Stockmen’s Association urges common-sense implementation of cool



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Stockmen’s Association urges common-sense implementation of COOL

The North Dakota Stockmen’s Association (NDSA) submitted formal comments to the U.S. Department (USDA) of Agriculture’s Agricultural Marketing Service this week regarding its proposed mandatory country-of-origin labeling (COOL) rules. The producer organization emphasized that the program be implemented in a common-sense, non-burdensome fashion for cattle producers, NDSA Executive Vice President Wade Moser said. “Stockmen’s members have long felt that country-of-origin labeling will be a positive marketing tool for U.S. cattlemen and finally give them a chance to differentiate their superior product in the marketplace – that is, if the program is implemented correctly. That’s why we have and will continue to work with USDA to make sure this is done right.”

Moser stressed in the comments that the standards for determining eligibility of beef to be labeled as a “Product of the USA” be as simple as the standards for beef derived from animals born and raised in a foreign country to be eligible for a foreign label. For example, beef derived from a live animal imported from Canada is automatically eligible for a “Product of Canada” label simply by crossing the United States border from Canada, and no additional paperwork is required. The NDSA believes that an equally simple system be used to determine eligibility for the “Product of the USA” label. “Clearly, any animal that does not cross the United States border from a foreign country can be nothing other than an animal born and raised in the United States, “ Moser said. “Therefore, no third-party verification of calves or other complicated systems are needed to determine that American cattle are American cattle.”

Besides, the comments continued, USDA does not have authority to include U.S. cattle producers, backgrounders or feeders under its jurisdiction in regards to COOL, since Congress explicitly listed the entities that are subject to the COOL Act, including “any person that prepares, stores, handles or distributes a covered commodity for retail sale.” Producers, backgrounders and feeders do not match this definition, so USDA does not have the authority to require them to keep auditable records documenting origin or to disallow the use of self-certification as a means to verify their animals’ origin when the animals enter the next production phase.

What USDA must regulate, Moser said, is live cattle entering the United States from a foreign country at the border, since these are the only animals capable of producing beef that must be labeled other than “Product of the USA.” These animals must also be identified at the point of slaughter, since the beef that they yield will require a different label, he explained.


The NDSA suggested the use of brands, tattoos or permanent ear tags as the means to permanently mark foreign animals. A mandatory individual identification system, however, is not necessary, Moser said, since very little individual information is needed – only enough to distinguish the animal as being imported from its respective country. Such a requirement is already allowed through the General Agreement on Tariffs and Trade (GATT) and the Tariff Act of 1930. Cattle imported from Mexico are branded with a lone M on the hip and cattle imported from Canada possess special ear tags when they enter the United States.

The NDSA also emphasized that USDA should establish explicit rules prohibiting packers from imposing conditions on U.S. producers  to verify origin, since that is not necessary. Several U.S. packers have indicated they would require extra paperwork and other extras from producers when mandatory COOL is implemented. But because packers do not have the right or necessity to do that, Moser said, it needs to be specifically prohibited.

It is not practical or even possible to determine the origin of animals already residing in the United States, except for the Mexican and Canadian marked ones, the NDSA realizes. Thus, enforcement of these rules should only begin once the COOL Act takes effect, Moser urged USDA. Those animals should be exempt with a grandfather clause. “This is the only way to equitably and fairly clear the livestock presently within the production system,” he said.

The NDSA will present these and other suggestions about the COOL implementation at one of the USDA’s scheduled COOL listening sessions. Three meetings will be held in this region in the following locations: Kearney, Neb., May 8; Billings, Mont., June 6; and St. Paul, Minn., June 24.



To view the NDSA’s complete comments, log on to the association’s website at www.ndstockmen.org.       
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