Background and Renewed Interest in COOL

Mandatory Country-of-Origin Labeling (COOL) for meat was first enacted in the 2002 Farm Bill and implemented in 2009, requiring retailers to label fresh beef, pork, chicken, and certain other foods by origineverycrsreport.comeverycrsreport.com. In 2015, however, Congress repealed COOL requirements for beef and pork after the World Trade Organization (WTO) upheld complaints from Canada and Mexico that the U.S. labeling program discriminated against their livestockeverycrsreport.comamericanagnetwork.com. Since then, momentum has grown to reimplement COOL in a trade-compliant way. Recent testimony to the U.S. Trade Representative (USTR) and bipartisan bills in Congress underscore this renewed push, citing evidence that COOL can be economically viable, legally compatible with trade obligations, and highly demanded by consumersamericanagnetwork.com. Below, we summarize key factual findings (from 2000 onward) that support reinstating COOL for beef, pork and chicken, focusing on economic viability, trade compatibility, consumer demand, and cost impacts.

Strong Consumer Demand for Origin Transparency

American consumers have consistently expressed overwhelming support for origin labeling on meat. Multiple surveys indicate 85–90% of U.S. adults favor mandatory COOL for fresh meat productsconsumerfed.org. For example, a 2017 Consumer Federation of America poll found 89% of Americans strongly or somewhat favor requiring retailers to disclose the country of origin of meat, and a similar share support even more detailed labels showing where animals were born, raised, and processedconsumerfed.org. This robust public support reflects consumer interest in food safety, supporting U.S. farmers, and perceived quality differences. Importantly, the WTO’s appellate ruling on COOL affirmed that providing consumers with origin information is a legitimate objective for policyeverycrsreport.com. In other words, international trade law recognizes consumers’ right to know where their food comes from – a principle the United States “welcomed” as an affirmation of its right to adopt labeling requirements for meateverycrsreport.com. Reinstating COOL would directly respond to consumer demand for transparency, allowing shoppers to identify and choose U.S.-origin beef, pork, and poultry at the point of purchase. Proponents note that, in the current absence of mandatory labels, imported meat can be intermingled and sold as indistinguishable from U.S.-raised product, denying consumers the information they overwhelmingly wantamericanagnetwork.comlink.mediaoutreach.meltwater.com. Restoring mandatory COOL would remedy this by ensuring clear origin labels on all beef, pork, and chicken – a change widely expected to increase consumer trust and satisfaction without compromising food safety or qualityamericanagnetwork.com.

Economic Viability and Benefits for Domestic Producers

Evidence suggests that COOL can be implemented in a way that bolsters U.S. producers and rural economies, addressing prior concerns about competitiveness. Today, industry data reveal troubling trends in the U.S. cattle sector that COOL supporters link to the lack of origin labeling. The U.S. beef cow herd has fallen to its smallest level in about 70 years, even as beef imports have climbed to record highs (over 4.5 billion pounds last year)link.mediaoutreach.meltwater.comlink.mediaoutreach.meltwater.com. Without mandatory COOL, imported meat and cattle have “gained equal footing” with domestic production, undercutting U.S. ranchers’ ability to obtain premiums or market share for homegrown beefamericanagnetwork.com. Joe Maxwell, co-founder of Farm Action, testified in 2025 that independent ranchers currently “cannot justify rebuilding their herds because the market does not reward U.S. origin”link.mediaoutreach.meltwater.com. Reinstating COOL is seen as a critical step to “level the playing field” for American cattle, hog, and poultry producers and to incentivize investment in rebuilding herds and processing capacityamericanagnetwork.com.

From an economic standpoint, mandatory labeling would give U.S. farmers and ranchers a tangible marketing advantage: the ability to differentiate their product as American-raised. Maxwell explained that COOL provides a “reliable, enforceable market signal that U.S.-raised beef will be recognized and rewarded” by consumers and the supply chainlink.mediaoutreach.meltwater.com. In practice, that means cattle and hog producers could finally capitalize on the majority of consumers preferring U.S. origin, rather than having domestic and foreign product blended with no transparency. Supporters argue this could translate into better prices or market share for U.S. meat. Indeed, economic analyses have noted that COOL, by increasing transparency, can improve competition in a highly concentrated meatpacking industry and potentially help correct the pricing power imbalances that often disadvantage producersiatp.orgiatp.org. In short, the policy is viewed as economically viable because it leverages a competitive strength of U.S. producers – origin – without fundamentally altering the product.

