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Country of Origin Labeling
Recordkeeping Procedures
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Overview
• Retailer’s Recordkeeping Requirements • Follow-up Retail Review Workbook • Identifying Pre-labeled Commodities • Conducting a Follow-up Review • Requesting Records • Recording Unique Identifiers
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Retailer’s Recordkeeping Requirements
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Recordkeeping Requirements
• Retailers are required to maintain records used in the normal course of business that verify: – Country of origin – Method of production (fish & shellfish only) – Immediate previous supplier information
(name, city, and state).
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Recordkeeping Requirements
• Records for covered commodities must be maintained for 1 year from the date the origin declaration is made at retail.
• Records may be maintained in any location and in any format.
• Retailers have 5 business days to provide records.
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Follow-up Retail Review Workbook
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Retail Review Workbook
• There are 2 types of Retail Surveillance Reviews. 1. Initial Retail Surveillance Review Workbook ü 6 commodity categories ü 5 interview questions
2. Follow-up Retail Surveillance Review Workbook ü 6 commodity categories ü 6 recordkeeping sections
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Supplier Traceback Audits
• In addition to Initial and Follow-up Reviews
the COOL Division also conducts Supplier Traceback Audits.
• Supplier Traceback Audits are initiated from the recordkeeping information obtained during follow-up reviews.
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Supplier Traceback Audits Purpose
• Items are selected on a random basis. • Auditors examine record documents
provided by each supplier in the chain of commerce from the retail store to the initiator of country or origin and method of production claims to verify whether information is accurate and correctly transmitted through the supply chain.
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Follow-up Retail Review
• Retailer records will ONLY be required during the performance of a Follow-up Retail Review.
• The Follow-up Retail Review workbook will include 6 recordkeeping sections for each commodity category.
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Follow-up Review Workbook
Information Form Tab
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Follow-up Review Workbook
Checklist Tab Page 1: • General Retailer and
Reviewer information
• Non-Compliance Code Legend
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Follow-up Review Workbook
Page 2: • Labeling Non-
Compliance section for Fruits and Nuts & Ginseng
• Recordkeeping section for Fruits and Nuts & Ginseng
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Follow-up Review Workbook
Page 3: • Labeling Non-
Compliance section for Vegetables and Fish & Shellfish
• Recordkeeping section for Vegetables and Fish & Shellfish
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Follow-up Review Workbook
Page 4: • Labeling Non-
Compliance section for Chicken and Lamb & Goat
• Recordkeeping section for Chicken and Lamb & Goat
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Follow-up Review Workbook
Page 5: • Additional Items
section
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How do I know if I am conducting a Follow-up Review?
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Follow-up Retail Review File Name
Follow-up Retail Reviews will include an “F” before the 4 digit number in the file name. This indicates store location was reviewed previously and results warranted a follow-up retail review.
Example: TX 16 F9867
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Pre-Labeled or Not
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What is a pre-labeled covered commodity?
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Pre-Labeled Definition
• A covered commodity that has the commodity’s – country of origin, – method of production (when applicable), and – The supplier’s name and place of business
(city and state) of the manufacturer, packer, or distributor.
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Location of Information
• The country of origin, method of production, and supplier information can be located: – On the covered commodity itself, – On the package in which it is sold to the
consumer, or – On the master shipping container
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Not Pre-Labeled
• The covered commodity is NOT a pre-labeled item if it is missing any of the following: – country of origin, – method of production (when applicable), and – The supplier’s name and place of business
(city and state) of the manufacturer, packer, or distributor.
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Is this a Pre-labeled item?
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Is this a Pre-labeled item?
FRONT BACK
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Is this a Pre-labeled item?
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Is this a Pre-labeled item?
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Conducting Follow-up Review
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3 Step Process
Step 1: Review all COOL guidance documents and prepare the Workbook.
Step 2: Conduct COOL Surveillance Review at the retail establishment.
– Part A: Opening Meeting – Part B: Conduct Review – Part C: Recordkeeping (Follow-up reviews only) – Part D: Closing Meeting
Step 3: Submit Workbook to USDA COOL Division.
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Opening Meeting
• During the opening meeting with the Retailer’s Responsible Authority, advice them you will be requesting records for 6 covered commodities.
• Records can be provided at the time of the review or within 5 business days.
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Requesting Records
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Requesting Records
For FY16 records will be requested for all 6 commodity categories:
1. Fruits 2. Nuts & Ginseng 3. Vegetables 4. Fish & Shellfish 5. Chicken 6. Lamb & Goat
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Recordkeeping Item
• Recordkeeping Items for follow-up reviews will be included with the FY16 Retail Review list.
• You will be provided with a total of 6 letters, one for every commodity category.
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Requesting Records: Pre-Labeled Item
• For Pre-labeled items, retailers must provide record that identifies: – The Retailer’s Immediate Previous Supplier
(name, city and state) • The record is not required to have the
country of origin or method of production because that is printed on the pre-labeled item.
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Requesting Records: Non Pre-Labeled Item
• For items that are NOT Pre-labeled, retailer must provide a record that identifies the: – Country of origin, – Method of production (when applicable), and – Retailer’s immediate previous supplier (name,
city and state).
