of the U.S., county "X" and country "Y".
Writing the rule this way allows the beef production chain to continue processing beef without separation of beef by country of origin. For cost reasons plants that process beef from more than one country will benefit.
USCA leadership was told this decision was made on the basis that rules are written to be the least restrictive to business. On a positive note, consumers will have more information than they do now about the origin of their beef if this provision is not altered.
"Will retailers and consumers ask for more information about the products involved under this provision," asked Beer. "We certainly hope they will ask for USA-born and raised beef after they are given this additional information.
Part of our job as producers is to promote our product, and that's a responsibility we must assume through our beef checkoff or other means, if necessary."
2. The "processed food" provision is too broad. This part of the rule doesn't affect beef as much as some of the other covered commodities. For example, 95% of peanuts will not be labeled under the Interim Final Rule because USDA considers "roasted" peanuts as a processed food item. This provision in the rule is far too inclusive to be of much benefit to consumers who want to make informed purchasing decisions.
View the 233 page Final Interim Rule at www.uscattlemen.org. On the page, click on the COOL Library and then click on the Rules button in the upper left hand corner.
Comments on the rule should be sent to USDA COOL Program, Docket No. AMS-LS-07-0081, Room 2607-S, AMS USDA Stop 0254, 1400 Independence Ave. SW, Washington, DC 20250-0254 or comments can be faxed to 202/354-3693 referencing Docket No. AMS-LS-07-0081.