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The Keys to Compliance. Common SenseFlexibilityTrust. Specifics of Florida's Program. Country of Origin Statute since 1979 for fruits, vegetables, and honey. Since 1996, aquacultured products Country of Origin Labeling checked while in the stores at point of sale as part of routine sanitation
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1. Florida’s Country of Origin Labeling Law Florida Department of Agriculture and Consumer Services
2. The Keys to Compliance Common Sense
Flexibility
Trust
3. Specifics of Florida’s Program Country of Origin Statute since 1979 for fruits, vegetables, and honey. Since 1996, aquacultured products
Country of Origin Labeling checked while in the stores at point of sale as part of routine sanitation inspection
75,000 annual inspections in 40,000 establishments
4. Complying with Florida’s Law Hand Lettered Card on Bulk
Permanent Lettering if Desired
Individual Stickers on Product
Attached Label
Random Weight Slug Printed by Retail Store
Displayed on Labeled Box
Country Checked on Display Box
5. Record Keeping in Florida Presumption Of Truthfulness That Information Supplied On Shipping Containers Is Accurate/Truthful
We Have The Ability To Research Records Or Audit The Firm If We Suspect That Product Is Improperly Labeled
Intentional Mislabeling Very Rare
If We Suspect Incorrect Label, We Check Product Against Boxes In Back Or Shipping Invoice Which Lists Country Of Origin
6. Level Of Enforcement For Florida Program Emphasis Is On Compliance, Not Enforcement
1st Violation = Education And Instruction On Compliance Notice of Violation Issued
2nd Violation = Modest Fine ($200) If Outreach Yields No Results
3rd Violation = Fines Progressively Increase If Willful Non-compliance In 2002, Only 154 Firms (Out Of 40,000) Fined
7. Nutritional LabelingExample Of Federal Program With Presumption Of Truthfulness Began In 1993
Voluntary For First Two Years
Turmoil (Similar To COOL) At First
10 Years Later It Is Effective Program Used By All
Of Labels Analyzed For Truthful Labeling, 91% Are Deemed To Be In Compliance (True To Their Label)
8. Verifiable Audit Trails Already in Existence Perishable Agricultural Products Act (PACA)
Hazard Analysis Critical Control Point Records (HACCP)
Animal Feed Certification (Prohibited Ruminants, Etc.)
Marketing/Breed Certification
Current Business Records
9. Florida Program Costs Prior To 1998 – Retail Establishments Estimated It Cost Between $5-10 Per Store Per Week To Comply With Florida Law
1998 Estimates were increased to $30 per store per week
10. Retail Survey In 20 Stores (5 Cities) Produce Marked As Foreign – 518
Of The 518, Amount Already Marked By Supplier – 255 (Or 49%)
Seafood With Import Status Marked – 152 Out Of 224 (68%)
11. Requirements on Industry Provide Origin In Some Form To Consumer
Presumption Of Truthfulness Of Declaration Of Product
Record Keeping Requirements – No More Than What Store Normally Maintains. Our Ability To Audit Is Intact
12. USDA Enforcement Every State Has Some State/Local Entity With Food Inspection Responsibilities
Most Economical Would Be To Contract With Agency In State Already Doing Retail Food Inspections
Remove Restrictive Recordkeeping In Favor Of Common Sense Approach