Fresh Produce: Potential Consequences of Country-of-Origin Labeling
(Letter Report, 04/21/99, GAO/RCED-99-112).

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.

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.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-99-112
     TITLE:  Fresh Produce: Potential Consequences of Country-of-Origin 
             Labeling
      DATE:  04/21/99
   SUBJECT:  Labeling law
             Food and drug law
             Importing
             Safety standards
             Consumer protection
             Agricultural products
             Cost effectiveness analysis
             Health hazards
             International trade restriction
             State programs
IDENTIFIER:  NAFTA
             North American Free Trade Agreement
             Florida
             Texas
             Maine
             
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Cover
================================================================ COVER


Report to Congressional Committees

April 1999

FRESH PRODUCE - POTENTIAL
CONSEQUENCES OF COUNTRY-OF-ORIGIN
LABELING

GAO/RCED-99-112

Country-of-Origin Labeling

(150094)


Abbreviations
=============================================================== ABBREV

  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

Letter
=============================================================== LETTER


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 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
ï¿½labelï¿½ means any label, mark, sticker, stamp, placard, or other
clear visible sign. 


--------------------
\1 This report uses the term ï¿½loose produceï¿½ 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). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :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 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 lawsï¿½in 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 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. 


--------------------
\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. 


   BACKGROUND
------------------------------------------------------------ Letter :2

The Tariff Act of 1930, as amended, generally requires imported
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 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 thirdï¿½from about 48 billion to about 64
billion pounds. 

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

   Figure 1:  Source of Fresh and
   Frozen Imported Produce, 1997,
   by dollar value

   (See figure in printed
   edition.)

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

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


--------------------
\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 ï¿½containers.'

\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. 

\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. 


   UNCERTAINTIES EXIST ABOUT THE
   COSTS ASSOCIATED WITH
   COMPLIANCE AND ENFORCEMENT
------------------------------------------------------------ Letter :3

Complying with mandatory country-of-origin labeling for fresh produce
could change the way retailers and others involved in the production
and distribution of produce do business, thereby affecting their
costs and consumers' choices.  Furthermore, such a law could be
difficult to enforce. 


      MAGNITUDE OF COMPLIANCE
      COSTS AND THE RESPONSIBILITY
      FOR THESE COSTS ARE
      UNCERTAIN
---------------------------------------------------------- Letter :3.1

The fresh produce industry and retailers will have to incur costs to
comply with a mandatory country-of-origin labeling law.  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.  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 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
ï¿½prohibitive.ï¿½


      FEDERAL AGENCIES WOULD NEED
      ENFORCEMENT RESOURCES FOR AN
      INHERENTLY DIFFICULT TASK
---------------------------------------------------------- Letter :3.2

According to Food and Drug Administration (FDA) and USDA officials we
spoke with, enforcing a labeling law would require significant
additional resources.  The agency enforcing such a law would have to
implement a system to ensure that the identity of produce is
maintained throughout the distribution chain.  While inspectors could
ensure that retailers have signs or labels in place and could review
documentationï¿½if 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 ï¿½reservations about its priority as a public health issue,
its cost to administer, and [FDA's] ability to enforce it.ï¿½ FDA
further noted that the cost of enforcement ï¿½would be significant,ï¿½
and ï¿½it is unclear that enforcement would even be possible.ï¿½ Among
other enforcement problems, FDA cited the need for accompanying
paperwork to verify country-of-origin labels and said this would
place ï¿½an enormous burdenï¿½ 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. 

   Figure 2:  Labeled Produce in
   Florida Grocery Stores

   (See figure in printed
   edition.)

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. 


   A LABELING LAW COULD HAVE TRADE
   IMPLICATIONS
------------------------------------------------------------ Letter :4

Depending on what it might require and how it might be implemented, a
law mandating country-of-origin labeling for fresh produce could have
adverse trade implications.  U.S.  trading partners might challenge
the law's 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 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
attachï¿½s 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) require country-of-origin labeling for
bulk produce at the retail level, and 15 require such labeling for
packaged produce.\10 Attachï¿½s 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. 


--------------------
\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. 

\9 USDA surveyed these countries in 1998. 

\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. 


   LABELING WOULD PROVIDE LIMITED
   BENEFITS IN RESPONDING TO
   OUTBREAKS OF FOODBORNE
   ILLNESSES
------------------------------------------------------------ Letter :5

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. 

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. 

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. 


   ALTHOUGH CONSUMERS FAVOR
   LABELING, OTHER INFORMATION IS
   MORE IMPORTANT TO THEM
------------------------------------------------------------ Letter :6

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.\12 However, when asked to rate the
importance of several types of labeling information, households
reported information on freshness as most important, followed by
information on nutrition, storage 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

   (See figure in printed
   edition.)

