COUNTRY OF ORIGIN RESEARCH SERIES | RESEARCH PAPER
The Case Against Mandatory COOL: What the Economic Studies Found
Producer prices, consumer demand and trade costs under the 2009–2015 program for beef and pork.
Prepared for publication by Farm Animal Transparency | First published December 2025; revised October 2026
The main USDA-commissioned study found no measurable increase in demand for COOL-labeled beef or pork, and estimated that the program cost both industries more than it returned.
| At a glance |
|---|
| No demand lift found: the May 2015 Tonsor, Schroeder and Parcell study for USDA found no evidence COOL increased demand for beef or pork. |
| Estimated losses: about $8.07 billion for beef producers and $1.31 billion for pork producers over ten years under the 2009 rule; a $753 million gain for chicken producers. |
| Imports discounted: COOL widened the discount on Canadian fed cattle (Pouliot and Sumner, 2014). |
| Trade cost: the WTO authorized about C$1.05 billion and US$228 million a year in retaliation before Congress repealed beef and pork COOL in December 2015. |
Abstract
Mandatory country of origin labeling (MCOOL) applied to beef and pork at retail from 2009 until Congress repealed it in December 2015. This paper summarizes the economic research on what the program did to producers, consumers and trade. It is the “against” side of a pair; its companion, The Case for Mandatory COOL, sets out the arguments for restoring it. The finding most relevant to ranchers is that the main USDA-commissioned study found no measurable increase in demand for labeled beef or pork, and therefore estimated net losses for both industries.
1. Before implementation: what demand increase was needed?
Lusk and Anderson (2004), in the peer-reviewed Journal of Agricultural and Resource Economics, modeled COOL before it took effect. They concluded that an increase in aggregate consumer demand of about 2% to 3% would likely be enough to offset producer losses, but that beef could need about 7.5% if compliance costs were large and fell mainly on producers. Whether labeling would produce that demand increase was the central uncertainty.
2. After implementation: the 2015 USDA-commissioned study
The 2014 farm bill required USDA to report to Congress on the economic effects of COOL. Glynn Tonsor and Ted Schroeder of Kansas State University and Joe Parcell of the University of Missouri prepared the core study, dated May 2015, for USDA’s Office of the Chief Economist. Its main findings:
- It found no evidence that consumer demand for beef or pork increased because of COOL.
- To break even, retail demand for covered beef would have needed to rise at least 6.8%, and for covered pork at least 5.6%, under the 2009 rule.
- Only about one-third of beef and about 16% of pork was sold in forms that required a COOL label; restaurants and processed products were exempt.
| Ten-year change in economic welfare, 2009 rule | Estimate |
|---|---|
| Beef producers | −$8.07 billion |
| Pork producers | −$1.31 billion |
| Chicken producers | +$753 million |
| Beef consumers | −$5.98 billion |
| Pork consumers | −$1.79 billion |
The 2013 revision, which required labels naming each production step, added further estimated losses of $494 million for beef producers and $403 million for pork producers, and a further $67 million gain for chicken producers. The chicken gain came from shoppers shifting toward chicken as beef and pork costs rose, not from any premium for labeled chicken. These are model estimates, not observed accounts, and R-CALF USA and other supporters disputed the study’s assumptions; USDA defended its approach in a July 2015 response.
3. Effects on imported cattle
Pouliot and Sumner (Food Policy, 2014) found that COOL widened the price discount on Canadian fed cattle by about C$3.30 to C$8.22 per hundredweight, from a pre-COOL gap of roughly C$9.90, and reduced Canadian fed-cattle imports as a share of U.S. slaughter by about 0.5 to 1.0 percentage points (from about 3%). That pattern is what the WTO relied on in finding that the program treated imported livestock less favorably. A self-released 2015 analysis by C. Robert Taylor of Auburn University reached the opposite conclusion, attributing the import decline to market conditions; it has not been peer reviewed.
A wider discount on imported cattle could in principle help U.S. cattle prices, but no peer-reviewed study located by FAT found a sustained price gain for U.S. cattle or hogs attributable to COOL. Cattle prices in 2009–2016 were driven mainly by the cattle cycle, drought and feed costs.
4. Trade costs
The program’s most concrete cost was the trade dispute. In December 2015 WTO arbitrators authorized retaliation of about C$1.05 billion a year for Canada and about US$228 million for Mexico. Congress repealed beef and pork COOL on December 18, 2015, before retaliation was imposed.
5. What the evidence does and does not show
| Finding | Strength |
|---|---|
| No measurable increase in demand for COOL-labeled beef or pork | Strong (USDA-commissioned study; consistent with earlier modeling) |
| Net producer losses for beef and pork | Moderate; model-based and disputed by supporters |
| Wider discounts on Canadian cattle and fewer imports | Moderate; peer-reviewed, but one contrary non-peer-reviewed study |
| Trade retaliation risk | Strong; authorized by the WTO in 2015 |
| Origin information has no value to consumers | Not shown; the studies measured purchases, not the value of information |
The research shows that the 2009–2015 program did not pay ranchers. It does not show that consumers place no value on origin information, and it does not test a program designed the way current proposals describe.
What this means for FAT’s 16 categories and the FAT App
FAT treats origin as consumer information, which is a separate question from whether a mandate raises producer prices. 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: weigh the 2015 study’s cost estimates and the WTO record before reinstating a mandate, and fund an independent post-implementation review if one passes.
- Ranchers: do not count on a mandate alone to raise calf prices; premiums for origin have come from programs that contract for it.
- FAT readers: read this paper with its companion; neither side’s strongest claim stands on its own.
Sources
- Lusk & Anderson, “Effects of Country of Origin Labeling on Meat Producers and Consumers,” Journal of Agricultural and Resource Economics 29(2), 2004 — peer-reviewed.
- Tonsor, Schroeder & Parcell, “Economic Impacts of 2009 and 2013 U.S. Country-of-Origin Labeling Rules on U.S. Beef and Pork Industries” (May 2015) — university study prepared for USDA’s Office of the Chief Economist report to Congress.
- University of Illinois Extension, “COOL report shows producer, consumer losses” (May 12, 2015) — extension summary.
- USDA response to R-CALF USA on the COOL economic analysis (July 2015) — agency letter.
- Pouliot & Sumner, “Differential impacts of country of origin labeling: COOL econometric evidence from cattle markets,” working paper; published in Food Policy 49 (2014) — peer-reviewed (working-paper version linked).
- 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.
- 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)
- Consolidated Appropriations Act, 2016, Pub. L. 114-113, Div. A §759 (repeal of beef and pork MCOOL, Dec. 18, 2015)
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 for 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 That Does Not Support COOL”. Figures are as of the dates shown in the sources. Corrections welcome: dirkadams@farmanimaltransparency.com.