SALEM – Several food retailers are asking their suppliers to submit country-of-origin labeling compliance plans by Sept. 30 of this year, a full year ahead of the mandatory compliance deadline.

On the advice of the Food Marketing Institute, retailers are asking for plans that include documentation and audits verifying country-of-origin information and creation of a label or sticker for product display.

Under the law passed by Congress in last year’s Farm Bill, retailers must exhibit country-of-origin labels on beef, pork, lamb, fresh and frozen fruits and vegetables, fresh and frozen seafood and shellfish and peanuts by Sept. 30, 2004.

In a letter included in a packet FMI sent to its members, the Washington, D.C.-based institute wrote: “Given the substantial penalties that retailers will face and the length of the production cycle for some covered commodities … it is essential that you start working with your suppliers immediately to ensure that you will have the documentation necessary to limit your liability.”

Bill Greer, editorial director of FMI, said that many products that will hit retailer shelves next year are being produced now.

“That’s why there is some urgency to this,” he said. “We need to start that audit trail now.”

FMI is encouraging early compliance despite opposing COOL, Greer said. FMI also is continuing to lobby for changes in the law. The law, Greer said, will be cumbersome to implement, cost the industry billions of dollars and provide little benefit to consumers and the food industry.

Some suppliers, however, view the extra costs as simply the cost of doing business.

In the long run, said Rick Lee, a supervisor at the Portland bean sprout processor Shanghai, the program will benefit the U.S. food industry.

“We understand that in today’s society, consumers want to know where their products come from,” he said. “It’s good labeling.”

FMI included in the packet a sample letter that maps out actions retailers should request of their suppliers, including the creation of a sample or mock-up label, a plan to segregate commodities by country-of-origin and an audit ensuring accuracy of information.

Lee said the letter he received from Unified Western Grocers last month was helpful in that it clarified what the food wholesaler and retailer expected from him. “The biggest issue was that we did not know what we were expected to do,” he said. “We still don’t know how all of this is going to work out, but this helps.”

Retailers with sales over $230,000 face penalties of up to $10,000 per event if information is missing or inaccurate. Suppliers also can be fined.

Cost estimates associated with meeting the requirements have fluctuated from just under the $70 million estimated in a study by agricultural economists from five universities to the nearly $9 billion Texas A&M University livestock economist Dr. Ernie Davis estimated it will cost the beef industry alone. A study from the U.S. Department of Agriculture estimates initial record keeping costs will be just under $2 billion.

Covered commodities used as ingredients in processed foods are exempt from COOL requirements.

Suppliers of blended products, such as ground meat or mixed salads, must declare country-of-origin for each covered commodity in the descending order of predominance.

Jim Cramer, administrator of the commodity inspection division of the Oregon Department of Agriculture, said the agency is geared up to conduct audits that will enable suppliers to fill COOL tracking requirements. Cramer said ODA will provide the services in conjunction with the good handling practices and good agricultural practices programs it conducts for the USDA or as an independent service.

Suppliers also can contract with independent auditing services to fill COOL requirements, he said.