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 ï¿½a little more to get
U.S.  produce.ï¿½\15 However, the survey did not specify the additional
amount that consumers would be willing to pay. 

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
groupï¿½used 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. 


--------------------
\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. 

\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. 

\16 Survey conducted for The Packer newspaper.  Twenty percent said
U.S.  produce was about the same, 3 percentï¿½worse, and 6
percentï¿½don'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. 


   AGENCY COMMENTS AND OUR
   RESPONSE
------------------------------------------------------------ Letter :7

We provided the departments of Agriculture and State, Office of the
U.S.  Trade Representative, CDC, U.S.  Customs Service, EPA, and FDA
with a draft 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 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. 


---------------------------------------------------------- Letter :7.1

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


U.S.  TRADING PARTNERS THAT
REQUIRE COUNTRY-OF-ORIGIN LABELING
FOR FRESH PRODUCE AND THE SCOPE OF
THEIR REQUIREMENTS
=========================================================== Appendix I

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 attachï¿½s 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. 
Attachï¿½s 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

Australia                Loose and packaged    \a                    \a

Brazil                   Packaged              High                  Moderate

Canada                   Loose\b 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

United Kingdom                                 Very high             Very high

Guatemala                No requirement

Honduras                 No requirement

Hong Kong                No requirement

Indonesia                No requirement

Japan                    Loose and packaged\c  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        Loose and packaged    Moderate              Moderate
Africa

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

Hungary                  Loose and packaged    \a                    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
-----------------------------------------------------------------------------------------
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. 


INFORMATION ON OUTBREAKS OF
ILLNESSES RELATED TO FRESH PRODUCE
========================================================== Appendix II

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

                   Country of        Implicated\a                        Cause of
Year               origin            commodity         Pathogen          contamination
-----------------  ----------------  ----------------  ----------------  ----------------
1998               United States     Alfalfa sprouts   Salmonella        Contaminated
                   (California)                        Senftenberg       seed.

                   Unknown           Mangos            Salmonella        Unknown.
                                                       Oranienberg

                   Unknown           Fruit salad       E. coli O157:H7   Unknown.

                   United States     Cabbage (cole     E. coli O157:H7   Unknown; field
                                     slaw)                               contamination
                                                                         suspected.

                   Unknown           Lettuce           E. coli O157:H7   Unknown.

                   United States or  Cabbage (cole     E. coli O157:H7   Unknown; field
                   Canada            slaw)                               contamination
                                                                         suspected.

                   United States     Alfalfa sprouts   E. coli O157:H7   Contaminated
                                                                         seed.

                   United States     Alfalfa sprouts   Salmonella        Contaminated
                                                       Havana;           seed.
                                                       Salmonella
                                                       Cubana

                   Mexico            Parsley           Shigella sonnei   Unknown; wash
                                                                         water or ice for
                                                                         packing
                                                                         suspected.

1997               Unknown           Melons or lemon   E. coli O157:H7   Unknown; cross
                                     bars                                contamination by
                                                                         food handlers
                                                                         suspected.

                   United States     Alfalfa sprouts   E. coli O157:H7   Contaminated
                   (Idaho)                                               seed.

                   United States     Alfalfa sprouts   Salmonella        Contaminated
                   (Kansas and                         Infantis;         seed.
                   Missouri)                           Salmonella
                                                       Anatum

                   Guatemala         Raspberries       Cyclospora        Unknown;
                                                       cayetanensis      nonpotable
                                                                         water\b may have
                                                                         been used in
                                                                         pesticide spray
                                                                         mix.

                   Unknown           Mesclun lettuce   Cyclospora        Unknown.
                                     (baby lettuce)    cayetanensis

                   Unknown           Basil             Cyclospora        Unknown.
                                                       cayetanensis

                   Unknown           Lettuce salad     Shigella sonnei   Unknown; food
                                                                         handler
                                                                         suspected.

                   United States     Salad             Salmonella        Cross
                                                       Enteritidis       contamination
                                                                         from turkey.

                   Unavailable       Red cabbage in    Unknown           Unavailable.
                                     vinegar

1996               United States     Alfalfa sprouts   Salmonella        Contaminated
                   (California)                        Montevideo;       seed.
                                                       Salmonella
                                                       Meleagridis

                   Unknown           Lettuce           E. coli O157:H7   Unknown.

                   Guatemala         Raspberries and   Cyclospora        Unknown;
                                     blackberries      cayetanensis      nonpotable
                                                                         water\b may have
                                                                         been used in
                                                                         pesticide spray
                                                                         mix.

                   United States     Mesclun mix       E. coli O157:H7   Unknown;
                   (California)      (baby lettuce                       contamination in
                                     mix)                                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        Contaminated
                   (country-of-                        Newport           seed.
                   origin unknown)

1995               Unknown           Salad or          E. coli O157:H7   Unknown.
                                     sandwich

                   Unknown           Caesar salad      E. coli O157:H7   Unknown; food
                                                                         handler
                                                                         suspected.

