News for Dairy Co-Ops

More than a year of work from NMPF and the U.S. Dairy Export Council (USDEC) reaped dividends for dairy Jan. 4, as a landmark decision found that Canada is improperly restricting access to its market for U.S. dairy products and violating its U.S.-Mexico-Canada Agreement (USMCA) tariff-rate quota (TRQs) commitments.

The case, the first of any kind brought before a USMCA Dispute Settlement Panel, was launched with broad bipartisan support last May after months of urging from NMPF and USDEC, which is urging Canada to comply swiftly with the panel’s ruling.

“The United States and Canada negotiated specific market access terms covering a wide variety of dairy products, but instead of playing by those mutually agreed upon rules, Canada ignored its commitments. As a result, U.S. dairy farmers and exporters have been unable to make full use of USMCA’s benefits,” said Jim Mulhern, president and CEO of NMPF, calling the decision” an important victory for U.S. dairy farmers and the millions of Americans whose jobs are tied to the U.S. dairy industry.”

TRQs are a system of tariffs negotiated between countries that allow a predetermined quantity of imports at a specified tariff rate, where that rate is often at or near zero. Any additional imports above that predetermined quantity are subject to significantly higher tariffs. In the case of U.S. dairy products, these additional Canadian tariffs typically price U.S. dairy products out of Canada’s market, making fair access to Canadian dairy TRQs vital to maximizing exports to that market.

When the Office of the U.S. Trade Representative (USTR) brought the case in May, it argued that Canada has maintained dairy TRQ measures that run counter to its market access obligations under USMCA. USMCA specifically requires that Canada open its TRQ application process to anyone active in the Canadian food and agriculture sector. Yet USTR noted that Canada designates the bulk of its quotas to Canadian dairy processors who have little incentive to import, does not provide fair or equitable procedures for administering the quotas, and does not give retailers any access to them. These measures deny the ability of U.S. dairy farmers, workers, and exporters to use the TRQs and fully benefit from USMCA.

While the United States tried to resolve the matter through consultations with Canada before initiating the Dispute Settlement Panel, Canada refused to change its policies. NMPF and USDEC engaged USTR and Congress, achieving broad bipartisan support from more than 125 members of the House and Senate for bringing this matter to the USMCA Dispute Settlement Panel. There, a panel of legal experts evaluated Canada’s current dairy trade policies against its commitments under USMCA and found Canada was not meeting its USMCA obligations.

NMPF is urging farmers to sign up for maximum coverage in 2022 under the Dairy Margin Coverage (DMC) program.

This year’s signup, with a deadline of Feb. 18, is accompanied by new enhancements that make the program more valuable than ever for producers seeking protection against unforeseen market risks. NMPF-backed improvements include an enhanced feed cost formula to better reflect the cost of high-quality alfalfa hay, and Supplemental DMC enrollment for many producers whose milk production has increased since 2014.

More than $1.2 billion – a record – in DMC payments are expected to be distributed to dairy producers under the 2021 program, according to USDA data as of Jan. 3.

“Signing up for DMC, which offers cost-effective margin protection for small and medium-sized producers as well as inexpensive catastrophic coverage for larger dairies, is a no-brainer for 2022, especially considering the improvements we fought for in Congress and advocated for at USDA,” said Jim Mulhern, president and CEO of NMPF, in a statement when the program was announced.

DMC is part of a suite of federally backed risk-management tools, including the Dairy Revenue Protection (DRP) program and the Livestock Gross Margin for Dairy Producers (LGM-Dairy) program, which were revamped in the 2018 Farm Bill at NMPF’s urging. DMC resulted from NMPF’s effort to improve inadequate federal margin-protection insurance. LGM-Dairy and DRP were made workable via NMPF’s efforts to remove spending caps and a ban on enrollment in multiple programs, which previously limited their usefulness.

DMC in 2022 will fully incorporate the premium-quality alfalfa price into the DMC feed cost formula, an improvement from the previous structure that used a 50-50 blend between the premium-quality price and the overall average price. USDA also will make retroactive payments to producers using the new formula, dating from January 2020.

Meanwhile, the new Supplemental Dairy Margin Coverage program will enable some producers who are also enrolled in DMC to receive additional payments reflecting increases in their production since 2014 retroactively to January 2021.

More information about the DMC Program, including a webinar detailing this year’s improvements and a Supplemental DMC Q&A, can be found here.

