March 28, 2017


NAEBA Requesting All American Members and State Associations Comment Now in Opposition to USDA AMS’ COOL Changes for Elk Meat

Comment Period Ends April 13th!


The North American Elk Breeders Association (NAEBA) has identified numerous concerns in the USDA Agriculture Marketing Service (AMS)’s proposed changes to the Country of Origin Labeling (COOL) program for venison. This includes elk.

COOL is a labeling program that requires retailers, such as grocery stores, convenience stores and farmer’s markets, to provide extra labeling noting the country of origin.  This change originates from the 2014 Farm Bill. USDA AMS’ proposed rule estimates this mandate will cost the industry nearly $1 million to comply with little or no economic benefit.

Please request USDA AMS to not take any regulatory action.

See below for several of the major concerns that can impact the elk industry. We need you to submit a public comment citing one or more of these concerns and a quick reason why this is important to you. The public comment period ends April 13, 2017.  After the comment period ends, the USDA will consider submitted comments and publish their final rule.  Please protect one of the industry’s greatest markets.

The NAEBA Board of Directors voted to oppose these changes for the reasons below.

  1. NAEBA finds this change as an expensive government mandate with virtually no benefit to the average elk producer.Page nine of the proposed rule acknowledges there would be little or no economic benefit because of this change. In contrast, the proposed rule expects it will cost the industry nearly $950,000 to implement.

  2. The proposed rule picks winners and losers as elk retailers will be required to provide country of origin information labeling. This falls back to the small American producer. However, restaurants are exempt from this labeling requirement, which the proposed rule acknowledges is the largest avenue for venison consumption. The proposed rule further details the overwhelming majority of venison is imported from New Zealand, which then goes to the restaurants. Therefore, the proposed rule’s intent is not accomplished as the foreign meat that enters the country is not subject to be labeled as a foreign meat. The restaurant loophole defeats the purpose of the rule’s intent.

  3. This is difficult for producers that import animals from Canada. For example, if an American producer purchases animals from Canada and eventually harvests them for meat, often times elk are sent to processing plants in a group with other elk. A processor would have to keep track of the individual cuts within a large groupto label as Canadian. This creates an unnecessary headache for the producer to appease bureaucracy.


    You may submit comments by either of the following methods: Federal Rulemaking Portal: or  Postal Mail/Commercial Delivery: Comments may also be submitted to Julie Henderson, Director, COOL Division, Livestock, Poultry, and Seed Program, Agricultural Marketing Service, U.S. Department of Agriculture (USDA); STOP 0216; 1400 Independence Avenue S.W., Room 2620–S; Washington, DC 20250–0216. All comments should reference docket number AMS–LPS–16–0014.

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