For the record, I still feel mandatory country-of-origin labeling (COOL) is a waste of time, energy and dollars.

So, before anyone accuses me of flip-flopping on this issue — let me start by pointing out that the headline is simply a statement of fact that the COOL rules are written — not an endorsement.

To the point about dollars, USDA estimates the total first-year costs to all firms directly affected by the rules at $2.5 billion. They estimate the cost per producer at $376, for intermediaries at $53,948, and $235,500 for retailers.

That's a pretty hefty tab on a program that adds little or no value to the consumer, who is already plenty peeved about higher grocery bills.

If the concept had real merit, you can bet your paycheck that retailers would have launched a voluntary program years ago.

Regardless of how we feel about it, shortly after you receive this edition of National Hog Farmer, COOL requirements will be enacted. After nearly six years on a bumpy path, the USDA on July 29 issued the Interim Final Rule on mandatory COOL implementation and earmarked Sept. 30, 2008 as the official start date.

Commodities subject to COOL include the muscle cuts and ground meat products from beef, lamb, chicken, goat and pork sold at retail. The rule also covers wild and farm-raised fish and shellfish, fresh and frozen fruits and vegetables, raw peanuts, pecans, macadamia nuts — and ginseng, the “root of heaven,” commonly used in southeastern Asian countries for its medicinal qualities. I'm told the most sought-after ginseng is found in the wild and its whereabouts is often tightly guarded — so good luck with that!

USDA has urged retailers to begin phasing in COOL, setting in motion a domino effect that will impact everyone down the food chain, including you at the load-out door of your finishing barn.

Here are the Rules

USDA has established four labeling categories for the commodities covered in the COOL rules:

“Product of the U.S.” — These animals must be born, raised and slaughtered in the United States.

“Product of U.S. and Country ‘X’” — The contents of this product may have originated in multiple countries. Hamburger, for example, might read: “May include product of U.S. and countries X, Y and Z.”

“Product of Country ‘X’ and U.S.” — Animals imported for immediate slaughter in the United States, such as market hogs from Canada.

“Product of Country ‘X’” — This category accounts for finished products ready for sale.

Your packer must tell you what documentation is required on cull breeding stock and market hogs.

All along, I've felt it would be far more logical to require identification of only those animals that were not born, raised and/or slaughtered in the United States, leaving those and/or born raised elsewhere with the identification and documentation chore. Of course, that sort of logic eludes Washington.

To their credit, however, they did make allowances for animals that are part of the U.S. National Animal Identification System or the official identification systems in Canada and Mexico, so long as they have the appropriate ear tag or body markings.

The official rule reads: “Any person engaged in the business of supplying a covered commodity to a retailer, whether directly or indirectly, must maintain records to establish and identify the immediate previous source (if applicable) and immediate subsequent recipient of a covered commodity for a period of one year from the date of transaction.”

Records You'll Need

The records you use for day-to-day operations, with individuals or groups of pigs identified, will fulfill the COOL requirements. Birth records, receiving records, purchase records, animal health papers, sales receipts, animal inventory documents, feeding records, breeding stock information and other normal documents used to track everyday production are examples.

The USDA-AMS rule considers a producer affidavit “acceptable evidence,” provided it is documented by someone with “first-hand knowledge of the origin of the animals and identifies the animals unique to the transaction.”

By the way, animals born or imported before July 15, 2008 will be grandfathered in as U.S. origin.

Iowa State agricultural economist John Lawrence boils it down to five easy points:

  1. Be proactive and show good faith.

  2. Develop an identification policy and stick to it.

  3. Maintain normal business records at the farm and make them available within five days, if audited.

  4. Be sure an affidavit accompanies all animal movements.

  5. Keep track of all pig movements one step forward (who you sell to) and one step back (who you acquire pigs from) and keep those records for one year.

Additional information about COOL can be found at