oversight

Fresh Produce: Potential Consequences of Country-of-Origin Labeling

Published by the Government Accountability Office on 1999-04-21.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                  United States General Accounting Office

GAO               Report to Congressional Committees




April 1999
                  FRESH PRODUCE
                  Potential
                  Consequences of
                  Country-of-Origin
                  Labeling




GAO/RCED-99-112
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Resources, Community, and
      Economic Development Division

      B-282173

      April 21, 1999

      The Honorable Thad Cochran
      Chairman
      The Honorable Herb Kohl
      Ranking Minority Member
      Subcommittee on Agriculture, Rural
        Development, and Related Agencies
      Committee on Appropriations
      United States Senate

      The Honorable Joe Skeen
      Chairman
      The Honorable Marcy Kaptur
      Ranking Minority Member
      Subcommittee on Agriculture, Rural
        Development, Food and Drug Administration,
        and Related Agencies
      Committee on Appropriations
      House of Representatives

      The containers in which fresh produce of foreign origin enters the United
      States must be marked with the country-of-origin. However, this
      identification is not required to be maintained for loose, or bulk, produce
      at the retail level.1 In the past few years, several legislative proposals have
      been introduced to require that fresh produce be labeled at the retail level
      by its country of origin.

      As requested by the Senate and House conferees for the Omnibus
      Consolidated and Emergency Supplemental Appropriations Act, 1999,2 we
      reviewed a number of issues associated with the potential costs and
      benefits of a mandatory labeling requirement. Specifically, as agreed with
      your offices, this report provides information on (1) the potential costs
      associated with the compliance and enforcement of a mandatory
      country-of-origin labeling requirement at the retail level for fresh produce,
      (2) the potential trade issues associated with such a requirement, (3) the
      potential impact of such a requirement on the ability of the federal
      government and the public to respond to outbreaks of illness caused by
      contaminated fresh produce, and (4) consumers’ views of

      1
       This report uses the term “loose produce” to refer to bulk produce.
      2
      Conference Report 105-825 accompanied H.R. 4328, which became the Omnibus Consolidated and
      Emergency Supplemental Appropriations Act, 1999 (P.L. 105-277, Oct. 21, 1998).



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                   country-of-origin labeling. Finally, appendix I identifies U.S. trading
                   partners that have country-of-origin labeling requirements for fresh
                   produce, the nature and scope of those requirements, and the record of
                   U.S. challenges to those requirements.

                   For the purpose of this report, and as agreed with your offices, we
                   assumed that the retailer would be responsible for ensuring that produce
                   is labeled as to its country of origin and that the term “label” means any
                   label, mark, sticker, stamp, placard, or other clear visible sign.


                   The magnitude of compliance and enforcement costs for a
Results in Brief   country-of-origin labeling requirement at the retail level would depend on
                   several factors, including the extent to which current labeling practices
                   would have to be changed. According to an association representing
                   grocery retailers, changing store signs to ensure that produce is properly
                   labeled would cost about 2 staff hours per store per week. However, it is
                   unclear who would bear the burden of any such additional labeling
                   costs—retailers could absorb some or all of the costs or pass them to
                   consumers or to their suppliers. Regarding enforcement, the Food and
                   Drug Administration, in commenting on a recently proposed bill, estimated
                   that federal monitoring would cost about $56 million annually and said
                   that enforcement would be difficult. Inspectors would need documentary
                   evidence to determine the country-of-origin of the many produce items on
                   display, and this documentation is often not available at each retail store.
                   Enforcement is carried out in only one of the three states with labeling
                   laws—in Florida, where inspectors check shipping boxes against display
                   signs during semiannual routine state health inspections. Florida
                   inspectors told us that they sometimes have no reliable means to verify the
                   accuracy of labels.

                   According to U.S. Department of Agriculture officials and industry
                   representatives, mandatory labeling at the retail level could be viewed by
                   other countries as a trade barrier. For example, a country currently
                   exporting produce to the United States may be concerned about the
                   additional costs its exporters may incur if they are required to label loose
                   produce. Officials also noted that countries concerned with a labeling law
                   could take actions that could adversely affect U.S. exports. For example,
                   these countries may develop or more strictly enforce their own labeling
                   laws. Currently, about half of the countries that account for most of the
                   U.S. trade in produce require country-of-origin labeling for fresh produce
                   at the retail level. Additionally, officials from the departments of



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             Agriculture and State believe that a U.S. labeling law is more likely to be
             challenged than other countries’ labeling laws because the United States is
             such a large importer and exporter of fresh produce.

             When outbreaks of foodborne illness occur, country-of-origin labeling for
             fresh produce would be of limited benefit to food safety agencies in
             tracing the source of contamination and to the public in responding to a
             warning of an outbreak, according to officials from the Food and Drug
             Administration and the Centers for Disease Control and Prevention. It can
             take weeks or months for food safety agencies to identify an outbreak,
             determine the type of food involved, identify the source of the food
             contamination, and issue a warning. Retail labeling would help consumers
             only if they remembered the country of origin or still had the produce, or if
             the produce were still in the store.

             Finally, according to nationwide surveys sponsored by the fresh produce
             industry, between 74 and 83 percent of consumers favor mandatory
             country-of-origin labeling for fresh produce, although they rated
             information on freshness, nutrition, and handling and storage as more
             important.3 Most consumers also prefer to buy domestic produce if price,
             taste, and appearance are equal. In addition, survey responses show that
             consumers believe that U.S. produce is safer than imported produce;
             however, officials from the U.S. Department of Agriculture, the Food and
             Drug Administration, and the Centers for Disease Control and Prevention
             told us that sufficient data are not available to make this determination.


             The Tariff Act of 1930, as amended, generally requires imported
Background   articles—such as clothing, appliances, and canned and frozen goods—to
             be marked by country of origin. Under the statute, however, certain
             articles, including fresh produce, are not required to be marked
             individually. For these items, the container holding the article must be
             marked by the country of origin. U.S. Customs Service rulings provide that
             when fresh produce is taken out of its container and put into an open bin




             3
              Based on nationally representative samples of U.S. households: Three surveys were conducted
             between 1990 and 1998 by Vance Publishing Corporation for The Packer newspaper and were
             published in its annual supplement, Fresh Trends and one survey was conducted by the Charlton
             Research Group in 1996 for the Desert Grape Growers League. For the data we included in our report,
             we obtained frequency counts, survey instruments, and other documents, in order to review the
             wording of questions, sampling, mode of administration, research strategies, and the effects of
             sponsorship. We used only the data that we judged to be reliable and valid.



