This week we are happy to announce the release of our new CC4F News Community Website. We will be activating the features of the site one at a time as we introduce them in the newsletter so you will have the opportunity to comment on each and let us know what you like, or don't like. Today we'll be looking at the costs you have incurred getting ready for the COOL regulations and we would like you to take a moment and try out our new comment system.
Paul Hernandez-Cuebas
Over the last few months we have been revisiting the Country of Origin Labeling topic as each new ruling was released. Today the COOL regulations go into effect as described in the Q&A:
Q. When does COOL go into effect?
A. The interim final rule for mandatory COOL for fish and shellfish became effective on April 4, 2005. The interim final rule for mandatory COOL for the remaining covered commodities that was published on August 1, 2008, will take effect on September 30, 2008, as directed by the statute. The requirements of this rule do not apply to covered commodities produced or packaged before September 30, 2008. In addition, during the six month period following the effective date of the regulation, AMS will conduct an industry education and outreach program concerning the provisions and requirements of this rule.
You might remember several months ago when we talked about the COOL ruling that the study included some projected costs of implementation.
"...it is believed that $1,309 represents a reasonable estimate of average cost for all firms. Based on this, it is estimated that the initial recordkeeping costs to intermediaries such as handlers, processors, and wholesalers (importers are included with wholesalers) will be approximately $27 million..."
In addition to these start-up costs maintenance is expected to be approximately 1 hour a week for wholesalers and 20 hours per week for processors who may co-mingle products.
We'd like kick off our comments section by asking you whether you are affected by the COOL requirements, and if so whether you feel these projected costs are accurate for your company.
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