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Coalition Letter Opposing COOL Repeal and Voluntary COOL

July 28, 2015

The Honorable Pat Roberts

Chairman, Senate Agriculture Committee

328A Russell Senate Office Building

Washington, DC 20510

The Honorable Debbie Stabenow

Ranking Member, Senate Agriculture Committee

328A Russell Senate Office Building

Washington, DC 20510

Dear Chairman Roberts and Ranking Member Stabenow:

The undersigned 142 farm, ranch, rural, faith, environmental, farmworker, manufacturing

and consumer organizations respectfully urge you to reject both efforts to repeal the mandatory

Country-of-Origin Labeling (COOL) law and any attempts to convert the COOL law into a

voluntary program. Instead, we urge you to defend consumers’ right to know where their food

comes from and the ability of farmers and ranchers to proudly identify their livestock as born and

raised in America.

Today, consumers want to know more about the food they are feeding their families and farmers

want to share that information. The overwhelming majority of consumers and farmers support

the current mandatory COOL labeling law, with more than nine out of ten Americans supporting

COOL.

Although the World Trade Organization (WTO) Appellate Body has issued its decision on

COOL, the United States has a sovereign right to allow the dispute process to proceed to its

completion, which is months away, and then decide how and whether to implement the adverse

ruling. Our organizations remain steadfast in opposing any efforts to undermine or weaken

mandatory COOL, including outright repeal or by making COOL a voluntary program.

It is premature for Congress to unilaterally surrender to saber-rattling from our trading partners

in the midst of a long-standing dispute. COOL opponents have highlighted Mexico and Canada’s

threats of retaliation as if their aspiration to seek billions of dollars in penalties were already

approved by the WTO. But these unapproved, unrealistically high retaliation claims are merely

aggressive litigation tactics designed to frighten the United States — a standard practice in WTO

disputes. Congress should not fall for it.

The WTO can only authorize penalties based on the extent to which COOL caused a reduction in

the volume and price of livestock imports. But the economic recession was the driving factor

behind declining livestock imports, not the application of a simple label. Cattle imports are

higher today than when COOL went into effect and hog imports are rapidly rebounding, even

with COOL in place. This straightforward logic is buttressed by a recent economic report from

Auburn University that demonstrates that COOL has not impacted the livestock trade and that

any harm to our trading partners has in fact been negligible at most.

Moreover, retaliation is only relevant if the United States, Canada and Mexico cannot reach an

agreement after the parties have undergone the full WTO arbitration process. In past WTO

disputes that the United States has lost, the United States has waited for the process to conclude

and then has successfully avoided WTO-authorized trade sanctions by negotiating a settlement

with the other country in the dispute. Despite this successful track record, the House passed a

measure to repeal COOL for beef, pork, ground meats and chicken in June – the first time

Congress has acted to change a U.S. law before the completion of a WTO dispute process.

Additionally, the House-passed COOL repeal legislation is particularly extreme in that it would

roll back commonsense labels that the WTO actually supported or that never were raised in the

WTO dispute. The legislation would repeal COOL for ground beef and ground pork as well as

for chicken, but the WTO explicitly ruled that the COOL label on ground meat was WTO-legal,

and the dispute never addressed chicken or other covered commodities (including seafood, fresh

and frozen fruits and vegetables, goat, venison and some nuts).

Voluntary COOL labeling is no solution to the WTO dispute: Meatpackers won’t use it,

consumers won’t see it, farmers and ranchers won’t benefit from it and Canada and Mexico have

already bluntly rejected this so-called compromise. Voluntary COOL is indistinguishable from

repealing COOL, as meatpacking companies would be permitted to use voluntary COOL labels

even if mandatory COOL were repealed under the U.S. Department of Agriculture’s Processed

Verified Program.