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or display rack, there is no obligation to identify the items by the country
of origin.4

Three states—Florida, Maine, and Texas—have enacted country-of-origin
labeling laws for fresh produce. Florida requires all imported fresh
produce to be identified by the country-of-origin by, for example, marking
each produce item or placing a sign or label adjacent to the bin. Maine
requires country-of-origin labeling for fresh produce at the retail level
when it has been imported from countries identified as having specific
pesticide violations.5 Texas requires country-of-origin labeling for fresh
grapefruit. In addition, labeling laws for fresh produce have been proposed
in at least five other states: California, Connecticut, Oregon, Rhode Island,
and Virginia.

Most large grocery stores carry over 200 produce items. Fresh produce is
often imported to fill seasonal needs when U.S. production is not sufficient
to cover demand or to satisfy the demand for tropical fruits not normally
grown in the United States. Two-thirds of imported fresh produce arrives
between December and April, when U.S. production is low and limited to
the southern portions of the country. The majority of these imports are
warm-season vegetables like peppers, squash, and cucumbers, although
some imports, such as tomatoes, occur year round.

Total U.S. consumption of fresh produce has increased 43 percent since
1980, from about 56 billion pounds to nearly 80 billion pounds in 1997, the
latest year for which the U.S. Department of Agriculture (USDA) has
compiled such data. During this same period, the amount of fresh produce
the United States imported more than doubled—from 7.5 billion pounds to
16 billion pounds. The domestic share increased by one third—from about
48 billion to about 64 billion pounds.

In 1997, most imported produce came from Mexico, Canada, and Chile, as
shown in figure 1.




4
 U.S. Customs ruling HRL 722992. This ruling was interpreted in Customs ruling HRL 733798 not to
require marking because open bins or display racks were not determined to constitute ‘containers.’
5
 Maine also requires packages of Maine apples to state that they are from Maine and potatoes
packaged in Maine to be labeled as to their country-of-origin.



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Figure 1: Source of Fresh and Frozen
Imported Produce, 1997, by Dollar
Value
                                                                                         2%
                                                                                         Guatemala

                                                                                         3%
                                                                                         Netherlands


                                                                •
                                                                     •                   4%
                                                                                         Costa Rica

                                                                     12%
                                                                       •

                                            51%
                                              •                          13%
                                                                           •


                                                                    15%
                                                                      •



                                                                                         Chile

                                                                                         Other

                                                                                         Canada

                                                                                         Mexico




                                       Source: GAO’s analysis of data from USDA’s Economic Research Service.




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                           The United States is also the world’s largest exporter of fresh produce,
                           valued at $2.9 billion in 1998. Three-fourths of exported U.S. produce goes
                           to Canada, the European Union, Japan, Hong Kong, and Mexico.6


                           Complying with mandatory country-of-origin labeling for fresh produce
Uncertainties Exist        could change the way retailers and others involved in the production and
About the Costs            distribution of produce do business, thereby affecting their costs and
Associated With            consumers’ choices. Furthermore, such a law could be difficult to enforce.
Compliance and
Enforcement
Magnitude of Compliance    The fresh produce industry and retailers will have to incur costs to comply
Costs and the              with a mandatory country-of-origin labeling law. The additional efforts and
Responsibility for These   associated costs for compliance would depend on the specific
                           requirements of the law and the extent to which current practices would
Costs Are Uncertain        have to be changed. For example, some produce is already labeled with a
                           brand sticker. In these cases, compliance would require adding the name
                           of the country to the sticker. For unlabeled produce, the additional effort
                           would be more significant.

                           Associations we spoke with representing grocery retailers are particularly
                           concerned that a labeling law would be unduly burdensome for a number
                           of reasons. First, retailers would have to display the same produce items
                           from different countries separately if each individual item is not marked,
                           which in some cases would result in only partially filled bins. According to
                           these retailers, consumers are less likely to buy from such bins because
                           they are less appealing, causing the retailers to lose sales. Second, retailers
                           report that they do not have sufficient display space to separate produce
                           and still stock all the different varieties consumers want. Large grocery
                           stores usually carry over 200 produce items. Third, because the country of
                           origin of retailers’ produce shipments may vary each week, retailers would
                           incur costs to change store signs and labels to reflect the origins of the
                           different shipments. According to the Food Marketing Institute, an
                           association representing grocery retailers, it would take about 2 staff
                           hours per store per week to ensure that imported produce is properly
                           labeled. Costs would also be incurred if retailers were required to maintain
                           paperwork at each store as evidence of the origin of these multiple



                           6
                            The European Union is composed of Austria, Belgium, Denmark, Finland, France, Germany, Greece,
                           Ireland, Italy, Luxembourg, the Netherlands, Portugal, Spain, Sweden, and the United Kingdom.



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shipments. Florida does not require its retail stores to maintain paperwork
documenting the country of origin.

It is unclear who would bear the burden of compliance. A law requiring
retailers to ensure that produce is properly labeled would initially place at
least some of the compliance costs on retailers. However, retailers would
not necessarily bear all these costs. Retailers could raise prices to pass
their costs to consumers. However, if consumers reduce their purchases of
fresh produce in response, retailers will absorb part of the cost through
lower sales volume. For produce that does not have close substitutes, and
for which consumer demand is relatively insensitive to price changes,
retailers are likely to be more successful in passing costs on to consumers
through price increases without experiencing significant declines in sales
volume.

Retailers may decide to require their suppliers to either package produce
or label individual produce items. If retailers can impose this requirement
without paying more for the same quantity and quality, they will have
shifted the labeling costs to their suppliers. Consumer responses may also
influence the eventual effect of a country-of-origin law. If consumers
prefer domestic produce, they may buy more domestic and less imported
produce, which would allow domestic producers to gain market share
and/or raise their prices. However, if foreign countries respond by
imposing their own labeling requirements, and if this resulted in foreign
consumers’ buying less U.S. produce, then U.S. exports could suffer.

It is also possible that a country-of-origin labeling requirement would
result in fewer choices for consumers. This would occur if retailers decide
to stock more prepackaged produce, which would already be labeled, and
fewer bulk items, which would have to be labeled. Furthermore, if a law
required labeling for imported produce only, retailers could decide to
stock fewer imported produce items in order to avoid the compliance
burden.

An additional cost would be borne by restaurants and other food service
providers if the labeling law applies to them. They would have to let their
customers know the country of origin of the produce they use, which
could involve, for example, changing information on menus each time the
source of the produce changed. According to the National Restaurant
Association, the cost of changing menus would be “prohibitive.”




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Federal Agencies Would      According to Food and Drug Administration (FDA) and USDA officials we
Need Enforcement            spoke with, enforcing a labeling law would require significant additional
Resources for an            resources. The agency enforcing such a law would have to implement a
                            system to ensure that the identity of produce is maintained throughout the
Inherently Difficult Task   distribution chain. While inspectors could ensure that retailers have signs
                            or labels in place and could review documentation—if it were
                            available—they might not be able to determine from a visual inspection
                            that produce in a particular bin was from the country designated on the
                            sign or label. Such documentation is often unavailable at the retail store.

