AMI Advises Producer Groups to Prep for COOL Implementation

WASHINGTON -- The American Meat Institute (AMI) here sent a letter to 97 producer organizations advising them that their members may soon hear from meat packers about what they will require of their suppliers as part mandatory country of origin labeling, which becomes effective in September 2008.

AMI sent the letter after receiving a similar one from The Food Marketing Institute, which represents retailers and is helping its members prepare for country of origin labeling implementation.

"Although we adamantly oppose mandatory country of origin labeling [COOL], it is the law and it is our job as the meat industry's trade association to help companies prepare for full implementation," said AMI s.v.p./regulatory affairs and general counsel Mark Dopp.

In the letter, AMI noted that the final COOL rule has not yet published, but said it is essential to prepare.

"Given the fact that animals born now will be subject to mandatory country of origin labeling, we thought it was wise to begin preparing," Dopp said. "If the final rule deviates from what was in the proposal, we will advise our members."

In its letter to producer groups, AMI said it told its members that in order to comply with the law and satisfy retail customers, packers should demand a number of things from livestock producer, including verified documentation of where the livestock purchased were born and raised and an affidavit or declaration with each load of livestock purchases stating that there is a verifiable audit trail in place that identifies where the livestock in each load were born and raised.

AMI also advised its members to ask producers to provide access to records so that the packer can perform audits as necessary to satisfy retail customer and to indemnify the packer for liability should inaccurate information be provided to the packer.

The letters generated some unexpected controversy from supporters of mandatory country of origin labeling, including a call to rescind it.

"We stand by our letter and we will not rescind it because there is no reason to do so," Dopp said. "Complex new obligations will be imposed upon us and if we are to comply, we need information from producers. Those who supported the law can't avoid their obligations to provide us with information we need to comply."
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