COUNTRY OF ORIGIN RESEARCH SERIES | RESEARCH PAPER
The Case for Mandatory COOL: What Supporters Cite and How Strong It Is
Consumer demand, trade law, the post-2015 market, and costs — with each claim graded against the evidence.
Prepared for publication by Farm Animal Transparency | First published December 2025; revised October 2026
The strongest case for restoring mandatory origin labels on beef and pork rests on consumer information and a trade-compliant design. The claim that labels would raise ranchers’ prices is the weakest part of it.
| At a glance |
|---|
| Scope: beef and pork. Mandatory COOL for chicken was never repealed and still applies at retail. |
| Consumer support: 89% favored mandatory origin labels on fresh meat in a 2017 advocacy-commissioned poll. |
| Trade: the WTO accepted origin information as a legitimate goal; it faulted how the U.S. program treated imported livestock. |
| Market: beef imports reached about 5.39 billion pounds in 2025 (carcass weight); beef cows numbered 27.6 million on January 1, 2026. |
| Weakest link: no peer-reviewed study found that the 2009–2015 program raised U.S. cattle or hog prices. |
Abstract
This paper sets out the strongest evidence-based case for restoring mandatory country of origin labeling (MCOOL) for beef and pork, the two meats Congress removed from COOL in December 2015. (Chicken was never removed; it is still covered.) It is written as the “for” side of a pair. Its companion, The Case Against Mandatory COOL, presents the economic studies that found producers lost money under the old program. Read together, the two papers show where the evidence is solid and where it is contested.
1. Consumers say they want it
A July 2017 poll by ORC International for the Consumer Federation of America (1,000 adults, ±3 points) found 89% of respondents favored requiring retailers to label the country of origin of fresh meat, and 88% favored labels showing where animals were born, raised and processed. The poll was commissioned by an advocacy group, but its result is consistent with other surveys over the past two decades. Stated support is not the same as willingness to pay, a point the companion paper takes up.
2. Trade law does not forbid origin labeling
The WTO did not rule that origin labeling is illegal. In the Canada and Mexico disputes (DS384 and DS386), the WTO accepted that giving consumers origin information is a legitimate objective. What it found was that the U.S. program, as designed, treated imported livestock less favorably in practice: the recordkeeping and segregation burden fell on imported animals, while exemptions for restaurants and processed foods meant much of that information never reached consumers. Supporters argue that a redesigned program, with broader coverage and the same requirements for domestic and imported animals at every step, could address those findings. That remains an argument; no redesigned program has yet been tested at the WTO.
A second path is negotiation. Some advocates urged that the 2026 USMCA joint review be used to obtain Canadian and Mexican agreement to non-discriminatory origin labeling. At the July 2026 review the United States declined to extend the agreement, moving the three countries to annual reviews; FAT found no public text on origin labeling from it.
3. The market has changed since 2015
- Imports are at a record. U.S. beef and veal imports were 4.64 billion pounds in 2024 and about 5.39 billion pounds in 2025 (carcass-weight equivalent), with USDA forecasting about 6.1 billion pounds for 2026.
- The herd is small. USDA’s January 1, 2026 Cattle report counted 27.6 million beef cows, down 1% and the seventh straight annual decline.
- More imported lean goes into ground beef. Oklahoma State University economist Derrell Peel estimates imported trimmings were 38.7% of all trim used for U.S. ground beef in 2025, against a 20-year average of about 25%.
Supporters argue that when imports are high and cow numbers low, a reliable way for shoppers to identify U.S. beef matters more, and that ranchers deciding whether to rebuild herds need a market signal that rewards U.S. origin. These figures describe the market; they do not by themselves show that MCOOL would change prices.
4. Some cost estimates were high and front-loaded
USDA’s 2009 final rule estimated first-year incremental costs of about $2.6 billion across all covered commodities, falling to about $212 million in annual costs to the economy (higher prices and lower production) by the tenth year. Supporters read this as evidence that most costs are one-time adjustments. Other evidence cuts both ways:
- Lusk and Anderson (2004) estimated that an increase in aggregate consumer demand of about 2% to 3% would likely offset producer losses, though beef could need more if costs fall mainly on producers.