                            It is also unclear who would be responsible for these inspections. Grocery
                            store inspections for compliance with federal health and safety laws are
                            now generally conducted by state and local officials, often under
                            memorandums of understanding with the Food and Drug Administration.
                            USDA officials pointed out that if state and local governments were to carry
                            out the inspections required by a federal country-of-origin labeling law,
                            such a law would have to specify the states’ enforcement role and provide
                            funding for enforcement activities.

                            In commenting on a Senate amendment to the fiscal year 1999
                            appropriations bill regarding country-of-origin labeling, FDA expressed
                            “reservations about its priority as a public health issue, its cost to
                            administer, and [FDA’s] ability to enforce it.” FDA further noted that the
                            cost of enforcement “would be significant,” and “it is unclear that
                            enforcement would even be possible.” Among other enforcement
                            problems, FDA cited the need for accompanying paperwork to verify
                            country-of-origin labels and said this would place “an enormous burden”
                            on industry. FDA estimated that the federal cost for 1-year’s monitoring
                            under this proposed amendment would be about $56 million.

                            The three states that have labeling laws vary in their degree of
                            enforcement. In Florida, which has a mandatory labeling law for all
                            imported produce, enforcement occurs during the course of routine state
                            health inspections that are conducted about twice each year in every
                            store. During the routine inspections, officials check the shipping boxes
                            and packages in the store against the display signs or labels—a task they
                            estimate requires about 15 minutes per visit. However, they said they
                            sometimes have no reliable means to verify the accuracy of these signs
                            and labels. When violations are found, Florida officials said that it takes 5
                            minutes to process paperwork for new violations and 30 minutes for
                            repeat violations. Figure 2 shows produce labeled in Florida grocery
                            stores.



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Figure 2: Labeled Produce in Florida Grocery Stores




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                       According to the Inspection Manager for Maine’s Department of
                       Agriculture, Maine does not enforce its country-of-origin labeling
                       requirements because the list of countries to be identified keeps changing
                       and paperwork to verify the country of origin is often unavailable. In
                       Texas, the labeling law applies only to grapefruit. According to a Texas
                       Department of Agriculture official, grapefruit is rarely imported into
                       Texas, and the labeling law is not currently being enforced.


                       Depending on what it might require and how it might be implemented, a
A Labeling Law Could   law mandating country-of-origin labeling for fresh produce could have
Have Trade             adverse trade implications. U.S. trading partners might challenge the law’s
Implications           consistency with international trade obligations or take steps to increase
                       their own country-of-origin labeling requirements. Moreover, according to
                       USDA officials, enacting a labeling law could make it more difficult for the
                       United States to oppose foreign countries’ labeling requirements that it
                       finds objectionable.

                       Any labeling law would need to be consistent with U.S. international trade
                       obligations in order to withstand potential challenges from U.S. trading
                       partners. International trade rules that the United States has agreed to,
                       such as those embodied in the World Trade Organization (WTO) and the
                       North American Free Trade Agreement (NAFTA), permit country-of-origin
                       labeling.7 For example, WTO provisions recognize the need to protect
                       consumers from inaccurate information while minimizing the difficulties
                       and inconveniences labeling measures may cause to commerce. WTO rules
                       require, among other things, that the labeling of imported products must
                       not result in serious damage to the product, a material reduction in its
                       value, or an unreasonable increase in its cost.8 Correspondence from the
                       Office of the U.S. Trade Representative (USTR) stated that our trading
                       partners could raise concerns that country-of-origin labeling requirements
                       adversely affect their exports by raising costs.

                       Similarly, NAFTA requires that any country-of-origin marking requirement
                       must be applied in a manner that would minimize difficulties, costs, and


                       7
                        The WTO was established in 1995, as a result of the Uruguay Round of the General Agreement on
                       Tariffs and Trade (1986-94). WTO facilitates the implementation, administration, and operation of
                       multiple agreements that govern trade among its member countries. NAFTA is a multilateral trade
                       agreement that contains obligations governing trade among Canada, Mexico, and the United States.
                       NAFTA negotiations began in 1991 and the agreement entered into force in 1994.
                       8
                        In addition, country-of-origin labeling is covered as a technical regulation subject to the WTO
                       Agreement on Technical Barriers to Trade. This agreement provides guidelines for developing and
                       applying technical regulations.



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inconveniences to a country’s commerce. USTR and Department of State
officials stated that Mexico requested consultations to discuss its concerns
that one recently proposed U.S. country-of-origin labeling bill would
violate certain NAFTA provisions on country-of-origin marking.

USDA  officials and food industry representatives expressed concern that
mandatory country-of-origin labeling at the retail level could be viewed as
a trade barrier and might lead to actions that could hurt U.S. exports. For
example, a country currently exporting produce to the United States may
be concerned about additional costs if its exporters are required to label
loose produce. Such a country could respond by enacting or more strictly
enforcing retail labeling laws that could hinder U.S. exports. The officials
were also concerned that adopting mandatory country-of-origin labeling at
the retail level could complicate U.S. efforts to address other countries’
labeling laws that the United States found objectionable. According to
USDA officials, the United States has opposed certain country-of-origin
labeling in other countries for various reasons, including concerns about
the potential of those laws to raise the costs of U.S. exports and
discourage consumers from purchasing imported goods.

While U.S. representatives have worked informally and cooperatively to
oppose certain foreign country-of-origin labeling requirements, the United
States has not formally challenged any such requirements within the WTO.
WTO officials said they were unaware of any formal challenges to any
country’s country-of-origin labeling requirement. However, USDA and WTO
officials agreed that the absence of any formal challenge does not
necessarily indicate that existing country-of-origin labeling requirements
are consistent with WTO rules. Moreover, the absence of formal challenges
to existing laws does not preclude these laws from being challenged in the
future. Finally, because the United States is such a large importer and
exporter of fresh produce, officials with USDA and the Department of State
pointed out that a U.S. labeling law is more likely to be formally
challenged than are other countries’ laws.

In February and March 1999, we surveyed U.S. embassy agricultural
attachés in 45 countries with which the United States exports and imports
agricultural products to determine which countries have and enforce
country-of-origin labeling requirements for fresh produce at the retail
level. Our survey included 28 countries that account for most of the U.S.
produce imports and exports and 17 countries that USDA identified as
having produce labeling requirements.9 Of the 28 countries, 13 (46 percent)

9
 USDA surveyed these countries in 1998.



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                      require country-of-origin labeling for bulk produce at the retail level, and
                      15 require such labeling for packaged produce.10 Attachés in these
                      countries reported the countries with requirements generally have a high
                      level of compliance and moderate to high levels of enforcement.11
                      Appendix I identifies the U.S. trading partners that require
                      country-of-origin labeling for fresh produce and the scope of their
                      requirements.