A year of NMPF advocacy to alleviate shipping supply chain disruptions for dairy exports took a significant step forward Dec. 8 with the U.S. House of Representative’s passage of the Ocean Shipping Reform Act.

With input from a joint NMPF-U.S. Dairy Export Council Supply Chain Working Group launched in last July to draw on the expertise of members’ dairy logistics staff, NMPF worked closely with Representatives John Garamendi (D-CA) and Dusty Johnson (R-SD), USDEC and other agricultural partners to shape the legislation, which passed the House with a broad, bipartisan vote of 364-60. The bill is intended to mitigate the delays, disruptions and unreasonable fees that dairy exporters have faced for more than a year.

Following this win, NMPF now is building Senate support for the bill by highlighting key provisions meant to ease disruptions that have cost dairy exporters over $1.3 billion through the first three quarters of 2021.

If signed into law, the legislation would amend the U.S. Shipping Act to provide new oversight and enforcement authority to the Federal Maritime Commission, expand opportunities for shippers to seek redress from ocean carriers, and increase transparency and accountability among foreign-owned ocean carriers. The bill specifically would reign in carriers’ ability to deny contracted export shipments, increase the availability of containers, improve protections against retaliation, and better address fees that are accruing outside of dairy exporters’ control.

As part of the push that led to the overwhelming House vote, NMPF spearheaded a Dec. 8 letter from 78 dairy cooperatives, companies and associations reiterated the legislation’s importance to the continued success of U.S. dairy exports, which are on pace for a record volume in 2021 when final numbers are compiled. A FAQ on the bill that NMPF and USDEC created is here.

“We thank Representatives Garamendi and Johnson for their leadership in working to address the challenges dairy and other agricultural exporters have struggled with for the most of this year,” said Jim Mulhern, president and CEO of NMPF, in a statement after House passage. “The Ocean Shipping Reform Act is an important move toward ensuring the international competitiveness of our dairy producers is not unfairly limited by abuses from ocean carriers. We look forward to working with the Senate to carry this momentum forward.”

Robert Chesler, CEO of NMPF member cooperative United Dairymen of Arizona, emphasized the importance of securing new dairy market access opportunities through bilateral or multilateral Free Trade Agreements during a Dec. 14 Farmers for Free Trade (FFT) virtual town hall.

NMPF collaborates with the farmer trade group on town halls and meetings with public officials to tout the benefits of free trade and the need for the United States to pursue agreements that expand U.S. farm exports. The December town hall, headlined by Rep. Jim Costa (D-CA), focused on lost competitiveness for American dairy and agricultural producers as the U.S. government fails to move forward with new trade agreements.

During the virtual event, Chesler addressed the challenges that American dairy exporters face as trade competitors secure greater dairy market access in key export markets. Countries such as New Zealand, Australia, and the EU are aggressively pursuing new trade deals, which then harms the competitiveness of U.S. dairy products at a time when international demand is growing, Chesler said.

“We urge the Administration to seek Trade Promotion Authority renewal to go after new trade agreements,” Chesler said. “This is critical to realizing fully the potential of dairy markets in places like Vietnam, Indonesia, the United Kingdom and other major dairy purchasers. In the meantime, the U.S. should be using all types of trade tools to expand access and reduce barriers to U.S. exports with major agricultural importing markets.”

Chesler’s comments echoed statements made by Doug Chapin, Michigan Milk Producers Association chairman, at a Nov. 3 FFT town hall, part of NMPF’s effort to maintain grassroots pressure for the administration to act.

An NMPF and USDEC member based in Tempe, the United Dairymen of Arizona is a full-service milk marketing cooperative founded in 1960. Its farmer-owned manufacturing facility produces milk powder, cream, butter, and a variety of other dairy ingredients, many of which are exported around the world.

The November margin under the Dairy Margin Coverage program was $9.14/cwt, up $0.60/cwt. from October, as higher milk prices more than offset gains in feed costs. The new calculation will generate a payment of $0.36/cwt. for $9.50/cwt. coverage, which will be the smallest since September 2020.

The all-milk price component of the November margin was $20.80/cwt., $1.10/cwt. higher than a month earlier. The November DMC feed cost was also higher for the month, by $0.50/cwt., with nearly equal contributions from higher corn and soybean meal prices. The November premium alfalfa hay price was down slightly from a month earlier after rising steadily almost every month since September 2020.

