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A Tale of a Fish from Two Countries

Posted by Craig A. Morris, Deputy Administrator of the AMS Livestock, Poultry, and Seed Program in Trade
Feb 21, 2017
Back of a product showing the country of origin
The Country of Origin Labeling regulations require most grocery stores to provide the country of origin for fish and shellfish, and the method of production (farm-raised or wild-caught), at the point of sale where consumers make purchasing decisions.

How can fish in a grocery store be labeled as both “Alaskan” and “Product of China” on the same package?  The answer is that although much of the seafood sold in the United States is labeled with a foreign country of origin, some of that same seafood was actually caught in U.S. waters.

Under the Country of Origin Labeling program regulations – enforced by USDA’s Agricultural Marketing Service – when fish are caught in U.S. waters and then processed in a foreign country that foreign country of processing must appear on the package as the country of origin.  This processing usually takes the form of filleting and packaging the fish into the cuts you see in the grocery store seafood department or frozen food aisle.  However, if the fish was actually caught in Alaskan waters, retailers are also able to promote the Alaskan waters the fish was actually caught in, in addition to the country in which the processing occurred.

An example of this would be when a wild cod is caught off the coast of Alaska and, due to economic factors, is shipped to another country to be fabricated into fillets and packaged.  If this process of turning a whole fish into packaged fillets occurs in China, the cod fillets are declared “Wild Caught Product of China” upon import into the United States.  However, if the importer can demonstrate that the cod was caught in Alaskan waters, the packaged cod fillets are also eligible to say “Alaskan”.

The Country of Origin Labeling regulations require most grocery stores to provide the country of origin for fish and shellfish, and the method of production (farm-raised or wild-caught), at the point of sale where consumers make purchasing decisions.  Suppliers to retailers, including distributors, repackers, processing facilities, harvesters, and importers, are also required to convey this Country of Origin Labeling information to their subsequent buyers.

The Country of Origin Labeling program, in close partnership with many State and Federal agencies, assesses labeling compliance in grocery store locations across the United States every year.  In addition, the Country of Origin Labeling program audits the supply chain to verify the accuracy of country of origin and method of production declarations.

Not only are seafood labels checked for mandatory country of origin labeling declarations, but much of the fruits and vegetables, peanuts, pecans, macadamia nuts, ginseng, lamb, goat, and chicken at your local grocery store must also include country of origin information.  For more information about the mandatory Country of Origin Labeling program, visit:

Pacific Cod product
The Country of Origin Labeling regulations require most grocery stores to provide the country of origin for fish and shellfish, and the method of production (farm-raised or wild-caught), at the point of sale where consumers make purchasing decisions.
Category/Topic: Trade

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Dec 05, 2016

So is this exchange of cod part of the COOL Act that designates meat labeling changes?
Trade has gone array while we were sleeping, it seems. Handling of food is not being monitored the way U.S. Americans believe.
I knew about this issue and am glad to see it brought into the limelight.
The more people know, then actions to stop bad practices can be best addressed.
Thank you.

Michael Pace
Jan 30, 2018

Why are the rules for some stores and not all? Name stores exempt from this requirement please.

Ben Weaver
Feb 01, 2018

@Michael Pace - thank you for your question about which retail food stores are subject to COOL requirements. Stores that annually sell only small amounts of fruits and vegetables, and other retail fish markets and butcher shops that do not purchase fruits and vegetables for resale in an amount greater than the $230,000, are not considered retailers under this law and are not subject to COOL requirements. USDA has no authority to maintain records on the name and address of stores that are exempt from COOL requirements.

There are more than 37,000 facilities nationwide that are required to provide country of origin information on covered commodities at the point of sale. They include national firms such as Walmart, Kroger, Safeway, and Costco.

For additional questions about COOL, please visit:, contact the COOL Program by e-mail,, or by phone (202) 720-4486.

Kristen Waring
Feb 18, 2018

Is the USDA working to bring back labeling for beef and pork or is that requirement gone for good?