                      Considerable time—several weeks or months—generally passes between
Labeling Would        the outbreak of a produce-related illness, the identification of the cause,
Provide Limited       and a warning to the public about the risks of eating a specific produce
Benefits in           item, according to the Centers for Disease Control and Prevention (CDC)
                      and FDA officials. By the time a warning is issued, country-of-origin
Responding to         labeling would benefit consumers only if they remembered the country of
Outbreaks of          origin or still had the produce, or if the produce were still in the store.
                      Consequently, country-of-origin labeling would be of limited value in
Foodborne Illnesses   helping consumers respond to a warning of an outbreak.

                      Several factors contribute to the delays in identifying causes of foodborne
                      illness, including how quickly consumers become ill after purchasing and
                      eating the food and whether they seek medical attention. State and local
                      agencies report known or suspected foodborne illnesses to CDC, which
                      uses this information to identify patterns of related
                      illnesses—outbreaks—and to work with state, local, and FDA officials to
                      identify the source. Once the source is identified, state and local public
                      health officials generally issue a warning to the public if the product is still
                      available in the marketplace.

                      In most cases of foodborne illness, however, officials are not able to
                      identify the specific point at which the food associated with the outbreak
                      became contaminated. Between 1990 and 1998, CDC identified 98 outbreaks
                      of foodborne illnesses linked to fresh produce. In 86 of these cases, the
                      point of contamination was never identified. The remaining 12 cases were
                      traced to contamination in food handling and to seed that was
                      contaminated. Appendix II provides information on outbreaks of illnesses
                      related to contaminated fresh produce since 1990.


                      10
                        The European Union (EU) has a single requirement for labeling of both loose and packaged produce
                      that applies to all 15 EU member countries. Our 28 largest produce trading partners include 6 EU
                      member countries.
                      11
                        Although the EU has a single labeling requirement for all 15 member countries, we surveyed these
                      countries individually to obtain a better understanding of compliance and enforcement with the
                      labeling requirement.


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                        Because of the time needed to identify the cause of an outbreak,
                        country-of-origin labeling would not generally be useful in preventing
                        more consumers from becoming ill. For example, when
                        cyclospora-contaminated raspberries from Guatemala caused outbreaks of
                        illnesses in 1996 and 1997, many individuals did not become ill until a
                        week or more after they ate the fruit.

                        CDC  officials said that country-of-origin labeling might be a starting point in
                        tracing the source of contamination if a person who had eaten a
                        contaminated product remembered the source for that product. However,
                        they said that more detailed information identifying every step from farm
                        to table—for both domestically grown and imported produce—would be
                        of greater use in tracing the source of an outbreak and identifying the
                        practices that resulted in the contamination. Identifying such practices
                        may enable officials to devise control measures that could be used
                        throughout the industry to decrease the potential for additional illnesses.
                        CDC officials also pointed out that a country-of-origin labeling law would
                        be more useful to them if it required retailers to keep better records,
                        including invoices and shipping documents. Such records would allow
                        investigators to identify the source of produce that was in grocery stores
                        at a particular time in the past.

                        Finally, FDA and CDC officials observed that a law exempting food service
                        establishments from country-of-origin labeling would be of limited value
                        because many identified outbreaks have been traced to food served in
                        restaurants or at catered meals. U.S. consumers are eating more meals,
                        including more fresh produce, outside the home. Indeed, a significant
                        portion of the illnesses that were traced to Guatemalan raspberries were
                        contracted from meals eaten outside the home.


                        Surveys representing households nationwide, sponsored by the produce
Although Consumers      industry between 1990 and 1998, showed that between 74 and 83 percent
Favor Labeling, Other   of consumers favor mandatory country-of-origin labeling for fresh produce
Information Is More     at the retail level.12 However, when asked to rate the importance of several
                        types of labeling information, households reported information on
Important to Them       freshness as most important, followed by information on nutrition, storage



                        12
                          Surveys conducted for The Packer newspaper in 1990, 1992, and 1998 and for the Desert Grape
                        Growers League in 1996. For the data we included in our report, we obtained frequency counts, survey
                        instruments, and other documents, in order to review question wording, sampling, mode of
                        administration, research strategies, and the effects of sponsorship. We only used data that we judged
                        to be reliable and valid.



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                                         and handling, and preparation tips. Information on country-of-origin was
                                         ranked fifth, as shown in figure 3.13



Figure 3: Importance of Different Types of Produce-Labeling Information to Consumers




                                         Source: GAO’s analysis of 1996 survey data collected for The Packer, a publication of the fresh
                                         produce industry.




                                         In addition, most consumers would prefer to buy U.S. produce if all other
                                         factors—price, taste and appearance—were equal.14 And, about half of all
                                         consumers would be willing to pay “a little more to get U.S. produce.”15
                                         However, the survey did not specify the additional amount that consumers
                                         would be willing to pay.


                                         13
                                           Survey conducted for The Packer newspaper in 1996.
                                         14
                                           Survey conducted for the Desert Grape Growers League in 1996.
                                         15
                                           Survey conducted for the Desert Grape Growers League in 1996.



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                   Furthermore, according to a 1998 industry-sponsored nationwide survey,
                   70 percent of consumers believe that domestically grown produce is
                   safer.16 In the same survey, about half of consumers reported having
                   concerns about health and safety and growing conditions, and about
                   one-third had concerns with cleanliness and handling when buying
                   imported produce. Despite these concerns, officials with USDA, CDC, and
                   FDA, told us that sufficient data are not available to compare the safety of
                   domestic and imported produce. However, CDC officials told us that, in the
                   absence of specific food production controls, the potential for
                   contaminated produce increases where poor sanitary conditions and
                   polluted water are more prevalent.

                   In addition, Consumers Union—a nationally recognized consumer
                   group—used data collected by USDA’s Agricultural Marketing Service to
                   compare the extent to which multiple pesticide residues were found in
                   selected domestic and imported fresh produce.17 For its analysis,
                   Consumers Union developed a toxicity index, which it used to compare
                   the pesticide residues. According to this analysis, pesticide residues on
                   imported peaches, winter squash, apples, and green beans had lower
                   toxicity levels than those found on their domestically grown counterparts.
                   In contrast, the pesticide residues on domestically grown tomatoes and
                   grapes were less toxic than their imported counterparts. The study
                   acknowledges that almost all of the pesticide residues on the samples
                   were within the tolerance levels allowed by the Environmental Protection
                   Agency (EPA). We did not independently determine the validity of the
                   toxicity index developed by Consumers Union or verify its analysis or
                   results. However, according to FDA officials, pesticide residues present a
                   lower health risk than the disease-causing bacteria that can be found on
                   food.


