COO comments

The three organizations said that if the guidelines were issued as binding regulations they would be “administratively unsound and in some respects legally impermissible.” They recommended that mixed processed food products, all frozen produce, and frozen seafood be excluded from the regulations.

Requirements to list the country where processing occurred and that multiple countries of origin be listed in order of predominance of weight should be dropped, they said. The organizations believe the guidelines “overregulate” by prescribing COO labeling on products already required to bear such labeling.

GMA said that by eliminating the flaws and maintaining a voluntary labeling system USDA could “prevent consumer confusion at the supermarket and significantly reduce the potential regulatory burden placed on the U.S. food processors.”

NFPA also requested that labeling or record-keeping requirements not be imposed on products packaged before the date when mandatory rules become effective.

In separate comments, the American Meat Institute told USDA the guidelines should be modified so that meat products that must bear ingredient statements do not also need COO labels. Under the 2002 Farm Bill, which established the COO requirements, fresh beef, pork, and lamb must bear COO labels, but processed meat products are exempt. The definition of processed meat products was unclear, and AMI is attempting to write a definition. AMI estimated that the total cost of COO labeling would be approximately $353 million annually.