USDA's guidance for implementation of mandatory country-of-origin labeling for meat products is the most costly, cumbersome and complex labeling proposal in history. Consumers are unlikely to ever see the labels that USDA described in voluntary guidance issued today because this program cannot be implemented.
The fact is,
USDA's complicated guidelines will result in
hundreds and possibly thousands of product
labels that must describe where animals were
raised, where they were fed and where they were
slaughtered. The U.S. is not an island.
Rather, we trade meat and livestock with other
nations. We raise animals here, feed them in
other nations and bring them back for
slaughter. In other cases, we import livestock
from other nations and feed and slaughter them
We also source our raw
materials for ground products like ground beef
from a host of nations, including Canada, New
Zealand and Australia. Today's guidelines not
only require that ground products bear a label
indicating the country of origin of every
animal that makes up the product, but that they
declare those countries based on the weight of
the raw ingredients in descending order.
Because U.S. ground beef producers may source
beef trimmings and raw materials from different
nations in different quantities hour by hour
and day by day, depending on cost and supply,
this labeling system becomes utterly
unmanageable and disrupts the free market.
Some may ask, "Precisely how many
possible labels will be required?" The
industry is still doing the algebra to answer
that question - and we don't anticipate an
answer any time soon.
What this guidance
will do is force companies to source their meat
not based on quality or price, but based on
what will simplify their labeling requirements.
This is bad for livestock producers, bad for
business and bad for consumers, who will be
asked to pay a premium as a result of this
The ironic fact is
that no evidence exists that consumers want
this labeling. In fact, in a consumer survey
conducted for the International Food
Information Council in August 2002, three
quarters of consumers said there was no
additional information needed on food labels.
If consumers had a strong desire to know the
country-of-origin of their food products, beef
companies surely would have used the voluntary
country-origin labeling program that has been
available through the Agricultural Marketing
If this guidance becomes a
final rule, it will succeed only in restricting
meat trade between the U.S. and other nations.
And that will trigger the fastest and most
blistering complaints against the U.S. to the
World Trade Organization (WTO) that we have
There is no comment or
suggestion that we can provide to USDA to
improve this guidance other than to start over.
And even then, the industry continues to
question the value of any mandatory
country-of-origin labeling program in the
absence of any proven benefits to consumers or
AMI represents the interests
of packers and processors of beef, pork, lamb,
veal and turkey products and their suppliers
throughout North America. Together, AMI's
members produce 95 percent of the beef, pork,
lamb and veal products and 70 percent of the
turkey products in the U.S. Headquartered in
Washington, DC, the Institute provides
legislative, regulatory, public relations,
technical, scientific and educational services
to the industry. Its affiliate, the AMI
Foundation, is a separate 501(c)3 organization
that conducts research, education and
information projects for the industry.
Statement of the American Meat Institute on Country-of-Origin Labeling GuidanceTuesday, October 8, 2002
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