Country of origin labeling, COOL, is USDA's rule that grocery stores tell shoppers where certain foods came from. It covers fresh fruits and vegetables, fish and shellfish (with wild or farm-raised), muscle cuts and ground lamb, chicken and goat, and peanuts, pecans, macadamia nuts and ginseng. Beef and pork were taken out in 2016. The label duty sits with retailers, but anyone who supplies a covered food to a retailer must pass the origin on, on the product, the master case or a paper that travels with it, and keep a record of who they got it from and who they sold it to for one year. Foods that are cooked, cured, smoked, restructured or combined with another covered food are processed food items and leave COOL behind; so does anything sold to a restaurant. In the example below, a food hub sorts seven products for its grocers. Below are the rules, what's excluded, the records, "Product of USA", the example, and a free checklist.
The short version
- Covered: fresh fruits and vegetables; fish and shellfish; lamb, chicken and goat; peanuts, pecans, macadamia nuts and ginseng.
- Not covered: beef and pork (since 2016), eggs, dairy, and most foods outside the list.
- Excluded: processed food items, such as roasted peanuts, breaded chicken tenders and fruit medley.
- Retailers label; restaurants and other food service are exempt.
- Suppliers pass on the origin: on the product, the master case, or a document that goes with it.
- Fish and shellfish also say wild or farm-raised.
- Suppliers keep one-up, one-down records for 1 year, and hand them to USDA within 5 business days.
- "Product of USA" on meat, poultry and eggs means born, raised, slaughtered and processed in the US, since January 1,
- TaroStack keeps each lot's supplier and its customers, the record COOL asks for. More below.
The rules
| Rule | What 7 CFR parts 60 and 65 say |
|---|---|
| Covered commodities | Muscle cuts and ground lamb, chicken and goat; perishable agricultural commodities; peanuts; macadamia nuts; pecans; ginseng; wild and farm-raised fish and shellfish |
| Who labels | Retailers: anyone required to be licensed as a retailer under the Perishable Agricultural Commodities Act |
| Exempt | Food service establishments: restaurants, cafeterias, food stands, salad bars, delis serving ready-to-eat food |
| Suppliers | Give the buyer the country of origin on the product, the master shipping container, or an accompanying document |
| Who starts the claim | For lamb, chicken and goat, the slaughter facility |
| Imports | Keep the origin declared to Customs through retail sale |
| Mixed origins | A case mixing countries lists all of them |
| Online sales | The origin on the website, or at delivery |
| Records | Suppliers: the immediate previous source and next recipient, 1 year from the transaction |
| On request | Records to USDA within 5 business days |
The rules are 7 CFR part 65 and, for fish and shellfish, 7 CFR part 60. The label can be a sign, sticker, band, twist tie or check box, saying "Product of USA", "Grown in Mexico" or only "USA". This is general information, not legal advice.
What's excluded
A covered food that's an ingredient in a processed food item isn't covered. Processed means its character changed by cooking (frying, roasting, baking, steaming), curing (salt or sugar curing, drying), smoking, or restructuring (emulsifying, extruding), or it's combined with another covered commodity or a substantive food such as chocolate, breading or tomato sauce. Adding water, salt or sugar alone doesn't make it processed. So raw pecans are covered; roasted pecans and chocolate pecans aren't. A bag of carrots is covered; a salad of lettuce and carrots isn't.
Separately, Customs requires every imported article to be marked with its country of origin for the ultimate purchaser (19 CFR 134.11). If you turn an imported ingredient into a new product, such as imported cocoa into chocolate bars, you're the ultimate purchaser and the bars aren't marked under that rule, though the outer cases you received still are.
"Product of USA" on meat, poultry and eggs
Beef and pork left COOL, but a voluntary claim has its own rule. Since January 1, 2026, "Product of USA" or "Made in the USA" on a meat, poultry or egg product means it came from animals born, raised, slaughtered and processed in the United States; on a product with more ingredients, every other ingredient is domestic too, except spices and flavorings (9 CFR 412.3, from a 2024 final rule). A plant that uses the claim keeps records to support it.
An example: a food hub supplying grocers
Two Rivers Food Hub, a made-up food hub in Mankato, Minnesota, I use in these examples, buys from about 40 farms and sells to grocers, restaurants and schools:
| Product | Covered? | What Two Rivers does |
|---|---|---|
| Tomatoes, to a grocer | Yes: a fresh vegetable | "Product of USA" on the case label |
| Frozen chicken breasts, to a grocer | Yes: chicken | Passes on the processor's "Born, raised and slaughtered in the United States" |
| Frozen ground beef, to a grocer | No: beef left COOL in 2016 | Nothing under COOL |
| Eggs, to a grocer | No: not a covered commodity | Nothing under COOL |
| Salad mix of lettuce and carrots | No: two covered vegetables combined | Nothing under COOL |
| Tomatoes, to a restaurant | No duty: food service | Nothing under COOL |
| Frozen lake herring fillets, to a co-op | Yes: fish | "USA, wild" on the case label |
For every covered lot, Two Rivers keeps the farm or plant it came from and each grocer it went to, for a year: the same records as one-up, one-back traceability. How a grocer's vendor setup works is in selling to grocery stores requirements.
Get the checklist
Download the country of origin labeling checklist. Two sheets: covered or not, each product with its commodity group, whether it's processed, who buys it and its countries, with what to pass on; and one up, one down, each lot's source and recipient with the date the record can go. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
Forty farms, three kinds of buyer, and a case of tomatoes that splits between two grocers: the origin has to follow each case, and the record has to say where each lot came from and went. Paper invoices hold it, but not in a way anyone can search in 5 business days. How a lot follows a case is in what is lot tracking.
How TaroStack does it
TaroStack keeps each lot's supplier and its customers, the record COOL asks for.
Lots at receiving. Receiving records the farm or plant and gives each delivery a lot, so the previous source is on record from the start.
Lots on orders. Each grocer's order records the lots it got, so one recall report shows where a lot came from and every customer it reached: one up and one down together.
Labels and exports. Lot labels with GS1-128 barcodes print for each case, and every list exports to CSV when USDA or a grocer asks.
| The job | Paper | In TaroStack |
|---|---|---|
| Where a lot came from | The farm's invoice | Recorded at receiving |
| Which grocers got it | Your invoices, one by one | One recall report |
| Records within 5 business days | A search through a year of paper | A CSV export |
Lots, receiving, orders and lot labels are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.