A coalition of food industry trade groups is strongly against USDA's proposed rule implementing the country of origin labeling (COOL) provision in the Farm Security and Rural Investment Act of 2002. In a letter to Bill Hawks, under secretary for marketing and regulatory programs at USDA's Agricultural Marketing Service, the associations said they oppose the rule because it "fails to implement fully the exemption from mandatory COOL Congress created for processed food items." Rather than honor the Congressional intent, the associations charge the proposed rule employs an overly narrow interpretation of the processed food item exemption and is at odds with its common sense, plain meaning.

"As we and numerous other commentators have noted, the term ‘processed' in relationship to food has been defined broadly and consistently by many federal agencies in a variety of contexts," the industry groups said.

The associations include the American Frozen Food Institute, the Grocery Manufacturers of America, the National Fisheries Institute, the National Food Processors Association and the US Tuna Foundation.