Legal Ledger Brief: Groups submit COOL comments | Western Livestock Journal
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Legal Ledger Brief: Groups submit COOL comments

WLJ
Aug. 27, 2018 2 minutes read
Legal Ledger Brief: Groups submit COOL comments

Both the U.S. Cattlemen’s Association (USCA) and the Ranchers-Cattlemen Action Legal Fund (R-CALF) submitted comments regarding proposed changes to the Food Safety Inspection Service’s (FSIS’) Policy Book’s definition of “Product of U.S.A.” label claims.

The proposed changes came from a petition from the Organization for Competitive Markets (OCM) and the American Grassfed Association to change a portion of the “Product of the U.S.A.” policy. Currently, the policy allows for such made-in-America labels to be placed on items if the product is processed in the U.S. The petitioners requested in June that that section be changed, requiring “significant ingredients … are of domestic origin.”

The two commenting groups voiced support for changing the FSIS Policy Book’s position on U.S. origin label claims but took slightly different positions. On the one hand, USCA argues that the existing policy guiding voluntary U.S.-origin label claims concerning beef is likely to confuse consumers and needs to be amended.

“To eliminate the likelihood of confusion and to better inform consumers, USCA contends that voluntary labels indicating ‘Made in USA,’ ‘Product of USA,’ or similar content should be limited to beef from cattle born, raised, and harvested in the United States.”

R-CALF’s comments took a slightly different tack, suggesting that the proposed change does not go far enough.

“If the Policy Book is to continue providing universal guidance regarding when a ‘Product of U.S.A” label may be affixed to any meat or poultry product, the FSIS should adopt the most stringent standard currently in force within the universe of meat and poultry labeling standards.” This stringent standard, according to R-CALF’s comments, is the existing U.S. mandatory Country-of-Origin Labeling law in place for some meats, but no longer covering beef and pork.

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