As a specialist in food packaging design, I frequently get questions regarding labeling and compliance. The Country of Origin Labeling (COOL, a requirement of US Customs and Border Protection, CBP) can be particularly confusing, especially when you have different components coming from different countries.
In this article, I’m going to address a couple of common COOL scenarios to shed some light on the subject. For demonstration purposes I’m going to use example ingredients and countries.
In the first example, Cocoa is imported from Mexico but is sometimes imported from Chile instead. The Country of Origin Labeling requirement states that “Food labeling statements regarding geographical origin must not be false or misleading in any particular.” So it would be incorrect to state that the cocoa is a product of both Mexico and Chile on the label. You would need two labels in this case—one for each respective country of origin. One exception to this example is certain oils used in certain products.
In the second example, some spices are imported from India, but are blended in the USA with other spices imported from China to create a new spice blend, different from the individual imported spices. Country of origin statements are not currently required for individual ingredients in an end product if the product is substantially transformed during the blending/preparing process and is no longer identifiable as the product itself. If the end product is mixed/created/blended and substantially transformed in the USA then it is a product of the USA even if all its individual ingredients are imported from other countries. (If you’re importing these individual ingredients though, their own packaging needs to state the country of origin.)
It is not required to state when a food is a product of the USA, but many brands choose to do so. Transparency in the food manufacturing process is important to consumers, and many consumers prefer to buy products made in the USA, so this helps build trust and can be a selling point. It can be a bit misleading to the consumer however, because “Product of the USA” or “Made in the USA” does not necessarily mean all or even any of the product’s ingredients come from the USA (for products with multiple ingredients), but rather that the making or blending of the product happens in the USA.
It is not necessary to state the origin of the food container itself. For example, if a jar is imported from China but the product is made in the USA or elsewhere, it is not necessary to state that the container comes from China.
Here are some direct links to the source information:
This article is provided for information purposes only and does not constitute professional advice nor does it substitute for your reading and reviewing the applicable language from the FDA, CBP or COOL regulations or obtaining advice from the appropriate professional regarding what is and is not required by the FDA, CBP or COOL regulations. This article is not intended to provide advice and direction on how to comply with the FDA, CPB or COOL requirements. The reader of this article is urged to read the FDA, CPB and COOL regulations and/or obtain the appropriate professional advice on the FDA, CPB and COOL regulations. No professional, business or other advisory or economic relationship is created herein, and in some states these materials may be considered advertising.