- C. Robert Taylor of Auburn University (January 2015, self-released, partly supported by the United States Cattlemen’s Association) found that COOL played no role in the decline in Canadian and Mexican cattle imports and did not harm prices for imported slaughter cattle. The study has not been peer reviewed, and it is contradicted by Pouliot and Sumner (2014), discussed in the companion paper.
- The 2024 “Product of USA” rule now requires the same born-raised-slaughtered-processed records for any company using the claim, so part of the record system MCOOL would need already exists for those firms.
5. Chicken shows labeling can run alongside a large market
Mandatory COOL for chicken, added in the 2008 farm bill, has stayed in force since 2009 without the WTO challenge that ended beef and pork labeling. This is a fair point but a limited one: the U.S. imports very little chicken, so compliance is mostly a matter of stating “Product of USA” on product that was all domestic anyway.
6. Where the policy stands (October 2026)
- The American Beef Labeling Act of 2025 (S.421) would direct USDA and USTR to design a WTO-compliant mandatory label for beef (not pork).
- On August 6, 2026 the Senate Agriculture Committee added beef-labeling language to its farm bill; on September 16 it advanced the farm bill with that language included. FAT has not located a full Senate vote.
- Executive Order 14425 (September 4, 2026) gave USDA 90 days to review its authority for mandatory beef origin labeling.
7. How strong is the case?
| Claim | Evidence quality |
|---|---|
| Consumers support origin labels | Strong and consistent in surveys; stated support only |
| Origin labeling can be WTO-compatible | Plausible; the WTO accepted the objective, but no redesigned program has been tested |
| Costs were overstated and mostly one-time | Mixed; USDA projected declining costs, but the 2015 USDA-commissioned study found net producer losses |
| MCOOL would raise U.S. cattle or hog prices | Weak; no peer-reviewed study found a sustained price gain from the 2009–2015 program |
What this means for FAT’s 16 categories and the FAT App
FAT’s position does not depend on how this policy debate ends: origin is one of the 16 facts a label should disclose, mandatory or not. 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
- Lawmakers: design any new program so imported and domestic animals face identical requirements, and cover processed and food-service beef if the goal is information that reaches consumers.
- Supporters: rest the case on consumer information and verifiable design, not on price promises the 2009–2015 record does not support.
- Researchers: study how the 2026 voluntary rule is used in practice; it is the first U.S. test of a born-raised-slaughtered standard since 2015.
Sources
- Consumer Federation of America, poll release (July 24, 2017; ORC International, n=1,000) — advocacy-commissioned survey.
- Congressional Research Service, RS22955, “Country-of-Origin Labeling for Foods and the WTO Trade Dispute on Meat Labeling” (2016 update) — CRS report.
- WTO, DS384, United States — Certain Country of Origin Labelling (COOL) Requirements
- White & Case, “USMCA 2026 Joint Review: United States declines to extend Agreement” (July 2, 2026) — law-firm analysis.
- USDA ERS, Livestock, Dairy, and Poultry Outlook LDP-M-386 (Aug. 18, 2026) — agency outlook; beef imports in carcass-weight equivalent.
- DTN, report on USDA NASS January 1, 2026 Cattle inventory (Jan. 30, 2026) — trade press.
- Derrell Peel, Oklahoma State University Extension, “The Hamburger Story” (Apr. 27, 2026) — extension analysis.
- GAO-09-333R, review of USDA’s 2009 COOL final rule — GAO report.
- Lusk & Anderson, “Effects of Country of Origin Labeling on Meat Producers and Consumers,” Journal of Agricultural and Resource Economics 29(2), 2004 — peer-reviewed.
- Agri-Pulse, “Study finds COOL had no role in drop in imports of Canadian cattle” (Jan. 2015), on C. Robert Taylor’s Auburn analysis — trade press on a self-released, non-peer-reviewed study.
- USDA AMS, Country of Origin Labeling (COOL) — covered commodities — agency page.
- 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)
More in the Country of Origin Research Series
- Country of Origin Labeling (COOL): Where It Stands in 2026 — start here
- Product of USA: Regulatory Meaning and Trade History
- What “American” Means on a Ground Beef Label
- 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 the December 2025 paper “Evidence Supporting Reinstatement of COOL for U.S. Beef, Pork, and Chicken”. Figures are as of the dates shown in the sources. Corrections welcome: dirkadams@farmanimaltransparency.com.