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Law Educator, Esq.
Law Educator, Esq., Attorney
Category: Legal
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Experience:  JA Mentor -Attorney Labor/employment, corporate, sports law, admiralty/maritime and civil rights law
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This is related to Country of Origin marking regulations. We

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This is related to Country of Origin marking regulations.
We manufacture packaging materials which are institutional, and would not be used in any retail applications. Are we exempt from COOL marking?

John
Kenosha WI
Thank you for your question. I look forward to working with you to provide you the information you are seeking.

Please explain more specifically what you are asking about the COOL exemptions, since there are exemptions that apply to specific situations but just because they are for institutional use is no one of the exceptions and more is required.
Customer: replied 4 years ago.

In review of USDA 65.300, there abouts it discusses the requirements for marking of country of origin.


The basic questions is do we need to mark our product as "Product of USA"?


 


I will be back in 30 min.


 

I understand that regulation, but we know nothing about your specific product or situation and that is how the regulation is applied.
Customer: replied 4 years ago.

Sorry about that!


We manufacture packaging Blown film bags and sheeting that is used for large bulk packaging of food, and we also manufacture films for Medical applications.


Most of our products are sold to American site companies.


My perception of the reg. is that it applies to items that would be sold as retail items, our products are not retail point of sale packaging.


There are instances where we will internationally ship, or the company that buysa pour product will ship internationally.


This help?


 

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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Customer: replied 4 years ago.


Paul,


 


Thank you for the information. This did confirm my suspicion related to the reg.


Could I possibly speak to you on the phone?


 

Thank you for your response.

I apologize, but the rules of this site forbid us from making contact in any manner other than this forum as we cannot be construed as engaging in representation and telephone or email contact could be construed as such.