FAT scores every label using the same three-step analysis: What is disclosed? How credible is the disclosure? Who stands behind the label? This page walks the three steps for country-of-origin claims on U.S. meat.

1 — What this label tells you (and doesn’t)

When shoppers see Product of USA, Raised in the USA, or American beef, most assume the animal was born, raised, and slaughtered in the United States. That assumption feels intuitive — but until 2026 it has often been incorrect.

Country-of-origin claims on U.S. meat are mostly voluntary marketing claims, not mandatory disclosures. Until December 31, 2025, meat could be labeled Product of USA if it was simply processed in the United States, even if the animal was born and raised abroad. Mandatory Country-of-Origin Labeling (often called COOL) for beef was repealed in 2015 for muscle cuts and ground beef following a WTO ruling.

The 2024 rule. Under a 2024 USDA FSIS rule (9 CFR 412), starting January 1, 2026, the voluntary Product of USA claim may be used only if the animal was born, raised, slaughtered, and processed in the United States. The rule is voluntary — producers are not required to make a country claim — but those who do must meet the new four-step standard. Mandatory COOL for muscle cuts and ground beef remains repealed; bipartisan H.R. 5818 / S.421 mCOOL bills are now moving in the 119th Congress to restore it.

2 — How credible is the disclosure?

FAT assigns tiered, partial credit to country-of-origin claims based on what they actually verify.

Tier A — Full credit. Claims that disclose where the animal was born, raised, slaughtered, and processed, supported by third-party documentation or by participation in a formal verification program with audited records. Under the 2024 rule, Product of USA claims meeting the four-step standard fall here.

Tier B — Partial credit. Claims supported by USDA-reviewed label language and producer affidavits, but without independent third-party audit. Pre-2026 Product of USA claims fall here when the producer can document U.S. processing but not the full life history of the animal.

Tier C — Minimal or no credit. Claims that rely on marketing language (American beef, USA proud) without documentation, or claims that disclose only processing location while the animal was raised abroad. After January 1, 2026, Product of USA cannot be used for these without violating the new rule — but other country-suggesting language remains permissible if not misleading.

3 — Who stands behind the label?

A country-of-origin claim is only as credible as the entity that makes it. FAT surfaces three layers of accountability for every meat package.

The processor. Every USDA-inspected meat package carries an FSIS establishment number (EST. ####). FAT links that number to the processor’s public enforcement record — recalls, humane-handling violations, residue findings, and FSIS enforcement actions. A country claim on a package whose processor has an active enforcement issue carries less weight.

The brand and the corporate parent. The brand on the front of the package is often not the processor and often not the ultimate corporate parent. FAT traces beneficial ownership where it exists — including foreign ownership (for example, Smithfield is owned by China’s WH Group). For country-of-origin claims, foreign ownership is a relevant disclosure even when the animal itself is domestically raised, because the entity making the claim is foreign-controlled.

The voluntary disclosure choice itself. Two companies sourcing identical product can make opposite voluntary disclosure choices. FAT documented one such case: Verde Farms — sold through Target, Harris Teeter, Albertsons, and BJ’s, and self-described as the largest U.S. supplier of USDA Certified Organic grass-fed beef — does not disclose Uruguayan origin at retail, while Whole Foods (Amazon), drawing on the same Uruguayan organic supply, does disclose origin. Same regulatory regime, same seal, same source country, opposite voluntary disclosure choices. The who behind the label matters as much as the what.

For the full research treatment — including the WTO ruling history, the 2024 rule text, the bipartisan mCOOL legislation now in the 119th Congress, and the Verde Farms / Whole Foods natural experiment in detail — see Country of Origin Labeling (COOL) in U.S. Beef: Law, Loopholes, and the New Rule.