Ben Weaver
Feb 28, 2018

@Kristen Waring - While the ultimate fate of COOL for beef and pork at the federal level was decided two years ago after Canada and Mexico filed a dispute with the World Trade Organization, proposals recently began circulating among certain states requiring retailers to indicate the country of origin of beef sold.

Since 2016 retailers and their suppliers are no longer required to convey country of origin information for beef or pork products to their buyers and consumers under the mandatory COOL program.  Imported beef and pork products sold in consumer ready packages however, must still bear the foreign country of origin under USDA’s Food Safety and Inspection Service (FSIS) regulations.

In general, packers and retailers may voluntarily provide origin information to their consumers, as long as the information is truthful and not misleading.  Packers and retailers should work directly with FSIS for guidance and label review.

Country of origin information for the remaining covered commodities must still be conveyed to buyers and consumers. For additional questions about COOL, please visit:, contact the COOL Program by e-mail,, or by phone (202) 720-4486.

USDA’s Economic Research Service recently released a comprehensive study that sheds light on the issue of food labels, including COOL. The findings offers excellent background about retail compliance with COOL as well as consumer information regarding labels. For a copy of this report, please view the Beyond Nutrition and Organic Labels—30 Years of Experience With Intervening in Food Labels report.

Rita Filler
Jul 27, 2018

We only buy food grown and processed in the USA. If there is any confusion, we figure we can do without.

Mary Reitz
Feb 10, 2019

All products packaged in China and Korea should be banned from entering the United States.

Feb 20, 2019

Insane. I will never buy fish again in america until the USDA bans chinese imported and processed fish. China has ZERO health regulations and this once again shows the USDA putting Americans health at risk. Shame on you!

Walter Contreras
Mar 10, 2019

Not COOL I do not trust the Chinese government. They are notorious for not breaking the law.

Cory Herbst
Apr 28, 2019

Country of origin labeling
When fish are caught in U.S. waters and then processed in a foreign country that foreign country of processing must appear on the package as the country of origin. If the fish was actually caught in Alaskan waters, retailers are also able to promote the Alaskan waters the fish was actually caught in.
Fish caught in Alaska but processed into say fillets and packaged in China must be labeled in china must be labeled as coming from China.
I do believe this labeling is misleading to consumers if they were fished in one country and processed in another the labeling should always say the correct country of origin then say processed in the other country. I'm not sure if it is harmful or helpful to domestic producers unless other countries are monopolizing U.S. waters too much or if they can farm our own fish and sell it to us cheaper than we can produce it ourselves. If we produce in a similar a competitive product at a comparable price I don't see how it could be harmful.

Shirley Jacobsen
Jun 11, 2019

Why can't we process here in USA?

Art Sanchez
Sep 04, 2019

Very good and interesting information - explains it well...thanks.

Oct 08, 2019

How do we know that the packaged fish from China is actually the wild caught Alaskan type as claimed? Is there any oversight in China? How's about integrity of their goods and their past history of adding all sorts of fish cuts to their final product....

It's a shame that the packaging is mosly mis-leading as the "product of China" is in small print...

Oct 22, 2019

Inquiry still remains and not answered. If product purchased states it was caught in Alaskan waters but ------- processed in China, is the processing of COD filets SAFE for consumption?
How is the Alaskan cod processed in China?????

Ben Weaver
Oct 25, 2019

@jane - thank you for your interest in the Country of Origin Labeling (COOL) regulation. You asked about the food safety of Cod fillets labeled as “caught in Alaskan waters, processed in China.” COOL is a federal retail labeling law that requires retailers (most grocery stores and supermarkets) to provide country of origin information to consumers for certain covered commodities. Commodities subject to the law and regulation include muscle cuts and ground portions of chicken, lamb and goat meat; fresh and frozen fruits and vegetables; wild caught and farm-raised fish and shellfish; raw peanuts, pecans, macadamia nuts, and ginseng. The intent of the law is to provide consumers with additional information on which to base their purchasing decisions in grocery stores and supermarkets. COOL is not a food safety initiative Other federal agencies address food safety standards and conduct food safety inspections.

