NMPF’s August Sees Flurry of Comments, Initiatives

NMPF spent the traditional August lull in Washington policymaking actively pushing its members’ priorities, submitting regulatory comments to federal agencies.

NMPF stood with other major agricultural organizations in joint comments submitted Aug. 13 against a draft risk assessment in which EPA models human exposure to the “forever chemicals” PFOA or PFOS from the application of sewage sludge, or biosolids, to farmland. The organizations asserted that EPA’s models operate on extreme assumptions that don’t account for the reality of agriculture, despite the agency’s best intentions.

NMPF also continued its decades-long fight against improper and ineffective air emissions modeling through comments Aug. 18 to the National Air Emissions Monitoring Study Group in response to draft revised emission models for animal feeding operations released by EPA late last fall.

After significant analysis, NMPF concluded that the current draft EPA dairy Air Emissions Estimating Methodologies (EEMs) are not appropriate for predicting dairy farm emissions. NMPF described the specific modeling flaws in its comments to support its argument that EPA should permanently cease its efforts in this area.

August also was highlighted by more activity from NEXT (NMPF Export and Trade), the revamped, cooperative-led export assistance program. NEXT member cooperatives secured 37 contracts in August, adding 8.6 million pounds of product in NEXT-assisted sales in 2025. These products will go to customers in Asia, Oceania, Middle East-North Africa, Central America, the Caribbean and South America and will be shipped through December.

NMPF also opened its fundraising raffle for its annual scholarship awards. The raffle runs through this year’s Joint Annual Meeting and concludes on Nov. 12 when winners will be announced.

Prizes this year include a $100 Airbnb gift card, a Cabot Creamery Fan Favorite gift box and more. The raffle can be accessed here. Back by popular demand, the scholarship committee will also be hosting a combination silent and live auction during the Cheese Reception on Nov. 11.

The NMPF National Dairy Leadership Scholarship Program supports master’s and Ph.D. students conducting vital research for the future of the industry. The program is largely funded through raffles and auctions. Donations are also welcome. These events are critical to ensuring the opportunity to support the next generation of dairy enthusiasts.

NMPF’s Joint Annual Meeting on Nov. 10-12, held with the National Dairy Promotion and Research Board (NDB) and the United Dairy Industry Association (UDIA), is open for registration. More information and registration is available here.

Meanwhile, the FARM team is beginning to develop its Version 2028 of its Animal Care program, conducting a stakeholder survey through Sept. 5 collecting input from dairy farmers, industry stakeholders and partners about topics, issues and potential changes. The survey results will inform a final report available on the FARM website early next year.

Finally, according to August USDA data, the July margin under the Dairy Margin Coverage program dropped to $10.94/cwt, as the DMC feed cost formula decreased by $0.34/cwt, and the all-milk price fell by $0.50/cwt to $20.80/cwt. The July DMC feed cost dropped on lower corn and soybean meal prices, while the premium alfalfa price changed little from June.

Dairy is Meeting the MAHA Moment

Few topics have gained as much discussion in agriculture in the second Trump administration as the Make America Healthy Again initiative, which this month sent its report on food and agriculture to the president. MAHA is many things, and for dairy it offers opportunities for policies that better align with what nutrition scientists and families already know — that dairy boosts public health and its consumption should be encouraged. But it could also be a double-edged sword for both farmers and consumers — which is why, as MAHA evolves, dairy needs to be ready to support good ideas and educate both policymakers and consumers in ways that benefit everyone it serves.

First: A little bit of a shakeup isn’t a bad thing. Dairy’s been in several decades-long battles that at this point can’t be explained by anything other than bureaucratic inertia. Some examples: Science supports the benefits of dairy at all fat levels, so why not whole milk in schools? Consumer transparency demands that plant-based beverages stop misleadingly using dairy terms to imply nutritional values they don’t have, so why can’t FDA enforce its own Standard of Identity for milk?

MAHA’s energy can break through some of these generations-old policy logjams. It also provides some tangible benefits to dairy consumers and the industry, such as:

  • Potential increased demand for whole-food dairy: MAHA’s emphasis on nutrient-dense “real” foods, including whole milk, could further raise demand for traditional dairy products. Fluid milk, yogurts, and butter are viewed as less processed than their alternatives. Those products are gaining market share — just look at cottage cheese and yogurt in the snack category. MAHA is part of this trend toward consumers shifting away from additive-laden options toward time-tested nutrition.
  • An even greater competitive edge against plant-based alternatives: Many plant-based alternatives rely heavily on synthetic ingredients, making them suspicious to the often-discussed “MAHA moms” who prefer a diet for their children that’s less dependent on products whose labels read like science projects. We’ve been talking about this for years, and the preference for so-called clean labels is yet another competitive advantage for dairy, which already wins on nutrition, cost and taste.
  • A focus on nutritional benefits: Speaking of nutrition — the MAHA conversation provides an opportunity to highlight the essential nutrients present in dairy products, including calcium, vitamins, and bioactive fatty acids. Dairy can be front-and-center in a healthy diet. We can lead the conversation.

MAHA cuts through many of the weeds that have grown up around food policy. At the same time, cutting through bureaucratic weeds shouldn’t hamstring farmer efforts to control actual weeds — you know, the ones that require herbicides. And that’s where the double-edged sword comes in.

