Country of Origin Labeling

COOL QUICKLINX

Many Iowa producers have received letters in the mail from packing plants asking for documentation on animals as we reach the Sept. 30, 2008 deadline for mandatory Country-of-Origin Labeling (COOL) compliance. Feedlots may be asking for country-of-origin confirmation on calves purchased this fall because packers will ask for verification on any animals beginning in the fall of 2008.

Beef products will be labeled a product of the United States if they are born, raised, and slaughtered in the United States. Beef products shall be designated as a "product of the United States and Country X" if they are imported as feeder animals from either Canada or Mexico and are fed in the United States before going to slaughter. Beef products from cattle imported for immediate slaughter from Country X will be designated as "product of Country X and the United States." Currently, feeder cattle imported from either Mexico or Canada are permanently identified with a brand. However, buyers may still request a signed affidavit from the seller declaring the origin of the cattle.

The USDA has not specified a single record system to use. Cowherd owners should develop a record system to document that the calves born on their farms are "products of the U.S.” While not required, tagging calves and recording birth dates, tag number, and a description of the calf in a calving book would be a good place to start. Another strategy may be an established record system like the Iowa Green Tag program or a private sector electronic identification system. In both cases the cattle are entered into a formal database. Keep in mind that you likely will be asked for this documentation if you sell the cattle.

Sellers may be asked to provide an affidavit declaring the origin of the cattle. Typical business records are sufficient to prove origin of cattle if an audit occurs. Cattle producers with production and financial records should feel confident providing a signed affidavit.

Country-of-Origin Documentation Recommendations At-A-Glance

Cow-Calf Producers: To begin building a good foundation for verification, producers can begin with:

       Ear tags
       Calving books
       Herd inventories
       Purchase receipts of herd animals
       Sale bills from sold animals

Feedlots: Cattle feeders will also need to document that cattle were "raised" in the U.S. Appropriate documentation can include:

       A declaration of origin from the seller
       Scale tickets with in- and out-weight
       Closeout records

Feedlots will need documentation on where the cattle were before the feedlot, place of birth and stocker operation.

Feedlot owners need to begin thinking about what type of documentation they will require from sellers and how that information will be transferred through the marketing channel (auction market, order buyer, trucker). Cattle feeders should also discuss COOL with their buyers to determine what information must be forwarded with the cattle when sold.

As proposed, COOL will require retailers to develop and maintain an audit trail on the products they sell to verify the label indicating the country of origin. Members of the supply chain will have to keep sufficient records to support their claim of origin.