AMS Module 5

Follow-Up Reviews and Recordkeeping
Lesson Objectives

• 2022 Follow Up Review Procedures. 

• Noncompliance (NC) Codes 10-16.

• Understanding COOL recordkeeping requirements in 7 CFR 

60.400 and 7 CFR 65.500.

• Record Selection Process.

• Recordkeeping and the BE-COOL CRM.

• Photographic evidence guidelines. 

2
Initial and Follow-Up Reviews

Both Initial and Follow-up Reviews include: 

• Opening Meeting,

• Reviewing commodities for labeling compliance,

• Citing noncompliant items with full details,

• Closing Meeting, and,

• Informing the Representative that USDA will provide the 

final results of the review.

3
Initial vs. Follow-Up Review

Initial Review

•Only NC codes 1-9 apply.

• Ask 5 Questions.

Follow-Up Review

• NC codes 1-16 apply.

• Must obtain pictures of 

noncompliant items and the 

store front. 

• Collect record information for 

the commodity groups.

4
2022 Follow Up Procedures Update

• Take picture of the retail store front.

• Review last year’s results – pay close attention to last year’s noncompliant items. 

• Capture email address from store 

representative – official results of the review 

will be provided by USDA via email. 

5
Follow Up Review Procedure 

Update – Record Request Form

New Records Request Form: 

• Complete the form, including the item info.

• The reviewer will sign the records request form.

• The store representative will sign the records request form. 

• You will take a picture of the completed records request form and 

upload the picture to the BE-COOL CRM system.

• The store representative keeps the signed form. 

6
Follow Up Review Update -

Photographs

• Take multiple pictures of all noncompliant items. Get a picture of the sign, 

the noncompliant item and all parts of the package that have writing on 

them. Pictures should include:

1. The noncompliant label (or missing information),

2. An image of the product in total including any signage, and,

3. Pictures of the front and back of the package where there is information. 

• Take a picture of the covered commodity selected for records review. (The 

item can be compliant or noncompliant). 

• Take a picture of the records themselves or obtain a copy of the records. 

Records will be uploaded to the BE-COOL CRM.

7
Noncompliance Codes 10-16
Noncompliance codes 10-16 are 

used for Follow-up Reviews

9
NC Code 10 – No Records Provided 

Within 5 Business Days

NC code 10 applies when the retailer does not provide 

records within 5 business days from the request. 

7 CFR 60.400 (a)and 7 CFR 65.500 (a)(2)

10
NC Code 11 – No Country of Origin 

on Records

NC code 11 applies when records do not provide the country of 

origin information for the covered commodity. The country of 

origin may be abbreviated on the record provided that the 

retailer can accurately decipher the country information. 

7 CFR 60.400 (c)(3) and 7 CFR 65.500 (c)(2) and 7 CFR 65.500 (c)(4)

11
NC Code 12 – No Method of 

Production (MOP) on Records

NC code 12 applies when records do not provide the method of 

production information. The method of production may be 

abbreviated on the record provided that the retailer can 

accurately decipher the country information. 

7 CFR 60.400 (c)(2) and 7 CFR 60.400 (a)(2)

12
NC Code 13 – No Supplier 

Information on Records

NC code 13 applies when records do not provide the supplier 

information. The required supplier information includes the 

supplier name and address (city and state at a minimum). 

7 CFR 60.400 (c)(3) and 7 CFR 65.500 (c)(4)

13
NC Code 14 – Conflicting Records 

Country of Origin

NC code 14 applies when the country of origin on the record from 

the supplier is not accurately conveyed to the consumer.

7 CFR 60.400 (c)(1) and 7 CFR 65.500 (c)(1)

14
NC Code 15 – Inaccurate Method 

of Production

NC code 15 applies when the method of production provided by 

the supplier’s record is not accurately conveyed to the 

consumer.

7 CFR 60.400 (c)(1)

15
NC Code 16 – Records for a Pre-labeled 

Item Not Received in 5 Business Days

NC code 16 applies when records identifying the immediate 

previous supplier for a pre-labeled item were not provided within 5 business days. 

7 CFR 60.400 (c)(3) and 7 CFR 65.500 (a)(2) and 7 CFR 65.500 (c)(4)

16
Refresher on pre-labeled items

Pre-labeled: An item that lists on the package the Country of 

Origin and Method of Production (if applicable) along with the 

packer or distributor’s name, city and state. 7 CFR 60.118 and 7 

CFR 65.218 

When a pre-labeled item is selected in a Follow-up review, a 

second record is required. The pre-labeled item is considered 

the first record and the second record needs to shows the 

immediate previous supplier. 

17
Difference between NC 10 and 

NC 16

If the retailer did not provide records from their 

immediate previous supplier within 5 business 

days, cite the appropriate NC code:

•NC 10 applies for items that are not pre-labeled.

•NC 16 applies for items that are pre-labeled.

