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Country of Origin Labeling Requirements
For the Food and Beverage Industry

As of October, 2008, retailers are required by law to label the Country of Origin on all fresh produce, meat, poultry and fish sold in the United States.

In addition to the labeling requirements under the COOL regulation, other government agencies also have requirements for labeling the origin of imported products, including U.S. Customs and Border Protection (CBP) and USDA’s Food Safety and Inspection Service (for meat products only) (FSIS).

The following lists labeling requirements based upon the 2008 Farm Bill legislation.

Country-of-Origin Labels are required on:

Meat sold in supermarkets Sliced cantaloupe Raw shrimp
Fish sold in supermarkets Raw almonds Fresh salmon
Raw peanuts Bagged lettuce  
Pork chops Frozen peas  

Country-of-Origin Labels are not required on:

Meat sold in butcher shops Fruit salad Cooked shrimp
Fish sold in fish markets Trail mix Smoked salmon
Roasted peanuts & peanut butter Bagged mixed salad greens  
Ham and bacon Frozen peas and carrots  

Exemptions

Food service establishments such as restaurants, cafeterias, lunch rooms, food stands, saloons, taverns, bars, lounges, salad bars, and delicatessens, food enterprises located within retail establishments that provide ready-to-eat foods that are consumed either on or outside of the retailer’s premises are exempt from COOL requirements.

Stickering and Other Labeling Options

The law provides retailers have a flexible variety of options for marking commodities in compliance with the law. These options include POS placement of a placard, sign, label, sticker, band, twist tie, pin tag, or other format. Country of origin declarations may also be in the form of a checkbox on the master container. The USDA encourages retailers to supplement stickers on individual saleable items with point-of-purchase placards and other signage as a way to more clearly indicate information to consumers. Prescriptions for font size, typeface, color or location of country of origin claims are not included in the current law. However, declarations must be legible and placed in a conspicuous location for consumer review under normal conditions of purchase.

Read more important information about stickering and labeling options for retailers.

Records and Documentation Requirements

In general, retailers must maintain records or other documentary evidence that permits verification of origin claims made at retail. These records may be maintained in any location and, unless specified otherwise, must be maintained for a period of 1 year from the date the declaration was made at retail.

Read more important information about record and documentation requirements for retailers.

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