Farmscape Article 2444  March 31, 2007

Pork producers on both sides of the Canada U.S. border are voicing concerns in the wake of the resurgence of efforts to implement mandatory Country of Origin Labeling in the United States.

A product t of the 2002 U.S. Farm Bill, Mandatory COOL has been twice delayed, first to 2006 and then to 2008 by U.S. Congressional legislation which denied the U.S. Agriculture Department the necessary funding for its implementation. Many observers no longer expect the mandatory labeling provisions scheduled to go into effect at the end of September 2008 to be delayed.

Mandatory Cool Offers More Cost than Benefit

“We’ve always said that we felt country of origin labeling, as it is, is more cost than benefit back to the producer,” says Joy Philippi, the immediate past president of the U.S. based National Pork Producers Council. She estimates the rules, as written for the program, could result in, “… Around a ten dollar per head cost” and adds that right now is a very bad time to add anything to the cost of production.

COOL a Cause for Concern on Both Sides of the Border

Martin Rice, the Executive Director of the Canadian Pork Council agrees. “This is a problem for the whole North American hog and beef industries,” he says.

“This is going to add significant costs to the value chain for delivering hogs and pigs because it will require a great deal of record keeping and systems for auditing and so on. Those are costs that are not on the backs of the chicken sector or the turkey sector. It's going to create cost disadvantages for pork and beef vis-à-vis chicken.”

Philippi points out, “As it was originally written, we would have to identify every pig for the born, raised and slaughtered provision. That would mean a pig that was born in Canada would then be a Canadian pig that was born and then raised and slaughtered in the United States. All of those things would have to be noted on the label.”

“We believe in voluntary country of origin labeling,” she adds. “We have producers that use that kind of program today, not many, but there are some and they do receive better proceeds back. However, if all product is labeled according to country of origin labeling then some of those that have the specialty markets will not get the benefits back that they had been receiving.”

Mandatory COOL Could Cause Negative Reaction at Retail

Rice also fears it may cause some people in the value chain, the retailers for example, to be less interested in dealing with those products because it does involve costs that they don’t have for chicken. It could even deny consumers some of the current choices they have.

“We would fear that all these costs are going to be imposed on the supply chain and not passed along to consumers because consumers frankly didn't ask for this and are not likely to want to pay anything more for the products to accommodate it,” he says.

Philippi adds, “If it’s going to cost the retailers more to do all this labeling and segregation we understand that those costs would be passed back to the producers of the product itself.”

The Canadian Pork Council has been following the experience with Country of Origin labeling for fish and shell fish, which has been in effect now for two or three years.

“What we have heard and learned,” observes Rice, “is that it has not been something that consumers have expressed satisfaction over and has not increased the price of fish and shellfish or increased the consumption of it. It has simply been an additional burden that the sector has had to carry.”

COOL Could Piggyback Animal Identification

Philippi observes, “The desire that we hear from congress is that they would like to look at putting M-COOL and ID (livestock identification) together.”

“We’re willing to work with them on that, but the one thing we stress to them is though that what ever we put together has to be a low cost solution for this. We believe there would have to be quite a bit of change in the rule itself.”

She adds, “We think that would be one way we could get an ID program running but it would have to be done right so it wasn't very costly back to producers. We looked very closely at the response from the shell fish industry and we just can't see that the program, as it is, would work for us.”

September 2008 Implementation Most Likely

M-COOL is currently expected to be put into effect by the end of September of 2008 but there efforts to move up that time table.

Rice observes, “There seem to be so many challenges to implement COOL, to set up the record keeping systems, to set up the auditing systems, that many believe it's simply impossible to implement it any sooner than late 08.”

However he admits, “Right now the fear is that it will be coming sooner than later.”

Philippi insists, “If the ID program is worked in it would absolutely have to be rewritten as well. We question the necessity of having a born provision in there. That adds a lot of cost to the record keeping and segregation of everything in the plants and that would be passed back to us. We just can’t see that there’s any benefit in having to keep track of where a pig is born, when it’s more important where it’s raised and slaughtered.”

CPC to Support U.S. Producer Based Efforts to Address the Problems

Rice notes, “We are looking for opportunities to strengthen messages that are already being delivered by U.S. interests. We would look at the U.S. interests and the U.S. opposition to mandatory COOL as being what the U.S. congress will listen to. Frankly they're not going to be persuaded by people who don't vote.”

However he points out, “We have, in the past, had a recognition of the points we submitted to the U.S. Department of Agriculture whenever it asked for comments on COOL. Indeed we did put in comments on the fish and shellfish rule where we raised a number of issues with mandatory country of origin labeling.”

“And we have asked that the U.S. open the comment period for the final COOL rule because we think there still is opportunities to change the elements of the rule to make it less onerous for the industry. But we’ve also said that it is a question whether it adds any value for consumers or whether it just represents an additional cost for the industry.”

Staff Farmscape.Ca