United States Food Law Update: Pasteurized Almonds and Country of Origin Labeling

The last six months of 2008 found the nation occupied with a heated presidential election campaign and the transition to a new party's control of the executive branch. The outgoing president, as is often the case in the waning months of an administration's time in office, attempted to finalize several policy initiatives. This version of the Food Law Update will discuss two major developments with significant long-term impact on the law of food: the implementation of mandatory country of origin labeling (COOL) for most unprocessed agricultural commodities; and the increasing use of the United States Department of Agriculture's (USDA) Agricultural Marketing Service to regulate food safety via marketing orders/agreements. Specifically, this update will discuss new rules mandating treatment of raw almonds to reduce the risk of Salmonella bacteria.

As an update, this article does not attempt to exhaustively analyze the implications of these developments, but merely to identify and briefly discuss the issues as a departure point for further analysis.