I called USDA after all and I got a call back within hours - the system does work after 
all...the person I spoke to is; 

Albert K. Hoover, Head of the Inspection and Standardization Section at 202-720-5021 or 
[log in to unmask]

He referenced 7 CFR PArt 52
Doc No AMS-FV-08-0075; FV08-330
RIN 0581-AC89

here is a link

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5078052

Anyhow here is what he told me if I got it right over the phone. 

"US Grade A" is considered a USDA mark or statement.

If you have US Grade A on your label you are required to state the country of origin as in 
"Product of USA". 

A penalty for producers for not listing the country per the COOL regulation is no 
inspection. But since honey and maple syrup are the only exempt crops from inspection 
by USDA in order to claim US Grade A, the new COOL regulation is essentially 
unenforceable for beekeepers. I'm not sure how this applies to importers/packers but it 
sounds like they have other rules.

He did say it would be a good idea to come into compliance when you reprint labels but 
did not think it was necessary to toss out label inventory. This discussion was in the 
context of me being a producer/packer and not having a large national distribution. 

Unless I am missing something, this is a great day for american honey producers and 
those of us who are competing with OUS honey on shelves. 

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