Mandatory COOL Tips For Producers

By Sarah Young Livestock Editor
Thursday, September 18, 2008 9:51 AM CDT

Continuous Affidavit Sample

In less than two weeks, producers, retailers and everyone in between will begin the mandatory country-of-origin labeling process.

Producers will be required to provide first-hand information about the animals they are sending up the supply chain, but producers shouldn’t worry, says Chuck Adami, president and CEO of Equity Cooperative Livestock Sales Association.

“The producer is able to comply with COOL through the keeping of his normal business records,” he says.

As long as producers were keeping records including birth dates, sales receipts, health records, inventory records, etc., they have all the necessary information.

“If he were to be buying an animal for replacement purposes, then the invoice that he receives would show the origin of the animal, where the animal was born would be sufficient,” he explains.

To move that information up the chain, producers would pass the information on to whoever sells it.

“If he happens to be selling it directly to another producer, he’d have to give some documentation to that other producer what the origin of that animal is,” he says.

That information could include an affidavit declaring that through first-hand knowledge or through business records that the animal sold animal was born in the United States.

If sending it to an auction market, producers would also have to provide information about the country of origin. The producer should check with auction markets and packers for requirements.

Equity will require producers to provide an Equity approved affidavit. The affidavits are available on the Equity website www.equitycoop.com and are approved by the USDA.

Affidavits

Two different affidavits have been approved for use by the USDA n continuous and stand-alone type affidavits, both of which are available and used by Equity.

A continuous affidavit is a document that is intended to remain on file with the buyer to verify all livestock from a particular seller or producer is of the specified origin unless noted otherwise.

For example, Producer A raises his own calves and normally sells the calves at the local auction market. Producer A, therefore, would sign this continuous affidavit to remain on file with the auction.

The local auction can use Producer A’s affidavit, combined with sales records, to verify the U.S. origin of Producer A’s livestock. This assures the local auction has documentation to pass along to purchasers of Producer A’s calves.

Filing a continuous affidavit with primary purchasers may be the simplest way to provide origin information.

“That should simplify the process for the producer who is pushing animals upstream,” he explains. “He only has to do it one time at a market and that (affidavit) stays on-file at the market.”

The stand-alone affidavit is for an individual or group of animals that are of a different country-of-origin than what the continuous affidavit states.

For example, Producer B has a continuous affidavit on file stating the livestock are from the United States. Now he/she is selling livestock of Canadian origin, the stand-alone affidavit would need to accompany those animals of Canadian origin.

Dates of importance

The starting date for mandatory COOL is Sept. 30, but what about animals born before this date?

The regulation says that any animal that was in existence and in the United States as of July 15 could be considered a U.S. origin animal,” Adami explains. “But for animals between July 15 and Sept. 30 that’s not true.”

Producers will have to go by their records for those animals to determine their country-of-origin.

For the first six months of implementation, USDA will be providing education and evaluation of the system.

“They are giving it some grace period to get it going,” he says.

However, markets want it to start on Sept. 30 with the collection of affidavits with animals received.

“The quicker we start the faster we get it in,” he says.

Once the continuous origin affidavits are collected then until stand-alones are needed, the process is ultimately done for both producers and markets.

Don’t fret

Producers should not be worried about providing origin information because it is a marketing program.

“The producers shouldn’t fear this because it’s not a regulation to try and get back to a liability situation,” he says. “It’s the marketing side that is going to be regulating. It is not the disease side.”

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