AMS Module 1

Intro to COOL and 

Regulatory Requirements
Module 1 Lesson Objectives

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By the end of this lesson, you will understand:

• Why COOL exists.

• Who is subject to COOL.

• What is subject to COOL.
Country of Origin Labeling (COOL) 

Introduction

The USDA’s Agricultural Marketing Service (AMS), Food 

Disclosure and Labeling Division (FDLD) is responsible for 

oversight of the Country of Origin Labeling (COOL) regulations. 

This video provides an overview of the COOL regulations:

https://www.youtube.com/watch?v=19h0QNbi3IM

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COOL Authorization

COOL celebrates 20 years on May 13, 2022; it 

was authorized by the 2002 Farm Bill (Public 

Law 107–171) and the corresponding law is 

located at 7 U.S.C. 1638a. COOL provides 

consumers information about the source of 

certain food items, referred to as “covered 

commodities”. 

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COOL Regulatory Requirements

The COOL Final Rule is available at 

7 CFR Part 60 for fish and shellfish 

and 7 CFR Part 65 for all other 

covered commodities.

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Who is Subject to COOL?
Retailer

• 7 CFR 60.124 and 7 CFR 65.240 define retailer as: Any person subject to be licensed as a retailer under the Perishable Agricultural Commodities Act (PACA) of 1930 (7 

U.S.C. 499a(b)).

• PACA defines retailer as a person with an invoice cost of perishable agricultural 

commodities in excess of $230,000 in a calendar year. 

• 7 CFR 65.205 defines perishable agricultural commodities as: fresh and frozen 

fruits and vegetables of every kind and character that have not been manufactured into articles of a different kind or character and includes cherries in 

brine as defined by the Secretary in accordance with trade usages.

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Supplier

A supplier is: Any person engaged in the business of supplying a 

covered commodity to a retailer, whether directly or indirectly 

(i.e., including but not limited to growers, distributors, handlers, 

packers, and processors). 7 CFR 60.400(b) and 7 CFR 65.500(b)

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Exempt From COOL

Food Service Establishments, as defined in 7 CFR 60.107 and 7 CFR

65.140, are exempt from COOL. These include:

• Restaurant

• Cafeteria, lunchroom

• Food stand

• Saloon, tavern, bar

• Food service facilities

• Salad bar, delicatessen (deli)

• Food enterprises located 

within a retail store that 

provide ready-to-eat foods 

such as a deli counter

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Knowledge Check 1
Who is subject to COOL? 

a.USDA defined farmers and ranchers.

b.FDA defined food manufacturers.

c. Retailers subject to be licensed under PACA.

d.United Nations defined farmers and retailers.

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Who is subject to COOL? (cont)

a.USDA defined farmers and ranchers.

b.FDA defined food manufacturers.

c. Retailers subject to be licensed under PACA.

d.United Nations defined farmers and retailers.

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What is Subject to COOL? 
COOL Covered Commodities

7 CFR 65.135

• Muscle cuts of lamb, chicken, and goat

• Ground lamb, ground chicken, and ground goat

• Perishable agricultural commodities

• Peanuts

• Macadamia nuts

• Pecans

• Ginseng 14

7 CFR 60.105

• Farm-raised fish and shellfish 

(including fillets, steaks, 

nuggets, and any other flesh)

• Wild fish and shellfish 

(including fillets, steaks, 

nuggets, and any other flesh)

The COOL regulations list the specific food items, called covered commodities, that 

it covers. Both domestic and imported covered commodities are subject to COOL. 
Perishable Agricultural Commodities

• 7 CFR 65.205 defines perishable agricultural commodities as: fresh 

and frozen fruits and vegetables of every kind and character that 

have not been manufactured into articles of a different kind or 

character and includes cherries in brine as defined by the Secretary 

in accordance with trade usages.

• Unsure if an item is a perishable agricultural commodity? Check the 

PACA Commodities List.

