I am writing this if for no other reason than to remind myself of the timeline and events that have contributed to this international discussion. I was in junior high and high school and remember talking about it at 4-H meetings, hearing about it at industry conferences, but it was something at that time that was so removed from my focus. Today, it’s touching every discussion I participate in the beef industry. I hope this is a resource and “SparkNotes” like version for reference with little emotion.
Some quick FAQs:
So what is Mandatory County of Origin Labeling (mCOOL)?
Mandatory Country of Origin Labeling (mCOOL) is a consumer labeling law that requires retailers (full-line grocery stores, supermarkets, and club warehouse) to identify the country of origin on certain foods referred to as “covered commodities”. The law requires retailers to notify their customers of the country of origin of muscle cuts and ground lamb, chicken, goat, wild and farm-raised fish and shellfish, perishable agricultural commodities, peanuts, pecans, ginseng, and macadamia nuts.
What defines retailer?
The legislation defines a “retailer” as any person engaged in the business of selling any perishable agricultural commodity at retail by the Perishable Agricultural Commodities Act of 1930 (PACA). Those who sell more than $230,000 in fresh or frozen producer in a calendar year are required to get a PACA license.
- Includes: grocery stores, supermarkets, and warehouse stores.
- Doesn’t Include: retail stores that do not meet the $230,000 threshold of purchasing examples include small grocery stores, small fish markets, and small butcher shops.
- Foodservice establishments and restaurants are also exempt.
Is locally grown the same as mCOOL?
No. Local or regional names are not specific enough. State marketing programs “Idaho Preferred” would qualify as a mCOOL designation.
What is and is not subject to be labeled for mCOOL designation?
If an included commodity has been processed, meaning it has undergone a specific process resulting in a change of character (i.e.) cooking, curing, smoking, restricting) or has been combined with another food component are excluded from mCOOL.
Any product that has been cut, trimmed, chopped, or sliced are considered activities that do not change the character of the product. Therefore, if the product if the character of the product is not changed in any way during the processing it falls under designation for mCOOL. Therefore, whole muscle cuts of chicken, goat, and lamb.
Now for ground meats of chicken, goat, and lamb. The meat derived from animals where production steps occurred in multiple countries including the U.S. must be labeled with product steps at the point of sale.
Now for the meat, potatoes and the dollars of this discussion.
COVID-19 is continuing to cause a major disruption to our nation’s economy, which of course involved commodity products such as beef. If you review the history of mCOOL, you will see that beef and pork have been at the center of this debate since the beginning. mCOOL discussions were coming back up through members of Congress in late 2019. The economic downturn of 2020 and imports of lean beef from around the world has brought mCOOL back to center stage.
What was mCOOL intended to do?
The original intentions of mCOOL were to provide customers with information to make buying decisions.
There are no food safety standards included in the law.
Now, that was the stated intention of the law. An understated aspect of the legislation was food marketing, not just consumer information.
What is voluntary COOL labeling?
Voluntary COOL labeling is implemented by the private industry and is in response to the consumer demand or marketing ability of the producer. There are multiple private brand labels include voluntary COOL standard as part of their branded product line. You will need to determine which program is right for your location and production practice. Or producers can create their own label.
Dollars and Sense
I am going to stay as far away from trade discussions in this post as possible. mCOOL’s history obviously is largely tied to international trade as you can see in the timeline. Domestic is the focus here.
The main study reviewing the impact of mCOOL on the beef and pork industry has lots of interesting insight. If you have the time to read it, I would do so.
Tonson, Schroeder and Parcell stated in the report to Congress “Economic Analysis of Country of Origin Labeling (COOL) in April 2015 that, “While there is evidence indicating consumer interest in COOL information, the evidence does not support a conclusion that COOL significantly increases consumer demand even though consumers desiring such information benefit from its provision.”
What does that look like in the way of dollars based on the 2013 ruling? Over 10 years, the loss of the beef industry was estimated to be $494 million beef industry and $403 million to the pork industry. Consumer losses for beef and pork were estimated at $378 million and $428 million.
In keeping this direct, based on this study it indicated that beef and pork would both lose significant market shares and being able to compete on a price basis with mCOOL. Poultry would end up seeing an increase due to consumer demand for protein and not purchasing beef or pork. Consumers may be interested in aspects of food production, but are they willing to pay for it? Some might be, but the model for this study did not indicate consumers were willing to pay a premium to cover the costs.
With all of the noise in social media and media platforms about this issue, Agriculture Secretary, Sonny Perdue, said in March that mCOOL “is not going to happen unless we want to do a billion-dollar litigation damage with Mexico and Canada.”
I hope you found this helpful in understanding the history and current status of this food policy legislation.
