AMS

Module 3

Retail Review Procedures for All 

Reviews
Lesson Objectives

At the end of the lesson, you will be able to: 

• Prepare for a retail review. 

• Conduct an opening meeting.

• Conduct the retail review.

• Conduct a closing meeting.

• Enter the review results into the CRM system.

• Understand the retail reviews timeline.

2
Retail Reviews

• Retail reviews assess a retailer’s compliance with the USDA 

COOL regulations.

• USDA determines which stores will be reviewed. State and 

Federal personnel conduct reviews on behalf of USDA.

• There are two types of reviews: Initial Reviews and FollowUp Reviews. 

3
Retail Review File Name

• Each review has a unique file name that is assigned by USDA. 

• The file name includes 4 segments. File name CA22N2633:

• CA – Identifies the state where the retailer is located. 

• 22 – Identifies the review cycle year. 

• N – Identifies the type of review: “N” indicates an initial review 

and “F” indicates a follow-up review.

• 2633 – This is a unique identifier assigned by the BE-COOL CRM 

system. 

4
Retail Review Updates for 2022

• Provide the retailer the COOL Retailer Fact Sheet instead of the 

Information Form. 

• States will not be reimbursed for closed stores, instead closed stores 

must be replaced with another location to review.

• Results of retail reviews are not final until reviewed by USDA and USDA 

will send results via email to the retailer. You must collect their email 

address and let them know this. 

• If a retailer states they are not subject to a PACA license, still complete 

the review and include a note within the review in CRM. USDA will 

investigate it once the review is submitted to USDA.

5
Requirement for All Managers 

and Reviewers 

• Reviewers must be “COOL-Certified” before doing reviews. 

This involves completing the training (ideally live) and 

passing the exam in ProProfs. 

• Reviewers and Managers must score 85% or higher on the 

exam to be “COOL-Certified”.

• Additionally, Managers who are assigned follow-up reviews, 

and Reviewers conducting follow-up reviews, must take the 

follow-up training and pass the follow-up review exam. 6
Review Quick Tips

• Ensure the store is open. 

• Know what type of review you will be conducting (initial or 

a follow-up). 

• Bring your business card and the Retailer Fact Sheet with 

you to hand out to the representative. 

• Keep USDA’s phone number handy in case you run into any 

issues that your Manager cannot resolve. 202-720-4486.

7
Opening Meeting for All Reviews

• Upon arrival, go to the customer 

service desk and introduce yourself. 

• Offer your business card and briefly 

explain why you’re there – to conduct 

a COOL retail review.

• Ask to speak with the store manager 

or person in charge, then introduce 

yourself to them and offer the COOL 

Retailer Fact Sheet.

8
Opening Meeting for All Reviews 

(cont.)

• Let the store manager or representative know you are there to 

conduct a COOL retail review and what they can expect.

• Confirm the store’s name, address, and phone number. Obtain 

the representative’s name, and the responsible authority’s name, 

title and email address – this is who will receive the final report. 

• Inform the representative that there will be a closing meeting. 

This includes asking questions about recordkeeping procedures 

(Initial Review) or requesting records (Follow-Up Review). 

• Invite them to join you on the review and encourage them to ask 

questions. 9
Inputting Store Details in CRM 

• Section 1: Store Details

• Information collected during 

the opening meeting, such as 

the store representative’s 

name, the responsible 

authority’s name, position 

and email address, are 

entered here. 

• If the store’s actual address / 

phone number is different 

than shown in CRM, please go 

to Edit Store Account Details.

10
Editing Account Details in CRM 

• You may edit store 

details here. 

• Please remember to 

press Save Account 

Changes. 

• Ensure you obtain the 

email address. Official 

results will be provided 

from USDA via email.

11
• After the opening meeting, begin the review:

• Count the number of covered commodities in each of the 6 commodity 

categories.

• Review all covered commodities for labeling compliance. If a section of the 

store is temporarily closed off, return to that section towards the end of the 

review. If that section of the store still cannot be reviewed, note in the BECOOL CRM system. 

• Record all noncompliant items and the noncompliance code(s) in the correct 

commodity category in the CRM system. Be sure to include appropriate 

details. 

• Answer questions from store personnel regarding COOL.

Review of Covered Commodities

12
Review of Covered Commodities (cont.)

Review all sections of the retail store to evaluate 

all COOL covered commodities for labeling compliance, including: 

• Produce department; 

• Baking aisle;

• Meat department;

• Seafood department; 

• Full-service counters; 

• Grab and Go areas by registers; and

• Sale counters and promotional displays. 13
Counting Covered Commodities

• Count the total number of items reviewed for each of the 6 covered 

commodity categories: 

1. Fruits (fresh and frozen);

2. Vegetables (fresh and frozen);

3. Chicken (muscle cut and ground); 

4. Lamb, and Goat meat (muscle cut and ground);

5. Fish and Shellfish (fresh and frozen);

6. Peanuts, Pecans, and Macadamia Nuts, and Ginseng.

• Write the totals for each commodity category in the appropriate section of 

the BE-COOL CRM system for “Number of Items Reviewed.” 14
Counting Covered Commodities 

(cont.)

