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NCBA COVID-19/Coronavirus Response Update

REMINDER: All of our response materials can be found at:

  1. In our final installment on COOL, we look back at how mandatory COOL had several exemptions. Most proponents of COOL maintain that the consumer has the right to know where their beef comes from, and that is why we need the return of mandatory COOL. The mandatory COOL program that was law for 6 ½ years had two significant exemptions. Food service was exempt from mandatory COOL. There was no requirement for restaurants, hotels, institutions, or other food service outlets to label. With approximately 40% of our production going into food service, how can you make the claim that mandatory COOL was a consumer right to know program? You can’t. Mandatory COOL only applied to beef being labeled in grocery stores.

Processed beef was also exempt from COOL. The processing definition was very broad, so many products in the grocery store did not have to be labeled because they were processed in some way. Here is an example. Let’s take the tenderloins off of one carcass. Take one tenderloin, seal it up, and ship it to a grocery store. That tenderloin had to be labeled under mandatory COOL. Take the other tenderloin, roll it in crushed peppercorns or spices, seal it up, and ship it to the grocery store. Since it was rolled in spice, it was deemed as being processed and therefore exempt from mandatory COOL. Same animal, possibly the same store, but one is labeled and the other isn’t because of the exemption. Again, proving that mandatory COOL was not a consumer right to know program.

  1. In 2012, economists Glynn Tonsor (K-State), Ted Schroeder (K-State), and Jayson Lusk (then at Oklahoma State, now at Purdue) studied the implementation of COOL to determine the impact on consumers. Some of their findings included:

  2. Demand for beef was not impacted by mandatory COOL. Proponents of COOL often claim that we would sell more beef if we had a mandatory program. The research did not support that claim.

  3. Typical U.S. residents were unaware of mandatory COOL and did not look for origin information when purchasing beef. As part of their research, consumer interviews were conducted in the grocery stores to actually observe the consumer while they were shopping. The majority of consumers interviewed didn’t know whether mandatory COOL labels were in place or not, even though they were standing right next to the meat counters. At the time, mandatory COOL had been in place for over three years. Proponents of COOL often say the consumer is demanding to know where their beef comes from. The research did not support that claim, either.

  4. Mandatory COOL is not a food safety program. It is merely a marketing program. We have a robust food safety system in this country that looks at all beef sold regardless of origin. Countries that wish to export to the United States are subjected to on-site audits by UDSA’s Food Safety and Inspection Service (FSIS) and Animal and Plant Health Inspection Service (APHIS). These audits can take years, and in some cases have to be done multiple times before a country is approved. Once approved, follow up audits are conducted to ensure they remain compliant. Imports are inspected at the ports by the agriculture officers of Customs and Border Protection (CBP), a division of the Department of Homeland Security. If an approved country violates our food safety standards, they can be de-listed and have to go through the approval process again. That happened to Brazil in 2017. Mandatory COOL does not enhance food safety. The concept of mandatory COOL protecting against “dirty” imported beef is an oft-used, yet irresponsible, talking point by COOL proponents.

  5. And speaking of origin, just where is Namibia? Namibia is a country in Southern Africa that gained its independence from South Africa in 1990. Agriculture and mining form the basis of its economy. As mentioned in Thursday night’s update, Namibia spent 18 years trying to get USDA approval to ship product to the United States. A shipment of 27 metric tons arrived in April. That equates to approximately 59,525 pounds of beef (roughly a truckload and a half of boxed beef). Here is a photo of the one container as it was leaving Namibia last month:

As discussed above, it is important to remember that any country that wishes to export to the United States must meet our food safety standards. USDA audits those standards in their country, and the product is subject to inspection when it arrives here.

Our sleuthing determined that this product was purchased by a chain of organic grocery stores. Much of this shipment was lean trim.

Keep in mind that these countries don’t just ship this product over and then wait for a buyer. Somebody has to source it and buy it before it gets put in a container. Willing buyer, willing seller. In this case the buyer was not a packer.

Colin Woodall Chief Executive Officer

9110 E. Nichols Ave, Suite 300

Centennial, CO 80112 PH: 303.694.0305 |

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