On December 4, 2012, the Agricultural Marketing Service (AMS) of the U.S. Department of Agriculture announced in the Federal Register its intention to request approval from the Office of Management and Budget, for an extension and revision to the currently approved information collection of the Mandatory Country of Origin Labeling (COOL) of Covered Commodities. On June 29, 2012, the World Trade Organization (WTO) Appellate Body issued a report upholding a WTO Dispute Settlement Body (DSB) panel report that ruled COOL was an illegal trade barrier. The WTO Arbitrator has granted the United States time until May 23, 2013, for the U.S. to implement the recommendations and rulings of the DSB. The Food Marketing Institute (FMI) believes that this Paperwork Reduction Act information collection request (ICR) review process provides an opportunity to change the program to make it more consistent with the rulings of the DSB, while reducing the burdens of the COOL regulation. Food retailers and wholesalers bear the greatest share of the COOL burden. FMI appreciates the opportunity to comment on this important matter.

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