USDA does not have authority to regulate food safety of fish and shellfish species other than catfish. Catfish inspection is carried out by USDA’s Food Safety Inspection Service. Food safety of all other fish and shellfish species is regulated by the U.S. Food and Drug Administration (FDA) and the National Oceanic and Atmospheric Administration (NOAA). FDA’s Seafood Safety Division and NOAA Fisheries may be better able to answer your question regarding the specifics of food safety protocols and inspections on Cod fillets labeled as you describe.

The FDA Seafood Safety Division’s website provides up-to-date consumer information and advice, guidance documents and regulations for industry, as well as science and research content for anyone interested in seafood.

NOAA Fisheries operates as Seafood Inspection Program. Information about NOAA Fisheries’ seafood inspections can be accessed at:

We suggest you submit your question to FDA’s Center for Food Safety and Applied Nutrition (CFSAN) using their Inquiry Form page:

You may also contact NOAA Fisheries using their “Contact Us” page:

Thank you again for your interest in COOL. If you have additional questions about any aspect of USDA’s COOL regulation and its administration, please contact USDA’s Agricultural Marketing Service’s Food Disclosure and Labeling Division by e-mail: or by phone: (202) 720-4486.

Mark hayes
Mar 13, 2020

Thanks for the info. I can. Eat my fish now with no. Doubt about its edibility.

Leigh Olson
Apr 11, 2020

This is good information but it doesn’t tell you if it is safe to eat wild caught salmon caught in the US and processed in China? And I am assuming that the salmon has been frozen twice then?

May 11, 2020

I just purchesed 1lb of cod fish its labeled
wild caught usa
does that means its really from the usa or it can be also from china ?
thank you in advance .
Mel. s

Mike Hunt
Jun 01, 2020

As there is no way for USDA to verify that cod imported from China was actually caught in Alaska there is no way it should be allowed to besr the Alaskan label. The Chinese are not to be trusted. USDA do yiur job and protect American consumers and business!

Jul 18, 2020

Since the country of processing is listed as the country of origin, would fish caught or farmed internationally, then sent to the USA for processing, be labeled as "Product of USA"?

Ben Weaver
Jul 21, 2020

@Jennifer - thank you for your comment. If a fish caught or farmed internationally was imported to the U.S. and subsequently substantially transformed (as established by U.S. Customs and Border Protection) in the U.S., then the product should be labeled at retail as “From country X, processed in the United States.” Alternatively, the product may be labeled as “Product of country X and the United States”.

Jul 30, 2020

We only buy Fresh Fish that is locally (USA) caught and processed, as for species like Salmon, we only purchase products labeled caught in North Atlantic waters or farmed raised in U.S or South American Country's, as for Cod, Scrod or Haddock, we only purchase those fish that are caught in North Atlantic waters, and processed in the United States, Canada or Norway,
We purchase Nothing labeled Alaskan, or caught in Northern Pacific Waters, because most of it is processed in China.
As for Canned Tuna, like Chicken of The Sea and other big U.S name Brands, I would sooner buy 9 Lives canned Tuna, because in my opinion there is no difference.

Aug 22, 2020

Every time I see Product Of China on FOOD in the grocery store I’m shopping in I immediately reject it. My family will not consume anything processed in China because we don’t trust it. I hope the fishing industry gets the message and stops this practice and returns the fillet processing back to the USA. As a consumer I rather pay more for the fish and have peace of mind because it was processed here in the USA.

Pat Marsh
Sep 20, 2020

We dont know the conditions of the China facilities that these products are packed in it's really fraudulent deception. I had to stop and make myself believe this is true..It needs to stop people want food caught and packaged in US or some accountable country with health rules

Tanya Rovin
Oct 24, 2020

It is so sad that your fish is processed in China. I was just going out to buy Gorton's salmon but thought I had better check the country of origin etc. Of course I would never buy anything processed in China. I would rather eat half the amount and buy American processed. Sorry.

Christine Thomas
Jul 10, 2021

I'm returning salmon processed in China for Seattle. I don't trust food processed in China for USA. Why do we need to do this? The almighty dollar drives safety and it's not in the best interest of the !!

