Country of Origin Labeling (COOL)

Country of Origin Labeling (7 U.S.C. §§ 1638–1638d) requires retailers to inform consumers where certain food products come from — labeling the country of origin at the point of sale for covered commodities including fresh and frozen fruits and vegetables, fish and shellfish (both wild-caught and farm-raised), peanuts, pecans, macadamia nuts, ginseng, and certain other items. Originally enacted in the 2002 Farm Bill and implemented in stages through 2009, COOL was designed to give you the information to make purchasing decisions based on where your food was produced. The program has had a turbulent history: mandatory COOL for beef and pork was repealed in 2015 after the World Trade Organization ruled it violated U.S. trade obligations, but COOL requirements remain in effect for other covered commodities.

Current Law (2026)

Legal Authority

• 7 U.S.C. § 1638 — Definitions (defines "covered commodity" to include muscle cuts and ground meat from lamb, venison, chicken, and goat; farm-raised and wild fish; fresh and frozen fruits and vegetables; peanuts, pecans, macadamia nuts; and ginseng; beef and pork were removed in 2015)
• 7 U.S.C. § 1638a — Notice of country of origin (retailers must inform consumers at the final point of sale of the country of origin for every covered commodity; labels must distinguish between products of U.S. origin, foreign origin, and mixed origin; wild-caught fish must identify the country and whether wild-caught; farm-raised fish must identify the country and that it is farm-raised)
• 7 U.S.C. § 1638b — Enforcement (USDA notifies retailers and suppliers of violations and provides a 30-day correction period; willful violations after notice may result in civil penalties up to $1,000 per violation)
• 7 U.S.C. § 1638c — Regulations (Secretary must issue guidelines for voluntary COOL by September 30, 2002, and mandatory regulations thereafter)

How It Works

Retailers selling covered commodities must display the country of origin at the point of sale — on the product packaging, a nearby placard, or a sticker. For fruits and vegetables, this means identifying where the produce was grown ("Product of USA," "Product of Mexico"). For fish and shellfish, the label must include both the country of origin and whether the product is wild-caught or farm-raised — a distinction many consumers consider important for sustainability and quality. Multi-ingredient processed products (like canned fruit cocktail or frozen stir-fry mixes) are generally exempt.

The beef and pork repeal is COOL's most controversial chapter. The original law required country of origin labeling for beef and pork, including designations for products "Born in, Raised in, and Slaughtered in" the United States versus imported or mixed-origin products. Canada and Mexico challenged this requirement at the WTO, arguing it discriminated against their livestock exports. The WTO Appellate Body ruled against the United States in 2012 and 2015, finding that the recordkeeping and segregation burdens imposed on imported livestock outweighed any consumer information benefits. Facing over $1 billion per year in authorized retaliatory tariffs from Canada and Mexico, Congress repealed mandatory COOL for beef and pork in December 2015. The repeal was deeply unpopular with U.S. cattle ranchers, who saw COOL as a competitive advantage for domestically produced beef.

Only retailers — grocery stores, supermarkets, and similar establishments — are required to display COOL labels. Suppliers (packers, wholesalers, importers) must provide country of origin information through the supply chain to enable retailer compliance. Restaurants, cafeterias, and food service establishments are exempt from COOL requirements.

Enforcement is intentionally graduated. When USDA's AMS identifies a COOL violation during an audit, the retailer receives written notice and a 30-day period to correct the problem. Civil penalties (up to $1,000 per violation) apply only for willful violations — deliberate non-compliance after notice. This structure means that inadvertent labeling errors typically result in correction rather than penalties.

Although mandatory labeling was repealed, voluntary "Product of USA" labeling for beef remains available. In 2024, USDA finalized a rule tightening the standard: a product must now be born, raised, slaughtered, and processed in the United States to carry the label — preventing its use on imported cattle only slaughtered domestically. This voluntary standard preserves consumer information without creating the WTO compliance issues that doomed mandatory COOL.

How It Affects You

If you're a grocery shopper trying to use COOL labels: COOL labels appear at the retail display of covered commodities — fresh produce, fish, shellfish, peanuts, pecans, and macadamia nuts. For fresh fruits and vegetables, look for a sign or placard near the bin or shelf ("Product of USA," "Product of Mexico," "Produce of Chile"). For fish and shellfish, the label is typically on the packaging and must state both the country of origin AND the production method ("Wild-Caught" or "Farm-Raised"). These two pieces of information together help you make meaningful choices: a "Wild-Caught Pacific Salmon — Product of USA" is a very different product from a "Farm-Raised Atlantic Salmon — Product of Chile."

Important limitations to understand: (1) Restaurants are exempt — COOL only applies at retail. The restaurant menu doesn't tell you where your shrimp came from. (2) Processed products are exempt — a frozen salmon fillet with nothing added must be labeled; a frozen salmon patty with breadcrumbs is a processed product and exempt. (3) Beef and pork are not covered by mandatory COOL — that requirement was repealed in 2015. The voluntary "Product of USA" label that appears on beef and pork in some stores is a different, voluntary program with tightened 2024 standards (requiring born, raised, slaughtered, and processed in the U.S.) — but it's not mandatory.

