Country of Origin Labeling (COOL)

Country of Origin Labeling (COOL) is now required for many foods found in your local grocery store. COOL gives consumers information about the origin of their foods. Food operations such as restaurants, cafeterias, food stands, butcher shops and fish markets do not have to label their foods. Grocery stores that sell less than $230,000 a year also do not need to provide this labeling.

The following foods must be labeled by the COOL regulation if they were produced after September 30, 2008:

  • Muscle cuts of beef, pork, lamb, goat and chicken
  • Ground beef, pork, lamb, goat and chicken
  • Wild and farm-raised fish and shellfish
  • Fresh and frozen fruits and vegetables
  • Peanuts, pecans and macadamia nuts
  • Gingseng

Foods that are covered by COOL do not have to be labeled if they have been processed, that is undergone a physical or chemical change, such as by cooking, curing or smoking. Here are some examples of foods that are covered by the COOL regulations and those that are not:

  • A package of raw chicken legs is covered. Breaded chicken fingers are not. (Breading is a process.)
  • Farm-raised salmon is covered. Smoked salmon is not. (Hot or cold smoking makes them processed.)
  • Frozen peas are covered. Canned peas are not. (Canned peas are cooked during the canning process.)
  • Fresh strawberries are covered. Dried strawberries are not. (Drying is a process.)
  • Raw peanuts are covered. Roasted peanuts are not. (Roasting is a process.)

Foods that are mixed together are not covered by the COOL regulation. For example, a frozen peas and carrots medley would not be covered by COOL. However, anything pre-packaged overseas will be marked as an import under the Tariff Act of 1930 even if it is not covered by COOL. So, if the peas and carrots medley are packaged overseas they will be labeled as imported, but if they come to the U.S. in bulk and then are combined and packaged here, they will not be labeled as imported. Other foods covered under the Tariff Act that must be labeled with country of origin information even though they are processed include roasted peanuts, pecans and macadamia nuts, imported salmon that is smoked in the U.S. and imported shrimp that is cooked in the U.S.

Meat Labeling

You might notice that some meats are labeled with two or more countries of origin. The reason for this is that only meat from animals that have been born, raised and slaughtered in the U.S. may be labeled as a “Product of the U.S.” If the meat is from animals born in another country and raised and slaughtered in the U.S. or imported into the U.S. for immediate slaughter, both countries will be listed. The country where the animal was raised is listed first. Animals and food products imported into the U.S. must meet the same requirements for safety as those produced in the U.S.

Labeling Fish & Shellfish

Fish and shellfish must state whether it is wild or farm-raised in addition to the country of origin.

Product of the U.S.: Farm-raised fish and shellfish that are hatched, raised, harvested, and processed in the U.S., or wild fish and shellfish harvested in waters of the U.S. and processed in the U.S.

Product of Country X: Imported fish and shellfish that have not undergone substantial transformation in the U.S.

Product of Country X, Processed in the U.S.: Imported fish and shellfish that have undergone substantial transformation in the U.S.

Originally published 04/09

If this document didn’t answer your questions, please contact HGIC at or 1-888-656-9988.

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