The end-of-year dairy futures indicate a possible small payment to $9.50/cwt. coverage for December, but the current strong milk price outlook makes this questionable for future months, given the current market outlook.

Signup for the 2022 DMC program is underway and will close on Feb. 18. This year’s program has paid out $1.2 billion as of January 3, and NMPF is urging dairy farmers who haven’t yet joined the program to do so. NMPF has a page of resources for members who may have questions here.

NMPF was pleased to support Senator Tammy Baldwin’s (D-WI) efforts to bring attention to the need for Food and Drug Administration (FDA) enforcement of dairy standards of identity at the confirmation hearing of Dr. Robert Califf to become the next commissioner of FDA.

NMPF has long partnered with Sen. Baldwin on the issue, with the Senate committee hearing on Dec. 14 serving as the latest opportunity to bring critical attention to the agency’s lack of enforcement.

After speaking to the importance of dairy standards of identity, Sen. Baldwin asked Dr. Califf whether and when the FDA will begin enforcing its own labeling standards. Dr. Califf responded that he would make the issue a priority should he be confirmed as FDA commissioner, stating there is “almost nothing more fundamental about safety than people understanding exactly what they’re ingesting, so I am committed to making this a priority if I am confirmed.”

NMPF president and CEO Jim Mulhern thanked Sen. Baldwin for pressing Dr. Califf for “urgent action” on the issue, explaining that the issue “needs to be a top-of-mind issue for Dr. Califf” as the “ground has shifted since his previous tenure in the Obama administration, both as dairy imitators proliferate and the abuse of lax labeling enforcement creates nutritional confusion for consumers.”

NMPF has been advocating for the enforcement of standards of identity and integrity in the marketplace for four decades. The recent, long overdue FDA attention to the issue – including a pledge to provide guidance on enforcement in the coming months – provides an opportunity to lead to key progress toward enforcement. NMPF will continue to work with Sen. Baldwin, other members of Congress, and administration officials on the issue, now with Dr. Califf’s positive comments in hand.

FARM Program stakeholders identified care for  sick animals, calves, and non-ambulatory cattle as dairy’s  greatest priority to maintain focus on for Version 5 of FARM’s Animal Care Program as determined by an industry wide survey distributed through the fall with results presented at a virtual town hall Dec. 14.

The survey was intended to collect feedback from farmers, veterinarians, cooperatives, processors, and others within the dairy supply chain as planning commences for Version 5 of FARM Animal Care which will launch July 1, 2024. The survey questions were developed following a series of  focus groups hosted last August by the National Dairy Farmers Assuring Responsible Management (FARM) Program. FARM received 682 complete responses, and staff were able to identify potential refinement opportunities for the next program cycle in addition to the top animal care priorities from stakeholders.

The survey also showed general support for making minor modifications and adding clarity to the FARM Animal Care Program while avoiding large overhauls. Most survey respondents, including farmers, showed they would willingly support small changes to better address animal care vulnerabilities. Respondents also were in consensus that standards that aren’t direct measures of good animal welfare practices should be updated to prioritize an outcomes-based approach.

For more information, visit the Version 5 development page.

Despite not taking bids for two weeks during December breaks, CWT member cooperatives secured 41 contracts in December adding 3.5 million pounds of American-type cheeses, 105,000 pounds of butter, 44,000 pounds of whole milk powder, 767,000 pounds of cream cheese and 300,000 pounds of anhydrous milkfat to CWT-assisted sales in 2021. These products will go customers in the Caribbean, Asia, Middle East-North Africa and South America, and will be shipped from December 2021 through June 2022.

CWT-assisted dairy product sales contracts for 2021 total 53.1 million pounds of American-type cheese, 16 million pounds of butter, 6.4 million pounds of anhydrous milkfat, 12.2 million pounds of cream cheese and 45.1 million pounds of whole milk powder. This brings the total milk equivalent for the year to 1.447 billion pounds on a milkfat basis.

Exporting dairy products is critical to the viability of dairy farmers and their cooperatives across the country. Whether or not a cooperative is actively engaged in exporting cheese, butter, anhydrous milkfat, cream cheese, or whole milk powder, moving products into world markets is essential. CWT provides a means to move domestic dairy products to overseas markets by helping to overcome U.S. dairy’s trade disadvantages.

