Get COOL with the USDA

The (COOL) Country of Origin labeling requirements are here for retail food manufacturers and grocery stores. The USDA has finalized the labeling requirements and an interim final rule becomes effective September 30, 2008. This law specifically covers raw muscle cuts of beef, pork, chicken, lamb, goat, perishable agricultural commodities, shellfish, ginseng and some nuts. The law excludes processed, ready-to-eat food items or items produced or packaged before Sept 30, 2008.

What “processed” means is an on-going controversy. Right now, the rule states that any combination of ingredients=a processed item. For example, roasted nuts and mixed vegetables are exempt.

How should food producers address these new labeling requirements on packaging? For design elements, there are no rules for the font, size or color but, it must be legible and in a conspicuous location. Symbols and flags alone are not acceptable. The "Country Of" designation can be made on placards, labels, signs, stickers, twist ties, etc. Simple statements like, “Product of U.S.A.” should cover most applications and there is a provision for labeling multiple countries of origin.

Want to help blend this new regulation with your branding message? For products other than meat, fish and shellfish, you can still use the allure of the hills of California by using the state or regional identification in place of the Product of USA claim.

The rules should be finalized by January, and according to the USDA, the next six months will be an education and outreach phase.

What does this mean for producers, retailers and package designers? In the short term, reading the 47 page regulation, squeezing in some more copy on the packaging and probably more packaging reviews with the USDA office.

Want clarification on this? For the USDA information use the following link
www.usda.gov

For commentary on this regulation, see these links
CU lauds mandatory country of origin labeling

USDA sets interim rules for country of origin labeling

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