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Another commenter stated that because imported products
will now have to be separated under the proposal, the cost of
U.S. products sold to supermarkets will go up, and imported
product will be sold through foodservice channels like
restaurants where it will not have to be labeled and likely will
be sold at a cheaper price.
Agency Response: The Agency recognizes that additional
costs will be borne by industry participants. Estimates of
those costs include adjustment costs to processors and retailers
due to losing the flexibility to commingle muscle cut covered
commodities for purposes of COOL. In addition, the estimated
costs include adjustments due to the need to change the labels
currently in place. As discussed in further detail in a prior
response, the Agency has, to its best ability, sought to
minimize the cost to industry at each step of the marketing
process, including allowing abbreviations to be used on the new
labels.
The Agency further notes that the existing COOL regulations
already require retailers to maintain records and other
documentary evidence upon which they have relied to establish a
covered commodity’s country or countries of origin. Similarly,
any person directly or indirectly engaged in the business of
supplying a covered commodity to a retailer, including
wholesalers, must make available information to the buyer about
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