The amounts of dairy products and related milk volumes reflect current contracts for delivery, not completed export volumes. CWT will pay export assistance to the bidders only when export and delivery of the product is verified by the submission of the required documentation.

Export supply chain challenges persisted as 2022 began, as did NMPF’s work, together with the U.S. Dairy Export Council (USDEC), to spotlight the disruptions faced by dairy exporters to build momentum for government action.

NMPF’s focus on the issue in January continued its two-track approach of pushing for both legislative reform and near-term steps by the administration to complement that.

NMPF co-hosted an Agri-Pulse press event with USDEC on Jan. 31 to assess and discuss solutions to agricultural export supply chain snarls. The hybrid event, held at the National Press Club, featured a panel of industry speakers impacted by the agricultural export supply chain concerns, including USDEC member Leprino Foods, and a government panel of USDA Secretary Vilsack; John Porcari, the Biden Administration’s Supply Chain Ports Envoy; and Ocean Shipping Reform Act lead sponsors Congressmen John Garamendi (D-CA) and Dusty Johnson (R-SD).

“We hope to be able to make sure that people understand this isn’t just an import issue, it’s also an export issue,” Vilsack said at the event.  “And the Department of Agriculture wants to be part of the solution.”

The event, which had more than 1,200 RVSPs from industry professionals, advocates and media outlets, provided the opportunity to refocus attention on how supply chain challenges are affecting exports. NMPF conducted outreach to multiple news outlets to foster robust coverage of those aspects nationwide, gaining attention from Bloomberg News and the Hagstrom Report to the Bakersfield Californian.

The webinar followed a Jan. 27 CEO roundtable discussion hosted by Sec. Vilsack that included two NMPF members – Dairy Farmers of America and California Dairies Inc. –to examine what other steps the Administration could take to mitigate the export supply chain snarls still plaguing dairy and other agricultural exporters.

The events took place as NMPF worked to build support in the Senate for companion legislation to the House of Representatives-passed Ocean Shipping Reform Act. The Senate bill planned for introduction early this month by Senators Amy Klobuchar (D-MN) and John Thune (R-SD) reflects many of the key provisions NMPF worked to secure in the House bill. To build on that positive starting point, NMPF is urging some targeted improvements as the legislation proceeds through the Congressional process.

NMPF also built support for a robust bipartisan message to President Biden urging him to take several near-term steps allowed under current law to provide further relief to agricultural exporters. The House letter, led by Reps. Jim Costa (D-CA) and Dusty Johnson (R-SD), garnered 71 signatures. NMPF worked closely with Congressional offices to help craft the letter’s messages.

The U.S. Supreme Court on Jan. 13 blocked the Biden Administration from enforcing a vaccination-or-testing requirement crafted by the Occupational Health and Safety Administration. The court’s decision stayed the OSHA ETS COVID vaccination and testing requirements for employers with 100 or more employees and the Biden Administration abandoned pursuit of the mandate Jan. 26.

The ruling, which was in line with NMPF concerns, means that employers with 100 or more employees do not need to follow the OSHA ETS COVID vaccination and testing requirements.

This means employers can continue to implement COVID safety precautions as they determine for their business, subject to any state or local requirements.

“We are pleased with the Supreme Court’s decision on a stay of the ETS,” said NMPF President and CEO Jim Mulhern in a statement. “NMPF has long been concerned about the practical application of the OSHA regulation at a time when testing supplies are scarce and food and agriculture supply chains are already disrupted by a lack of worker availability. We have voiced those concerns in meetings and other communications to federal officials over the last several months. The court’s decision will bring relief to dairy employers who strive 24/7 to put nutritious products on consumer plates.”

Parts of the mandate requiring record-keeping and masks had been scheduled to go into effect on Monday, with full requirements going into effect by Feb. 9.

The Supreme Court decision in effect ends the Biden Administration’s attempt to establish a sweeping nationwide vaccine mandate. It also ends a brief but intense storm of activity for NMPF, which was discussing the requirement with federal officials even before it was announced.

The ETS itself was issued last Nov. 4.