• Generally, a stock keeping unit (SKU) is counted as one item.

• An organic 6 oz. bag of carrots and a conventional 6 oz. bag of 

carrots have different SKUs therefore are counted as 2 

commodities.

• Bananas in the produce section and bananas by the cash register 

that have the same SKU are counted as 1 commodity.

• Do not count the individual number of each item. A bulk bin that has 

30 oranges counts as 1 covered commodity for the fruit section, and 

not 30 commodities.

15
Knowledge Check
Knowledge Check (cont)

You review Gala, Fuji, Granny Smith, Red Delicious and 

Honeycrisp apples. How many covered commodities have 

you reviewed?

17
Knowledge Check (cont.)

Answer: You have reviewed 5 items. This would go towards your 

total count for the fruit category.

18
Conducting Retail Reviews

• Document noncompliant items. Noncompliance codes will 

be discussed in Module 4. 

• Include the exact item name (brand, weight, size, organic).

• List the appropriate noncompliance code(s).

• Include notes in the BE-COOL CRM system to indicate the 

issue observed. For example: Store sign says USA, PLU 

sticker says Canada. 

• NC 1 and NC 6 do not need notes included. 

19
Common Mistakes

• Citing incorrect noncompliance code.

• Incomplete or incorrect information in the noncompliance notes 

area. This should fully identify the commodity. 

• Listing a noncompliant item in the wrong commodity section. For 

example, a fruit noncompliant item should be in the fruit section. 

• “24 additional items” - is not acceptable. 

•All noncompliant items must be individually identified with the 

corresponding noncompliance code. This is key from an 

evidentiary standpoint.

20
Inputting NC Items in CRM 

1. If the commodity category is 

not present in store, check “Not 

Sold in Store.” 

2. Enter the Number of Items 

Reviewed.

3. If noncompliant items are 

observed, input the item name, 

select the noncompliant (NC) 

code(s), and include notes. 

4. Check “Mark As Complete?” 

once that section is completed. 

21
Example of a Complete Workbook

Please be as specific as possible when listing out commodities. 

• Example: 6 oz organic carrots instead of just “carrots”. 

• Example: Russet Potatoes, bulk. 

22
Closing Meeting

• For an Initial Review, ask the 5 recordkeeping questions of the store 

representative if this wasn’t already done during the opening meeting. 

For a Follow-Up Review, request records. 

• Discuss findings of the review with the representative and provide the 

unofficial copy of the review. Inform the representative that the 

“Results are not final until reviewed by USDA”. 

• Verify the retailer’s email address. Inform them that USDA will provide 

the official results and communicate with them via email. 

• Answer any additional questions and thank them for their time and 

assistance.

23
Initial Retail Review
Initial Retail Review

When conducting an initial retail review, the reviewer will: 

• Count and review all covered commodities sold at the retail 

location.

• Record noncompliant items and the appropriate 

noncompliance code(s) 1-9 in the BE-COOL CRM system. 

• Ask the responsible authority the 5 interview questions. 

• Enter the responsible authority’s response for each of the 

5 questions. Be as accurate as possible. 

25
Initial Retail Review: 5 Interview 

Questions

Ask the 5 interview questions during either the opening or closing meeting.

1. What types of records used in the normal course of business are 

received from suppliers that you rely on to create your own labels, such 

as signs, placards, and scale printers? 

2. Where are records maintained? 

3. How long are records maintained? 

4. As the responsible store authority, please briefly explain your 

knowledge of COOL requirements and your systems to ensure 

compliance. 

5. Would you be interested in receiving additional outreach materials and 

guidance from FDLD to assist your staff and consumers? 26
After the Review: Submit to USDA

• Input your findings and completely fill out the information in the BECOOL CRM system.

• Submit the review to your State or Federal Manager for review.

• State and Federal Managers must check the review in CRM and have the 

reviewer correct any errors. Once the review is accurate and complete, 

the Manager submits the review in CRM to USDA. 

• USDA will evaluate reviews and return to the Manager if need be. Reviews 

are not eligible for reimbursement until USDA evaluates them and no 

corrections are needed. 27
Timeline for Retail Review Process

• COOL-certified reviewers begin their retail review assignments 

within 30 days of when state assignments are received.

• 50% of retail review assignment is completed and submitted to the 

USDA within 3 months of the initial assignment unless prevented by 

uncontrollable factors and communicated to the Federal Agency. 

• Ensure that retail reviews are promptly submitted to the USDA 

within 14 calendar days of the review being conducted.

• Ensure retail review assignments are completed and submitted by 

the deadline(s) provided by the Federal Agency. 

28
Retail Review Reminders

•Inform the retailer that results are not final until 

reviewed by USDA, and if a Noncompliance Letter is 

required, USDA will send it via email to the retailer.

• State and Federal Managers must review workbooks 

for accuracy and completeness, and attest they’ve 

checked them, prior to submitting to USDA. 

• Reviews will be returned from USDA for revision if they 

are not completed correctly. Reviews will not be 

eligible or reimbursement until evaluated by USDA. 29
Questions?
COUNTRY OF ORIGIN LABELING

Thank you for completing Module 3!