If you believe a retailer is mislabeling a covered commodity (e.g., labeling imported produce as domestic), report it to USDA's Agricultural Marketing Service (AMS) at ams.usda.gov. AMS conducts retailer audits and follows up on complaints; the enforcement process begins with a 30-day notice to correct before penalties apply.

If you're a cattle rancher or other beef producer: The 2015 COOL repeal removed the most valuable labeling protection your product had — consumers can no longer see at the grocery store whether they're buying domestic or imported beef. The replacement tool is the voluntary "Product of USA" label, which USDA tightened in 2024 to require that the animal was born, raised, slaughtered, and processed entirely in the United States — not just slaughtered domestically after importation. This is a meaningful standard and your beef legitimately qualifies if it meets these criteria.

To use the "Product of USA" label: USDA's AMS administers the voluntary program. Label claims are subject to documentation requirements — you must be able to substantiate that the entire production chain occurred in the U.S. through supply chain records (purchase records, brand documentation, production records). False "Product of USA" claims can be prosecuted under USDA regulations and the FTC's deceptive advertising rules. The primary commercial benefit: grocery chains with "locally sourced" or "American beef" branding programs can use this label to substantiate their marketing claims — and premium-priced domestic beef can command 15-25% price premiums over imported product in many markets.

For future mandatory COOL reinstatement: Bills to restore mandatory COOL for beef and pork have been introduced repeatedly since 2015. The WTO compliance obstacle remains — Canada and Mexico were authorized $1 billion+ in annual retaliatory tariffs under the old mandatory COOL, and restoring similar mandatory requirements could revive that dispute. USMCA (the NAFTA replacement) didn't resolve the underlying COOL framework. Monitor the American Farm Bureau Federation (fb.org) and National Farmers Union (nfu.org) for legislative developments on this issue.

If you're a seafood buyer concerned about sustainability, origin, and quality: COOL's fish labeling requirements — country of origin plus wild-caught/farm-raised designation — are the baseline legal minimum. For more detailed sustainability information: (1) Marine Stewardship Council (MSC) certified products (labeled with the MSC blue fish logo) come from fisheries certified to sustainable catch practices. (2) Aquaculture Stewardship Council (ASC) certified aquaculture products meet standards for responsible farm-raised seafood production. (3) The Monterey Bay Aquarium Seafood Watch program (seafoodwatch.org) provides consumer guides rating seafood by sustainability and origin — searchable by species and country of origin. (4) NOAA FishWatch (fishwatch.gov) provides profiles of U.S. seafood species including sustainability status, typical origin, and consumer tips.

Common label interpretation issues: "Atlantic Salmon" is almost always farm-raised (true wild Atlantic salmon is commercially extinct at scale). "Pacific Salmon" (Chinook, Sockeye, Coho) is typically wild-caught from Alaska, which has some of the most sustainable fisheries in the world. Shrimp labeled as "wild-caught" from the Gulf of Mexico is domestic; "farm-raised" shrimp from Vietnam, Thailand, and India dominates the imported supply. Price generally reflects these distinctions — domestic wild-caught shrimp is consistently more expensive than imported farmed product.

State Variations

COOL is exclusively federal, but state labeling laws may add requirements:

• Some states have enacted their own country of origin or "Product of USA" labeling requirements for specific products
• State consumer protection laws may address misleading origin claims beyond COOL's scope
• State departments of agriculture may conduct COOL compliance inspections under cooperative agreements with AMS
• California's Proposition 65 and other state labeling laws create additional disclosure obligations that coexist with COOL

Implementing Regulations

• 7 CFR Part 65 — Country of Origin Labeling of Lamb, Chicken, and Goat Meat, Perishable Agricultural Commodities, Macadamia Nuts, Pecans, Peanuts, and Ginseng. The Part covers the full COOL regulatory framework for non-beef/pork commodities (beef and pork labeling was repealed in 2015). Key provisions:

  • § 65.135 — Covered commodities: muscle cuts and ground forms of lamb, chicken, and goat; all perishable agricultural commodities (fresh and frozen fruits and vegetables); peanuts; macadamia nuts; pecans; and ginseng; not covered: processed food items (see §65.220), or food service establishment sales
  • § 65.220 — Processed food item exception: a covered commodity that has been physically or chemically altered (cooked, marinated, smoked, cured) or combined with at least one other covered commodity or real food ingredient (chocolate, breading, tomato sauce) is a "processed food item" and is exempt from COOL — this is the primary reason most frozen entrees and prepared foods carry no origin label
  • § 65.260 — United States country of origin standard: a meat product may bear a "Product of USA" label only if the animal was: (1) born, raised, and slaughtered in the United States; or (2) born and raised in the United States and then imported into the United States for immediate slaughter; or (3) if imported for immediate slaughter — that is, transferred directly from the port of entry to an approved slaughterhouse and slaughtered within 2 weeks of arrival — then labeled as a product of both the country of origin and the U.S.
  • § 65.300 — Country of origin notification requirements: retailers must display country of origin at the point of sale for every covered commodity in any form (loose, in bins, in packages); labels may appear on a sign, placard, sticker, band, twist tie, or packaging; food service establishments (restaurants, cafeterias, salad bars) are exempt; ingredients inside processed food items are exempt; items that are pre-labeled by the manufacturer (the label already shows origin and manufacturer name) satisfy the retailer's notification duty automatically
  • § 65.400 — Labeling methods: origin can be shown on a "sign, sticker, band, twist tie, tag, or placard" — any format readable without difficulty; acceptable phrases include "Product of USA," the bare country name, or standard abbreviations; the label must appear in English but may also appear in other languages
  • § 65.500 — Recordkeeping: suppliers and retailers must maintain legible records (paper or electronic) proving each covered commodity's origin; when USDA requests documentation, suppliers and retailers must produce records within 5 business days; records must be kept long enough to support any labeling claim — typically through the sales cycle of the product; failure to produce records on request is itself a violation