Prior to the issuance of that rule in October, NMPF and several other agricultural entities met virtually with the White House Office of Management and Budget (OMB) to express our concern about the unseen rule.  NMPF expressed concern about the availability of COVID tests and suggested that the government use the Defense Production Act (DPA) as was done previously in a number of COVID-related challenges, to ensure an adequate supply of tests.  The government failed to do so in a meaningful way, a mistake given current difficulty in acquiring both rapid home tests and PCR lab tests.  NMPF and the others also suggested suspending the application of the OSHA ETS to essential critical infrastructure workers as defined by DHS-CISA (which NMPF played a critical role in defining) should the rule create workforce problems.

Meanwhile, to prepare for the possibility that the mandate would take effect and be upheld in court, NMPF created a Toolbox on its website explaining ETS basics as litigation exploded. The 5th Circuit Court of Appeals issued a nationwide stay on OSHA’s implementation and enforcement of the ETS on Nov. 6. Within days of that action, every Court of Appeals in the country had at least one case before it – 34 in all. On Nov. 16, all the cases were consolidated into one and the litigation was assigned to the 6th Circuit Court of Appeals.

The 6th Circuit ultimately ruled with a three-judge panel that the 5th Circuit’s stay needed to be lifted.  Immediately thereafter that decision was appealed to U.S. Supreme Court, which blocked the ETS pending resolution in the 6th Circuit.

On Jan. 26, OSHA revoked the ETS while stating it would pursue a permanent final rule to be released in May. Such a rule would need to be drastically different from the broad unconstitutional rule that OSHA previously issues and even then, it is likely to be challenged in court.  Employers with 100 or more employees may now proceed with addressing COVID-19 in the workplace as they see fit subject only to state and local laws.

In a related matter, the government has asked NMPF at the end of December for assistance in determining the state of food and agriculture entities and their workforces given ongoing complications due to COVID-19 and the recent spike due to the Omicron variant.

2021 narrowly missed being the first calendar year during which the Dairy Margin Coverage program would have made payments at the maximum $9.50/cwt coverage level during every month. But a milk-price surge prevented that from happening.

The December margin under the program was $9.53/cwt, $0.39/cwt. higher than November’s margin and above the threshold needed to trigger payments at the maximum coverage level. From November to December, the all-milk price gained $1.00/cwt, to $21.80/cwt, while the DMC feed cost gained $0.61/cwt. On a per hundredweight of milk basis, half of the feed-cost increase was from higher soybean meal prices, one-third from higher corn prices, and one-sixth from higher premium alfalfa prices.

Late January dairy and grain futures continued to indicate a very small likelihood for payments during 2022; still, the generally strong milk price outlook has shown volatility in recent weeks, and grain prices have been showing renewed strength.

Signup for the 2022 DMC program is underway and will close on Feb. 18. Last year’s program has paid out nearly $1.2 billion to 18,800 enrolled operations as of Jan. 31. NMPF is urging dairy farmers who haven’t yet joined DMC to do so. NMPF has a page of resources for members who may have questions here.

After over a year of sustained effort by NMPF and a coalition of other dairy stakeholders, the Federation celebrated a U.S. District Court ruling made public on Jan. 6 that “gruyere” is a common food name in the United States.

This victory was spearheaded by NMPF’s trade policy team, who also staffs the Consortium for Common Food Names (CCFN) and the U.S. Dairy Export Council’s (USDEC) trade policy activities, including USDEC’s work on this case. The team prevailed in securing a decision from Senior Judge T.S. Ellis III that upholds a 2020 U.S. Patent and Trademark Office’s ruling that gruyere is a generic term that cannot be trademarked as a term exclusive to French and Swiss producers.

“Not only is this a landmark victory for American dairy farmers and cheese producers who offer gruyere, this win sets a vital precedent in the much larger, ongoing battle over food names in the United States,” said Jaime Castaneda, NMPF Executive Vice President for Policy Development & Strategy and CCFN Executive Director. “The European Union has tried for years to monopolize common names such as gruyere, parmesan, bologna or chateau. This verdict validates that we’re on the right path in our fight on behalf of American food and wine producers to preserve their ability to use long-established generic names.”

The court determined the arguments of the French and Swiss associations were “insufficient and unconvincing” and the defendants presented “overwhelming evidence that cheese purchasers in the United States understand the term GRUYERE to be a generic term which refers to a type of cheese without restriction as to where that cheese is produced.” Despite this, the Swiss and French associations filed their intent to appeal the ruling on January 7. This decision however, positions U.S. dairy farmers and cheese producers well as NMPF prepares to work with CCFN and USDEC to defend this positive ruling and the powerful it sets for other generic dairy names.