It’s also worth noting that mandatory COOL remains in effect for other covered commodities (lamb, chicken, goat, seafood, many fruits and vegetables), and those industries have continued to operate without issue under labeling rulesnationalaglawcenter.orgnationalaglawcenter.org. For example, COOL for chicken (added in the 2008 Farm Bill) is still in force, demonstrating that meat labeling can be implemented and enforced in the U.S. market. No significant disruption or cost-prohibitive burden has been reported in the poultry sector from complying with origin labels – likely because the U.S. imports very little poultry and the compliance simply involves affixing origin info on packageschoicesmagazine.orgchoicesmagazine.org. This experience bolsters the case that extending similar requirements back to beef and pork is feasible. Proponents contend that COOL’s benefits – giving domestic producers a fair shot and preserving local food supply capacity – outweigh the manageable costs (discussed below), especially in an era when the U.S. is increasingly concerned with food security. By reducing overreliance on imports and enabling consumers to choose American meat, COOL is presented as a strategy to strengthen the domestic supply chain and farm incomes without heavy government outlaysamericanagnetwork.com.

Trade Compatibility and Solutions to WTO Concerns

A major prior objection to COOL was the risk of violating trade agreements and provoking retaliation from trading partners. Canada and Mexico successfully challenged the U.S. COOL program at the WTO, leading to an arbitration authorization of about $1 billion in potential retaliatory tariffs in 2015everycrsreport.comeverycrsreport.com. Congress reacted by repealing beef and pork labeling to avoid these penaltieseverycrsreport.com. However, new strategies and evidence indicate that COOL can be re-crafted to be compatible with trade rules. Crucially, the WTO dispute findings did not strike down country-of-origin labeling per se – in fact, the WTO appellate body explicitly upheld the legitimacy of COOL’s objective (consumer information) and the U.S. “right to adopt labeling requirements” for that purposeeverycrsreport.com. The primary issue was that the implementation of U.S. COOL was deemed discriminatory in effect (imposing recordkeeping that disproportionately affected imported livestock, and exempting certain products and venues in ways that reduced consumer benefits)r-calfusa.comr-calfusa.com. Armed with this understanding, supporters have outlined how a revised COOL law could satisfy trade obligations: by eliminating loopholes and ensuring the same labeling standards apply evenly to domestic and imported meat.

One clear avenue is the United States–Mexico–Canada Agreement (USMCA) Joint Review in 2026. Farm Action and other groups point out that during this scheduled review of the trade agreement, the three countries “can agree to permit each country to adopt non-discriminatory origin-labeling requirements” for meatamericanagnetwork.com. In other words, Canada and Mexico could consent to a new COOL program as part of an updated understanding under USMCA, which would preempt any WTO conflict. Maxwell urged USTR to pursue exactly this: secure a trilateral agreement that expressly allows mandatory COOL, thereby removing the threat of trade cases or retaliationamericanagnetwork.comamericanagnetwork.com. Such an agreement would acknowledge each nation’s sovereignty to require origin labels for food, so long as the rules do not overtly favor domestic products over imports. Since Canadian and Mexican producers can also benefit from clearer origin labeling (e.g. Canadian beef could be recognized for export as such), a mutually agreeable COOL framework is plausible if negotiated in good faith. Early signals suggest this approach is on the table – by 2025, USTR had opened the issue for public comment, and farm organizations rallied thousands of supportive comments urging U.S. negotiators to restore COOL through the USMCA reviewamericanagnetwork.com.