Donna Ragsdale
Jul 15, 2021

Fish has never had hardly any regulation! Best thing to do is catch it yourself from where you know the water is clean. That not the half of it! Look into all canned products especially citrus!

Aug 02, 2021

It's actually a question.. How can we as the consumer be assured that the fish is not being switched for something caught in China? I got some Salmon from Safeway and packaging says from Alaska and product of China. Salmon was very pale as soon as it defrosted it was very brittle and lastly the smell was nasty like like the typical smell of fish cooking witch I happen to like, but a smell like nasty fish not really sure how to explain.
Thank you for any feedback

Syed T Ahmed
Aug 29, 2021

It would be sensable and informative for consumer to know 1. Where the product was grown or produced and 2. Where it was processed. this should be labled. To label "Produce of ?? China or any county" is not clear for consumer, as it seem to indicate that it was Produced or grown in the country listed. Most people prefer not to buy e.g seafood listed as product of China.

Stu Hoar
Sep 02, 2021

The information provided above is clear and certainly helpful. I recently purchased a package of pollock fillets produced by CONAGRA under their VandeKamp brand. The retail package did not include country of origin. I asked about the absent country of origin label and received assurance that 95% of their USA produced fish came from either the north pacific or waters off Prince Edward Island in Canada. So the answer was fairly assuring but missed the point that country of origin is not printed on the package and although the package has a "QR code" which leads to additional nutrition information it does not provide country of origin.

Is there a loophole in the law that allows american producers to avoid providing country of origin?

Ben Weaver
Sep 09, 2021

@Stu Hoar - thank you for your question about country of origin labeling (COOL) requirements for pollock fillets produced by CONAGRA under their Van de Kamp brand. Based on a review of fish fillet products described on the Van de Kamp website Fish Fillets | Van de Kamp’s ( the pollock fillets are sold as “Crispy Battered Fillets,” “Crunchy Breaded Fillets,” and “Beer Battered Fillets.” The additional food ingredients (battering and breading) added to the fish fillets result in processed food items as defined in the COOL regulation. Processed food items are excluded from COOL requirements.

The term “processed food item” is defined in the COOL regulation at 7 CFR §65.220 to mean: a retail item derived from a covered commodity that has undergone specific processing resulting in a change in the character of the covered commodity, or that has been combined with at least one other covered commodity or other substantive food component (e.g., chocolate, breading, tomato sauce), except that the addition of a component (such as water, salt, or sugar) that enhances or represents a further step in the preparation of the product for consumption, would not in itself result in a processed food item. Specific processing that results in a change in the character of the covered commodity includes cooking (e.g., frying, broiling, grilling, boiling, steaming, baking, roasting), curing (e.g., salt curing, sugar curing, drying), smoking (hot or cold), and restructuring (e.g., emulsifying and extruding).

Thank you for your interest in the COOL regulation. If you have additional questions about COOL, please contact USDA’s Food Disclosure and Labeling Division by emailing:

Thomas Nichols
Sep 30, 2021

Whats to stop Chinese fish processor's to use farm raised cod and mid it with cod caught off U.S. waters, I bought a box of cod marked off the Alaska cost but processed in China, I was very disappointed.

Beryl Andrews
Oct 23, 2021

I don’t think. Wild fish caught in us waters should be shipped to a foreign country for packing , how do we know that we’re getting the same fish back again, I recently purchased two cans of wild Alaskan salmon , only to notice on the can it was a product of Thailand , so I will not be eating it I will open the can and put the product down the disposal , I think that is deceptive advertising , it should say right next to the word salmon product of Thailand , in large letters , just my opinion.

Herb Akers
Feb 25, 2022

Doesn't make one bit of sense fish that are caught on the Alaskan coast and then shipped to vessels from China and then back to the U.S. I don't want to buy and eat fish that is processed in China . Nope not any more

Marilyn Hudson
Jun 08, 2022

So, every package of fish and chicken should have 1) country (EX: USA) & state of that country ( EX: alabama). AND ALSO: 2) foreign country where it is processed ( cut up & packaged) ?

Aug 31, 2022

Thanks for the information