COUNTRY OF ORIGIN RESEARCH SERIES | RESEARCH PAPER
Country of Origin Labeling (COOL): Where Meat Origin Labeling Stands in 2026
A short guide to the two origin rules for meat, what changed on January 1, 2026, and what is still under debate.
Prepared for publication by Farm Animal Transparency | First published November 2025; revised October 2026
Mandatory country of origin labeling no longer covers beef or pork. Since January 1, 2026, a voluntary rule decides what “Product of USA” means — but a package is still free to say nothing about origin at all.
| At a glance |
|---|
| Mandatory COOL for beef and pork ended in December 2015 after WTO rulings authorized Canada and Mexico to retaliate. It still applies to chicken, lamb, goat, seafood and produce. |
| “Product of USA” now has a fixed meaning. Since January 1, 2026, the claim requires an animal born, raised, slaughtered and processed in the United States (9 CFR 412.3). |
| The 2026 rule is voluntary. It governs claims a company chooses to make; it does not require one. |
| Mandatory beef labeling is back on the table. A Senate Agriculture Committee farm bill includes it, and an executive order gave USDA until early December 2026 to review its authority. |
Abstract
Country of origin labeling (COOL) is the umbrella term for the rules that tell shoppers where food came from. For meat, two different rules now matter: a mandatory one that no longer covers beef or pork, and a voluntary one that took full effect on January 1, 2026. This short guide explains both, what is still required on a package, what changed in 2026, and where the policy debate stands. It replaces FAT’s November 2025 note, which was written before the 2026 compliance date.
1. Two rules, often confused
| Mandatory COOL (MCOOL) | Voluntary “Product of USA” rule | |
|---|---|---|
| Who runs it | USDA Agricultural Marketing Service (AMS) | USDA Food Safety and Inspection Service (FSIS) |
| Where it applies | Retail point of sale | The product label, only if a company chooses to make a U.S.-origin claim |
| Beef and pork | Removed by Congress in December 2015 | Covered since January 1, 2026 |
| Chicken, lamb, goat | Still required at retail | Covered for FSIS-regulated products that make the claim |
| What it requires | An origin statement on covered commodities | Nothing, unless a claim is made; then born, raised, slaughtered and processed in the U.S. |
2. How mandatory COOL rose and fell
- 2002 and 2008: Congress enacted COOL in the 2002 farm bill and amended it in the 2008 farm bill, which added chicken and goat.
- 2009: AMS’s final rule took effect for beef, pork, chicken, lamb, goat and other commodities.
- 2013: AMS revised the rule to require labels naming where each production step (born, raised, slaughtered) took place.
- 2012–2015: Canada and Mexico challenged the program at the World Trade Organization. The WTO found that the U.S. rules treated imported livestock less favorably in practice, while accepting that giving consumers origin information is a legitimate objective.
- December 7, 2015: WTO arbitrators authorized retaliation of about C$1.05 billion a year for Canada and about US$228 million for Mexico.
- December 18, 2015: Congress repealed COOL for beef and pork in the Consolidated Appropriations Act, 2016. AMS removed the beef and pork provisions from its regulations on March 2, 2016.
Mandatory COOL still applies at retail to chicken, lamb and goat, fish and shellfish, fresh and frozen produce, and a few nuts and ginseng.
3. The 2026 “Product of USA” rule
FSIS published its final rule on voluntary U.S.-origin claims on March 18, 2024 (89 FR 19470, codified at 9 CFR 412.3). Companies that choose to use “Product of USA,” “Made in the USA,” or a standalone U.S. flag on meat, poultry or egg products had to comply by January 1, 2026. The claim now means the animal was born, raised, slaughtered and processed in the United States. Claims that name individual U.S. steps (for example, “sliced and packaged in the USA”) remain allowed. Companies keep the supporting records on file; FSIS verification began on the compliance date, and FAT found no delay or court challenge through October 2026.
The rule is voluntary. It sets the meaning of a claim if a company makes one; it does not require any origin statement. The details are in Product of USA: Regulatory Meaning and Trade History and, for ground beef, What “American” Means on a Ground Beef Label.
4. Where the debate stands (October 2026)
- Congress: The American Beef Labeling Act of 2025 (S.421) would direct USDA and the U.S. Trade Representative to design a WTO-compliant mandatory label for beef. On August 6, 2026 the Senate Agriculture Committee added beef-labeling language based on that bill to its farm bill, and on September 16 the committee advanced the farm bill with it included. FAT has not located a full Senate vote as of this revision. The House-passed farm bill (April 2026) does not include it.
