Matt Mullins


Country of Origin Labeling, COOL, Farm bill, grocery stores, labeling food, covered commodities

Document Type



The much anticipated and hotly debated Country-of-Origin Labeling (COOL) provision of the 2002 Farm Bill went into effect on September 30, 2008. The interim final rule published on August 1, 2008 finally put into law a provision first passed in the 2002 farm bill. This provision requires grocery stores and other retailers who sell food products to the private consumer to label certain meats, vegetables, fruits, and nuts with their country of origin. Foods that must be labeled are identified in the bill as "covered commodities." But, for all of the covered commodities, there exists a substantial list of products that do not require the COOL label: "processed food items." The United States Department of Agriculture (USDA), the purveyor of the interim final rule, has broadly defined processing to include any item "undergoing a specific processing to change the character of the commodity or combining it with at least one other covered commodity or substantive food component." These exceptions lead to some puzzling distinctions between covered and exempted commodities. For example, raw peanuts would require a label, but roasted peanuts would be exempt since roasting is considered by the rule to be a further processing; pork chops would require a COOL label, but ham and bacon would not require the label; and chopped lettuce in the produce section of the grocery store must be labeled, but chopped lettuce on the salad bar at the grocery store would be exempt under the restaurant exception.