18
Recordkeeping and Record Collection 

for Follow-up Reviews

19
Recordkeeping Requirements

• Records must be legible and may be maintained in either 

electronic or hard copy formats. 7 CFR 60.400(a)(1) and 7 

CFR 65.500(a)(1)

• Upon request by USDA representatives, retailers must 

provide records maintained in the normal course of 

business within 5 business days. Records may be 

maintained in any location. 7 CFR 60.400(a)(2) and 7 CFR 

65.500(a)(2)

20
Recordkeeping Requirements

Records that identify the item, the retail supplier, and for 

products that are not pre-labeled, the country of origin 

information and the method of production (wild and/or 

farm-raised) must be maintained for a period of 1 year from 

the date the declaration is made at retail. 7 CFR 60.400(c)(3) 

and 7 CFR 65.500(c)(3)

21
Recordkeeping Requirements: Prelabeled items

For pre-labeled items, the label itself, as illustrated in the 

example (Snowcrest Foods, Ltd., Abbotsford, British 

Columbia), as it has the country 

of origin, packer or distributor’s name, city and state is 

sufficient for the retailer to rely 

on to establish the product's 

origin and is a record. 7 CFR 

60.400(c)(2) and 7 CFR 

65.500(c)(2)

22
Examples of Records

Common examples of 

records used during the 

normal course of business 

include: • Invoice • Bills of Lading (BOL) • Shipping Manifest • Receipt • Master Container • Pre-Labeled Container

23
Requesting Records:

Selecting Items

Follow-Up reviews must request records during the 

review. Records are requested for six items, one item 

from each of the six covered commodity groups:

• Fresh and Frozen Fruits

• Fresh and Frozen Vegetables

• Fresh and Frozen Fish and Shellfish 

• Nuts (Macadamia, Peanuts, and Pecan) and Ginseng 

• Chicken (ground and muscle cuts) 

• Goat and Lamb (ground and muscle cuts)

24
Requesting Records: Selecting 

Specific Items

• Category: Fresh and Frozen Fruit. Please select records for 

one of these fresh items: 

1. Cantaloupe 

2. Tangerine 

3. Orange

*If none of the items listed above are sold at the store, select 

any item within the same fresh fruit commodity group.

25
Requesting Records: Selecting 

Specific Items, page 2

• Category: Fresh and Frozen Vegetables. Please select 

records for one of these fresh items: 

1. Eggplant

2. Collard greens

3. Green beans

4. Summer Squash

*If none of the items listed above are sold at the store, select 

any item within the same fresh vegetable commodity group.26
Requesting Records: Selecting 

Specific Items, page 3

Category: Fresh and Frozen Fish and Shellfish.

Order of preference for selection (any variety):

1. Fresh wild caught fish or shellfish item;

2. Frozen wild caught fish or shellfish item;

3. Fresh or frozen farm raised fish or shellfish item.

27
Requesting Records: Selecting 

Specific Items, page 4

Category: Nuts (Macadamia, Peanuts, and Pecan) 

and Ginseng.

Order of Preference for selection:

1. Ginseng

2. Macadamia Nuts

3. Peanuts

4. Pecans

28
Requesting Records: Selecting 

Items

•Category: Chicken/Lamb/Goat 

Any covered commodity.

29
Requesting Records: Not Sold in 

Store?

• If the store does not sell any items in an entire commodity group, 

check “not sold in store”. 

• For example, if a store doesn’t sell any ground or muscle cuts of 

goat and lamb, check “not sold in store”. 

• The review would then only have 5 records requested.

30
Records Verification

• Records provided by the store need to match the 

item observed during the review such as size, brand, item name, date. 

•The date must be reasonable. If the record for 

fresh raspberries show the shipment was 

received 3 months earlier, that record doesn’t 

pertain to the item observed during the review.

• If the records are submitted after the review for 

a shipment that the store received after the 

review occurred, the record doesn’t pertain to 

the item observed during the review.

• The reviewer must verify that the retailer has 

provided the correct record.

31
Requesting Records • Most stores will provide records during the 

review. 

• If the store does not provide records during 

the review, they may send them to the 

reviewer within 5 business days. 

• The Records Request Form provides the 

store with the necessary info to locate and 

submit records, such as the due date and 

how the store can send you the records, 

such as your email address or fax number. 

32
Requesting Records (cont.)

• New Record Request Form.

• Reviewer will fill out the form including 

name, date, review number, contact 

information, and signature. 

• The Reviewer and the store representative 

need to sign the records request form.

• Take a picture of the form and upload to 

the BE-COOL CRM system. 

33
Recordkeeping and the BE-COOL 

CRM System

USDA, Agricultural Marketing Service – Food Disclosure & Labeling Division 34
Documenting Recordkeeping 

Information in CRM

In addition to what is entered for Initial reviews, Follow-Up 

reviews include a recordkeeping section.

