MCOOL

COOL (Country of Origin Labeling)

The mandatory country-of-origin law became effective on September 30, 2008.  This law requires retailers selling fresh and enhanced meat products to identify the country of origin where the source animals were born, raised and harvested.  This law requires the packer to have sufficient information or documentation to substantiate the claim “Product of the USA.”  In other words, we will be required to verify that the animal was born and raised in the USA.  With this in mind it will be necessary for livestock producers, dealers or buying stations to provide documentation to support such a claim if audited.

IPC Requirements for Producers

In order to have sufficient information and documentation to support the “Product of the USA” requirements of MCOOL, the following requirements and documentation will be required from all livestock producers, dealers, and buying stations supplying hogs to Indiana Packers.

1. Indiana Packers Corporation will require a signed Country of Origin Declaration (COD, attached) prior to delivery of hogs.    Persons signing the Country of Origin Declaration must have first-hand knowledge of the animals “COOL claims” and be responsible for maintaining adequate records to support those claims.    The signed Country of Origin Declaration will be valid for a period of six (6) months.  Prior to expiration of each COD, Indiana Packers will assign a new COD to the supplier and send it to said supplier for signature.  The executed COD shall then be returned to Indiana Packers Corporation.  Indiana Packers Corporation will not accept hogs without a valid Country of Origin Declaration on file.    The Country of Origin Declaration states where the animals were “Born and Raised” which supports the claim “Product of the USA.” 
2. Persons signing the Country of Origin Declaration shall be responsible for maintaining adequate records to support the claims made in the executed Country of Origin Declaration and be able to provide this information when audited.  These records should include beginning and ending inventories as well as additions and removals of animals.
3. An “Indiana Packers Corporation Bill of Lading” will be required with each load of hogs.  This form is available on the Indiana Packers Corporation website at www.inpac.com.   Indiana Packers Corporation will maintain these records for a period of one year. These records will provide documentation to auditors when requested.
4. Auction markets, order buyers and other market intermediaries must take ownership, maintain records and sign as the seller or pass the seller’s information on to the buyer.
5. Producer, order buyer, dealers and other market intermediaries, shall provide Indiana Packers Corporation access to records when audited.
6. The producer will indemnify IPC for liability incurred that is a result of producer noncompliance.

Examples of documents to maintain for at least one year to provide an audit trail.

¹ Balance sheet, income statement, other financial records, scale tickets and purchase and sales receipts, closeout records and/or feed records or bills, health papers, vaccination or other health treatment records or receipts, shipping records, farrowing, breed association registered pedigrees. See http://www.ams.usda.gov/cool/records.htm for details.

Grandfather Clause

Due to the delay in the passing of the farm bill, the law allows for hogs purchased from Canada on or before July 15, 2008, to be defined as “Product of USA.” Hogs purchased after July 15, 2008 will be defined as Canadian product and as such Indiana Packers will not process hogs of Canadian origin.

Labeling of IPC Products

The logistics required for both the packer and the retailer to comply with USDA AMS MCOOL labeling, when multiple origin livestock is used, forces Indiana Packers Corporation to restrict our livestock purchases EXCLUSIVELY to livestock that are born and raised in the USA and qualify for labeling as “Product of the USA.”

Guidance Information from the USDA’s Agriculture Marketing Service (AMS)

The MCOOL guidelines place the burden of proof on retailers, but also indicate that suppliers to retailers (including producers and packers) must maintain auditable records documenting the origin of the hogs.  The USDA’s Agriculture Marketing Service (AMS) has suggested that recordkeeping for MCOOL may be done as a component of an operation’s regular records. Producers may be required to maintain “verifiable audit trail records” regarding MCOOL for a minimum of one year.  There currently are no official forms or recordkeeping systems for producers to use in the tracking of MCOOL information. All loads delivered to the plant MUST be accompanied with the “Indiana Packers Corporation Bill of Lading.”

Indiana Packers appreciates your cooperation and will continue to keep you informed of developments as they arise.  Should you have any specific questions, please feel free to contact us at 765-564-3680.