                   We provided the departments of Agriculture and State, Office of the U.S.
Agency Comments    Trade Representative, CDC, U.S. Customs Service, EPA, and FDA with a draft
and Our Response   of this report for their review and comment. These agencies generally
                   agreed with the facts presented in the report and provided technical
                   comments, which we incorporated as appropriate. Officials commenting
                   on the report included the Deputy Administrator, Fruit and Vegetable
                   Programs, Agricultural Marketing Service, USDA; the

                   16
                     Survey conducted for The Packer newspaper. Twenty percent said U.S. produce was about the same,
                   3 percent—worse, and 6 percent—don’t know.
                   17
                    Do You Know What You Are Eating? An Analysis of U.S. Government Data on Pesticide Residues in
                   Foods, Consumers Union, Feb. 1999.



                   Page 15                                          GAO/RCED-99-112 Country-of-Origin Labeling
B-282173




Economic/Commercial Officer in the Agricultural Trade Policy Division,
Department of State; the Director of Agricultural Affairs and Technical
Barriers to Trade, Office of the U.S. Trade Representative; the Director of
Food Safety Initiative Activities, Division of Bacterial and Mycotic
Diseases, National Center for Infectious Diseases, CDC; a Senior Attorney,
Office of Regulations and Rulings, U.S. Customs Service; the Interim
Associate Commissioner for Legislative Affairs, FDA.


We performed our review from November 1998 through March 1999 in
accordance with generally accepted government auditing standards. Our
scope and methodology are discussed in appendix III.

Copies of this report will be sent to Senator Richard Lugar, Chairman, and
Senator Tom Harkin, Ranking Minority Member, Senate Committee on
Agriculture, Nutrition, and Forestry; and Representative Larry Combest,
Chairman, and Representative Charles Stenholm, Ranking Minority
Member, House Committee on Agriculture. We are also sending copies to
the Honorable Dan Glickman, Secretary of Agriculture; the Honorable
Madeleine Korbel Albright, Secretary of State; the Honorable Jane Henney,
M.D., Commissioner, Food and Drug Administration; the Honorable
Jeffrey P. Koplan, M.D., Director, Centers for Disease Control and
Prevention; the Honorable Raymond W. Kelly, Commissioner of the U.S.
Customs Service; the Honorable Jacob J. Lew, Office of Management and
Budget; and Ambassador Charlene Barshefsky, the U.S. Trade
Representative. We will also make copies available to others upon request.

If you would like more information on this report, please contact me at
(202) 512-5138. Major contributors to this report are listed in appendix IV.




Robert E. Robertson
Associate Director, Food
  and Agriculture Issues




Page 16                                GAO/RCED-99-112 Country-of-Origin Labeling
Page 17   GAO/RCED-99-112 Country-of-Origin Labeling
Contents



Letter                                                                                                1


Appendix I                                                                                           20
U.S. Trading Partners
That Require
Country-Of-Origin
Labeling for Fresh
Produce and the
Scope of Their
Requirements
Appendix II                                                                                          23
Information on
Outbreaks of Illnesses
Related to Fresh
Produce
Appendix III                                                                                         28
Objectives, Scope,
and Methodology
Appendix IV                                                                                          31
Major Contributors to
This Report
Tables                   Table I.1: Trading Partner Countries’ Requirements for                      20
                           Country-of-Origin Labeling of Fresh Produce at the Retail Level
                         Table II.1: Outbreaks Associated With Fresh Produce in the                  23
                           United States Reported to CDC, 1990-98


Figures                  Figure 1: Source of Fresh and Frozen Imported Produce, 1997, by              5
                           dollar value
                         Figure 2: Labeled Produce in Florida Grocery Stores                          9




                         Page 18                              GAO/RCED-99-112 Country-of-Origin Labeling
Contents




Figure 3: Importance of Different Types of Produce-Labeling                14
  Information to Consumers




Abbreviations

CDC        Centers for Disease Control and Prevention
EPA        Environmental Protection Agency
EU         European Union
FDA        Food and Drug Administration
NAFTA      North America Free Trade Agreement
USDA       U.S. Department of Agriculture
WTO        World Trade Organization


Page 19                             GAO/RCED-99-112 Country-of-Origin Labeling
Appendix I

U.S. Trading Partners That Require
Country-Of-Origin Labeling for Fresh
Produce and the Scope of Their
Requirements
                                            This appendix identifies the U.S. trading partners that have
                                            country-of-origin labeling requirements for fresh produce at the retail
                                            level, the nature and scope of these requirements, and the record of U.S.
                                            challenges to those requirements.

                                            Table I.1 identifies U.S. trading partner countries, their requirements for
                                            loose or packaged fresh produce to be labeled at the retail level, and the
                                            degree of compliance and enforcement with those requirements. This
                                            information is based on our survey of U.S. agricultural attachés for 45
                                            countries. Of the 45 countries, 28 account for most of U.S. trade in
                                            produce. We also surveyed the 17 countries that were not among the
                                            largest produce trading partners but were identified in the Foreign
                                            Agricultural Service’s 1998 Foreign Country of Origin Labeling Survey as
                                            having produce labeling requirements. As the table indicates, 13 of the 28
                                            major produce trading partners require country-of-origin labeling for loose
                                            produce at the retail level, and 15 require labeling for packaged produce.
                                            Attachés reported that these countries generally have a high level of
                                            compliance and a moderate to high level of enforcement.

                                            Officials of the World Trade Organization, the departments of Agriculture
                                            and State, the Office of the U.S. Trade Representative, and U.S.
                                            agricultural attaches were not able to identify any formal U.S. challenges
                                            to country-of-origin labeling requirements for fresh produce.


Table I.1: Trading Partner Countries’ Requirements for Country-Of-Origin Labeling of Fresh Produce at the Retail Level
                                     Scope of labeling            Degree of                     Degree of
Country                              requirement                  compliance                    enforcement
Major produce trading partners (28)
Argentina                             No requirement
                                                                   a                             a
Australia                             Loose and packaged
Brazil                                Packaged                     High                          Moderate
Canada                                Looseb and packaged          High                          High
Chile                                 No requirement
Costa Rica                            Packaged                     High                          Moderate
Dominican Republic                    No requirement
European Union                        Loose and packaged
  Belgium                                                          Very high                     Moderate
  France                                                           Very high                     Very high
  Luxembourg                                                       Very high                     Moderate
  Netherlands                                                      High                          High
  Spain                                                            High                          High
                                                                                                                    (continued)


                                            Page 20                                  GAO/RCED-99-112 Country-of-Origin Labeling
                                      Appendix I
                                      U.S. Trading Partners That Require
                                      Country-Of-Origin Labeling for Fresh
                                      Produce and the Scope of Their
                                      Requirements




