COOL Is So Close – So Let’s Finish the Job

Ranchers, cattle feeders, and consumers are being defrauded by the lack of labeling transparency.

At the last minute, mandatory country-of-origin labeling (mCOOL) for beef was included in the Senate version of the Farm Bill. Next, the entire Senate will need to pass the Farm Bill without deleting mCOOL. Finally, mCOOL has to survive the reconciliation process with the House of Representatives.

It took the combined efforts of thousands of people and dozens of agricultural and consumer organizations to get this far. We also need to acknowledge Senators Thune’s, Hoeven’s, and Booker’s leadership in getting this through the Senate Agriculture Committee with seventeen in favor and only 6 opposed.

The National Cattlemen’s Beef Association (NCBA) and the meat-packing cartel appear to be stunned, and we can be sure that their lobbyists, decked out in white Stetsons and alligator-hide Tony Lamas, are stalking the halls of Congress, demanding that mCOOL be removed from the Farm Bill. The trouble they have is that there are no facts on their side, so they continue to resort to lies, innuendo, and exaggeration. This worked for the NCBA and Packers in the past, and we need to make sure that it will not work once again.

The NCBA/Packer argument boils down to three allegations: Consumers don’t care; it is too expensive to implement; and the United States will be fined billions of dollars by the World Trade Organization (WTO).

This last one is easy to dismiss. No one cares anymore what the WTO has to say. President Trump has upended the Free Trade regime and our trade obligations are now governed by bilateral agreements. Currently, the President is threatening Canada with a fifty percent tariff.

As for the assertion that consumers do not care to know the origin of their food, witness the current epidemic caused by contaminated lettuce from Mexico or the blueberries at Publix.

As for the assertion that consumers do not care to know the origin of their food, witness the current epidemic caused by contaminated lettuce from Mexico. When a health issue arises, people pay attention. The problem we have with beef is that many consumers don’t realize that they are not allowed to know the country of origin. Consumers understandably confuse the USDA inspection label to mean that the beef is of American origin. But explain this to any beef consumer you might randomly meet, and they are outraged.

Our brief experiment with labeling beef (from 2009 to 2015) did have an impact. A 2014 paper by Canadian researchers Sebastien Pouliot and Daniel Summer (Differential Impacts of Country of Origin Labeling: COOL Econometric Evidence from Cattle Markets, Food Policy, 2014) concluded: “We find significant evidence of differential impacts of COOL through widening of the price basis and a decline in ratios of imports to total domestic use for both fed and feeder cattle.”

This is exactly the result we were hoping for. No disrespect or animosity towards our Canadian neighbors, but this is the United States of America, not the Confederated Countries of North America. Our country has been hemorrhaging hundreds of thousands of ranchers and independent feeders, and the lack of transparent markets is one key reason.

The final argument, that implementing COOL is expensive and that these costs shall be borne by the producer, is a little trickier to counter. This is because the Packers control all the data and are not sharing. The Packers even withheld that information from their own researchers who just released a paper: Economic Impact of mCOOL on the Beef and Pork Value Chains, Meat Institute, June 2026. In orderto allege that mCOOL is too expensive, the Meat Institute relied on papers published before mCOOL was ever enacted. The authors of those original papers made extraordinary assumptions to prove their thesis.

Buried in the Meat Institute’s twenty-one tables of data is the assumption that the cost of implementing mCOOL for the domestic cattle chain would be $0.031 per pound. However, adding in the imported cattle and beef, they maintain, would jump the retail costs to $0.169 per pound. There does not seem to be any actual verifiable data; it is just assumptions compounded on assumptions. Oddly, the original assumption from 2009 was that the domestic supply chain cost would be $1.50 per head ($0.003 per pound). We have experienced inflation, but not tenfold.

We import three sources of beef. On the hoof come about 550,000 head of finished cattle from Canada. Then there are an additional 150,000 Canadian and 950,000 Mexican feeder cattle. All of these steers and heifers are electronically ear-tagged as to country of origin. Therefore, imported cattle make up about 6.5% of the cattle slaughtered annually. The NCBA and the Meat Institute want us to believe that because some of these cattle might be comingled with domestic cattle, it is too expensive to keep track of them. That dog does not hunt.

The third source of imported beef is 1,317,812 metric tons (2021 to 2025 average) that is frozen or chilled. For reference, each metric ton of beef represents about five animals. Much of this meat is blended with domestic fat trimmings to increase the fat content of the hamburger we buy in the supermarkets. All of this imported beef is already labeled as to the dozen or so countries from which it is sourced. The previous COOL labeling regulations allowed importers to list all of the countries from which the beef might have originated. There is no cost associated with that.

It is not just ranchers and feeders who are being defrauded by the lack of labeling transparency, but consumers as well. The whole point of mCOOL is to give producers and consumers more choices. In the absence of mandatory labeling, producers cannot market their products effectively. For instance, the majority of “grass fed” beef in the market comes from Australia. Therefore, domestic producers of, say, grass-fed Wagyu beef have trouble getting their product in supermarket meat cases because it is more advantageous for the packers and retailers to sell cheaper Australian beef at higher domestic prices.

In a transparent market, the consumer will be able to choose to buy locally sourced beef at a premium – or not. With mCOOL, we can anticipate that imported beef, primarily in the form of hamburger, will be offered at a lower price. Muscle cuts of domestic meat will probably stay at about the same level. Beef differentiated as to quality or local source may very well sell at a premium. In the end, the consumer will choose, but only if they are allowed to choose.

When the timing is right, you will be asked to contact your Congressperson to demand that they vote for mCOOL. We are so close, so let’s not blow the opportunity.

Gilles Stockton
Grass Range, Montana
(406) 428-2183 
 mca@montanacattlemen.org, gillesstockton@gmail.com