Beyond the joint review, legal experts note that tweaking the legislation itself could cure the specific WTO violations. The WTO panel criticized aspects of the original rule – such as allowing commingled origin labels and exempting processed foods and food-service establishments – which meant a large share of meat (especially trim used in processed products or restaurant meals) didn’t require labelingr-calfusa.comr-calfusa.com. This undermined the consumer information benefits while still burdening supply chains for live imports. A 2020 R-CALF USA white paper (drawing on the WTO rulings) recommended closing those gaps: for example, covering processed meats and broadening COOL to all retailers, so that the policy’s benefits (informed consumers) more fully justify the costsr-calfusa.comr-calfusa.com. By maximizing the scope of labeled product and treating imported animals no differently than domestic at each step, a new COOL law could avoid the “less favorable treatment” finding. Also, improved labeling precision (such as the 2013 rule’s requirement to list each production step – born, raised, slaughtered) can ensure labels are accurate and not misleadingeverycrsreport.com. Canada’s and Mexico’s grievance was partly that their cattle were being segregated and devalued; a well-designed system could label meat with multiple countries of origin without mandating costly segregation beyond what’s necessary for truthful labelingeverycrsreport.comcongress.gov. In sum, the trade compatibility question is no longer a deal-breaker: research and policy analysis indicate that through either diplomatic agreement or careful statutory fixes, the U.S. can reinstate mandatory COOL for beef, pork, and poultry in a manner consistent with trade commitments. This would neutralize the retaliation risk that loomed over the original COOL, while still delivering the policy’s intended benefitsamericanagnetwork.comamericanagnetwork.com.

Cost Impacts: Initial Expenses vs. Long-Term Realities

Perhaps the most frequently cited concern about COOL has been the cost of compliance – critics argued that segregating herds, tracking records, and labeling products would impose hefty costs on industry and ultimately raise prices for consumers. However, evidence accumulated over the past two decades suggests that COOL’s costs are largely upfront and tend to moderate over time, and that earlier cost estimates were likely overstated. The U.S. Department of Agriculture’s own economic analyses acknowledged that many COOL expenses would be one-time adjustments (for systems, labels, and processes) rather than ongoing burdens. For instance, USDA’s 2009 regulatory impact analysis estimated a first-year implementation cost of $2.6 billion across all covered commodities (about $1.3 billion for beef, $300 million for pork, $183 million for chicken)agri-pulse.com. But these were static, initial figures. In practice, once COOL was in place, firms adapted and streamlined the process. A follow-up econometric study by agricultural economists (Tonsor, Schroeder, and Parcell) found that the actual cost incurred by cattle producers was far lower than originally projected – on the order of “no more than $1.00 per head,” compared to the USDA’s assumption of $9.00 per head in its pre-implementation analysisagri-pulse.com. This stark difference suggests that the industry found efficiencies and that some compliance activities (like document retention or tag reading) were already part of normal operations, thereby mitigating net new costs.

More broadly, USDA modeling anticipated that COOL costs would peak initially and then “dissipate over time” as the supply chain adjustsagri-pulse.comagri-pulse.com. Early implementation might involve investments such as software upgrades, revised inventory systems, employee training, and new label printing – but these are largely one-off expenses. Once the systems are in place and operating procedures normalized, the ongoing cost of maintaining country-of-origin records and labels is relatively minimalagri-pulse.com. The USDA’s analysis noted that not accounting for this adjustment dynamic would overestimate the true long-run costsagri-pulse.com. In other words, initial cost accounting exercises (and opponents’ worst-case scenarios) failed to consider that businesses innovate and absorb compliance measures efficiently after a transition period. Indeed, by the time COOL had been in effect for a few years (2009–2013), many retailers and meat processors were routinely labeling product without major issues, and some even reported the labeling systems were less costly than feared (partly because the law allowed flexible methods like bulk bin labeling or master shipping container labels to convey origin)agri-pulse.comagri-pulse.com.

