Compliance & Enforcement

View the full COOL Compliance and Enforcement Requirements (pdf)

Retailers in physical (bricks and mortar) locations and those who sell remotely (such as online), are required to identify the country of origin of covered commodities.

For retailers in physical locations (brick and mortar) country of origin can be placed on covered commodities using a label, stamp, mark, placard or other clear and visible sign on the covered commodity or on the package, display, holding unit, or bin containing the commodity at the final point of sale to consumers. 

This information may be typed, printed or handwritten provided it is in conformance with other Federal labeling laws and does not obscure other labeling information required by Federal regulation. The information may be combined or listed separately but must be placed in a conspicuous location, so as to render it likely to be read and understood by a customer under normal conditions of purchase. Food service establishments, such as restaurants, cafeterias, food stands, and other similar facilities are exempt from these labeling requirements.

For remotely purchased products (i.e. internet sales, home delivery sales), the retailer may provide the country of origin notification either on the sales vehicle or at the time the product is delivered to the consumer for covered commodities.

Any person engaged in the business of supplying a covered commodity to a retailer, whether directly or indirectly, must make available information to the retailer or buyer about the country(ies) of origin and method of production (wild and/or farm-raised), if applicable, of the covered commodity. This information may be provided either on the product itself, on the master shipping container, or in a document that accompanies the product through retail sale provided that the document identifies the covered commodity and its country(ies) of origin and method of production, if applicable.

The regulation gives the Secretary of Agriculture and USDA the authority to conduct an audit of any person that prepares, stores, handles, or distributes a covered commodity for retail sale to verify compliance.