August 23, 2007

U.S. Cattlemen’s Association FAQ Sheet on COOL and Source/Age Verification of Cattle

Contact: Danni Beer, USCA COOL Committee Chairman 605/524-3383

The U.S. Cattlemen’s Association has discovered that some entities are issuing statements to producers that might be misleading about source and age verification versus country of origin verification for cattle under the Country of Origin Labeling Law (COOL). The U.S. Cattlemen’s Association offers the following facts in an effort to clarify the subject.

~ COOL does not require source or age verification. As written, the COOL law does not require SOURCE OR AGE verification. The law simply requires that producers verify the COUNTRY OF ORIGIN. There’s a big difference between the two. Verifying origin refers to the country the animal is born and raised in. Source verification, as interpreted by the industry related to certain programs like natural beef or branded beef programs, goes back to the specific ranch of origin.

~ The COOL Final Rule has not been completed; specific methods for origin verification will not be known until the rule is completed and issued. The COOL Final Rule is still being crafted; consequently, the specific methods by which producers can verify origin under the law to qualify for the exclusive USA label are not known and will not be known until the Final Rule is issued. USDA published a list of documents that would prove country of origin throughout the beef chain after the release of the preliminary rule in 2003. The list of documents that are acceptable can be found in the COOL Library at The U.S. Cattlemen’s Association is working closely with enforcement agencies to guide this process in a manner that is least burdensome for producers.

~ More comment periods likely on COOL Rule. The U.S. House of Representatives has passed its version of the Farm Bill, including the COOL law as amended by the U.S. House Agriculture Committee. The U.S. Senate will undertake debate over its version of the Farm Bill in September. It is likely that after that Senate passes its version of the Farm Bill, another comment period on the COOL Final Rule will be made available. This is yet another opportunity for producers to help shape the rules for implementation of the law. There is no evidence that U.S. cattle will have to participate in any sort of electronic identification system in order to qualify for labels under the COOL law.

~ The law precludes linking COOL and Animal I.D. Provisions in the law prevent the linking of mandatory animal identification and COOL.

~ Source/Age Verification and Export Markets. The packing and cattle feeding industries likely want cattle age and source verified so they are eligible for certain export markets that require age verification. This is because some of America’s most lucrative export markets do not accept beef from some of the countries the U.S. imports from. The U.S. Cattlemen’s Association supports producers’ opportunity to add value to their cattle. The source and age verification programs being suggested by some entities go far beyond what is required by certain export markets and far beyond the likely requirements for COOL implementation.

~ Congress has issued a time line for COOL implementation. Congress has ordered USDA, through the appropriations process, to meet certain deadlines and benchmarks with implementation of the law by September 8, 2008.

~ Don’t let COOL opponents distract us! It is crucial that producers do not become distracted from the COOL rule writing process by entities that are disseminating less than factual information. It is very important for producers to engage in comment periods with USDA to see to it that rules are written in a least-cost, least-burdensome manner. If producers are concerned about proving country of origin for the cattle they own, buy or sell, USCA recommends keeping good, accurate records producers are accustomed to keeping during their normal course of business.

Established in March 2007, USCA is committed to assembling a team to concentrate efforts in Washington D.C. to enhance and expand the cattle industry's voice on Capitol Hill. For membership forms and other information visit