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“COOL� AT FOOD By Beatriz Ackermann [*] COOL (Country of Origin Labeling) is the rule that establishes the obligation of indicating the country where a food product has been produced. Its application in the US and the European Union is of particular interest to food exporters who ship products to those destinations.

In the US COOL is not a food safety program, but a tool of commercial legitimacy and consumer protection. The competent authority is the USDA Agri-Food Marketing Service (AMS). Retail operators (supermarkets, department stores) are required to report on the origin of certain foods and keep records. The Customs and Border Protection Agency (CBP) and the Federal Trade Commission (FTC) are also involved in the control and implementation of this rule. Whole and ground meat (lamb, goats and poultry), fish, seafood, fresh and frozen fruits and vegetables, ginseng, as well as certain nuts (peanuts, pecans and macadamias) are subject to this measure. Meat In February this year, after an appeal filed by Canada and Mexico before the WTO which obtained a favorable ruling, the US Congress enacted an amendment eliminating mandatory COOL for beef and pork. Products of animal origin receive the greatest impact, as long as they must detail accurate information on place of breeding, slaughter and packaging. On the other hand, the products included in the rule that have been produced in third countries, imported into the US and that have not undergone a subsequent substantial transformation within the US territory, must keep the same indication of origin as it was declared in the import documents until the final sale point.

Format The declaration of country of origin can be printed on the original label, or in a sticker, band, card or similar means that allows the consumer to identify the food source clearly and unambiguously. Legends such as "Product of USA", "Produced in Mexico" or "Grown in Peru" are acceptable. Also the only mention of the country is admitted, for example: "Spain". COOL must be precise, truthful and understandable, and should be located in a place of the packaging that is distinguishable by the naked eye. Exceptions The requirement applies only to retail businesses with an annual turnover of more than USD 230,000 in perishable products. The rule does not oblige small butchers, hotels, restaurants and places where food is served (clubs, fairs, food-trucks). Nor does it apply to processed food products such as chocolate bars, tomato sauce, instant soups, noodles, breakfast cereals, jams. ÂżWho cares? An indication of origin can be beneficial to both producers and consumers; it represents a significant element of added value. For those sectors of international industry that have invested heavily in achieving a certified designation of origin, COOL is an acknowledgment that rewards that effort and contributes as a marketing action. At the other end of the chain, the so-called "conscious" or "responsible" consumers give special consideration to those products whose labeling allows them to know the production history of the food they are buying. Manufacturers, on the other hand, question that COOL causes a heavy administrative and economic burden on industry. European Union Regulation 1169/2011 on Food Information to Consumer (FIC), which came into force in December 2014, introduced the mandatory COOL for meat products with the exception of beef produced on Community territory. Imported beef, poultry, fish and shellfish should show the country of origin on their label. Identical requirement applies to honey, olive oil, wines and most of imported fruits and vegetables. European Community legislators agree to prioritize the interest of consumers and argue that COOL should be extended to more food and ingredients. At the moment, all supply chain sectors involved in the trade of the products included in the current regulation are obliged. Under FIC, mandatory indication of provenance also applies where its omission may result in confusion or deception for the consumer and for those products in whose composition the primary ingredient does not originate in the same country where the final product has been produced. [*] Beatriz Ackermann, expert consultant on international trade and food safety Container Magazine, Year 12, #135, Cordoba, ARG., December 2016.


COOL (Country of Origin Labeling) is the rule that establishes the obligation of indicating the country where a food product has been produc...

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