Recent regulatory developments bolster the view that labeling costs are manageable and largely one-time. In 2023, USDA finalized a new voluntary “Product of USA” label rule (which, while voluntary, mirrors what a mandatory COOL might require: only U.S.-born, raised, slaughtered meat can be so labeled). As part of that rule’s economic analysis, USDA estimated the relabeling costs for industry. The average one-time cost to update a label was on the order of $874for a minor label change (coordinated with other planned label updates) and up to about $5,000 if a company had to do a standalone label changefederalregister.gov. These are modest amounts in the context of food product marketing. In fact, USDA calculated that for most small meat businesses, the total cost of complying with the new origin label rule would be about $1,500 per business (one-time), which is only 0.005%–0.01% of annual revenue on averagefederalregister.govfederalregister.gov. Such figures put in perspective the scale of COOL costs: they are a tiny fraction of operating costs for retailers and packers, and they do not meaningfully translate into higher prices for consumers in the long run. To the extent there are any price impacts, USDA had estimated retail meat prices might need to rise on the order of 1–2% to cover COOL, absent any increase in demandcongress.govchoicesmagazine.org. This is a very small price effect – and importantly, if consumers do preferentially buy origin-labeled U.S. meat, that demand shift could offset cost impacts by rewarding domestic supply. Some studies have suggested even a one-time demand increase of around 4% for labeled U.S. beef and pork would make producers as well off or better off than before COOLchoicesmagazine.orgchoicesmagazine.org. While the exact demand response is uncertain, the consistently high consumer approval for COOL indicates that Americans value the information, even if they are not always willing to pay a large premium for it in surveysers.usda.govers.usda.gov. At minimum, the cost of labeling itself is too small per unit to significantly burden consumers – one analysis noted a theoretical maximum of a couple of cents per pound in added costs, much of which would be borne in the supply chain, not at retail checkoutchoicesmagazine.orgchoicesmagazine.org.

In summary, the narrative that COOL is prohibitively expensive is not supported by post-2000 evidence. Rather, the evidence shows COOL incurs a manageable, mostly one-time implementation cost for segregating and tracking origin, after which normal market forces resume with little friction. The U.S. meat industry successfully implemented COOL from 2009–2015, and during that period retail beef and pork prices were influenced far more by supply/demand factors (and global feed costs) than by labeling. When COOL was removed in late 2015, consumer prices did not noticeably drop as a result – indicating that COOL’s cost had not been a significant add-on at the grocery store. Meanwhile, U.S. producers lost a tool that could differentiate their product. Reinstating COOL now, especially with modern traceability technology, would come at an even lower relative cost (thanks to electronic record-keeping, QR codes, etc.), and those costs are transitory. As one comprehensive USDA review concluded: “labeling costs associated with the COOL regulation would be higher initially and then decline over time”, so static cost estimates overstate the long-term burdenagri-pulse.comagri-pulse.com. This directly counters prior opponents’ claims that COOL would impose permanent, draconian expenses on the meat supply chain.

Addressing Prior Concerns: How New Evidence Counters Old Arguments

Revisiting the main objections that led to COOL’s 2015 repeal, we find that current research and developments effectively respond to each concern:

• Trade Retaliation: The risk of retaliation can be eliminated by securing agreement from trade partners. By using the USMCA joint review process, U.S. negotiators can obtain consent from Canada and Mexico for a COOL program, preempting any WTO disputeamericanagnetwork.com. This proactive approach turns a former flashpoint into a cooperative solution. Additionally, if COOL is designed to apply equally to domestic and imported meat (a non-discriminatory rule), it would comply with WTO principles – Canada and Mexico have indicated their main issue was differential treatment, not the labeling itselfr-calfusa.comr-calfusa.com. Thus, prior trade concerns are being met with a plan for a WTO-compatible COOL, endorsed through diplomacy and better legislation rather than imposed unilaterally.

• WTO Legality: As noted, WTO panels took issue with how the U.S. implemented COOL, but even at the height of the dispute, the WTO upheld countries’ right to pursue origin labeling for legitimate objectiveseverycrsreport.com. Learning from that, supporters have tightened the legal rationale. The new COOL proposals emphasize truthful labels and full coverage (so consumers truly benefit), which strengthens the case that the measure is necessary and justified. In fact, other countries (like those in the EU) successfully require origin labels on meats in a WTO-consistent manner by applying the rules evenly. The U.S. can do the same, especially now that it has the WTO guidance on what pitfalls to avoid. In short, the legal pathway exists to reinstate COOL without violating trade rules, addressing the core of previous international objections.

