Overview

Amazon requires all sellers of certain food products to comply with the United States Department of Agriculture's Country of Origin Labeling (COOL) regulations. These federal rules mandate that specific unprocessed agricultural products carry clear labeling indicating where they were sourced, grown, or raised. For Amazon sellers dealing in fresh food categories, understanding and adhering to COOL is essential to remaining compliant on the platform and avoiding regulatory penalties.

Key Points / What Sellers Need to Know

• COOL is a federal requirement, not just an Amazon policy — The USDA mandates Country of Origin Labeling under the Agricultural Marketing Act. Amazon enforces compliance as part of its broader food safety and labeling standards, but the underlying obligation comes from federal law.
• Only "covered commodities" are subject to COOL — Not all food products require country of origin labeling. The regulation specifically targets certain unprocessed items including meats, seafood, fresh produce, and select nuts.
• Physical product labels must include origin information — The country of origin must appear on the actual product packaging or label. Simply including this information in an Amazon listing is not sufficient to meet the legal requirement.
• Non-compliance carries real consequences — Sellers who fail to properly label covered commodities risk product removal from Amazon, account health issues, and potential USDA enforcement actions including fines.
• Both domestic and imported products are covered — Whether a product is sourced domestically within the United States or imported from abroad, the origin must be clearly disclosed on the label.

Which Products Are Covered

The USDA defines several categories of unprocessed food as "covered commodities" under the COOL program. These include muscle cuts of beef, lamb, chicken, goat, and pork, as well as ground versions of these meats. Wild-caught and farm-raised fish and shellfish also fall under the regulation. Fresh and frozen fruits and vegetables — collectively referred to as perishable agricultural commodities — are covered as well. Additionally, certain tree nuts including peanuts, pecans, and macadamia nuts must carry country of origin labels. Ginseng is also included in the list of covered commodities. It is important to note that processed food items, such as cooked, cured, or smoked products, are generally exempt from COOL requirements because the processing step changes the commodity's classification.