What is country of origin labeling (COOL)?

COOL is a USDA law requiring retailers to tell consumers the country of origin of certain foods called covered commodities, and for fish and shellfish, whether they were wild-caught or farm-raised. It is administered by the Agricultural Marketing Service under 7 CFR Part 60 for fish and shellfish and 7 CFR Part 65 for other covered commodities. It is a labeling law, not a safety law.

Why is beef no longer labeled under COOL?

A 2016 appropriations law removed beef and pork, both muscle cuts and ground, from mandatory country-of-origin labeling, following a World Trade Organization dispute. As a result, fresh beef and pork at retail are no longer required to carry COOL origin declarations, though other covered commodities like lamb, chicken, goat, fish, produce, and certain nuts still are.

How long do you have to keep COOL records?

Records substantiating a country-of-origin claim generally must be kept for one year from the transaction and be available to USDA on request. Suppliers keep records identifying the covered commodity and its origin, and retailers keep the records supporting the declaration they post. The unifying requirement is being able to trace any label back to a documented origin.

Is COOL the same as Product of USA?

No. Mandatory COOL is a retail disclosure of origin for covered commodities, enforced by USDA's Agricultural Marketing Service. 'Product of USA' is a voluntary marketing claim on meat, poultry, and egg products, governed by USDA FSIS. They involve different agencies, different rules, and different products, an item can be subject to one, both, or neither.

Country of Origin Labeling (COOL)

Q: What is the Product of USA rule?

It is a separate, voluntary USDA FSIS labeling standard, finalized in 2024, for meat, poultry, and egg products. A 'Product of USA' or 'Made in the USA' claim can now be used only when the animal was born, raised, slaughtered, and processed in the United States. Label changes align to the uniform compliance date of January 1, 2026. It is distinct from mandatory COOL.

Which foods COOL covers, the origin categories, the new voluntary Product of USA rule, and the records retailers and suppliers must keep.

Country of Origin Labeling (COOL) is a USDA law that requires retailers to tell shoppers where certain foods come from. It applies to a defined list of "covered commodities" and is enforced by the Agricultural Marketing Service under two rules: 7 CFR Part 60 for fish and shellfish, and 7 CFR Part 65 for everything else. It is a labeling and recordkeeping law, not a food-safety law.

COOL trips people up for two reasons: the covered list has changed, beef and pork muscle cuts were pulled out in 2016, and it is easy to confuse mandatory COOL with the separate, voluntary "Product of USA" claim, which got a major rewrite that takes full effect in 2026. This guide sorts out what is covered, the origin categories, the new Product of USA rule, and the records retailers and suppliers have to keep.

What is country of origin labeling?

Country of origin labeling is a mandatory retail-disclosure program: for covered commodities, the retailer must declare the country or countries of origin (and for fish, whether it was wild-caught or farm-raised) at the point of sale. The obligation lands at retail, but it depends on a paper trail that runs all the way back up the supply chain, because a retailer can only label what its suppliers documented.

COOL is administered by USDA's Agricultural Marketing Service, and it is worth being clear about what it is not. It is not about safety, quality, or grade, it does not tell you a food is better or safer, only where it came from. And it is not the same as the "Product of USA" claim on a meat package, which is a separate, voluntary marketing claim governed by a different USDA agency and a different rule. Keeping those two straight is half of understanding COOL.

What products are covered by COOL?

COOL covers a specific list of commodities and pointedly excludes others. The single biggest thing to know is that a 2016 change removed beef and pork, both muscle cuts and ground, from mandatory COOL, so the meat most shoppers picture is no longer covered.

The covered list, and the notable exclusions. Beef and pork were removed from mandatory COOL in 2016; processed foods fall outside it entirely.

Covered commodities include muscle cuts and ground lamb, chicken, and goat; wild and farm-raised fish and shellfish; fresh and frozen fruits and vegetables; raw peanuts, pecans, and macadamia nuts; and ginseng. Two categories fall outside COOL: beef and pork (removed in 2016), and processed foods. A commodity that has been cooked, cured, restructured, or combined with other ingredients into a distinct product is generally no longer a covered commodity, a bag of frozen peas is covered, a frozen vegetable medley in sauce is not.

What are the COOL origin categories?

For covered meats, COOL sorts origin into categories based on where the animal was born, raised, and slaughtered. The label has to reflect the actual production steps, which is why the supply-chain records matter so much, a retailer cannot assign a category it cannot document.

Category A, United States origin. The animal was born, raised, and slaughtered in the U.S. Labeled as product of the U.S.
Category B, multiple countries of origin. The animal was born or raised in another country and slaughtered in the U.S.; the label names each country and its production step (for example, "Born and Raised in Country X, Slaughtered in the United States").
Category C, imported for immediate slaughter. The animal was imported into the U.S. for immediate slaughter, labeled to reflect that path.
Category D, foreign origin. The product was produced entirely in another country and imported; it retains the origin declared to U.S. Customs through retail sale (for example, "Product of Country X").

