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TO: National Meat Association Members January 22, 2003 As you are aware, the USDA has issued guidelines implementing “voluntary” country- of- origin labeling provisions based on the 2002 Farm Bill. Later this year, USDA will solicit comments and issue mandatory country-of-origin labeling regulations, which will become effective on September 30, 2004. It is extremely likely that the mandatory regulations will be very similar to the voluntary guidelines already circulated. NMA believes that mandatory regulations based on the existing “voluntary” guidelines will violate the Constitution, and, if that is the case, NMA plans to evaluate a challenge to those regulations in court with other like-minded organizations as soon as they are promulgated. Whether or not there is a court challenge to USDA’s ultimate mandatory country- of- origin regulations, NMA members need to prepare themselves to comply with those regulations in the event that either they they become effective before a court takes action, or that a court refuses to take action. To comply with the provisions which are likely to be included in mandatory regulations, processors and slaughterers need to be contacting their suppliers of meat and livestock immediately – that is, right now – and requesting assurance that those suppliers will be able to provide the animal identification information that is required by the country- of- origin labeling law. The reason to do this needs to be done now is that in October 2004, those suppliers will have to provide information about the origin and ownership of animals that have already been born. Therefore, livestock sellers have to begin preparing records and start record keepingrecord keeping today. Specifically, slaughterers will want toshould go to their suppliers of livestock and obtain assurances that each of these suppliers can identify each animal back to its place of birth, and processors will want toshould contact each slaughter supplier to be sure that the slaughterer can supply the same information regarding the origin of animals it slaughters and the meat provided by itthose animals. This request is best made in writing, and a copy placed in the file for the record. In the interim, between now and the publication of the mandatory guidelines, NMA urges individual companies to contact their respective representatives and senators and make their opinion on the matter known. While the NMA’s presence in Washington, D.C. is beneficial to the entire organization, it is still effective to attempt to acquire a relationship with your elected representative’s local office. Sometimes what they need to hear is how a certain piece of legislation affects affects theat company that is right in their district. Every member of the NMA should be aware of who is their representatives are and make it a point to get to know them. The representatives and senators, for the most part, want to do what is best for their constituents, so the constituents have to make what is best for them it known what is best for them. You should send a copy of your letter to Shawna Thomas, c/o Olsson, Frank & Weeda, 1400 16th St. NW, Washington, D.C. 20036, or to [email protected] for her follow-up. NMA has scheduled a round table discussion on this subject at its cConvention in Las Vegas to be held on the morning of Monday, March 3. This will be a good time for members to obtain further information. |
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