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Perishable Agricultural Commodities 

(Cont)

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Examples of covered commodities 

include:

• Chopped raw onions

• 16 oz. bag of frozen peas

• Fresh apples

• Frozen blueberries

• 5 oz. container of spinach
Peanuts, Pecans, Macadamia Nuts, 

and Ginseng

Examples of covered commodities 

include:

• Raw peanuts sold in a bulk bin

• 8 oz. bag of raw macadamia nuts

• 2 oz. bag of chopped pecans

• Whole root raw ginseng

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Chicken (Ground and Muscle Cuts)

• Chicken is defined in 7 CFR 65.120 as the meaning given in 9 CFR 381.170(a)(1):

(i) Rock Cornish game hen or Cornish game hen

(ii) Broiler or fryer

(iii) Roaster or roasting chicken

(iv) Capon

(v) Hen, fowl, baking chicken, or stewing chicken

(vi) Cock or rooster

• Ground chicken means comminuted chicken of skeletal origin that is produced 

in conformance with all applicable Food Safety and Inspection Service labeling 

guidelines. 7 CFR 65.160

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Chicken (Ground and Muscle Cuts) 

(cont)

Examples of chicken covered 

commodities include: 

• Leg Quarters

• Breasts, wings

• Tenderloins

• Thighs

• Whole chickens

• Ground chicken

Examples of chicken items that 

are not covered commodities are:

• Organs (hearts, livers)

• Fat

• Feet and bones

• Living livestock

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Goat and Lamb (Ground and Muscle 

Cuts)

• Goat means meat produced from goats. 7 CFR 65.150

• Ground goat means comminuted goat of skeletal origin that is 

produced in conformance with all applicable Food Safety and 

Inspection Service labeling guidelines. 7 CFR 65.165

• Lamb means meat produced from sheep. 7 CFR 65.190

• Ground lamb means comminuted lamb of skeletal origin that is 

produced in conformance with all applicable Food Safety and 

Inspection Service labeling guidelines. 7 CFR 65.170

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Goat and Lamb (Ground and Muscle 

Cuts) (cont)

Examples of goat and lamb covered 

commodities include: 

• Mutton

• Lamb shank, lamb chops, 

• Ground lamb, ground goat

• Goat shoulder

• Goat leg

Examples of goat and lamb items 

that are not covered commodities 

are: 

• Organs (heart, tongue)

• Bones (neck bones, femur bones)

• Living livestock

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Fish and Shellfish

• Farm-raised fish means fish or shellfish that have been harvested in 

controlled environments, including ocean-ranched (e.g., penned) fish and including shellfish harvested from leased beds that have been subjected to 

production enhancements such as providing protection from predators, the 

addition of artificial structures, or providing nutrients; and fillets, steaks, 

nuggets, and any other flesh from a farm-raised fish or shellfish. 7 CFR 

60.106

• Wild fish and shellfish means naturally-born or hatchery-originated fish or shellfish released in the wild, and caught, taken, or harvested from non- controlled waters or beds; and fillets, steaks, nuggets, and any other flesh 

from a wild fish or shellfish. 7 CFR 60.133

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Fish and Shellfish (cont)

Examples of fish and shellfish covered 

commodities include:

• Salmon fillets

• Raw shrimp

• Lobster tails

• Golden pompano, on ice

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Knowledge Check 2
Which item(s) are COOL covered 

commodities?

a. Fresh and frozen fruits

b. Fresh and frozen vegetables

c. Peanuts, pecans, and macadamia nuts

d. Ginseng

e. All of the above 25
Which item(s) are COOL covered 

commodities? #1

a. Fresh and frozen fruits

b. Fresh and frozen vegetables

c. Peanuts, pecans, and macadamia nuts

d. Ginseng

e. All of the above 26
Which item(s) are COOL covered 

commodities? #2

a. Pig Ears 

b. Ground pork

c. Chicken hearts

d. Fresh salmon

e. All of the above

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Which item(s) are COOL covered 

commodities? #3

a. Pig Ears

b. Ground pork

c. Chicken hearts

d. Fresh salmon

e. All of the above

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What is Not covered by 

COOL?
Not a Covered Commodity 

The COOL regulation expressly lists what is a covered commodity. Items that are not

covered commodities are not covered by COOL, such as:

• Coconut

• Other nuts such as walnuts, almonds, cashews

• Guinea fowl, turkey, quail, duck

• Beef, pork

• Frog legs, turtle, alligator

• Livestock

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Not a Covered Commodity (cont) 

The COOL regulation expressly lists what is a covered commodity. Items that are not

covered commodities are not covered by COOL, such as:

• Decorative corn, gourds, and carving pumpkins

• Potted or living herbs

• Floral arrangements

• Items intended for planting such as onion sets, seed potatoes

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Processed Food Items are Excluded

Processed food items are excluded from COOL. 