                                Scope of labeling              Degree of                 Degree of
Country                         requirement                    compliance                enforcement
  United Kingdom                                               Very high                 Very high
Guatemala                       No requirement
Honduras                        No requirement
Hong Kong                       No requirement
Indonesia                       No requirement
Japan                           Loose and packagedc            High                      High
Malaysia                        No requirement
Mexico                          Loose and packaged             High                      Moderate
New Zealand                     No requirement
Peru                            Loose and packaged             High                      Moderate
Philippines                     No requirement
Republic of Korea               Loose and packaged             High                      High
Republic of South Africa        Loose and packaged             Moderate                  Moderate
Singapore                       No requirement
Taiwan                          No requirement
Thailand                        No requirement


Other countries surveyed (17)
Czech Republic                  Packaged                       High                      Moderate
Egypt                           Loose and packaged             High                      Very high
European Union                  Loose and packaged
  Austria                                                      Very high                 Very high
  Denmark                                                      Very high                 Moderate
  Finland                                                      High                      Moderate
  Germany                                                      High                      High
  Greece                                                       Very high                 Very high
  Ireland                                                      Very high                 Very high
  Italy                                                        High                      High
  Portugal                                                     High                      High
  Sweden                                                       High                      Moderate
                                                               a
Hungary                         Loose and packaged                                       Moderate
Israel                          No requirement
Russia                          Loose and packaged             Moderate                  Moderate
Switzerland                     Loose and packaged             Very high                 Very high
United Arab Emirates            No requirement
Venezuela                       No requirement

                                                                                                (Table notes on next page)




                                      Page 21                                GAO/RCED-99-112 Country-of-Origin Labeling
Appendix I
U.S. Trading Partners That Require
Country-Of-Origin Labeling for Fresh
Produce and the Scope of Their
Requirements




Source: GAO survey
a
Agricultural attaches were uncertain about this information.
b
 Requirements for labeling loose produce are provincial government requirements and do not
include all Canadian provinces.
c
 Requirements currently apply to broccoli, taro, garlic, ginger, wet shitake mushrooms, edible
burdock, asparagus, field peas, and onions. According to U.S. Department of Agriculture
correspondence, labeling of all produce at the retail level will be required in Japan beginning
April 1, 2000.

Note: The European Union requires country-of-origin labeling for loose and packaged fresh
produce.




Page 22                                            GAO/RCED-99-112 Country-of-Origin Labeling
Appendix II

Information on Outbreaks of Illnesses
Related to Fresh Produce

                                           Table II.1 provides information on the 98 outbreaks of produce-related
                                           illnesses that were identified between 1990 and 1998 by the Centers for
                                           Disease Control and Prevention (CDC). Contamination may occur when
                                           fresh produce is grown, harvested, washed, sorted, packed, transported, or
                                           prepared. As the table shows, food safety officials could not identify the
                                           source of the contamination in 86 of these cases. Food safety experts
                                           believe that there is not sufficient information to assess the relative safety
                                           of fresh produce from the United States and foreign countries.


Table II.1: Outbreaks Associated With Fresh Produce in the United States Reported to CDC, 1990-98
                                                    Implicateda
Year                        Country of origin       commodity                Pathogen                  Cause of contamination
1998                       United States (California) Alfalfa sprouts         Salmonella Senftenberg   Contaminated seed.
                           Unknown                    Mangos                  Salmonella Oranienberg   Unknown.
                           Unknown                    Fruit salad             E. coli O157:H7          Unknown.
                           United States              Cabbage (cole slaw)     E. coli O157:H7          Unknown; field
                                                                                                       contamination suspected.
                           Unknown                    Lettuce                 E. coli O157:H7          Unknown.
                           United States or Canada Cabbage (cole slaw)        E. coli O157:H7          Unknown; field
                                                                                                       contamination suspected.
                           United States              Alfalfa sprouts         E. coli O157:H7          Contaminated seed.
                           United States              Alfalfa sprouts         Salmonella Havana;       Contaminated seed.
                                                                              Salmonella Cubana
                           Mexico                     Parsley                 Shigella sonnei          Unknown; wash water or
                                                                                                       ice for packing
                                                                                                       suspected.
1997                       Unknown                    Melons or lemon bars    E. coli O157:H7          Unknown; cross
                                                                                                       contamination by food
                                                                                                       handlers suspected.
                           United States              Alfalfa sprouts         E. coli O157:H7          Contaminated seed.
                           (Idaho)
                           United States              Alfalfa sprouts         Salmonella Infantis;     Contaminated seed.
                           (Kansas and Missouri)                              Salmonella Anatum
                           Guatemala                  Raspberries             Cyclospora cayetanensis Unknown; nonpotable
                                                                                                      waterb may have been
                                                                                                      used in pesticide spray
                                                                                                      mix.
                           Unknown                    Mesclun lettuce (baby   Cyclospora cayetanensis Unknown.
                                                      lettuce)
                           Unknown                    Basil                   Cyclospora cayetanensis Unknown.
                           Unknown                    Lettuce salad           Shigella sonnei          Unknown; food handler
                                                                                                       suspected.
                           United States              Salad                   Salmonella Enteritidis   Cross contamination
                                                                                                       from turkey.
                                                                                                                     (continued)


                                           Page 23                                    GAO/RCED-99-112 Country-of-Origin Labeling
                           Appendix II
                           Information on Outbreaks of Illnesses
                           Related to Fresh Produce




                                     Implicateda
Year      Country of origin          commodity                     Pathogen                 Cause of contamination
          Unavailable                Red cabbage in vinegar        Unknown                  Unavailable.
1996      United States (California) Alfalfa sprouts               Salmonella Montevideo;   Contaminated seed.
                                                                   Salmonella Meleagridis
          Unknown                    Lettuce                       E. coli O157:H7          Unknown.
          Guatemala                  Raspberries and               Cyclospora cayetanensis Unknown; nonpotable
                                     blackberries                                          waterb may have been
                                                                                           used in pesticide spray
                                                                                           mix.
          United States (California) Mesclun mix                   E. coli O157:H7          Unknown; contamination
                                     (baby lettuce mix)                                     in the field suspected.