Moreover, the meatpackers are unlikely to employ voluntary COOL labels because they do not

believe that consumers have a right to know where their meat products came from. The

meatpacking industry sued the U.S. Department of Agriculture to block mandatory COOL

because the meatpackers believed they had a constitutional free speech right to conceal the origin

of the meat they sell to consumers, a contention that was rejected repeatedly by the federal

courts.

That was the historical experience with voluntary COOL from 2002 to 2009, before mandatory

COOL finally was implemented. Although mandatory COOL was passed in the 2002 Farm Bill,

the appropriators blocked its implementation and only allowed a voluntary COOL program that

reserved the USA label for meat derived from livestock exclusively born, raised and slaughtered

in the United States — identical to the standard in the recently proposed voluntary COOL socalled

compromise. Few if any meat products were ever labeled under those voluntary regimes

for the simple reason that neither packers nor most major retailers want to provide origin

information to their customers.

Neither consumers nor livestock producers believe that we can allow the meatpacking, food

processing and grocery retail industries to decide what to disclose to consumers. These food

industries have long resisted providing basic information on food labels. We do not believe that

the interests of producers or consumers can be served by granting to the opponents of COOL the

exclusive right to decide whether or not to affix voluntary COOL labels.

COOL is extremely important to our organizations and to the American public. We oppose any

legislation that would undermine any portion of the COOL law, whether by outright COOL

repeal or by converting the mandatory COOL law to a voluntary program. We urge Congress to

stand up for America’s consumers, farmers and ranchers by rejecting any effort to unilaterally

repeal or weaken a popular food label even before the WTO process has concluded. Thank you

for your consideration of this request.

Sincerely,

Alabama Contract Poultry Growers Association

Alabama State Association of Cooperatives

American Agriculture Movement

American Federation of Government Employees

(AFL-CIO), Local 3354, USDA-St. Louis

American Grassfed Association

American Raw Milk Producers Pricing Association

Ashtabula, Geauga, Lake County (OH) Farmers’

Union

Berks (PA) Gas Truth

BioRegional Strategies

Buckeye Quality Beef Association (OH)

California Dairy Campaign

California Farmers Union

Carolina Farm Stewardship Association (NC)

Social Services Office-Catholic Charities of Central

and Northern Missouri/Diocese of Jefferson City

Catholic Rural Life

Cattle Producers of Louisiana

Cattle Producers of Washington

Center for Family Farm Development (GA)

Center for Food Safety

Center for Foodborne Illness Research & Prevention

Center for Media and Democracy’s Food Rights

Network

Center for Rural Affairs

Church Women United in New York State

Citizen Action Coalition of Indiana

Citizens for Sanity.Com, Inc. (FL)

Coalition for a Prosperous America

Colorado Independent CattleGrowers Association

Community Alliance for Global Justice (WA)

Community Farm Alliance (KY)

Community Food and Justice Coalition (CA)

Consumer Federation of America

Contract Poultry Growers Association of the

Virginias

The Cornucopia Institute

Dakota Resource Council

Dakota Rural Action of SD

Dawson Resource Council (MT)

Delmar Farmers Market (NY)

East New York Farms!/United Community Centers

EcoHermanas

Ecological Farming Association (CA)

The Ecology Party of Florida

Equal Exchange

Fair World Project (OR)

Family Farm Defenders (WI)

Farm Aid

Farm and Ranch Freedom Alliance

Farms Not Arms (CA)

Farmworker Association of Florida

Federation of Southern Cooperatives/Land

Assistance Fund (AL)

Florida Certified Organic Growers and Consumers,

Inc.

Food & Water Watch

Food Chain Workers Alliance

Food Democracy Now!

Food for Maine’s Future

Friends of the Earth U.S.

Hmong National Development, Inc.

