08/31/2026
I’ve spent the last couple of days talking about beef imports, and today I want to talk about something that sounds really good on paper: Mandatory Country of Origin Labeling, or mCOOL.
First, an important clarification: mCOOL is NOT currently mandatory for beef and pork. Congress repealed the mandatory COOL requirements for beef and pork in 2015, and USDA stopped enforcing them.
There are current efforts in Congress to reinstate mCOOL for beef. One proposal, the American Beef Labeling Act of 2025, would bring beef back into the COOL system.
So what would that look like from a rancher's perspective?
Let me use our calves at Rockin J Spear Cattle as an example.
Every fall, our calves generally go down two very different paths.
🐂 PATH #1: RETAINED OWNERSHIP
I select a few calves to retain ownership of through our DTC program.
Those cattle remain right here on our property until their final journey to a local custom processing facility and ultimately onto the plate of our consumer.
Pretty simple.
I know where that animal was born.
I know where it was raised.
And I know where it was processed.
🐂 PATH #2: THE CONVENTIONAL MARKETING CHAIN
The rest of our calves are either sold through an online auction such as Superior Livestock Auction or through our local livestock sale barn.
From there, their journey can look very different.
They may be purchased by a backgrounder, who grows recently weaned cattle to a heavier weight before they move into the finishing phase.
Then they may be purchased by a finisher or feedlot, where cattle are fed a high-energy ration and managed until they reach market condition.
Eventually, the finished cattle are purchased by a packing plant, where they are harvested, fabricated and packaged before the beef moves on to a retailer, restaurant or other destination.
That is a LOT of hands, decisions and locations between my pasture and your dinner table and this is just for product of the USA BEEF!
Every hand that touches that particular product can have an effect on the end result.
What the animal is fed.
How it is handled.
How long it spends in each phase of production.
How long it is transported.
How it is handled at harvest.
How the carcass is chilled and fabricated.
How the beef is packaged and distributed.
All of those things matter.
Beef is not a product that grows on a plant, gets picked, put in a box and shipped to the consumer.
The beef industry is a complex supply chain.
And this is where mCOOL has that warm, feel-good appeal.
I understand why consumers like the idea. I am also a consumer!
Who doesn't want to look at a package of beef and know where that animal came from?
Transparency sounds good. And I believe consumers deserve accurate information about their food.
But here is the question I think we need to ask:
What does that transparency cost, and who ultimately pays for it? The consumer and price run hand in hand and in my personal experience, is ultimately the deciding factor at time of purchase.
A 2026 economic analysis commissioned by the Meat Institute estimated that reinstating mCOOL for beef and pork could create approximately $1.02 billion in additional costs during the first year, including an estimated $721 million associated with beef.
The study estimates those costs could total more than $4.8 billion over five years and $10.1 billion over ten years.
It is important to point out that these are estimates from one economic analysis, and the methodology has been challenged by organizations that support mCOOL.
But regardless of where you fall on the issue, the underlying point is important:
Tracking and documenting an animal's journey costs money.
Someone has to maintain records.
Someone has to verify them.
Someone has to keep cattle or beef separated when required.
Someone has to manage additional labeling, inventory, recordkeeping, auditing and compliance.
And those costs don't simply disappear.
They move through the supply chain.
The rancher can absorb some.
The backgrounder can absorb some.
The feedlot can absorb some.
The packer and processor can absorb some.
And eventually, some portion can make its way to the consumer.
The same 2026 analysis estimated that consumers could ultimately pay approximately $835 million more per year for beef because of these additional compliance costs.
Now, I know there are ranchers who strongly support mCOOL.
And I understand the argument.
I am NOT against transparency.
I'm also not saying consumers shouldn't want to know where their beef originated.
What I am saying is that we need to understand the whole story before we decide how that story should be labeled.
Because whether that calf is born in Colorado, raised in Colorado and processed locally, like the cattle I retain for our DTC customers, or whether it enters the conventional marketing chain and passes through several different owners and production phases, there are real people, real businesses and real costs involved at every step.
That same complexity exists when we talk about imported cattle or imported beef.
Every hand that touches the animal or product can change the end result.
So let's keep having the conversation.
What information does the consumer actually need?
What will that information cost?
Who will bear that cost?
Will the benefit to the consumer outweigh the cost of adding another layer of regulation to an already incredibly complicated beef supply chain?
I'm not against transparency.
I'm for understanding the whole story before we decide how to tell it.
Because that calf standing in my pasture today has a much longer story ahead of him than simply being “grown, picked, put in a box and shipped.”
Sources & further reading:
• USDA Agricultural Marketing Service — Country of Origin Labeling FAQs
• USDA FSIS — COOL requirements and current beef/pork labeling status
• Decision Innovation Solutions — The Economic Impact of mCOOL on the Beef and Pork Value Chains
• Superior Livestock Auction — How cattle are marketed through video/online auctions
• University of Nebraska–Lincoln Beef — Cattle production phases and backgrounding/finishing