• Compliance Costs to Industry: Current data show that compliance costs are much lower and more short-livedthan opponents warned. Initial estimates of billions in costs did not account for adaptation over timeagri-pulse.com. Now we know that after the one-time investment in labeling systems, the ongoing costs dissipate to a negligible level – on the order of fractions of a percent of revenuesfederalregister.govfederalregister.gov. This undercuts the argument that COOL would permanently saddle ranchers, packers, or retailers with untenable expenses. Moreover, the cost burden is shared across the supply chain. For example, ranchers can provide affidavits of animal origin with minimal effort (many already maintain birth records for other programs), and packers simply keep those identities through processingagri-pulse.comagri-pulse.com. Modern logistics and IT make such tracking routine (many companies already track lots for food safety traceability). Thus, evidence from implementation and modeling shows COOL’s cost impact is not only modest but also largely a one-time adjustment, countering the doomsday cost scenario presented by early critics.

• Consumer Prices and Benefits: Opponents claimed consumers wouldn’t benefit from COOL (or wouldn’t care), yet the near-90% public support suggests consumers strongly value the informationconsumerfed.org. While it’s true that simply wanting a label doesn’t equal paying more, consumer advocacy groups have documented cases where origin labeling matters for informed choice (e.g. during animal disease outbreaks or food safety incidents, consumers may prefer domestic sources). The benefit of COOL is giving consumers agency and assurance, which, while hard to quantify, is a real public good. Even the WTO panel acknowledged COOL’s legitimate consumer information goal. So prior arguments that “no one uses the labels” or that “COOL has no benefit” ring hollow against consistent polling data and the vocal support of consumer organizations. On the contrary, many Americans were displeased when COOL was repealed – a 2016 survey found a large majority wanted it reinstated for meat. In economic terms, even if the average shopper isn’t paying a premium, COOL allows market segmentation: consumers who do prefer USA-labeled meat can seek it out, potentially rewarding those producers, while others experience essentially no harm. The cost-benefit balance, when considering intangibles like consumer confidence and national origin pride, has tilted in favor of COOL as a reasonable policy.

In essence, each of the historical concerns (trade, cost, consumer impact) has been met with solid evidence or strategies that mitigate the issue:

• Trade concerns -> Solution: negotiate and design COOL for mutual acceptance and non-discriminationamericanagnetwork.com.

• Cost concerns -> Evidence: costs are short-term and minor relative to industry sizeagri-pulse.comfederalregister.gov.

• Dubious benefits -> Evidence: consumers overwhelmingly want labelsconsumerfed.org, and producers see it as crucial for fair competitionlink.mediaoutreach.meltwater.com.

Conclusion

All available evidence since 2000 supports the notion that reinstating mandatory COOL for beef, pork, and chicken is feasible and beneficial. Factual analyses and real-world data show that COOL can be done in a WTO-compliant way that preserves its value to consumers, with initial implementation costs that are largely one-off and then fadeagri-pulse.comagri-pulse.com. Consumer demand for origin labeling is clear and persistent, providing a strong mandate for the policyconsumerfed.org. Perhaps most importantly, COOL offers a way to strengthen U.S. agriculture by empowering domestic farmers and ranchers to differentiate their products in the marketplace, thereby promoting competition and potentially enhancing the resilience of the U.S. food supplyamericanagnetwork.com. The key arguments in favor of COOL directly counter the concerns that led to its repeal: new trade accommodations would avoid retaliation, and extensive research shows the cost impacts are much smaller and shorter-lived than once feared. As Farm Action’s testimony put it, “MCOOL is not optional – it is essential” for fairness and food securityamericanagnetwork.com. Given the convergence of consumer interests, producer needs, and workable policy design, the case for reimplementing COOL rests on a solid foundation of evidence and experience, not mere ideology or advocacy. All signs point to COOL being an economically sound and publicly supported policy whose time has come again, armed with lessons learned to ensure it works for all stakeholders.

Sources: Recent USTR hearing testimony and comments; Congressional Research Service reports; USDA regulatory analyses; Consumer Federation of America survey; academic economic studies on COOL impactslink.mediaoutreach.meltwater.comamericanagnetwork.comconsumerfed.orgagri-pulse.com, among others. These factual sources demonstrate the viability of COOL when properly implemented and lay out a roadmap for addressing past issues. The growing body of evidence strongly supports moving forward with mandatory country-of-origin labeling for meat in the United States.