Processed food item means a retail item derived from a covered commodity that has undergone 

specific processing resulting in a change in the character of the covered commodity, or that has 

been combined with at least one other covered commodity or other substantive food 

component (e.g., chocolate, breading, tomato sauce), except that the addition of a component 

(such as water, salt, or sugar) that enhances or represents a further step in the preparation of the 

product for consumption, would not in itself result in a processed food item. Specific processing 

that results in a change in the character of the covered commodity includes cooking (e.g., frying, 

broiling, grilling, boiling, steaming, baking, roasting), curing (e.g., salt curing, sugar curing, drying), 

smoking (hot or cold), and restructuring (e.g., emulsifying and extruding). Examples of items 

excluded include roasted peanuts, breaded chicken tenders, and fruit medley. 7 CFR 60.119 and 7 

CFR 65.220

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Processed Food Items: Change of 

Character

Examples of processed food items that have undergone processing resulting in a 

change of character include: 

Cooked Fried Canned Roasted Smoked Restructured

Steamed 

crab legs

Fried chicken Canned 

vegetables

Roasted 

peanuts

Smoked salmon Fish sticks

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Processed Food Items: Combined with 

Another Food Component

Examples of processed foods that have been 

combined with another food component 

include:

• Mixed fruit cup, mixed vegetable bag, mixed nuts

• Stuffed chicken, chicken cordon bleu

• Lemon pepper marinated chicken breasts

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Knowledge Check 3
Which item is subject to 

COOL?

a. Shredded coconut

b.Marinated chicken

c. Salted raw peanuts

d.Potted basil

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Which item is subject to 

COOL? (cont)

a. Shredded coconut

b.Marinated chicken

c. Salted raw peanuts

d.Potted basil

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Activity 1
Country of Origin Labeling 

Options
Country of Origin Notification

Labeling of covered commodities offered for sale 

whether individually, in a bulk bin, carton, crate, 

barrel, cluster, or consumer package must contain 

country of origin and method of production (wild and/ 

or farm-raised) as set forth in this regulation. 7 

CFR 60.200(a) and 7 CFR 65.300(a)

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COOL Labeling Options

Country of origin declarations can be made on any of the following 

ways per 7 CFR 60.300(a) and 7 CFR 65.400(a): 

• Placard

• Sign

• Label

• Sticker

• Other format that allows the consumer to identify the COOL

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• Band

• Twist tie

• Pin tag

• Checkbox
COOL Labeling Options (cont)

Labeling examples include:

• On package, such as the raw shrimp 

from Mexico with method of 

production as wild.

• Tag on Kiwi from Chile.

• Sticker on lemons from Chile.

• Band on asparagus from Peru.

• Checkbox showing Mexico.

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Country of Origin Notification

Not Acceptable

The following are examples of country of origin declarations that are not an 

acceptable COOL declaration:

• Symbols and flags representing origin. 7 CFR 60.300(e) and 7 CFR 65.400(e)

• The disjunctive term “OR”(e.g., Product of Thailand or Vietnam).

• The term “AND/OR” (e.g., Product of U.S., Canada, and/or Mexico).

• The term “May Contain” (e.g., May contain products from U.S. and Mexico). 

7 CFR 60.300 and 7 CFR 65.400

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Abbreviations

In general, country abbreviations are not acceptable. Only those 

abbreviations approved for use under CBP rules, regulations, and 

policies, such as 7 CFR 60.300(e) and 7 CFR 65.400(e) are permitted:

• “U.S.” or “U.S.A.” for United States

• “U.K.” for United Kingdom including Northern Ireland

• “P.R. China” or “China” for Peoples’ Republic of China

• “Holland” for The Netherlands

Visit the AMS Website to view the Abbreviations Guidance

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State Abbreviations

State abbreviations are only acceptable for fruits, vegetables, 

peanuts, pecans, macadamia nuts, and ginseng. 7 CFR 

65.400(f):

• Abbreviations may be used for state, regional, or locality 

label designations for these commodities whether 

domestically harvested or imported using official United 

States Postal Service abbreviations or other abbreviations 

approved by CBP. 

• The label must refer to the product, not the farm or 

distributor.

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Labels that are Not COOL Compliant

Some labels do not meet the 

COOL requirements. Vague 

regional designations do not 

provide accurate COOL and are 

not acceptable, such as:

• Appalachian Grown

• Pacific Northwest

• Locally Grown

• Island Fresh

• Product of Asia

7 CFR 60.300(f) and 65.400(f)

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Activity 2
COUNTRY OF ORIGIN LABELING

Thank you for completing 

Module 1!

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