Hunger Action LA (CA)

Idaho Organization of Resource Councils

Illinois Right to Know GMO

Illinois Stewardship Alliance

Independent Cattlemen of Nebraska

Independent Cattlemen of Wyoming

Indian Nations Conservation Alliance

Institute for Agriculture and Trade Policy

The Institute for Rural America (IA)

Iowa Citizens for Community Improvement

Johns Hopkins Center for a Livable Future (MD)

LabelGMOS.org

Land Stewardship Project (MN)

The Manufacturers Association of Central New York

Michigan Land Trustees

Midwest Organic Dairy Producers Association

Minnesota National Farmers Organization

Mississippi Sustainable Agriculture Network

Missouri National Farmers Organization

Missouri Rural Crisis Center

Missouri’s Best Beef Cooperative

Montgomery Countryside Alliance (MD)

Murray County (OK) Independent Cattlemen’s

Association

National Consumers League

National Family Farm Coalition

National Farmers Organization

National Latino Farmers & Ranchers Trade

Association

Nature Abounds

Nebraska Women Involved in Farm Economics

Neighboring Food Co-op Association (New England)

Nevada Live Stock Association

New York Women Involved in Farm Economics

NH Right to Know GMO

N. Carolina Assoc. of Black Lawyers, Land Loss

Prevention Project

Northeast Organic Dairy Producers Alliance

Northeast Organic Farming Assoc. – NH

Northeast Organic Farming Assoc. – NY

Northeast Organic Farming Assoc. – VT

Northeast Organic Farming Association, Interstate

Council (NOFA-IC)

Northern New Mexico Stockman’s Association

Northern Plains Resource Council (MT)

Northern Wisconsin Beef Producers Assoc.

Northwest Atlantic Marine Alliance (MA)

Northwest Farm Bill Action Group

Oglala Sioux Livestock and Land Owners

Association (SD)

Ohio Ecological Food and Farm Association

Ohio Environmental Stewardship Alliance

Oregon Rural Action

Organic Farmers’ Agency for Relationship Marketing

(OFARM)

Organic Seed Alliance

Organization for Competitive Markets

Panola Land Buying Association/Housing

Development Corporation (AL)

PCC Natural Markets (WA)

Peaceroots Alliance (CA)

Pesticide Action Network North America

Powder River Basin Resource Council (WY)

Progressive Agriculture Organization (PA)

Public Citizen

R-CALF United Stockgrowers of America

Ranch Foods Direct (CO)

Rochester (NY) Technology & Manufacturing

Association

Roots of Change (CA)

Rural Advancement Foundation International – USA

(RAFI-USA)

Rural Coalition/Coalición Rural

Rural Development Leadership Network (NY)

Rural Vermont

Simply Living (OH)

Slow Food USA

South Dakota Farmers Union

South Dakota Livestock Auction Markets

Association

South Dakota Stockgrowers Association

Southern Sustainable Agriculture Working Group

Springfield Food Co-op (VT)

Texas Certified Farmers Market Association

350 Berks and Lehigh Valley Climate Action (PA)

Tidal Creek Cooperative (Food Market) (NC)

Tilth Producers of Washington

Tooling, Manufacturing and Technologies Assoc.

(MI)

Virginia Association for Biological Farming

Western Colorado Congress

Western Organization of Resource Councils (WORC)

Western Sustainable Agriculture Working Group

WhyHunger

Williams County Alliance (OH)

Women Involved in Farm Economics

Wood County (OH) Citizens Opposed to Factory

Farms

4 thoughts on “Coalition Letter Opposing COOL Repeal and Voluntary COOL”

  1. The letter notes, “the legislation would repeal COOL for ground beef and ground pork as well as for chicken, but the WTO explicitly ruled that the COOL label on ground meat was WTO-legal, and the WTO never addressed chicken or other covered commodities. The broad-based coalition vehemently opposes any effort to repeal COOL but also opposes any effort to weaken COOL, including converting it into a voluntary labeling program.

  2. COOL is extremely important to our organizations and to the American public. We oppose any legislation that would undermine any portion of the COOL law, whether by outright 2186 COOL repeal or by converting the mandatory COOL law to a voluntary program,” the coalition letter states.

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