ASI Comments on COOL Interim Rule

September 26, 2008 - The American Sheep Industry Association (ASI) submitted comments this week on the interim final rule for mandatory country-of-origin labeling (COOL) on behalf of the industry. ASI has long been on the record supporting COOL for sheep products and believes that the benefits provided to the industry and to consumers will be substantial.

In its comments, the sheep industry strongly supports the use of a producer affidavit to ensure that meat covered by COOL is accurately labeled at retail. Several livestock industry groups reached agreement on wording of such an affidavit and ASI urges the U.S. Department of Agriculture (USDA) to accept it as a valid country-of-origin claim.

There are no common terminology differences describing the meat from different age groups of species such as cattle and swine. Yet, there is a difference between lamb and mutton. The sheep industry, therefore, encourages the amendment of covered commodities to include mutton.

Like many other commodities, ASI, in 2000, developed and registered a trademark for Fresh American Lamb to be used by marketers to differentiate their product from imported and/or frozen sheep meat. Since this mark is clearly consistent with the labeling requirement of born, raised and slaughtered in the United States, it is recommended that the use of the trademark on packaging be allowed as proper evidence that the product packaged under this mark is a product of the United States.

Through USDA, the sheep industry operates the National Scrapie Eradication Program which includes a regulated animal identification program. Feeder and slaughter sheep being imported into the United States must carry official permanent identification. Since the rule allows for slaughter facilities to utilize the "National Animal Identification System or other recognized official identification system" as proof of animal origin, it is the request of the sheep industry that processors recognize the scrapie identification as a means to prove the origin of sheep at slaughter.

"This interim final rule is an improvement over earlier proposed rules on country of origin," commented Burdell Johnson (N.D.), ASI president. "The industry encourages the move that only sheep exclusively born, raised and slaughtered in the United States should carry the 'Product of the U.S.' label on them. The sheep industry is excited to finally have a program that will offer consumers the ability to identify where the meat is from that they buy at retail."

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