- Executive branch: Executive Order 14425 (September 4, 2026) gave USDA 90 days, working with USTR, to review what legal authority exists for mandatory beef origin labeling and report back. The review is due in early December 2026. It does not itself require any label.
- Trade: At the July 2026 USMCA joint review the United States did not agree to extend the agreement, which moves the three countries to annual reviews. FAT found no public text on origin labeling from that review.
5. What a shopper can rely on today
- Beef and pork: an unqualified “Product of USA,” “Made in the USA” or U.S. flag now means U.S. born, raised, slaughtered and processed. Silence means nothing either way.
- Chicken, lamb and goat: the store must disclose origin at retail under mandatory COOL.
- Restaurants and most processed products: exempt from mandatory COOL.
What this means for FAT’s 16 categories and the FAT App
For FAT, origin is about the animal, not the plant. Origin is Category 4 (Country of Origin) in FAT’s 16-category framework. An unqualified “Product of USA” claim now has a defined, documented meaning and counts as an origin disclosure; a claim naming U.S. steps discloses only those steps; patriotic wording without a defined meaning does not count; and a package with no origin statement is reported as silent. The farm of origin (Category 5) and the processing plant (Category 7) are separate facts. The FAT App applies the same reading at the shelf: scan a package and it shows which of the 16 categories the label discloses, which it leaves blank, and the plant behind the EST. number.
Recommendations
- Shoppers: treat the three defined signals as origin information and read every other patriotic phrase literally.
- Producers and brands: keep birth and movement records that would support a U.S.-origin claim; they are now what makes the claim usable.
- Policymakers: any return to mandatory beef labeling needs a design that treats imported and domestic animals the same way at every step; that was the WTO’s central objection.
Sources
- USDA AMS, Country of Origin Labeling (COOL) — covered commodities — agency page.
- Consolidated Appropriations Act, 2016, Pub. L. 114-113, Div. A §759 (repeal of beef and pork MCOOL, Dec. 18, 2015)
- USDA AMS final rule removing beef and pork from COOL, 81 FR 10755 (Mar. 2, 2016)
- Congressional Research Service, RS22955, “Country-of-Origin Labeling for Foods and the WTO Trade Dispute on Meat Labeling” (2016 update) — CRS report.
- Global Affairs Canada, joint statement by Canada and Mexico on WTO retaliation authorization (Dec. 2015)
- FSIS final rule, “Voluntary Labeling of FSIS-Regulated Products With U.S.-Origin Claims,” 89 FR 19470 (Mar. 18, 2024) — agency rule.
- 9 CFR 412.3, voluntary U.S.-origin claims (eCFR)
- Reed Smith, “Where’s the beef from? USDA issues a new directive on ‘Product of USA’” (Dec. 2025) — law-firm summary of FSIS Directive 7221.1.
- S.421, American Beef Labeling Act of 2025 (congress.gov)
- Capital Press, “Senate advances beef MCOOL even as Farm Bill stalls” (Aug. 7, 2026) — trade press.
- DTN, “Mandatory Country of Origin Labeling Clears Key Senate Farm Bill Hurdle” (Sept. 21, 2026) — trade press.
- Executive Order 14425, “Supporting America’s Ranchers,” Sec. 4 (signed Sept. 4, 2026)
- White & Case, “USMCA 2026 Joint Review: United States declines to extend Agreement” (July 2, 2026) — law-firm analysis.
More in the Country of Origin Research Series
- Product of USA: Regulatory Meaning and Trade History
- What “American” Means on a Ground Beef Label
- The Case for Mandatory COOL
- The Case Against Mandatory COOL
- Policy and Market Pressures on Transparent Domestic Beef
- From Retail Demand to Producer Incentives
- From Compliance to Brand: Proving It’s U.S. Beef
- Federal Leadership on Beef Origin Labeling, 2021–2026
- Lean Beef Imports for Hamburger Sold in America
- Lean Beef in America
- Purchased Silence
- The Border Check
Working paper. Revised October 21, 2026 from FAT’s November 2025 note “Country of Origin Labeling (COOL) in U.S. Beef”. Figures are as of the dates shown in the sources. Corrections welcome: dirkadams@farmanimaltransparency.com.