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Requesting Records
Multiple records may be provided to verify country of origin, method of production and immediate previous supplier. Example: For a Non pre-labeled item, the retailer provided the following records: üInvoice with the Retailer’s Supplier Name,
City, and State. üShipping Manifest with the country of origin
and method of production.
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What if the record item assigned is not sold in store?
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Record Item Assigned
• If the record item
assigned is not sold in store, skip to the next letter within the commodity category color.
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Recordkeeping Item Assigned
Example: COOL Division assigned records to be requested for the letters A, D, H, K, M, and O. • O-Goat Muscle Cuts or
Ground are not sold in store
• P-should be chosen as the replacement
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What if the store does not sell any items listed in the commodity category?
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Commodity Category Not Sold In Store
• If the store does not sell any items for the commodity category, place an X in the “Not Sold in Store” field corresponding to the commodity category.
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What if Retailer cannot provide records at the time of the
follow-up review?
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Records Request Form
• If the retailer cannot provide records at the time of the follow-up review, fill out the Records Request Form and leave it with the Responsible Authority at the time of your closing meeting.
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Records Request Form
• Retailer’s Responsible Authority is required to provide records within 5 business days from the request.
• Day 1 begins the day after the review is conducted.
Example: Follow-up review was conducted on Tuesday, July 5, 2016. Records will be due on Tuesday, July 12, 2016.
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What records would be required?
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What records would be required?
FRONT BACK
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What records would be required?
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What records would be required?
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Recording Unique Identifiers
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Were Records Provided
• Select Yes, if records were provided within 5 business days from the date the review was conducted.
• Select No, if records were NOT provided within 5 business days from the date the review was conducted.
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Actual Group Reviewed
• Select Actual Group Reviewed by using the drop down field.
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Item Information
• Enter Item Description and Country of Origin located on store label.
• Enter Item Description and Country of Origin located on record provided.
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Records Received
• Select Record Reviewed by using the drop down field.
• Workbook will allow you to enter information for up to 3 records.
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Transaction ID
• The Record Transaction ID field is very important! • The data entered in the Record Transaction ID field will
be used to conduct Supplier Traceback Audits. • Enter any information that is unique to the commodity
and can help ensure traceability.
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• Invoice # • PO # • Order # • Delivery Date • Establishment # • Brand name • Pack date
• Lot number • Package size • UPC # & PLU # • Production # • Item # • Best if used by
date
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Records Received
• Enter Record Transaction ID’s obtain from records.
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Supplier Information (Pre-Labeled Package)
• In the Supplier Information (Pre-Labeled Package) field, enter the information found on the pre-labeled package.
• This field applies to Pre-labeled items only.
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Supplier Information (Pre-Labeled Package)
• If recordkeeping item is NOT Pre-labeled enter “N/A” in the Supplier Information (Pre-Labeled Package) field.
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Retailer’s Immediate Previous Supplier
Information (Store Record) • For the Retailer’s IPS Supplier Information
(Store Record) field enter the information for the supplier that directly delivered commodity to the retailer.
• This field should ALWAYS be completed because it applies to BOTH pre-labeled and non pre-labeled recordkeeping commodities.
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Retailer’s Immediate Previous Supplier
Information (Store Record) • Include additional information such as
supplier phone number, fax, email, and website, if provided on record.
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Complete all recordkeeping sections as thoroughly as
possible! The more information provided the easier it will be to
conduct a traceback audit.
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Part C – Invoice Sample
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• Supplier’s Name and Address
• Invoice Number • Delivery Date • Invoice Date • Country of Origin • MOP
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Part C – Master Container • Box Serial #:2762060 • Pack Date: 4/06/15 • Establishment #: 244C • 09615CNC0117 01 • Net Weight lbs. 15.4 • Use by: 4/27/15 *If you are not sure what a number is, just write it down.
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Part C – Consumer Package
• Product Code: A12080P • UPC: 051933 21140 7 • Distributed by: Save-A-
Lot Foods Store, LTD, Earth City, MO 63015
• Product of Guatemala • Best by: may be listed • Product size: may be
listed
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Part C – Consumer Package
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• Product: Pecans chopped • Best By: 10/22/2015 • Lot: 29545B • UPC: 011213025919 • Distributed By: Spartan Stores Distribution Grand
Rapids, MI. 49518 • COO: Product of USA, Mexico
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Part C – Consumer Package
• Product Description: – Red Tart Cherries – pitted – Net Wt. 20 oz.
• Product Code: – FSM328007 20:50 – Best by Oct 2015 – Product of Turkey
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Recordkeeping Section Complete
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Step 1 – Complete Recordkeeping Section
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Follow-up Review Overview
Preparation for Review
• Review COOL Regulation and Retail Review Procedures • Prepare your Workbook
Conduct Review
• Opening Meeting • Review all 6 commodity categories for labeling non-compliances • Take pictures of all non-compliances • Request recordkeeping information • Closing Meeting
Submit Review
• Complete workbook by entering any recordkeeping information submitted by the retailer within the 5 business days.
• Organize, label, and consolidate pictures in one file • Submit Workbook to USDA
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How could the Recordkeeping be improved?
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How could the Recordkeeping be improved?
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How could the Recordkeeping be improved?
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T19597
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How could the Recordkeeping be improved?
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Questions?
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