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Those costs will be incurred by processors and retailers as they
adjust to the loss of commingling flexibility and to the new
labeling requirements in this final rule. It is necessary,
however, to ensure label information accurately reflects the
origin of muscle cut covered commodities in accordance with the
intent of the statute while complying with U.S. WTO obligations.
That said, the Agency does not agree that additional
recordkeeping or verification processes will be required to
transfer information from one level of the production and
marketing channel to the next. There are no recordkeeping
requirements beyond those currently in place, and the Agency
believes that the information necessary to transmit production
step information is already maintained by suppliers in order to
comply with the current COOL regulations. As with the current
mandatory COOL program, this final rule contains no requirements
for firms to report to USDA. Compliance audits will continue to
be conducted at firms' places of business.
In addition, the Agency has sought to minimize the cost to
industry at each step of the marketing process. For example, the
Agency has clarified that retailers may continue to utilize
existing label and package inventories, as long as retail
establishments convey the more specific information concerning
the location where the production steps occurred via other means
(e.g., signage). This will reduce the costs of switching over
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