          Unavailable                Lettuce                       Unknown                  Unavailable.
          Unavailable                Salad                         Unknown                  Unavailable.
          Unavailable                Green salad                   Unknown                  Unavailable.
          Unavailable                Green salad                   Unknown                  Unavailable.
          Unavailable                Tossed salad                  Unknown                  Unavailable.
1996-95   Imported                   Alfalfa sprouts               Salmonella Newport       Contaminated seed.
          (country-of-origin
          unknown)
1995      Unknown                    Salad or sandwich             E. coli O157:H7          Unknown.
          Unknown                    Caesar salad                  E. coli O157:H7          Unknown; food handler
                                                                                            suspected.
          Unknown                    Unknown (produce              Cyclospora cayetanensis Unknown.
                                     suspected)
          Imported                   Alfalfa sprouts               Salmonella Stanley       Contaminated seed.
          (country-of-origin
          unknown)
          United States (Idaho)      Romaine lettuce or red        E. coli O157:H7          Cross contamination with
                                     cabbage                                                raw meat product during
                                                                                            preparation.
          United States (Montana)    Leaf lettuce                  E. coli O157:H7          Unknown; field
                                                                                            contamination likely but
                                                                                            unsanitary handling
                                                                                            practices at the grocery
                                                                                            store may have also
                                                                                            occurred.
          United States              Iceberg lettuce               E. coli O157:H7          Cross contamination
                                                                                            from ground beef.
          Unavailable                Lettuce                       Norwalk-like virus       Unavailable.
          United States              Salad                         Salmonella Enteritidis   Contaminated by
                                                                                            asymptomatic food
                                                                                            handler.
          Unavailable                House salad                   Unknown                  Unavailable.
                                                                                                           (continued)




                           Page 24                                         GAO/RCED-99-112 Country-of-Origin Labeling
                       Appendix II
                       Information on Outbreaks of Illnesses
                       Related to Fresh Produce




                                 Implicateda
Year   Country of origin         commodity                     Pathogen                 Cause of contamination
1994   Unknown                   Cole slaw or soup             E. coli O157:H7          Unknown.
       Unknown                   Potato salad                  E. coli O157:H7          Unknown.
       Unknown                   Salad bar                     E. coli O157:H7          Unknown; cross
                                                                                        contamination with raw
                                                                                        ground beef suspected.
       Unknown                   Lettuce                       E. coli O157:H7          Unknown; food handler
                                                                                        suspected.
       Mexico                    Green onions                  Shigella flexneri 6      Unknown; contamination
                                                                                        at harvest suspected.

       Unknown                   Fruit salad                   Campylobacter jejuni     Unknown; cross
                                                                                        contamination suspected.
       Unavailable               Pineapple                     E. coli O11:H43          Unavailable.
       Unknown                   Lettuce                       Salmonella Thompson      Unknown; food handler
                                                                                        suspected.
       Unavailable               Salad bar                     Viral                    Unavailable.
       Unavailable               Tossed salad                  Unknown                  Unavailable.
       Unavailable               Greens (edible fern           Unknown                  Unavailable.
                                 fronds)
       Unavailable               Strawberries                  Unknown                  Unavailable.
       Unavailable               Salad bar                     Unknown                  Unavailable.
       Unavailable               Spring salad                  Unknown                  Unavailable.
       Unavailable               Tossed salad                  Unknown                  Unavailable.
1993   United States (South      Tomatoes                      Salmonella Montevideo    Unknown; wash water
       Carolina)                                                                        suspected.
       Unavailable               Sliced watermelon             Salmonella Javiana       Unavailable.
       Unknown                   Vegetable salad               E. coli O157:H7          Unknown; cross
                                                                                        contamination suspected.
       Unknown                   Salad bar, lettuce or         E. coli O157:H7          Unknown.
                                 cheese
       Unknown                   Cantaloupe from buffet        E. coli O157:H7          Unknown; cross
                                                                                        contamination suspected.
       United States             Salad (carrots)               Enterotoxigenic          Unknown; contaminated
                                                               E. coli (ETEC)           carrots suspected.
       United States             Tabouleh salad (carrots)      Enterotoxigenic          Unknown; contaminated
                                                               E. coli (ETEC)           carrots suspected.
       Unavailable               Melon and strawberries        Campylobacter jejuni     Unavailable.
       Unknown                   Carrot and celery sticks      Hepatitis A              Unknown; food handler
                                                                                        suspected.
       Unknown                   Lettuce                       Salmonella               Unknown; foodhandler or
                                                               Heidelberg               cross contamination
                                                                                        suspected.
                                                                                                       (continued)



                       Page 25                                         GAO/RCED-99-112 Country-of-Origin Labeling
                       Appendix II
                       Information on Outbreaks of Illnesses
                       Related to Fresh Produce




                                 Implicateda
Year   Country of origin         commodity                     Pathogen                Cause of contamination
       Unavailable               Green salad                   Salmonella              Unavailable.
                                                               Infantis
       Unavailable               Muskmelon and                 Unknown                 Unavailable.
                                 honeydew
       Unavailable               Green beans or okra           Unknown                 Unavailable.
1992   United States             Vegetable                     E. coli O157:H7         Unknown; manure in
                                                                                       home garden suspected.
       Unavailable               Salad                         Unknown                 Unavailable.
       Unavailable               Tossed salad                  Unknown                 Unavailable.
       Unavailable               Tossed salad                  Unknown                 Unavailable.
       Unavailable               Fruit salad                   Unknown                 Unavailable.
       Unavailable               Green salad                   Unknown                 Unavailable.
1991   United States (Texas)     Cantaloupe                    Salmonella Poona        Unknown; contamination
       and Mexico                                                                      in field suspected.
       Unavailable               Salad bar                     Hepatitis A             Unavailable.
       Unavailable               Fresh fruit                   Giardia lambia          Unavailable.
       United States (Florida)   Watermelon                    Salmonella Javiana      Unknown; improper
                                                                                       handling (temperature
                                                                                       abuse) suspected.
       Unavailable               Tossed salad                  Unknown                 Unavailable.
       Unavailable               Tossed salad                  Unknown                 Unavailable.
       Unavailable               Fruit                         Unknown                 Unavailable.
       Unavailable               Cantaloupe                    Unknown                 Unavailable.
       Unavailable               Spring salad                  Unknown                 Unavailable.
       Unavailable               Salad                         Unknown                 Unavailable.
1990   Central America and       Cantaloupe                    Salmonella Chester      Unknown; possible
       Mexico                                                                          contamination from ice
                                                                                       used in shipping.
       Unknown                   Alfalfa sprouts               Salmonella Anatum       Unknown.
       Unavailable               Lettuce                       Hepatitis A             Unavailable.
       United States (South      Tomatoes                      Salmonella Javiana      Unknown; wash water
       Carolina)                                                                       suspected.
       Unavailable               Salad bar                     Giardia lambia          Unavailable.
       Unavailable               Salad                         Salmonella Montevideo   Unavailable.
       Unknown                   Raw vegetables                Giardia lambia          Unknown.
       Unavailable               Salad bar                     Unknown                 Unavailable.
       Unavailable               Lettuce                       Unknown                 Unavailable.
       Unavailable               Lettuce salad                 Unknown                 Unavailable.
       Unavailable               Salad bar                     Unknown                 Unavailable.
       Unavailable               Tossed salad                  Unknown                 Unavailable.
                                                                                                      (continued)



                       Page 26                                        GAO/RCED-99-112 Country-of-Origin Labeling
                      Appendix II
                      Information on Outbreaks of Illnesses
                      Related to Fresh Produce




                                  Implicateda
Year   Country of origin          commodity                     Pathogen                      Cause of contamination
       Unavailable                Lettuce                       Unknown                       Unavailable.
       Unavailable                Green salad                   Unknown                       Unavailable.
       Unavailable                Salad                         Unknown                       Unavailable.
       Unavailable                Fruit cup                     Unknown                       Unavailable.

