CU’s Comments on Interim Final Rule on Mandatory Country of Origin Labeling

Commenting on USDA’s Interim Final rule for mandatory country of origin labeling (COOL) for beef, pork, lamb, chicken, goat meat, perishable agricultural commodities, peanuts, pecans, ginseng, and macadamia nuts, Consumers Union continues to believe that this COOL should cover as many items as possible as it is clear that consumers desire to know where there food is coming from. Indeed, when Congress passed the 2002 Farm Bill, it was clear that COOL was meant to be for consumer information purposes. Consequently, we think that COOL labeling should be as expansive as possible. While we applaud the USDA for finally implementing COOL and for adding chicken, goat meat, pecans, ginseng and macadamia nuts, we are concerned that USDA has listened more to the retail food industry, which does not want COOL, than to consumers and has come up with an interim final rule that appears to minimize the number of items covered under mandatory COOL. In particular, we believe that USDA’s overly expansive definition of “processing,” which comes from the 2004 interim final rule for fish and shellfish and which would exclude large number of items from mandatory COOL should not be used. We urge USDA/AMS to make case by case rules for what is defined as “processed” and to be conservative in terms of allowing exemptions for such items. Mixtures, such as fruit salad, should also not be exempted.