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R-CALF USA Response:
Voluntary Country of Origin Guidelines Offer a Starting Point

Billings, MT — Danni Beer, R-CALF United Stockgrowers of America (R-CALF USA) COOL Committee Chair said USDA's release of voluntary country of origin labeling guidelines provides the cattle industry with a starting point to begin work on mandatory country of origin rules that will go into effect on September 30, 2004. "We appreciate the agency's efforts in providing these voluntary guidelines," she said.

R-CALF USA suggested last August that USDA must implement a partial mandatory system requiring the origin of all beef at the packer stage of production to be identified before retailers can effectively begin even voluntary labeling. "Today's guidelines provide retailers with no more assistance to identify the origin of beef than is currently available under the voluntary labeling programs that have been in effect for the past 30 years," said Beer. "The prospects of widespread adoption of the voluntary rules is limited, except for the competition that may occur among retailers to be the first ones in the marketplace to offer a label before the 2004 deadline," she added.

Beer said the guidelines reveal specific areas that need additional work before mandatory labeling can be accomplished. She said the definition of retailer does not even include a dealer in beef. "If a business deals solely in beef and sells $1 million dollars in beef annually, the current definition of a retailer quite possibly would not require this business to label beef," said Beer. She also said that the guidelines impose a greater burden on domestic producers than it does on importers. U.S. producers must maintain records from birth to retail while imported products are not subject to the same verification requirements. "It is nonsensical for USDA to saddle U.S. producers with a more burdensome and complicated verification system than is required of beef importers," she said. Beer is also concerned about the potential loophole established for the labeling of ground beef. "Under the guidelines, processors can circumvent the labeling requirements for ground beef by simply adding water, and perhaps ice, to the final product," she said.

In addition, Beer cited industry estimates suggesting that sales of pre-cooked beef may soon account for 30 percent of all beef sales. "Our markets are changing and labeling rules should be written in anticipation of these changes. If simply pre-cooking an item excludes it from the labeling requirements, as current rules suggest, then we have opened a huge loophole for processors to undermine the intent of Congress," Beer warned. The definition of processed is too vague and outdated in today's changing beef products.

Beer said R-CALF USA would continue working with USDA and the congressional sponsors of the mandatory country of origin labeling law to ensure the intent of Congress is maintained within the agency's rules. "We will work to strengthen the positive aspects USDA has included in the guidelines and to correct the deficiencies," she said.

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