March 3, 2009Client Alert

Implementation of United States Department of Agriculture Final Country-Of-Origin Labeling Rules Affirmed

After a six year rulemaking proceeding, the newly appointed United States Department of Agriculture (USDA) Secretary, Tom Vilsack, has signed off on final mandatory country-of-origin labeling (COOL) rules. The rules will go into effect on March 16, 2009, as scheduled.

In an “open letter” the Secretary sent to the industry, Secretary Vilsack encouraged voluntary adoption of additional labeling descriptors identifying where animals were born, raised and slaughtered alongside his calls for more restrictive inventory practices relating to the origin of ground product and expanding country-of-origin labels to certain categories of processed products exempted under USDA's final rule.

Secretary Vilsack‘s letter suggested the following voluntary labeling changes:

  • Labeling of product from animals with multiple countries of origin;
  • Labeling products that are subject to curing, smoking, broiling, grilling, or steaming;
  • The final rule allows a label for a ground meat product to bear the name of a country, so long as meat from that country was present in the processor’s inventory within the last 60 days. Vilsack suggests the time allowance be reduced to from 60 days to 10 days.

To see a copy of the USDA letter in its entirety, please visit:

For more information, please contact David A. Crass at or 608.257.3501.

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