                      Note: CDC obtains reports of outbreaks primarily from state and local health departments.
                      “Unavailable” describes information not reported to CDC. “Unknown” describes information that
                      CDC and state and local health departments did not determine.
                      a
                       The information implicating fresh produce as the source of contamination is not necessarily
                      conclusive for all of the outbreaks shown in the table.
                      b
                       Water unsuitable for drinking.

                      Source: Preliminary data from CDC.




                      Page 27                                           GAO/RCED-99-112 Country-of-Origin Labeling
Appendix III

Objectives, Scope, and Methodology


               As requested by the Senate and House conferees for the Omnibus
               Consolidated and Emergency Supplemental Appropriations Act, 1999,18 we
               reviewed a number of issues associated with the potential costs and
               benefits of a mandatory labeling requirement. Specifically, this report
               provides information on (1) the potential costs associated with
               compliance and enforcement of a mandatory country-of-origin labeling
               requirement at the retail level for fresh produce, (2) the potential trade
               issues associated with such a requirement, (3) the potential impact of such
               a requirement on the ability of the federal government and the public to
               respond to outbreaks of illness caused by contaminated fresh produce,
               and (4) consumers’ views of country-of-origin labeling. Finally, appendix I
               identifies U.S. trading partners that have country-of-origin labeling
               requirements for fresh produce, the nature and scope of those
               requirements, and the record of U.S. challenges to those requirements.

               To determine the potential costs associated with compliance and
               enforcement, we interviewed officials and reviewed documents from
               USDA’s Agricultural Marketing Service and the Foreign Agricultural Service;
               the U.S. Customs Service; the Food and Drug Administration; and the
               International Trade Commission. We also interviewed officials from the
               Food Marketing Institute and the Florida Retail Federation and visited
               several Florida groceries—both large chains and small independent
               stores—to examine how imported produce is labeled and how inspections
               are conducted. We interviewed officials from the United Fresh Fruit and
               Vegetable Association; the Food Industry Trade Coalition, which included
               representatives from the Food Distributors International, the National
               Grocers Association, ConAgra, Inc., the Chilean Fresh Fruit Association,
               the National Fisheries Institute, the Meat Importers Council of America
               Inc., the American Food Institute, and the National Food Processors
               Association; the Fresh Produce Association of the Americas; the Florida
               Fruit and Vegetable Association; the Northwest Horticultural Council; the
               Western Growers Association; and Chiquita Brands, Inc. To determine
               compliance and enforcement with state labeling laws, we interviewed
               officials from agricultural departments in Maine, Texas, and Florida.

               To determine the potential trade implications, we reviewed documents
               and interviewed officials from the Office of the U.S. Trade Representative,
               the Foreign Agricultural Service, the Department of State, and the World
               Trade Organization. We also examined international trade agreements.



               18
                Conference Report 105-825 accompanied H.R. 4328, which became the Omnibus Consolidated and
               Emergency Supplemental Appropriations Act, 1999 (P.L. 105-277, Oct. 21, 1998).



               Page 28                                        GAO/RCED-99-112 Country-of-Origin Labeling
Appendix III
Objectives, Scope, and Methodology




To identify U.S. trading partners that have country-of-origin labeling
requirements for fresh produce, we reviewed the survey conducted by the
Foreign Agricultural Service, 1998 Foreign Country of Origin Labeling
Survey, February 4, 1998. In addition, we developed a questionnaire to
determine the nature and scope of other countries’ labeling requirements,
which the Service sent electronically to the U.S. embassy agricultural
attachés for 45 countries. Twenty-eight of the countries were selected
because they are the countries with whom we import or export significant
dollar volumes of fresh produce. The remaining 17 countries we surveyed
were included because they were identified as requiring country-of-origin
labeling in the Foreign Agricultural Service’s 1998 survey. We received
responses for 45 countries. The survey was conducted in February and
March 1999.

To determine the potential impact on the federal government’s and
consumers’ ability to respond to outbreaks of illness from fresh produce,
we interviewed officials and obtained documents from the CDC, FDA, the
U.S. Department of Agriculture, and Florida’s Department of Health. We
also discussed these issues with consumer groups.

To determine the potential impact of mandatory country-of-origin labeling
on consumers, we reviewed the Tariff Act of 1930 and related regulations
and rulings and discussed these issues with Customs officials. We also
examined documents and interviewed officials with consumer groups,
including the National Consumers League, the Center for Science in the
Public Interest, and the Safe Food Coalition. We also analyzed the results
of eight consumer surveys conducted from 1990 to 1998 to determine
consumer opinions regarding mandatory country-of-origin labeling. The
surveys were identified by industry experts and through literature
searches. For the data we included in our report, we obtained frequency
counts, survey instruments, and other documents, in order to review the
wording of questions, sampling, mode of administration, research
strategies, and the effects of sponsorship. We used only data that we
judged to be reliable and valid.

Five surveys, conducted between 1990 and 1998, represented households
nationwide that have purchased fresh produce in the past year. These
surveys were published by Vance Publishing Corporation for The Packer
newspaper and were published in its annual supplement, Fresh Trends.
Another nationwide survey was conducted by the Charlton Research
Group in 1996 for the Desert Grape Growers League. Two surveys of




Page 29                              GAO/RCED-99-112 Country-of-Origin Labeling
Appendix III
Objectives, Scope, and Methodology




Florida consumers were conducted by the University of South Florida’s
Agriculture Institute in 1997 and the University of Florida in 1998.

We also spoke with officials and obtained documents from CDC, FDA, the
U.S. Department of Agriculture’s Agricultural Marketing Service, Florida’s
Department of Health, the Environmental Working Group, and Consumers
Union about the relative safety of imported and U.S. produce.

We conducted our review from November 1998 through March 1999 in
accordance with generally accepted government auditing standards.




Page 30                              GAO/RCED-99-112 Country-of-Origin Labeling
Appendix IV

Major Contributors to This Report


               Erin Lansburgh, Assistant Director
               Beverly A. Peterson, Evaluator-in-Charge
               Daniel F. Alspaugh
               Erin K. Barlow
               Shirley Brothwell
               Richard Burkard
               Daniel E. Coates
               Oliver Easterwood
               Fran Featherston
               Alice Feldesman
               Paul Pansini
               Carol Herrnstadt Shulman
               Janice M. Turner




(150094)       Page 31                             GAO/RCED-99-112 Country-of-Origin Labeling
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