35
Documenting Recordkeeping 

Information in CRM, page 2

• Click on the “Recordkeeping” tab for each commodity group.

• Select what was the item category observed (ie fresh fruit). 

36
Documenting Recordkeeping 

Information in CRM, page 3

Supplier Information: This captures the supplier who provided the 

retailer with the item, also known as the immediate previous 

supplier. Please provide as much detail as possible. 

37
Documenting Recordkeeping 

Information in CRM, page 4

Records Reviewed section: Select from the drop-down menu 

the type of record(s) reviewed (bill of lading, invoice, shipping 

manifest, master container label, package label, etc.). Provide 

the complete details and information from the record.

38
Documenting Recordkeeping 

Information in CRM, page 5

• “Recommended for STA?” – Leave blank.

• “Were Records Provided?” and “Were Records Validated?”

• For both, select yes if records were provided during the 

review or within 5 business days of your request. Select no

if records were not provided. 

39
Recordkeeping Noncompliances

If there is a recordkeeping noncompliance, add the appropriate NC code and 

description under the review section for records. NC codes 10 – 16 apply.

40
Capturing Photographic 

Evidence
Photographs • Take a picture of the store front for all 

follow-up reviews. 

• A picture of the store front is required even 

if the retailer has no findings. 

• Take pictures of every noncompliant 

item including the display.

• Take pictures of every item selected for 

recordkeeping.

• Take pictures of all records provided by 

the retailer for the record review items. 

42
Photograph Tips

• Take a picture of the item along with the specific NC issue, this should 

also include a picture of the item’s display. You likely will need multiple 

pictures. 

• If the Country of Origin is not accurate (NC 3), be sure to capture the 

conflicting labels and/or signs showing the different country of origins. 

• If the issue is no country of origin (NC1), capture the item’s display 

demonstrating there’s no COOL on a store sign, label, PLU, etc.

• If the NC is a records issue, such as inaccurate COOL, pictures 

are needed of the item with the COOL shown on the label or sign to the 

consumer as well as the records showing a different country of origin.

43
Photograph Tips for Evidence

44

• Take a picture of the records request form after it has been signed by the 

store personnel.

• Upload a picture of the records request form to CRM. 

• Utilize date and time stamp settings on camera. If possible, also include 

the name of who the photographer is on the photo. If not possible, 

include in comments section the photographer's name. 

• Each noncompliant item should be photographed in its entirety. 

• This includes the display and any store signage, the individual item itself. If 

the item has multiple sides to the package, then take pictures of all sides of 

the package. Why is this important? We want to remove any doubt that the 

COOL or MOP could have been elsewhere on the package or store sign.
Noncompliant Item Photograph 

Example

The item listed (Pepper Variety 

Frying) lacks the country of 

origin. NC 1 is cited, pictures are 

required.

• Picture 1: the overall display 

• Picture 2: the item itself

• Picture 3: the sign and item
Photos of Pre-labeled Packages

• Capture as much of the 

item/label as possible.

• For prelabeled peas, take 

pictures of the front and 

back of the item. 

• It’s necessary to know 

the brand, size, lot 

number, best by date, 

production codes, etc.

46
Photos of Documents as Records

Documents such as invoices, 

bills of lading, shipping 

manifests, etc. have many 

pages. When the item 

selected for review is not on 

the first page, capture the 

first page of the record 

(usually has the supplier’s 

info, number, date, etc.) and 

the specific page where the 

item is listed.

47
Photos of Master Containers as 

Records

Take pictures of all sides that have identifying info. This 

includes the supplier’s info, item size, box weight, production 

date, lot numbers, Best By dates, Establishment number, etc.

48
Non-Compliant Items

• Upload pictures of items into the CRM for the associated review. 

Include any store signage in the picture. 

49
Before Submitting to USDA

Manager Review includes checking that:

• All NC items have corresponding pictures,

• All NCs cited are correct,

• All information such as the retailer’s email was obtained,

• Records were collected for the correct item based on USDA 

instructions, and,

• All records match the item observed. 

• If necessary, the Manager should return the file to the reviewer for 

corrections before submitting the review to USDA.

50
Reminders

• Each Reviewer and Manager must be “COOL-certified” and pass the 

COOL Exam with a score of 85% or higher. Conducting follow-up 

reviews? Will also need to pass the follow-up exam. Sent via ProProfs.

• User information including eAuth must be provided to FDLD to use the 

BE-COOL CRM portal. 

• Call retailers to ensure they’re open. NEW in 2022: FDLD will not

reimburse for closed stores. 

• Submit retail reviews through the BE-COOL CRM portal. 

• Managers must review the retail review. USDA will return deficient 

reviews for correction. 

51
Your collaboration is key for 

consumers ensuring they know the 

source of their food. Thank you!
COUNTRY OF ORIGIN LABELING

Thank you for completing Module 5!