I will answer you in English because I don't know the technical terms in French very well.
The final rule that will come into place in March is the rule that was published on January 15, which allows for flexibility for packers and producers to not have to segregate their animals should they not desire to do so. It should allow a packer the option of running U.S.-product-only animals or the option of running mixed-origin labels, packages, without having to go through really extensive segregation--for example, Canadian-born animals in this pen over there--and in the slaughterhouses, not having to do one day of one slaughter and then one day of another, and so on. The hope is that under the rule that was published, which will be law as of June 16, business practices, more or less as usual, could continue.
The complication is that under the voluntary guidelines that have been provided, Secretary Vilsack has asked for that segregation to be put in place. In fact, he has asked for something that goes beyond what was in the 2008 Farm Bill--as Canada read it--back to what was in the 2002 Farm Bill--which is that not only must you say that this animal is a product of Canada or product of the United States, but also you must say that this animal was born in Canada, raised in the United States, slaughtered in the United States, or whatever it may be. You have to have a narrative history of the animal, which means the animal needs to be tracked from birth onwards. This is much more burdensome for processors, for producers, for packers, and for retailers.
We were just hearing stories that part of the problem is that the machines that run labels in grocery stores don't actually have the space to type up the number of characters required to have this narrative history. So that's going to have to take place.
That's one of the elements of the Secretary Vilsack voluntary guidance. Another has to do with ground-meat regulations. Under the final rule that was published in January, processors are allowed an inventory of 60 days, meaning if they've had meat in their inventory from Canada or Australia or New Zealand within the last 60 days, they may label it mixed origin--Canada and the United States, Australia and New Zealand. But under the voluntary guidance it goes back down to 10 days. You must have had product from those countries within the last 10 days in your inventory in order to use that country's name on a label.
Finally, the voluntary guidance proposes to expand the definition of what must be included under country-of-origin labelling to include more processed products, more cured and smoked products.
Essentially, the voluntary guidance goes back to COOL at its origins in 2002, which many parts of the industry in the United States were very unhappy with as well. But it's not legally binding. Perhaps the industry can speak to it better than I, but what is going on now is that people in the United States and in Canada are really trying to understand how they're going to deal with this very novel approach that the United States has taken where they have a rule that is legally binding, and voluntary guidance that is not, but that comes with something of a threat hanging over it.
It's not clear to anybody right now exactly what country-of-origin labelling is and what it means, and how it's going to be enforced. A telling date will obviously be March 16, when the final rule comes into force. And we will start seeing
Then we will see what the COOL really is.