While the U.S. Department of Agriculture (USDA) has not communicated specific COOL requirements for seedstock producers, the growing consensus is that sellers should provide an official “Recommended Country of Origin Affidavit / Declaration Statement” to buyers, along with a bill of sale. The North American Limousin Foundation (NALF) and others in the seedstock sector are communicating with UDSA about ways in which that affidavit information might be included in breed associations’ ownership-transfer records. In the meantime, NALF advises seedstock producers to provide purchasers with signed affidavits.

The COOL law states that anyone who supplies a covered commodity to a retailer, directly or indirectly, must maintain records (for example, affidavits and bills of sale) to identify the product’s immediate previous source (if applicable) and immediate subsequent recipient. Such records must identify the product uniquely, and they must remain accessible for one year after the transaction.