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On June 6, the USDA is holding a listening session in Billings on the mandatory implementation of country-of-origin labeling. This measure requires country-of-origin labeling for fresh and fresh-frozen fruits and vegetables, red meats, seafood and peanuts. Labeling is voluntary until September 2004 when it becomes mandatory.

The Montana Farmers Union was an early supporter of COOL and wants to make sure that its implementation is accurate and fair to producers and consumers alike. Unfortunately, as USDA undertakes the process of implementing the law, opponents of labeling have continued their campaign to confuse and misinform policy makers, producers and the general public about the issue.

Estimating costs In fact, the USDA itself has muddied the debate by estimating that COOL will cost at least $2 billion to implement with most of the record-keeping burden being borne by producers and the costs passed along to consumers.

However, a recent independent analysis of USDA assumptions and methodology by the University of Florida's Institute of Food and Agricultural Sciences reports that the USDA chose to analyze the most expensive implementation method at its disposal — rather than the least costly.

Presuming U.S. origin The Florida report says that the "Presumption of U.S. Origin Rule is most likely to comply with the law, lessens the burden on industry and government, and sufficiently deters potential label misrepresentation." This rule assumes all products are of U.S. origin unless they are marked otherwise.

For livestock producers, production records generally will be sufficient to satisfy the COOL law. Nonproducers covered by the law will need to include a line for country of origin on their purchase documents. The actual cost of record keeping as related to labeling according to the Florida report is between $69.86 million and $193.43 million, which is 90 percent to 95 percent less than the USDA estimate. "This cost translates into less than one tenth of a cent per pound for the covered commodities as consumed by US citizens," the report says.

Curiously, the USDA also did not consider the potential benefits of labeling in its analysis.

We believe that mandatory country-of-origin labeling represents an opportunity for the United States to provide a significant level of important information concerning agricultural products. Labeling will expand the level of consumer choice, confidence and knowledge in the retail marketplace and potentially increase the demand for U.S. origin commodities.

Many COOL opponents already label food products as to origin for export markets and spend significant dollars to create public awareness of their products through brands — or labels. We believe it is a sham to propose that labeling is OK for these businesses, but not for agricultural producers who seek to differentiate their product from foreign competitors.

We already have a fair amount of information on our food labels. We know calories, fat grams, fiber grams and vitamin content. We know number of servings and ingredients. But we don't know, for the most part, where our fresh fruit, vegetables, red meat and seafood comes from. As someone once said, "Does it make sense that you know where your T-shirt comes from but not your T-bone?"

Labeling is knowledge. Labeling produces brand recognition. And labeling can be profitable. Country-of-origin labeling provides an important link between farmers, ranchers and consumers. As consumers, knowing where our food has been grown or raised is important to us. As producers, we are willing to bet that consumers — if given the chance — will support locally grown and raised. That's the point of COOL.

COOL caravan Just for a moment, I'd like you to think of a sports shoe company and a soft drink company. I'm willing to bet that a couple of brand names come quickly to mind. Now think about the hamburger you may have had for lunch or will fix for dinner. Even though Montana is a significant beef producer, if you buy your hamburger through a grocery chain — and not directly from a producer — it is unlikely that the hamburger comes from Montana — or even the United States. And wouldn't it be nice for everyone to know that.

If you think country-of-origin labeling is long overdue and would like to state your opinions in person, join us in the COOL caravan as it travels from Great Falls to Billings on June 6. Just give me a call for details at (800) 234-4071.

Del Styren of Great Falls is president of the Montana Farmers Union, a statewide grassroots membership organization working for family farmers, ranchers and rural communities.