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noting only that the Agency had “been unable to quantify
incremental economic benefits from the proposed labeling of
production steps….” These commenters shared a belief that the
Agency’s analysis is consistent with recent work on COOL, which
has generally failed to document any demand-side benefits from
the program.
Numerous commenters stated that there is little evidence
that consumers benefit from country of origin labeling and
referred to a recent study by Kansas State University and
Oklahoma State University 1 which found no demand increase
following the implementation of the mandatory COOL program in
spite of previous research suggesting consumers would pay more
for products carrying origin information. The study concluded
that consumers do not value meat products carrying Product of
United States labels over those with Product of North America
labels and that economic gains would occur by utilizing the
latter, less expensive, labeling requirement.
One commenter stated their belief that there is no evidence
that consumers base their buying decisions on the source
information currently available through the COOL program. The
commenter stated that the market has demonstrated and fulfilled
1
Tonsor, Lusk et al. Mandatory Country of Origin Labeling: Consumer Demand
Impact, November 2012
http://www.agmanager.info/livestock/policy/Tonsor_KSU_FactSheet_MCOOL_11-13-
12.pdf
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