Feuz asks the important question to producers, “Are you ready for COOL?”
With today being the first inception date of Mandatory Country of Origin Labeling (MCOOL), I thought Dillon’s Feuz’s column was the perfect fit for today’s main headline. Feuz discusses on the impacts of this government program for anyone buying or selling cows, yearling, calves or bulls. Where are you at on this issue? Do you think American born and raised beef will fly off the shelves like hotcakes? Or will this be just another governmental intervention that will cost millions to implement, hurting producers and consumers alike? You tell me. Dillon Feuz sure did.
Hit it, Dillon.
Perhaps, I should have titled this article, “Why government intervention is seldom a good thing,” then you would know my bias and could decide if you wanted to keep reading. In case you are not aware, Mandatory Country of Origin Labeling (MCOOL) is set to go into effect on September 30, 2008. I will first outline what your minimum responsibilities are to be in compliance with the legislation. Then if I have the space left in this column you will get my rant on this poorly conceived and poorly written legislation.
The USDA-AMS released an Interim final rural with request for comments in the Federal Register on August 1, 2008. You can read the rule (all 45 pages of it) and submit comments prior to September 30. The rule may change slightly following the comments, but here are some of the requirements that relate to beef. Cattle are not directly covered in this federal legislation, but muscle cuts of beef and ground beef are.
Anytime you sell cattle you are going to need to sign an affidavit explicitly stating the country of origin of those animals. Anytime you buy cattle, you will need to obtain that affidavit from the seller to protect you when you subsequently resell the cattle. Furthermore, you may need some supporting evidence to substantiate the claims of origin in your affidavit. These supporting records are to be from “records maintained in the normal course of business.” Such items as herd records, vaccine purchases, feed purchases may be used to substantiate affidavit claims. If you are a part of a voluntary animal id system, that system may be used to substantiate country of origin. However, neither the USDA nor a packer entity can require an identification program. “The use of a mandatory identification system that would be required to track controlled product through the entire chain of commerce is specifically prohibited.”
An important provision in the rule is that all cattle in the U.S. as of July 15, 2008 are considered of U.S. origin. Therefore, producers need to document their current herd numbers and makeup as they will be selling these cows for several years and may need some evidence to support their affidavit claims in the future.
For those of you who supported this legislation, congratulations! It is here. For those of you who were opposed to this legislation, sorry. Big government just reached into your wallet and stole from you again.
You can find the rest of Feuz’s column at Cattle Market Analysis, where Utah State University’s Feuz discusses the impact of MCOOL on stockers, feeders and cattlemen’s organizations.