Re: USDA Country of Origin Labeling of Fish and Shellfish

From: Pamela Tom (pdtom@ucdavis.edu)
Date: Tue Mar 08 2005 - 23:03:54 PST

  • Next message: Jim Yonker: "RE: USDA Country of Origin Labeling of Fish and Shellfish"

    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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