After years of delaying the implementation of mandatory country-of-origin labeling (COOL) because of the problems associated with the law, it had come down to crunch time. Congress had to do something to make the law workable and it could no longer continue to delay its implementation, not with the China and dog food scandals on everyone's mind.

So in typical Washington fashion, they had to appear to be responding. The revised version of mandatory COOL is an improvement of sorts but nobody will truly be satisfied with this new law. While it will not devastate the industry as the original version would have, it doesn't address the competitive disadvantage with which it saddles beef. Nor does it close the loopholes that make the COOL component essentially worthless.

In fact, COOL as now proposed can't possibly make either side happy. It just mitigates the potential problems while giving everyone political cover.

It's a little difficult to explain the changes made to the law, but here are the highlights. The onerous record-keeping requirements have been eliminated, with no one now required to maintain anything but "normal" business records. The fines for noncompliance were reduced significantly, which eliminates some of the potentially devastating liability that would have been associated with selling our product.

The compromise also changed the possible package labels to include one called "Multiple Countries Of Origin," and another called "Imported For Immediate Slaughter." The result is that nearly all ground beef will be sold with a list of multiple countries (the list would include a list of all reasonably possible countries).

The previous version of mandatory COOL provided few or no benefits with a whole lot of costs and headaches. The proposed revision reduces the number of headaches and the costs, but reduces the chances of any benefits as well.

It's certainly an upgrade, but a long ways from ideal. It will be interesting to see if something different emerges from the Senate side.