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The Agency estimates a potential range of commingling of<br />
U.S. and foreign-origin livestock by U.S. packers of five<br />
percent to 20 percent. The Agency considers that the data<br />
analyzed support the possibility that the extent to which<br />
packers are commingling is closer to the lower end than the<br />
higher end of the range. Midrange estimates of commingling are<br />
12.5 percent for fed cattle and hogs.<br />
Estimated costs for the loss of commingling flexibility at<br />
the packer/processor level are $7.16 per head for cattle and<br />
$1.79 per head for hogs that are currently commingled.<br />
Estimated costs at the retail level are $0.050 per pound for<br />
beef and $0.045 per pound for pork muscle cuts derived from<br />
commingled livestock. For the beef segment, total costs for the<br />
loss of commingling flexibility to intermediaries and retailers<br />
are estimated to be $21.1 million, $52.8 million, and $84.5<br />
million at the lower, midpoint, and upper levels. Similarly for<br />
the pork segment, total costs for the loss of commingling<br />
flexibility to intermediaries and retailers are estimated to be<br />
$15.0 million, $37.7 million, and $60.3 million at the lower,<br />
midpoint, and upper levels.<br />
Combining costs for label changes with costs from the<br />
elimination of commingling flexibility yields estimated total<br />
adjustment costs of $123.3 million at the midpoint and ranging<br />
from $53.1 million at the low end to $192.1 million at the high<br />
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