FMI Opposes USDA’s Unreasonably Burdensome COOL Rule

Food Marketing Institute (FMI) submitted comments today to the U.S. Department of Agriculture (USDA) that criticize the scope of labeling required by proposed changes to the Country of Origin Labeling (COOL) program, offering alternative solutions unique to the needs of the food retailer and wholesaler.

FMI Regulatory Counsel Erik Lieberman wrote, “It would be unfair, and unreasonably burdensome, to require the food retailing and wholesaling industries to invest tens of millions of dollars retooling labels, upgrading equipment, training staff and segregating more product in stores and in the supply chain to comply with a regulation crafted for purposes of meeting World Trade Organization (WTO) requirements, before the WTO actually issues a ruling on the regulation.”

“If the proposed rule fails to fully address the WTO’s previous findings – which we believe will be the case – the whole purpose of the proposed rule will cease to exist and there will be no justification for moving forward with implementing it.”

USDA’s proposed changes carry with them significant costs for producers, retailers and consumers.  Lieberman explained, “Our current scale labels will not hold all the information required by USDA currently plus a statement of where the animal was born, raised and slaughtered. However, scales are only one small element of the changes necessitated by the proposed rule; there are tens of millions of dollars in additional costs that will be incurred up and down the entire supply chain.

These cost increases are being imposed without any clear benefits being offered to consumers. Lieberman corroborated, “While the regulatory burdens of COOL have led retailers and wholesalers to stop handling and selling many imported items, studies have found little to no impact on consumer purchasing behavior. FMI members have confirmed these findings that COOL has not impacted consumer demand.”

“The burdens of the regulation are clear, while USDA has failed to quantify a single benefit arising from this proposed rule.  Under these conditions, the proposed rule should not be implemented.”

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