Thank you for your response and additional information.
The regulation applies only to covered commodities that will be provided to consumers. If you are bulk packing food that is not for sale to the consumer, the markings do not need to be applied according to the rule. The problem with the international shipping is that while COOL markings do not have to be applied based on US laws, some foreign laws may differ and each country's law must be checked. I do not see in the regulation where your product would come under this regulation as long as it is not going to be sold retail to the customer, although I do see many manufacturers include the labeling even when it is not required, but that is their choice.
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