USDA was forced to reconsider its earlier assumptions that the COOL law would be costly and burdensome to producers after the initial estimates were called into question.

• The fish and seafood labeling program has benefited the U.S. shrimp industry and consumers. Recent food safety events surrounding Chinese fish found to be contaminated with substances not approved for use in fish production in the U.S. are a good example of how country of origin labeling of seafood has provided consumers with information they want and need when purchasing food for their families. A.J. Fabre, President of the Louisiana Shrimp Association says, "The Louisiana Shrimp Association is pleased that the COOL regulations are in place so consumers can identify shrimp from China and other countries where health and safety standards are lax. We think the COOL regulations work in tandem with our import standards to keep the public safe. The U.S. government has funding to inspect less than 2 percent of imports which means consumers must rely on the country of origin label for the shrimp products they purchase."

Since implementation of the fish and seafood labeling law no retailers have been forced out of business, nor have any been fined, for not complying with the law.

• Beef, pork, lamb fresh fruits and vegetables are covered commodities. Opponents of COOL have used the excuse that poultry and food service establishments are not covered under the law. This is true and the reason is because there was simply a lack of support from the integrated U.S. poultry industry and the food service industry. In fact, there was so much opposition from the food service lobbyists, COOL supporters decided to drop that part of the law in hopes of passing labeling in the grocery stores. Now the same groups that opposed labeling of the covered commodities are criticizing the law for not being more inclusive. USCA has no objection to poultry or other country of origin labeling. Concern about food products produced in other countries continues to grow and U.S. consumers will likely demand the same information on more than just the covered commodities. Certainly, USCA and other supporters of the 2002 farm bill COOL language would not oppose M-COOL for poultry products. Many COOL supporters also support food service establishments being considered the final consumer and that country of origin information should be provided to them as final consumers. More and more U.S. food service providers are turning to domestically grown and processed food products for their customers.

• Surveys show consumers overwhelmingly support labeling and will pay a premium for it.

86% of consumers surveyed by Fresh Trends in 2002 favored COOL.

68% of consumers surveyed by North Carolina State University in 2003 said they would pay more for food grown in the U.S.

74% of consumers surveyed by Colorado State University said they would be willing to pay more for beef with country of origin labeling. The study included an auction test market in Denver and Chicago, which revealed consumers would pay an 11% and 24% premium for steak and hamburger respectively.

• Livestock Record-Keeping Doesn’t Have to Be Difficult. USCA is very concerned that there are not set record-keeping requirements for livestock producers, yet meat packers are currently using intimidation tactics to undermine producer support for COOL. USDA has already stated in the new comment period announcement that changes made in the interim final rule for fish and seafood would be used for other covered commodities. USCA applauds these changes, which address many of the concerns of processors with regard to record-keeping. There is a large conflict of interest in allowing the packers, who have opposed mandatory COOL from its inception, to have authority to audit producer records. The producer record-keeping rules need not be costly or burdensome to the producer, and most importantly, should not be accessible to packer review. The record-keeping requirements should allow those who solely produce U.S. products to self-verify that fact; and allow producers, processors and retailers to maintain records in a manner of their choosing as long as the information is available and can be transferred to a standardized format in the event of an audit by USDA.

• COOL will not cause problems in border states that feed Mexican cattle. The assertion that COOL could cause a problem in Texas or any other state that regularly imports large numbers of foreign cattle is unfounded. All Mexican cattle are permanently identified as being a product of Mexico. So, while many Mexican cattle are fed in certain border states, the feedlots and processors know that these permanently identified cattle are not eligible for the Product Of The USA label. Identifying Mexican cattle is not the problem. It is simply a matter of passing that information on to the consumer.

• Mexican Feeder cattle will come into the U.S. There will still be a market for Mexican feeder cattle and no one in the U.S. will lose any of the margins they make on Mexican cattle now. U.S. cattlemen and businesses in the beef chain work from margins they control and can maintain. Stockers work off the gain on grass; feedlots work from the cost of gain in the feedlot, and packers will only pay as much as the market dictates in relation to the demand they have for it. As far as losing a share of the Mexican market, they will have the opportunity to buy grain fed beef of Mexican origin from the U.S.

• COOL does not prohibit the co-mingling of foreign and domestic beef. Those fast food burgers most people love are generally fabricated from lean foreign beef and enough domestic beef trim to make them tasty. Countries like Australia and South America raise the sort of cattle that produce very lean beef. Co-mingling is a practice that utilizes foreign beef along with domestic trim that would otherwise be waste product. While ground beef is covered under the law as a retail commodity, the current COOL law does not require food service establishments to comply, although more and more food service restaurants are seeking domestically raised product. COOL does not prohibit the practice of co-mingling beef, it just ensures the information about origin is passed on to consumers.

• COOL and Animal Identification should not be linked. COOL is a marketing issue. Animal identification is an animal health issue. The national animal identification system is a program still in its infancy and the controversy surrounding it would only further hinder the implementation of COOL. The unknown cost involved at this point prohibit the use for a simple passing of a consumer information law like M-COOL.

• COOL does NOT present a trade barrier that will hinder exports of U.S. beef. A study completed by the Government Accountability Office (GAO) found, "most of the USDA attaches for 57 U.S. trading partners surveyed reported their host countries require country of origin labeling for one or more of the commodities covered by the new law. Most countries with programs conduct routine inspections and impose fines for labeling violations." Nations utilizing country of origin labeling included some of America’s largest trading partners - Canada, Mexico and Japan. Foreign nations routinely utilizing country of origin labeling have reaped the economic benefits associated with their access to America’s beef market without distinguishing their product from U.S. product. Many consumers confuse the USDA grade stamp as meaning product born and raised in the U.S. when, in reality, the USDA grade stamp does not guarantee exclusive U.S. product.

• It’s time to implement COOL. Signed into law in 2002, country of origin labeling has yet to be implemented with the full intent of Congress integrated into the law’s application. It is time for Congress to establi

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Individuals or organizations wishing to join the Colorado Coalition Opposing Mandatory 4-H and FFA Premises Registration should contact John Reid at 719/446.5210