RECORDKEEPING REQUIREMENTS

Any person engaged in the business of supplying a covered commodity to a retailer, directly or indirectly, must maintain records to establish and identify the immediate previous source (if applicable) and immediate subsequent recipient of the product. Such records must identify the product unique to that transaction by means of a lot number or other unique identifier, for a period of one (1) year from the date of the transaction. 

Establishments that slaughter livestock are considered initiating suppliers of a covered commodity. The Agricultural Marketing Service (AMS), the agency administering the law and regulations, has indicated that the initiating supplier (packer) must have records in its possession that substantiate the country of origin of the meat product at issue. These records can be in a variety of forms, and can include animal health records, import or customs documents, as well as producer affidavits. Suppliers must make records available for review within five days of a request for such records.          

At retail, records and other documentary evidence relied upon at the point of sale to establish a product's country(ies) of origin also must be made available to USDA representatives for so long as the product is on hand and that information must be provided within five days of the request being made. For pre-labeled products, the label itself is sufficient evidence on which the retailer may rely to establish a product's origin.