PolicyBrief
S. 294
119th CongressJan 29th 2025
COOL Online Act
IN COMMITTEE

The COOL Online Act requires online retailers to clearly disclose the country of origin and the seller's location for foreign-made products offered for sale on the internet.

Tammy Baldwin
D

Tammy Baldwin

Senator

WI

LEGISLATION

New COOL Online Act Requires Digital Sellers to Disclose Country of Origin and Business Location

The COOL Online Act is designed to bring the 'Made In' labels we see in physical stores into the digital age. It mandates that online retailers clearly disclose both the country of origin for foreign-made products and the country where the seller’s principal place of business is located. This means when you are scrolling through a major marketplace for a new pair of headphones or a kitchen gadget, the listing must explicitly state where that item was manufactured and where the person selling it to you is actually based. The goal is to eliminate the guesswork for shoppers who want to know exactly where their money and products are coming from before they hit the 'buy' button.

Digital Labels for Your Digital Cart

This bill targets products that are already required to have origin markings under existing trade laws, such as the Tariff Act of 1930. If a product is 'multi-sourced'—meaning the same item is made in several different countries—the seller has to disclose that fact too. For those of us who buy over-the-counter (OTC) meds online, the rules get even stricter: listings must show the name and location of the manufacturer or distributor exactly as it appears on the physical drug label. This is a direct play to ensure that if you’re buying pain relievers or allergy meds from a website, you have the same level of transparency you’d get holding the bottle at a local pharmacy.

The Small Business and Grocery Pass

Not every digital transaction falls under these new rules. The bill carves out a 'small seller' exemption for individuals or tiny businesses moving less than $20,000 in goods or making fewer than 200 sales a year—think of a hobbyist selling handmade crafts or someone cleaning out their garage. It also skips over used goods that have already been sold at retail once before. Perhaps most importantly for your weekly budget, it excludes most food, meat, and poultry products already regulated by the USDA or FDA. So, while your new power drill will need an origin label, your online grocery order for steaks or produce won't be affected by this specific piece of legislation.

Accountability and the 'Good Faith' Buffer

Enforcement falls to the Federal Trade Commission (FTC), which will treat missing or fake origin info as an unfair or deceptive act. However, the bill acknowledges that a local online shop might not always know if a massive overseas manufacturer is lying to them. There is a 'safe harbor' provision: if a retailer relies on info from a supplier in good faith and quickly pulls a listing once they find out it's wrong, they aren't held liable. While this protects the person running an online boutique from being sued for a manufacturer's mistake, it also places the burden on consumers to stay vigilant if a seller is consistently 'accidentally' posting wrong information. The rules are set to kick in 12 months after the FTC and other agencies finalize their implementation plan.