Fish and shellfish carry an additional required disclosure: whether the product was wild-caught or farm-raised. So a fish label under COOL answers two questions, which country, and wild or farmed. That production-method requirement is unique to seafood, and it is enforced under the separate fish-and-shellfish rule at 7 CFR Part 60, which predates the broader Part 65 program. For a seafood supplier, both facts have to travel with every lot from the moment it enters the chain, because neither can be reconstructed at retail from the product itself.

There is also a retail-scope nuance worth knowing: COOL's obligations fall on "retailers" as the law defines them, which centers on larger grocery sellers. Small operations below the threshold, butcher shops that further process, and food-service establishments generally sit outside mandatory COOL, which is part of why a covered commodity can lose its labeling obligation once it is cooked, cured, or combined into a prepared item.

What is the "Product of USA" rule?

The "Product of USA" rule is a separate, voluntary labeling standard for meat, poultry, and egg products, finalized by USDA's Food Safety and Inspection Service in 2024. Under it, a "Product of USA" or "Made in the USA" claim on those products can only be used when the animal was born, raised, slaughtered, and processed in the United States, closing a prior loophole where imported meat merely repackaged domestically could carry the claim.

This matters because the old standard let "Product of USA" appear on meat that was only processed here, which many consumers reasonably read as fully domestic. The 2024 final rule ties the claim to all four production steps, and for multi-ingredient products it also requires the other ingredients (beyond spices and flavorings) to be domestic and the preparation to happen in the U.S. Under updated FSIS guidance released in late 2025, "raised" is defined to cover the entire period from birth through slaughter. The rule took effect in 2024, but label changes are aligned to FSIS's uniform compliance date of January 1, 2026 so any product still carrying the claim after that date must meet the new definition.

The Product of USA test. The claim is voluntary, but making it now requires all four production steps to occur in the United States.

The practical effect is that a producer wanting the claim has to trace its animals the same way a COOL retailer traces covered commodities, the substantiation problem is nearly identical. If you buy any live animals or meat inputs, you need documentation that each carried the claim honestly all the way back, or you cannot make it on the finished pack.

Keep the distinction sharp: mandatory COOL is a retail disclosure for covered commodities; "Product of USA" is a voluntary claim a producer chooses to make and must now substantiate. They are governed by different USDA agencies and different rules, and a product can be subject to one, both, or neither.

What do retailers and suppliers have to do?

Retailers must display the origin declaration for covered commodities at the point of sale, and everyone in the chain must maintain records that let the origin claim be verified back to the source. COOL is enforced through that audit trail, AMS verifies compliance by tracing the paperwork, so a correct label with no supporting records is still a problem.

Identify your covered commodities. Determine which of the products you sell or supply are covered, and confirm whether processing has taken a commodity out of scope.
Capture origin from your suppliers. Get country-of-origin (and, for fish, production-method) information documented from each supplier, in writing, for every covered lot.
Assign the correct category and label. Translate the supplier information into the right origin category and point-of-sale declaration.
Keep the records. Maintain the origin and production-method records that substantiate each claim, and be able to produce them on request.
Reconcile Product of USA separately. If you make a voluntary U.S.-origin meat claim, verify it meets the born-raised-slaughtered-processed standard before January 1, 2026.

How long must you keep COOL records?

Records that substantiate a country-of-origin claim generally must be kept for one year from the date of the transaction, and be available to USDA on request. The exact retention obligation runs through the supply chain: suppliers keep records that identify the covered commodity and its origin, and retailers keep the records that let them make the declaration they post. The unifying rule is traceability, you must be able to connect the label a shopper sees back to a documented origin.

By the numbers. COOL is codified at 7 CFR Part 65 (and 7 CFR Part 60 for fish and shellfish) and administered by USDA's Agricultural Marketing Service; a 2016 appropriations law removed beef and pork muscle cuts and ground from mandatory coverage. The separate voluntary Product of USA final rule (89 FR 19470) requires the claim to reflect animals born, raised, slaughtered, and processed in the U.S., with a uniform compliance date of January 1, 2026.

How does COOL connect to traceability and supplier records?

COOL is fundamentally a traceability program wearing a labeling coat, it works only if you can follow a covered commodity back to a documented origin. That makes it a first cousin of your broader FSMA 204 food traceability and traceability systems, which chase lot identity through the supply chain for a different reason (recall speed) but rely on the same lot-level records. Build them once and they serve both.

It also leans on supplier quality management: the origin information a retailer labels with is only as good as what suppliers certify, so origin capture belongs in your supplier approval and documentation process alongside your GMP and HACCP paperwork. Where temperature-sensitive covered commodities like fish move through the chain, COOL records and cold chain management records travel together on the same lots.

The hard part is never the label, it is keeping the origin records straight across hundreds of lots and dozens of suppliers so any claim can be substantiated on demand. Harmony's connected data model ties supplier documentation, lot identity, and origin claims into one searchable record, so a COOL verification request becomes a query instead of a filing-cabinet excavation.