Record Keeping for COOL Must Start Immediately

Animals in U.S. need documentation.

Technically mandatory Country of Origin Labeling is slated to go into effect on Sept. 30, 2008. However because there is not time to complete final implementation rules with time for public comments, USDA will publish an interim final rule that the program will operate under but is subject to future revisions. Although COOL is still a few months away, according to Dr. Brad Lubben of the University of Nebraska, producers need to start keeping records of livestock movement and births immediately.

"Animals in the United States as of July 15 will be considered U.S. animals for purposes of records and documentation of origin," Lubben says. "That means we've got to start documenting those animals now and documenting movements of those animals in order to be ready for regulations that still aren't officially published."

The interim final rule on mandatory COOL could be released in the next couple of weeks. Ag Secretary Ed Schafer says retailers and packagers will have a sixth-month grace period to attain compliance with mandatory country of origin labeling.

"We're not going to be the labeling police in the first six month," Schafer says. "We're going to be working with those retailers and packagers to make sure it is phased in and by the end of the six months we'll have full compliance."

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