Not COOL and why not
By Charlie Gracey
W
e are back, essentially, to square one on the Cool rules. There was good news and bad news in Secretary Vilsack’s announcement in February. On the positive side concerns that Vilsak might yield to pressures that would make labeling rules even more difficult have been allayed but he has signaled that he wants packers to voluntarily go beyond the present requirements and to continue to distinguish between B and C category cattle.While the final rule has not changed textually I have noted a
subtle change in the answers provided in the
Q&A put up on the website. Here is my understanding:
1. Cattle that were exported from Canada as feeders and fed in the USA prior to slaughter in a US plant are clearly category "B" cattle and their products may be labeled "Product of the US and Canada" or voluntarily, as Secretary Vilsakk would prefer "Born in Canada, fed and slaughtered in the USA."
2. Cattle born and raised in Canada and exported for immediate slaughter in a US plant are clearly category "C" cattle and their products must be labeled, "Product of Canada and the USA" or voluntarily as the secretary would prefer "Born and raised in Canada, slaughtered in the USA".
Only where cattle are commingled prior to or during the slaughtering process or where the beef products themselves from cattle of different origins are processed may the rules permit different label.
Where category B and category C cattle are commingled at slaughter or where the products of category B and Category C cattle are processed together the label may read "Product of US and Canada". However it is clear that Vilsack does not approve of this rule and prefers the clarity mentioned in his letter ( Where were the cattle born? Where were they raised? Where were they slaughtered?).
1. There is no advantage to anyone of commingling category A cattle with category B or C product because such US product would suffer a downgrade in C status.
The only apparent benefit of the final rule, as it is currently worded, is to place beef products from cattle that were exported for immediate slaughter into category "B" product of the USA and Canada, but only if those cattle were commingled with category B cattle during slaughter or processing. This is the exact issue that Secretary Vilsack seeks voluntary industry co-operation to avoid.
Secretary Vilsack has created a new sense of uncertainty by publicly urging packers to voluntarily go further and continue to distinguish between B and C category animals. US Packers will be left to decide whether this is wishful thinking or a veiled threat. The closing paragraphs of the letter strongly suggest the latter. They will also have to try to figure out what each of their competitors intends doing.
(Charlie Gracey is a former manager of CCA)