Country of Origin Labeling (COOL) in U.S. Beef: Law, Loopholes, and the New Rule
Country of Origin Labeling (COOL) has long been a contentious issue in the U.S. beef industry. While consumers routinely see meat packages labeled with “Product of USA,” this phrase has historically included foreign-born cattle that were simply processed in the U.S.
Despite pressure from ranchers and consumer advocates, Congress has not restored mandatory COOL since the 2015 WTO ruling. Even Senator Jon Tester’s popular bills on mandatory COOL have never received a vote in committee.
Meanwhile, the Biden administration finalized a major rule change in 2024: under 9 CFR 412, starting January 1, 2026, the label “Product of USA” can only be used if the animal was born, raised, slaughtered, and processed in the United States.
This rule is voluntary, but it aims to eliminate misleading origin claims and give domestic producers more recognition. The rule was finalized by USDA’s FSIS, not Congress—marking an administrative win, not a legislative one.
Large meatpackers have expressed concern about supply chain disruption, while smaller producers and consumer groups largely support the move. Whether this rule survives litigation remains to be seen, but it is currently in effect and being implemented.
The rule does not apply to restaurants, and enforcement will rely heavily on documentation in vertically integrated systems. It’s a step toward meaningful COOL, but still short of the mandatory, government-enforced standard ranchers sought post-2015.
