Country-of-origin labeling, or COOL, is a USDA labeling law run by the Agricultural Marketing Service (AMS). The label itself is the retailer's job: the grocery store has to tell shoppers where covered foods come from. But a retailer can only label what its suppliers tell it, so the rule reaches back up the chain. Anyone who supplies a covered commodity to a retailer, directly or through other businesses, has to pass along origin information and keep records. For a produce distributor selling to grocery stores, that includes you.

The rules are in 7 CFR Part 65 (produce, nuts, ginseng and some meats) and 7 CFR Part 60 (fish and shellfish), summarized on the USDA AMS COOL page.

What and who is covered

  • Covered commodities: fresh and frozen fruits and vegetables; peanuts, pecans and macadamia nuts; ginseng; muscle cuts and ground lamb, chicken and goat; and wild and farm-raised fish and shellfish. Beef and pork are no longer covered.
  • Retailers: COOL applies to retailers as defined under the Perishable Agricultural Commodities Act (PACA). Whether a particular grocery customer meets that definition depends on PACA's rules, so consult USDA's PACA program rather than guessing.
  • Food service is exempt. Restaurants, cafeterias, bars, food stands and similar businesses, including salad bars and delis inside retail stores, do not have to label origin.
  • Processed food items are excluded. That means a covered commodity that has been cooked, cured, smoked or restructured, or combined with another covered commodity or a substantive food component. The rule's own examples are roasted peanuts, breaded chicken tenders and fruit medley.

So a distributor's COOL exposure follows its customer mix. Sales to restaurants are outside the labeling requirement. Sales that end up at a retailer, directly or through another distributor, are inside it.

What you must pass to your buyer

The supplier rule (7 CFR 65.500) says origin information must be made available to the buyer in one of three ways: on the product itself, on the master shipping container, or in a document that accompanies the product through retail sale. For fish and shellfish, the method of production (wild or farm-raised) goes with it.

  • Imported product keeps the origin declared to U.S. Customs and Border Protection at entry, through to retail sale.
  • Mixed origins: when product from different countries is commingled, the declaration lists all of them.
  • Format rules at retail: country abbreviations are generally not acceptable, except approved ones such as "USA"; flags or symbols alone are not acceptable; and produce may use a State, regional or local designation instead of the country. Your documents should give retailers origin they can use as is.

Records to keep, and for how long

  • Every supplier in the chain, distributors included, keeps records that identify the immediate previous source and the immediate subsequent recipient of a covered commodity, for one year from the transaction.
  • The supplier that starts an origin claim keeps the records that back the claim up, also for one year. Importers of record have their own duty to keep records that tie product to its customs entry and declared origin.
  • Records can be paper or electronic and must be legible. When USDA asks, you provide them within five business days.

One provision protects distributors who keep good paper: an intermediary supplier that relied on the origin given by its own supplier is not liable for a wrong designation, unless it willfully ignored information showing the claim was false. Keep the supplier's origin documents with the receipt; they are your evidence.

How AMS checks

AMS reviews retail stores, and it runs supplier traceback audits that start from records collected at retail and follow an origin claim back through the chain. Any direct or indirect supplier can be audited. In practice the trail runs from the retailer's record to your invoice, from your invoice to your receiving record, and from there to your supplier's documents. You can test this yourself: pick a retail-bound invoice line and walk it back to the supplier paperwork that set its origin.

Where origin lives in your data

  • Origin belongs on the lot, not just the item. The same item can come from Mexico one week and the United States the next, so origin is part of lot tracking. A default origin on the item record is a convenience, not proof.
  • Capture it at receiving from the case marking or the supplier's documents, and note which document it came from.
  • Carry it through. The lot's origin should follow the pick onto the invoice line, the case label or the document that travels with the product for retail customers. The common failure is origin recorded correctly at receiving and then missing from everything the buyer actually receives.
  • Handle two-lot picks. If one order line is filled from two lots of different origin, the document should show both.
  • Correct with a trail. If receiving recorded the wrong origin, fix the lot, note who changed it and why, and check what has already shipped.

If you also handle foods on the FDA's Food Traceability List, much of this receiving discipline overlaps with FSMA 204. Our FSMA 204 readiness checklist covers that side.

How APFoodz handles it

APFoodz records each lot's events as the work happens, from the receipt to the shipment, so the receiving record behind any shipped lot, which is what a traceback asks for, is a lookup.