ASI Submits COOL Comments

August 24, 2007 - The American Sheep Industry Association (ASI) provided comments to the U.S. Department of Agriculture's (USDA) Agricultural Marketing Service (AMS) on the reopened proposed rule to implement country of origin labeling (COOL).

"ASI believes that mandatory COOL is needed so that American consumers can make informed choices. We believe that highlighting our respective identities is appropriate and provides useful information to consumers," ASI stated in its comments.

USDA requested that comments be centered around whether the provisions, definitions and requirements of the interim final rule for fish and shellfish could also be applied to beef, lamb, pork, perishable agricultural commodities and peanuts. The fish and shellfish interim final rule was published on Oct. 5, 2004.

Lamb, whether cooked, seasoned or marinated, is still lamb and should be considered a covered commodity and not exempt under the processed food item definition. To apply the definitions and examples used in the interim final rule for fish and shellfish to lamb would potentially result in many more products being exempt from labeling than congress intended.

ASI believes that the changes made in the fish and shellfish rule reducing the records retention period on specific transactions from two years to one year and changing the retail records requirement to match the time period that the product is for sale should be workable for lamb. Also, normal business records should be sufficient for the lamb industry to achieve COOL compliance.

ASI urges AMS to move forward expeditiously and finalize this proposed rule so that the industry will know what is to be expected of the various participants along the marketing continuum and to bring the added value that proper labeling for lamb creates in the marketplace.
Staff contact: Peter Orwick, ext. 33

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