The Country of Origin Labeling (COOL) provisions in the 2002 Farm Bill require, beginning September 30, 2004, that retail sellers of several food commodities inform consumers of certain product’s country of origin. As required by the statute, the USDA promulgated guidelines in the fall of 2002 designed to assist retailers and their suppliers in facilitating voluntary labeling. By September 30, 2004, however, the USDA is to have in place regulations implementing mandatory COOL. COOL raises important questions concerning what commodities are covered, how the labeling requirement is satisfied, and anticipated costs and benefits