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.

COOL Best Management Practices for Retailers Labeling and Signage

The goal of retailer labeling and signage practices is to provide country of origin information at the point of purchase for the consumer of products covered by the COOL law.

The following best management practices should be followed by retailers with respect to labeling and signing:

Retailers should rely on existing supplier-applied industry labeling practices (e.g. the PLU sticker, band, twist tie, clamshells, bags, or label on package) as a means to provide consumers with country of origin labeling at point of sale.

However, some produce items (e.g. loose green beans), due to their physical nature or how they are merchandised at retail, cannot use these labeling vehicles and so labeling for these items should be the responsibility of the retailer at point of sale.

In the event that produce cannot be reasonably or economically labeled, or if a retailer chooses to market the produce in bulk, it will be the retailer’s responsibility to provide signage at point of sale in order to convey the produce’s country of origin to the consumer.

Retailers may rely on master shipping cartons and containers that bear the origin (country, or U.S. state or region) of the produce contained therein for their signage decisions.

For produce that is in seasonal transition from one growing region to another (foreign to domestic or vice versa), retailers should provide reasonable and accurate signage at point of sale. This may include one, or more than one, origin sign to disclose multiple origins on bulk displays.

For supplier packaging inventory that does not convey country, U.S. state, or region for purposes of origin labeling, retailers must provide origin labeling at the point of sale via signage until the supplier has a reasonable opportunity to exhaust inventory and provide updated packaging to their customers that provides origin designation. Not to exceed one year through 2009 Retailers are encouraged to work with their suppliers to establish more opportunities to individually label produce with country, U.S. state, or region of origin.

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.

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