  The Part 65 rules bind retailers but work through supply chain documentation: the retailer's COOL label is only as accurate as the origin records it receives from the wholesaler, importer, or packer. This is why enforcement focuses heavily on the records trail rather than just the label itself — an incorrect label with a clean paper trail from the supplier shifts liability upstream, while a retailer that cannot produce documentation bears the compliance burden directly.

• 7 CFR Part 60 — Country of Origin Labeling for Fish and Shellfish (the AMS rules implementing COOL specifically for seafood; implements 7 U.S.C. § 1621). Fish and shellfish have their own dedicated Part (60) separate from the Part 65 rules governing produce and other covered commodities, reflecting the distinct wild-caught/farm-raised distinction that seafood labeling requires. Key provisions:

  • § 60.105 — Covered commodity: farm-raised and wild fish and shellfish in any form — fillets, steaks, nuggets, or any other flesh; not covered when used as an ingredient in a processed food item (so a fish taco kit with pre-seasoned tilapia is exempt but a fresh tilapia fillet in a grocery display case is not)
  • § 60.106 — Farm-raised fish defined: fish or shellfish harvested in controlled settings — ocean-ranched fish held in pens, shellfish grown on leased beds that receive predator protection, additional structures, or supplemental nutrients; covers any flesh products from those animals
  • § 60.107 / § 60.119 — Exemptions: food service establishments (restaurants, cafeterias, lunch counters, salad bars, delis) are entirely exempt; processed food items — fish or shellfish that have been changed in form (cooked, smoked, cured, marinated, combined with other food ingredients) are exempt from COOL notification
  • § 60.128 — "United States country of origin" standard: farm-raised fish qualifies as U.S. origin only if hatched, raised, harvested, and processed in the United States; wild fish qualifies as U.S. origin if harvested from U.S. waters (within the outer boundary of the U.S. Exclusive Economic Zone) or from any ocean aboard a U.S.-flagged vessel
  • § 60.130 — U.S. flagged vessel: a vessel documented under chapter 121 of title 46 U.S.C.; vessels registered in other countries that fish in international waters must label their catch with the country of registry, not "USA"
  • § 60.200 — Country of origin notification: retailers must disclose at the point of sale both (1) the country of origin and (2) whether the product is wild-caught or farm-raised; for commingled products from multiple countries, each country must be listed
  • § 60.300 — Labeling formats: origin information may appear on a placard, sign, sticker, band, twist tie, or packaging; must be legible; pre-labeled packages (already showing origin from the manufacturer or packer) satisfy the retailer's obligation automatically
  • § 60.400 — Recordkeeping: retailers and suppliers must maintain paper or electronic records showing the origin of each covered commodity; on USDA request, records must be produced within 5 business days; failure to produce documentation is itself a violation, independent of whether the label is accurate

  The fish/shellfish COOL rules mirror the Part 65 structure but add the wild/farm-raised production-method disclosure — a layer of consumer information that has no counterpart for produce or nuts. USDA AMS enforces Part 60 compliance through retail audits; violations carry civil penalties. Recent rulemakings: 78 FR 31385 (May 2013) updated the fish/shellfish COOL definitions to align with the 2008 Farm Bill amendments.

• 9 CFR Part 317 — FSIS labeling requirements for meat products (country of origin declarations on processed meat)

Pending Legislation

• HR 5818 — Country of Origin Labeling Enforcement Act of 2025: strengthen COOL enforcement and compliance. Status: Introduced.
• HR 4688 — COOL OFF Act: address country of origin labeling implementation. Status: Introduced.
• S 2868 — India Shrimp Tariff Act: address origin and import duties for shrimp from India. Status: Introduced.

Recent Developments

The 2024 "Product of USA" voluntary labeling rule was the most significant COOL-related action since the 2015 repeal, tightening the standard to require full domestic production chain. Congressional proposals to reinstate mandatory COOL for beef and pork have been introduced in every Congress since the repeal but have not advanced, due to concerns about WTO compliance and trade retaliation. The USMCA (the NAFTA replacement) did not address COOL, leaving the WTO rulings as the governing international trade law. Consumer demand for origin transparency continues to grow, driven by food safety concerns, sustainability preferences, and support for domestic agriculture.