On Tue, 8 Mar 2005, c_yeung wrote:
> Dear List,
>
> Have a question on COOL.
>
> We are a food manufacturing and USDA inspected plant. We do produce seafood
> products. We purchase seafood from vendor and add addition ingredient on
> seafood. For example: Stuffing cheese on Shrimp (Ready to Cook), Shrimp
> with Sun Dried Tomato Sauce (Ready to Eat product, shrimp cook in plant).
> Products for Restaurant / Hotel (institution use only). NOT FOR RETAIL.
>
> My question is do I need to declare the following statement on my product
> label.
>
> a) Labeling of country of original
> b) Labeling Wild or Farm Raised
>
> Regards,
>
> Cindy
> Customcraft Food Service
Cindy,
The short answer is "no."
An explanation from the USDA, plus links for additional information are
listed below.
Pamela Tom
University of California - Sea Grant Extension Program
Web: SeafoodNIC http://seafood.ucdavis.edu
======================================================================
The COOL provisions of the 2002 Farm Bill only apply to covered
commodities that are sold at retail. Further, fish and shellfish covered
commodities are exempt from COOL under The interim final rule if they are
an ingredient in a processed food item. An ingredient is a component
either in part or in full of a finished retail food product. A processed
food item is a retail item derived from fish or shellfish 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 components (e.g., 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 (cold or hot), and
restructuring (e.g., emulsifying and extruding, compressing into blocks
and cutting into portions). Examples of fish and shellfish combined with
different covered commodities or other substantive food components include
scallops and shrimp in a seafood medley, breaded shrimp, breaded fish
fillets, coated shrimp, and marinated fish fillets.
Source: Erin Morris (USDA, Agricultural Marketing Service, Washington,
DC)
****************************************************
A summary of the key components of the COOL interim final rule (based on a
presentation by William Sessions, USDA Agricultural Marketing Service) are
on the Seafood Network Information Center Web site:
http://seafood.ucdavis.edu/consumer/COOLFinalRulePresentation10-14-04.pdf
The presentation covers:
- Who must label
- What must be labeled
- Determining origin and method of production
- Recordkeeping
- Compliance and enforcement
***************************************************
Mandatory Country of Origin Labeling of Fish and Shellfish; Interim
Rule (Federal Register, October 5, 2004, Vol. 69, Number 192):
http://www.ams.usda.gov/cool/ifrls0304.txt
***************************************************
Talking points issued by the USDA:
http://www.ams.usda.gov/cool/talkingpoints.htm
***************************************************
COOL Questions and Answers:
http://www.ams.usda.gov/cool/Q&A.htm
Questions regarding whether a product is considered a covered commodity or
is labeled accurately under the COOL regulation may be e-mailed to
cool@usda.gov
***************************************************
Examples of records that may be useful for COOL Verification purposes:
Farm-Raised Fish - http://www.ams.usda.gov/cool/coolfish.pdf
Farm-Raised Shellfish - http://www.ams.usda.gov/cool/coolshellfish.pdf
Wild Fish - http://www.ams.usda.gov/cool/coolwfish.pdf
***************************************************
The COOL interim final rule will become effective April 4, 2005.
***************************************************
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