The National Young Cooperators (YC) Program Advisory Council elected Valerie Lavigne, a New York dairy farmer and Agri-Mark member, Chairperson for the 2022 program year. In this role, Lavigne will guide the program and represent its interests to the NMPF Board of Directors.

“I am honored to serve as chairperson of the National YC Program and I look forward to leading this program into its 72^nd year,” Lavigne said. “The challenges ahead are significant, and I am proud to represent the unique needs of beginning farmers as they seek to establish themselves and grow within the dairy industry.”

In addition to her participation on the YC Advisory Council, Lavigne is part of NMPF’s Dairy Voice Network and serves as an officer for Agri-Mark’s YC Program. Lavigne’s Unc Brock Farm thrives on diversity with a productive mix of turkeys, meat chickens and laying hens, milking goats, horses and a 200-cow dairy herd. The farm also manages two food trucks and a catering business in Schaghticoke, New York.

Wisconsin dairy farmer Dustin Brunn, a Dairy Farmers of America member, was elected Vice Chairperson. The remainder of the 2022 YC Advisory Council includes:

• Sid and Kristin Huls, Prairie Farms
• Jaime Mowry and Matt Harrigan, Upstate Niagara Cooperative
• Spencer Hurlimann, Tillamook County Creamery Association
• Kameron Paschel, Dairy Farmers of America
• Kip and Rochelle Siegler, Michigan Milk Producers Association
• Ben Smith, Maryland and Virginia Milk Producers Cooperative Association
• Jason and Tiffany Staehely, Northwest Dairy Association
• Brittany Thurlow, Southeast Milk Inc.

The 2022 YC Advisory Council convened Jan. 25 for a virtual cheese tasting and 2022 planning meeting. The program will continue to offer free monthly webinars and plans to meet in-person throughout 2022 for its Dairy Policy and Legislative Forum, World Dairy Expo seminar and reception, and Leadership & Development Program.

The FARM Workforce Development Program, which encourages best practices in Human Resources (HR) and safety on U.S. dairy farms, updated its Safety Reference Manual in December to include chapters on ergonomics and noise and hearing protection. A digital version of these chapters is currently available in English, and a Spanish version will be available soon. The chapters include information and checklists anticipating and recognizing the hazards for both safety considerations.

Understanding that HR and safety management look different on every farm, the FARM Workforce Development Program provides resources to support dairy farmers’ continuous improvement. The addition of the two new issue areas meets the growing demand from dairy farmers and managers seeking straightforward, relevant information on workplace safety and health. Dairy producers are encouraged to reference the manual as a resource for a safety management program.

FARM also announced its Workforce Development Evaluator Training dates for 2022, which include both virtual and in-person offerings. These two-day trainings go through the FARM Workforce Development evaluation while integrating a review of key safety and HR topics covered in the questionnaire. If you are interested in attending a training, please email dairyfarm@nmpf.org to enroll.

CWT member cooperatives secured 106 contracts in January, kicking 2022 off by adding 15 million pounds of American-type cheeses, 2.0 million pounds of whole milk powder and 1.7 million pounds of cream cheese to CWT-assisted sales in 2022. These products will go customers in Asia, Central America, the Caribbean, Middle East-North Africa and South America, and will be shipped from January 2022 through July 2022.

CWT-assisted 2022 dairy product sales contracts year-to-date total the same as above; 15 million pounds of American-type cheese, 1.7 million pounds of cream cheese and 2.0 million pounds of whole milk powder. This brings the total milk equivalent for the year to 166 million pounds on a milkfat basis. Over the last 12 months, CWT assisted sales are the equivalent of 1.444 billion pounds of milk on a milkfat basis.

Exporting dairy products is critical to the viability of dairy farmers and their cooperatives across the country. Whether or not a cooperative is actively engaged in exporting cheese, butter, anhydrous milkfat, cream cheese, or whole milk powder, moving products into world markets is essential. CWT provides a means to move domestic dairy products to overseas markets by helping to overcome U.S. dairy’s trade disadvantages.

The amounts of dairy products and related milk volumes reflect current contracts for delivery, not completed export volumes. CWT will pay export assistance to the bidders only when export and delivery of the product is verified by the submission of the required documentation.