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USA label only for born, raised, processed in the USA

Leo McDonnell
Director Emeritus US Cattlemen’s Association

January 27, 2020

Comments to Docket No. FSIS-2019-0024: The U.S. Cattlemen’s Association (USCA) Petition for the Imposition of Beef Labeling Requirements: To Address “Made in USA” or “Product of USA” Claims

These comments are submitted in support of this petition to ensure that only beef or beef products that are derived solely from cattle born, raised, and processed in the U.S. are eligible for labels such as “Made in USA,” “American Beef,” “Product of the USA,” “USA Beef,” or any other label that would imply the product is of U.S. origin.

U.S. consumers are already confused, with many thinking that a Grade stamp, such as USDA Choice is actually U.S. origin product. Many consumers also assume that a U.S. Inspection stamp also means it is U.S. Product. What consumers need is clarity.

USDA has already received examples of marketing claims of US Beef, American Beef, etc., where many of these same processors are also processing imported product. Under the current guidelines, these processors are allowed to label imported product as being of US origin even though, as USCA, pointed out, they fail to meet the FTC’s “all or virtually all” standard if they are to use “made in USA” or “product of USA” (or similar labeling ).

Previous opponents to Country of Origin Labeling have claimed that such record keeping was cumbersome & expensive during the years that mandatory country of origin (MCOOL) was in effect. Some said the costs during that period, from 2009-2915, was nearly $6 billion. But many of these tracking practices were already required by the government for food safety purposes, recalls, etc. Interestingly, when MCOOL was repealed in 2015, one would have thought based on these claims, that packer & retailer margins would have narrowed from the huge savings of having MCOOL repealed; instead, both packer and retail margins of All Retail Beef prices widened to historical shares, while US cattle producers’ shares shrank to record or near record low levels.

Others have said consumers did not show a preference for having COOL labeling. However, there were no promotional campaigns to market beef labeled as US origin; the fact is, and as the US Meat Export Federation ( USMEF ) pointed out several years ago and in the only market arena where US Beef was ever promoted and identified for marketing purposes which was in the international market, there were significant premiums for US labeled beef. Here in these foreign markets the Cattlemen’s Beef Board, with USDA matched funding, was spending about $16 million a year and had directed USMEF that all marketing efforts were to promote “ US Beef.” USMEF reported to the CBB during the MCOOL years that in the international markets US Beef was bringing a distinctive premium over all other countries, including Canada which has been rated as nearly a similar beef product. In fact, at that time, US Beef was averaging $3.27/lb. in the international market, while its next closest competitor in price was Canada at $2.53/lb.

However, even during the later years of MCOOL when US beef was being identified and labeled, significant premiums were being paid for 90% US Lean beef over 90% Imported Lean by US retailers and wholesalers to satisfy consumer demand.

In 2014 and early 2015, while consumers, retailers, and wholesalers were still being offered COOL choices, US Domestic Lean was bringing at times 60 cents over 90% Import Lean, a 25% premium. Historically dating back into the 1970’s, 90% Import & Domestic Lean traded for the most part within 3-15 cents of one another, with imported beef at times bringing a premium. With nearly 50% of beef in the US being marketed as ground beef, this clearly showed a strong demand for US produced product when consumers were given the choice with proper country of origin labeling.

It’s also important to note some of COOL opponents have claimed that “beef is beef no matter where it comes from.” It’s unclear if this included fake or cultured beef, but at least one of the industry trade groups filed in opposition to truth in labeling of the plant based and cell cultured beef imitations. Some of these same groups have also worked closely with the lamb and pork industry to commoditize and standardize specific beef cut nomenclature with similar meat cuts of these species; such as, porterhouse, ribeye, sirloin, etc. Unfortunately, this only further commoditized these various meat cuts and confused consumers. The point being, that such standardization of meat products, and origin, whether by country or plant base vs animal, only limits consumers choices and, sadly, what many now call the Information Age leaves consumers in the dark. It’s my hope that USDA will reject these Social Capitalistic agendas.

Additionally, to state “beef is beef no matter where it comes from,” fails to recognize the difference in production standards, regulatory requirements between countries and even food safety inspection standards. Several countries and companies involved in beef imports into the U.S have been caught using slave labor and bribing government officials for various things including food safety protocols and being involved in environmental degradation such as distruction of the rain forest in South America. Given the choice, many consumers would not support these countries by purchasing their product. While this petition does not address labeling of foreign beef, it does give US consumers the choice to purchase US beef over unlabeled beef, or beef that is falsely labeled as US beef.

Again, it has been said it is too difficult for U.S. packers and processors to keep track of where their beef and cattle come from. However, there are well over 150 branded beef programs today as well as several degrees of quality grades, breed claims, overweight carcasses, age claims, dark cutters, etc. that we depend on these same folks to label and identify properly without co-mingling for labeling claims. Certainly it can be agreed by all that processors have a long and successful history of being able to identify where various beef products originate under various market claims.

In the early years of MCOOL, when Mexico still had a ban on Canadian beef, Mexico required US beef being exported to Mexico that US plants be able to distinguish and segregate US beef for export from beef of Canadian Origin.

Canada was required to perform much the same for their exports of beef to China when the US was still banned from China. In fact, it was during the vary years that Canada participated in the WTO cases against the US for COOL on beef and pork that Canada itself was practicing the same segregation, tracking, and identification practices to ensure no beef of US origin went to China.

And now China is requiring of the U.S. to export beef to China:

All beef must be derived from cattle that were either:

(a) born, raised, and slaughtered in the United States,

(b) imported from Canada or Mexico and then raised and slaughtered in the United States, or

(c) imported from Canada or Mexico for direct slaughter in the United States.

The fact is, the Chinese consumers will have a better idea of the origin of beef from the US than the US consumers will in our own domestic market.

Also, while this administration has been a vocal proponent of buying American products, American ranch families and their beef products are not only not identified to consumers, but current USDA guidelines are allowing imported product to be falsely labeled as “ US “ beef. This consumer fraud practices must be corrected.

I encourage USDA also not to get caught up in verification schemes which may be suggested, and allow the markets to use the many models already in existence for verification of US beef product origin and other beef product marketing claims.

Respectfully,

Leo McDonnell

13 Bull Dr

Columbus, Mt 59019




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