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Retailers’ and Wholesalers’ Costs
Summary of Comments: Some commenters discussed the
additional cost related to retraining associates at their
stores, replacing scales, and upgrading distribution systems to
allow for the tracking of COOL related information for invoices
and manifests.
Several commenters stated that the proposed rule will
require retailers to double the number of words on the retail
label. For example, a product currently labeled “Product of the
US” would have to be labeled “Born, Raised and Slaughtered in
the US.” Those commenters also contended that the more likely
result will be that retailers will make an economic decision to
purchase only meat from animals born, raised and slaughtered in
the U.S. to reduce their risk of inadvertently not complying
with this rule. An additional commenter made the point that one
of the reasons the current scale systems have less space
remaining is due to the implementation of mandatory meat
nutrition labeling.
One commenter stated their opinion that certain retailers
repack muscle cuts and that the revised labeling requirements
would impose an additional layer of complexity and cost from
redoing labels, maintaining more complex records and
recordkeeping systems, buying new equipment and software, and
employee training.
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