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Producers need to prepare for COOLMandatory law takes effect Sept. 30 By Jennifer Bremer
Mandatory country-of-origin labeling will begin Sept. 30; therefore, producers must be able to provide an affidavit as evidence of where their animals were born and raised. "COOL is not only for cattle and hog producers, but also sheep, goat, chicken and seafood producers as well as fruit and vegetable growers," said John Lawrence, director of the Iowa Beef Center. "Some things are not clearly defined with the requirements. We are getting closer to understanding, but we are still on a learning curve," he said. "Packers and retailers are the ones required to have this information so we need to help them comply." While this is a requirement and has been met with mixed feelings from livestock producers, it is nothing to be feared, according to Lawrence. "Producers shouldn't be worried about this. They just need to be aware of what will be expected of them to comply with the new law," he said. Buyers may ask producers to sign an affidavit stating the origin of the animals they are selling. Normal business records that producers keep will be all they need to prove compliance if they are audited. Lawrence said these records would include birth record, inventory records, sales receipts or health papers that most producers already have. "There will be more communication and paperwork between buyers and sellers," he said. "Keep documentation and be able to provide the buyer of your animals with that information on all animals on the farm--raised and/or purchased." Labeling categories While there are additional labeling categories, livestock producers will mainly be concerned with two categories: 1. Product of the U.S.--born, raised and slaughtered in the U.S. or animals that have been continuously in the U.S. since on or before July 15, 2008. 2. Product of the U.S., Country X and/or Country Y (if applicable), where Country X and Country Y represent the actual or possible countries of foreign origin. For example: animals born in Canada and fed and slaughtered in the U.S. Other categories include: 1. Product of Country X and U.S., which is for animals imported for immediate slaughter in the U.S. 2. Product of Country X, which is for an imported finished product. Lawrence said it is important for producers to know which category their buyer is going to claim. "Producers need to communicate with their buyer so they know what to expect," he added. He said packers can't assume where an animal was born and/or raised, but they can assume if it has an official electronic ID, that is where it came from. "Individual animal IDs are not required, but it may be easier, especially for co-mingled groups, and buyers may require IDs or more information from producers," he said. Lawrence recommends producers keep records for one year of whom they bought animals from and whom they were sold to. "Packers have the right to ask producers for the information and producers must provide it," he said. Producer affidavits A producer affidavit stating where the animals were born and raised is considered acceptable evidence for COOL and should accompany animals when they are sold. Sellers are then in turn responsible for maintaining adequate records and to support country of origin claims. Nancy Robinson, vice president for government and industry affairs for the Livestock Marketing Association, said it will be easier for the entire industry if all sectors work together to make the process universal. LMA recently sponsored a meeting among producer, packer, feedlot, processor and species groups to discuss how to initiate producer affidavits. "If all sectors of the industry come together to make a universal statement, it will be easier to implement COOL," she said. "There may be some in our industry who don't want to use the guidelines we come up with, but in the end ,it will be best to work together." While LMA isn't requiring each sale barn to follow the specific guidelines, she expects most to adopt the policy to have the information they need to be in compliance. "Even though the law pertains to the packers and retailers, it is the responsibility of the rest of the industry to help them be in compliance with the law," she added. Iowa coalition A coalition of Iowa agricultural organizations, including the Iowa Farm Bureau, Iowa Cattlemen's Association, Iowa Pork Producer's Association, Iowa Department of Agriculture and Land Stewardship, and the Iowa Pork Industry Center and Iowa Beef Center at Iowa State University prepared suggestions to meet the COOL rules. 1. Buyers should request a signed affidavit from the seller identifying the date of sale, number of animals, seller contact information, and the country where the animals were born and raised prior to sale. 2. The buyers should maintain the affidavits, sale bills, health papers, etc. and be able to provide the documents if audited. USDA has also identified common production and businesses that are acceptable. 3. Auction markets, order buyers and other market intermediaries should maintain records and sign as the seller, or pass the seller's information to the buyer. 4. Sellers that sign the affidavit are responsible for maintaining adequate records to support country of origin claims if audited. Pork requirements Jim McKean, associate director of the Iowa Pork Industry Center, said communication is the main key to proper compliance. "Producers should check with their packers because each packer may go at the process a little differently," he said. In pork production, records will be pertinent since many producers either only raise and wean pigs or only feed out hogs. Breeding records, birth records, transfer records within a production system, sales and/or purchasing records, interstate and intrastate movement records, health records and others will need to be kept in order to follow the chain of origin. "Since it is all new, changes may occur because we don't know exactly what to expect. It is unknown how retailers and exporters will react, so producers must be ready for whatever is required," he said. "While electronic identification tags are not required for COOL, they may be some day, so producers should register their premise and be ready for whatever may happen," he added. History The COOL law was first introduced in the 2002 farm bill, which amended the agricultural marketing act of 1946. Ag marketing legislation was delayed in 2004 and 2006 and on July 29, 2008 the USDA issued the final rule for implementation, which will become mandatory on Sept. 30. COOL applies to fresh muscle cuts of beef, pork, lamb, goat and chicken as well as ground meat from those species. Processed meats are exempt from the ruling. For more information on COOL, visit www.countryoforiginlabel.org, www.ams.usda.gov/cool/ or www.iowabeefcenter.org. Jennifer Bremer can be reached by phone at 515-833-2120 or by e-mail at jbremermaj@hotmail.com. 9/8/08 Date: 9/3/08
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