The Organization for Competitive Markets (OCM) submitted public comments on a proposed rule that the Federal Trade Commission (FTC) would use to strengthen its enforcement program and help businesses understand and comply with Made in the USA (MUSA) labeling law. The proposed rule would set clear standards on what would constitute unqualified MUSA claims, and would authorize the FTC to assess penalties against businesses making unlawful MUSA claims on product labels.
The FTC’s request for comment on the proposed rule invited comments that would identify any inconsistencies in the rule that would conflict with current state or federal country of origin labeling (COOL) requirements.
In its comments, OCM outlined several inconsistencies between the FTC’s criteria and federal COOL law regarding imported meat. One of these inconsistencies is that some types of imported meat such as beef and pork are not included in the definition of products subject to COOL laws, while other types of meat such as lamb, goat, and chicken are required to be labeled. Another inconsistency identified by OCM is that, while processed foods are typically exempt by current COOL law, whole muscle cut meat and ground meat are not processed foods and should be subject to COOL requirements.
“The criteria set forth by the FTC’s proposed ‘Made in the USA’ labeling rule are straightforward, common sense standards that we feel are adequate to address the issues facing producers and consumers alike who deserve truth and transparency in the marketplace,” OCM stated in its comments. “The criteria in the NPRM should be enforced, with penalties for violations sufficient to discourage infractions. Only with consistent country of origin labeling standards across all sectors will any ‘Made in the USA’ claim be effective in establishing fair trade, producer protection, and consumer confidence,” OCM concluded.