NOBULL: R-CALF USA Urges USDA to Go Even Further to Modify COOL

R-CALF USA Urges USDA to Go Even Further to Modify COOL

Billings, Mont. – In comments supporting the U.S. Department of Agriculture’s (USDA’s) March 12, 2013 proposal to modify its country of origin labeling (COOL) regulations, R-CALF USA urged the agency to adopt additional modifications the group said would achieve cost savings, eliminate redundancies, and reduce the recordkeeping burden for all suppliers of cattle, both domestic and foreign.

In June 2012, the World Trade Organization (WTO) ruled that COOL regulations required livestock suppliers to gather more information than was ultimately provided to consumers via a label. Due to this imbalance between information gathering and information sharing, the WTO determined that COOL discriminated against Canadian and Mexican livestock.

USDA’s proposal is intended to bring COOL into compliance with the WTO ruling. R-CALF USA, however, has been urging USDA to modify its COOL regulations long before the adverse WTO ruling – since at least July 2009 according to the group’s comments.

The current COOL regulations "were improperly and unlawfully adopted, are contrary to the intent of Congress, and impose recordkeeping requirements on cattle producers that are not needed to accurately inform consumers as to the origins of beef," the group’s comments state.

In addition to its strong support for USDA’s proposal to eliminate the loophole that currently allows meatpackers to affix a label naming multiple countries even on products that are exclusively domestic, the group urged USDA to go further in its rulemaking to remove the recordkeeping requirement imposed on cattle producers who deliver cattle to meatpackers.

The comments state: "R-CALF USA encourages USDA . . . to eliminate the present regulatory burden on U.S. cattle producers to provide producer affidavits to meatpackers that attest to the origins of live cattle," and to, instead, exclusively authorize meatpackers to initiate origin designations on their own based on the same presumption of domestic origin methodology that USDA allows producers to use.

The group wrote that this modification would lower the overall cost of COOL compliance, eliminate redundancies, and reduce burdens on upstream cattle suppliers, which R-CALF USA states would address the WTO’s criticism regarding disproportionate recordkeeping compared to the detail of information conveyed to consumers.

"(O)ur suggestion is not only compatible with the proposed COOL rule, but also, it compliments the proposed COOL rule because it would further reduce costs, recordkeeping requirements, and burdens on upstream cattle suppliers while simultaneously improving the efficiency of COOL implementation," added the group.

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R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) is the largest producer-only cattle trade association in the United States. It is a national, nonprofit organization dedicated to ensuring the continued profitability and viability of the U.S. cattle industry. For more information, visit or, call 406-252-2516.