Furthermore, such a law could be difficult to enforce. The additional efforts and associated costs for compliance would depend on the specific requirements of the law and the extent to which current practices would have to be changed. 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. It is unclear who would bear the burden of compliance. Such documentation is often unavailable at the retail store. FDA estimated that the federal cost for 1-year’s monitoring under this proposed amendment would be about $56 million. However, they said they sometimes have no reliable means to verify the accuracy of these signs and labels. 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. Labeling Would Provide Limited Benefits in Responding to Outbreaks of Foodborne Illnesses

Considerable time—several weeks or months—generally passes between the outbreak of a produce-related illness, the identification of the cause, and a warning to the public about the risks of eating a specific produce item, according to the Centers for Disease Control and Prevention (CDC) and FDA officials. By the time a warning is issued, country-of-origin labeling would benefit consumers only if they remembered the country 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 helping consumers respond to a warning of an outbreak. The remaining 12 cases were traced to contamination in food handling and to seed that was contaminated. Although Consumers Favor Labeling, Other Information Is More Important to Them

Surveys representing households nationwide, sponsored by the produce industry between 1990 and 1998, showed that between 74 and 83 percent of consumers favor mandatory country-of-origin labeling for fresh produce at the retail level. 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. Of the 45 countries, 28 account for most of U.S. trade in produce. 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.
Why GAO Did This Study

Pursuant to a legislative requirement, GAO provided information on the: (1) potential costs associated with the compliance and enforcement of a mandatory country-of-origin labeling requirement at the retail level for fresh produce; (2) potential trade issues associated with such a requirement; (3) 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.

What GAO Found

GAO noted that: (1) the magnitude of compliance and enforcement costs for a country-of-origin labeling requirement at the retail level would depend on several factors, including the extent to which labeling practices would have to be changed; (2) 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; (3) 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; (4) 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; (5) 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; (6) enforcement is carried out in only one of the three states with labeling laws; (7) Florida inspectors told GAO that they sometimes have no reliable means to verify the accuracy of labels; (8) according to Department of Agriculture officials and industry representatives, mandatory labeling at the retail level could be viewed by other countries as a trade barrier; (9) officials also noted that countries concerned with a labeling law could take actions that could adversely affect U.S. exports; (10) 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; (11) 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; (12) 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; (13) 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; and (14) 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.