                   Unknown           Unknown (produce  Cyclospora        Unknown.
                                     suspected)        cayetanensis

                   Imported          Alfalfa sprouts   Salmonella        Contaminated
                   (country-of-                        Stanley           seed.
                   origin unknown)

                   United States     Romaine lettuce   E. coli O157:H7   Cross
                   (Idaho)           or red cabbage                      contamination
                                                                         with raw meat
                                                                         product during
                                                                         preparation.

                   United States     Leaf lettuce      E. coli O157:H7   Unknown; field
                   (Montana)                                             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      Unavailable.
                                                       virus

                   United States     Salad             Salmonella        Contaminated by
                                                       Enteritidis       asymptomatic
                                                                         food handler.

                   Unavailable       House salad       Unknown           Unavailable.

1994               Unknown           Cole slaw or      E. coli O157:H7   Unknown.
                                     soup

                   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          Unknown;
                                                       flexneri 6        contamination at
                                                                         harvest
                                                                         suspected.


                   Unknown           Fruit salad       Campylobacter     Unknown; cross
                                                       jejuni            contamination
                                                                         suspected.

                   Unavailable       Pineapple         E. coli O11:H43   Unavailable.

                   Unknown           Lettuce           Salmonella        Unknown; food
                                                       Thompson          handler
                                                                         suspected.

                   Unavailable       Salad bar         Viral             Unavailable.

                   Unavailable       Tossed salad      Unknown           Unavailable.

                   Unavailable       Greens (edible    Unknown           Unavailable.
                                     fern fronds)

                   Unavailable       Strawberries      Unknown           Unavailable.

                   Unavailable       Salad bar         Unknown           Unavailable.

                   Unavailable       Spring salad      Unknown           Unavailable.

                   Unavailable       Tossed salad      Unknown           Unavailable.

1993               United States     Tomatoes          Salmonella        Unknown; wash
                   (South Carolina)                    Montevideo        water suspected.


                   Unavailable       Sliced            Salmonella        Unavailable.
                                     watermelon        Javiana

                   Unknown           Vegetable salad   E. coli O157:H7   Unknown; cross
                                                                         contamination
                                                                         suspected.

                   Unknown           Salad bar,        E. coli O157:H7   Unknown.
                                     lettuce or
                                     cheese

                   Unknown           Cantaloupe from   E. coli O157:H7   Unknown; cross
                                     buffet                              contamination
                                                                         suspected.

                   United States     Salad (carrots)   Enterotoxigenic   Unknown;
                                                       E. coli (ETEC)    contaminated
                                                                         carrots
                                                                         suspected.

                   United States     Tabouleh salad    Enterotoxigenic   Unknown;
                                     (carrots)         E. coli (ETEC)    contaminated
                                                                         carrots
                                                                         suspected.

                   Unavailable       Melon and         Campylobacter     Unavailable.
                                     strawberries      jejuni

                   Unknown           Carrot and        Hepatitis A       Unknown; food
                                     celery sticks                       handler
                                                                         suspected.

                   Unknown           Lettuce           Salmonella        Unknown;
                                                       Heidelberg        foodhandler or
                                                                         cross
                                                                         contamination
                                                                         suspected.

                   Unavailable       Green salad       Salmonella        Unavailable.
                                                       Infantis

                   Unavailable       Muskmelon and     Unknown           Unavailable.
                                     honeydew

                   Unavailable       Green beans or    Unknown           Unavailable.
                                     okra

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     Cantaloupe        Salmonella Poona  Unknown;
                   (Texas) and                                           contamination in
                   Mexico                                                field suspected.

                   Unavailable       Salad bar         Hepatitis A       Unavailable.

                   Unavailable       Fresh fruit       Giardia lambia    Unavailable.

                   United States     Watermelon        Salmonella        Unknown;
                   (Florida)                           Javiana           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   Cantaloupe        Salmonella        Unknown;
                   and                                 Chester           possible
                   Mexico                                                contamination
                                                                         from ice used in
                                                                         shipping.

                   Unknown           Alfalfa sprouts   Salmonella        Unknown.
                                                       Anatum

                   Unavailable       Lettuce           Hepatitis A       Unavailable.

                   United States     Tomatoes          Salmonella        Unknown; wash
                   (South Carolina)                    Javiana           water suspected.

                   Unavailable       Salad bar         Giardia lambia    Unavailable.

                   Unavailable       Salad             Salmonella        Unavailable.
                                                       Montevideo

                   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.

                   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. 


OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================= Appendix III

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 groceriesï¿½both 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. 

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 attachï¿½s 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
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. 


--------------------
\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). 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV

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


*** End of document. ***