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Does COOL Achieve Its Purpose?

Jim Prevor’s Perishable Pundit, July 7, 2009

An industry luminary suggested we consider the following issue:

The FDA has said it is going to begin surveillance to determine retail compliance for COOL, seven years after the legislation was enacted. Here’s my question:

Is there any evidence COOL has done anything except add cost to the system? Are consumers now better informed? And if informed, do they act on the information?

Many domestic producers felt that if people knew where their products came from, they would prefer domestic product. Any evidence of that? Do you get the idea that I already know the answer!

Those who argued against COOL said that all it would do is add cost because product origin has very little to do with purchase decisions at the point of purchase. And that continues to be the case.

This shows the foolishness of how the government legislates in areas they know little about. It also shows a major flaw in process. Energy is spent in passing a law, but little effort spent to study whether the law achieved its intended purpose or if there were any unintended effects from the law.

We wrote quite a bit about country-of-origin labeling when it was still under negotiation, including a cover story in Pundit sister publication, PRODUCE BUSINESS, entitled Country-Of-Origin-Labeling: Nothing Cool About It . We were more than a little skeptical.

Basically the problem was that producers who were advocating for the program had a goal that was not likely to be realized. These producers believed that consumers, if made knowledgeable as to the origin of their produce, would in significant numbers decline to purchase foreign-produced produce and, instead, buy produce of the USA.

We knew of no reason to think that was true before passage and conversations with retailers have indicated no such effect after the implementation of COOL.

Yes, of course, when surveyed, consumers would make the politically correct noise about wanting to know where their food comes from but when it comes to behavior, the effect just isn’t there. Bryan Silbermann, President of the Produce Marketing Association, and the Pundit had an exchange on this subject in Pundit sister publication, PRODUCE BUSINESS.

Our correspondent looks at the history here and raises a big problem with our public policy efforts. All too often, what is wanted is simply a victory of some sort: A law enacted, a regulation approved. Whether those laws or regulations ever accomplish what they were sold as going to accomplish is virtually irrelevant and rarely followed up on.

Of course, this is not only an issue that involves the government. We raised the issue here of whether PBH was achieving its self-professed goal of increasing consumption? We have asked here whether the newly proposed generic promotion order is being proposed in such a way that there would be real metrics available for judging its success or failure?

We are probably going to have to live with COOL, but the process that produced it is deeply troubled. We should try very hard to find a better way.

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