  • Education about innovation: As the MAHA discussion continues, agriculture and dairy will need to be very clear in communicating the value modern agriculture provides to U.S. and global consumers. Technology and innovation has made America the world’s agricultural leader — and giving up on any of it without a thorough conversation and understanding the implications of any actions is essential. The administration has pledged to listen to farmers — let’s take them up on that. It’s a conversation to welcome, not to worry about, because agriculture and dairy have a great story to tell.
  • Continued commitment to food safety: The same is true for food safety, in which, again, America is the world’s leader. The impulse to help the small farmer who sells products locally, perhaps even directly, has long been a feature of agricultural policy in both parties. But any moves that create a two-tiered food-safety system will backfire against everyone. It will limit markets for small producers and create massive headaches in trade negotiations, just when agriculture badly needs better deals.

And a final thing to remember:

  • Dairy as an industry doesn’t need to rely on any single policy movement to thrive. Every opportunity MAHA creates for dairy unfortunately will have knee-jerk detractors who will question the administration’s motives, its science, and the legitimacy of its actions, often to score cheap political points at the expense of consumers. It’s just the moment we’re living in. But dairy’s current $10 billion investment opportunity isn’t being driven by Washington headlines. It’s driven by American and global consumers who recognize how dairy helps them, regardless of their ideological orientation. Milk isn’t Democratic or Republican — it’s universal, as household data shows. That’s something to prize in 2025. It should stay that way.

Dairy will do well in any marketplace that’s based on facts, transparency and quality. From the smallest Amish dairies to complex family businesses with thousands of cows — all of which are necessary to make sure that demand is met and preferences are served — the commitment to providing a product that genuinely serves the public is palpable.

MAHA may help create promising opportunities for dairy. It’s one part of an exciting time for the industry. Proactively engaging with policy shifts, embracing positive changes and staying alert for new challenges will be crucial for the dairy industry to thrive in this evolving landscape. We’re ready to do so.


Gregg Doud

President & CEO, NMPF

 

NMPF’s Galen Outlines Complaint About Country Crock Fake “Butter”

NMPF’s senior vice president Chris Galen explains for listeners of Dairy Radio Now why the American Butter Institute, which NMPF manages, recently filed a complaint with the Food and Drug Administration about the labeling of Country Crock’s “dairy free butter.” Galen, who is the Executive Director of ABI, says that a plant-based seed oil spread is by law not real butter, and shouldn’t be allowed to disguise itself as such.

Federal Regulations Evolving Fast

The regulatory climate in Washington is shifting in unprecedented ways, requiring quick responses and an eye for opportunities, NMPF regulation experts said in a Dairy Defined podcast released today.

The pace of evolution is “Intense, insane,” said Clay Detlefsen, NMPF’s Senior Vice President for Regulatory and Environmental Affairs. “It changes daily. It’s full of unknowns, and it’s moving forward at an absolutely crazy pace. We don’t know what to expect tomorrow or the next day or the day after that, but things are indeed happening.”

Joining Detlefsen to discuss what dairy farmers, processors and consumers should anticipate, from milk labeling to MAHA, are Dr. Jamie Jonker, NMPF’s Chief Science Officer, and Director of Regulatory Affairs Miquela Hanselman.

To hear more Dairy Defined podcasts, you can find and subscribe to the podcast on Apple Podcasts, Spotify and Amazon Music under the podcast name “Dairy Defined.”


Dairy’s Pronounced Advantage Over Plant-Based Alternatives

“This is a list of ingredients from foods — carrageenan, riboflavin, monosodium glutamate and 20 others that I can’t pronounce.” – HHS Secretary Robert F. Kennedy Jr.

This column isn’t here to call out specific food ingredients — carrageenan, for example, has made many an ice cream pint hold together well, proving the value of the raw seaweed extract. But if the idea is to take a more critical look at food ingredients that sound more like science experiments gone bad than healthy, nutritious products, we might just offer one helpful hint: Take a look at the plant-based “dairy” substitutes section and see what you find.

It takes a lot of substances to turn a slurry of chemicals, emollients, emulsifiers, additives and colorings — plus few almonds, oats, etc. — into something that looks like a dairy product. Things like, “mixed tocopherols.” Or “gellan gum,” (which, admittedly, is used in ice cream if you want it to stay stable when placed in flaming alcohol). Or “calcium disodium edta,” (which is also good at treating lead poisoning), among others.

Again, not casting aspersions on anything, just noting that your grandmother probably didn’t talk much about these ingredients over Thanksgiving dinner. Meanwhile, milk is made of… milk, with some vitamin fortification that dates back nearly a century. Cheese is made of… milk, with some additives that follow processes developed over generations. And other dairy products are made of… milk, with whatever else helps keep it safe and stable for consumers who are, in the end, experiencing the same nutrition and wholeness their forebears would have recognized in earlier, less pronunciation-challenged times.

This revelation isn’t anything new: In fact, Dairy Defined did a whole quiz on this theme in 2022 that’s still fun to complete. But it bears repeating as food policy gets a new look. Plant-based products or products derived from the fermentation of a fungus that are engineered to superficially resemble dairy are, by definition, imitations or (poor) substitutes of something that was already out there, already serving a public that understood what it did and what was in it. But in this case, the imposters want to call their product the same thing as the real thing, implying equivalencies in nutrition that just aren’t there and creating confusion in the marketplace.

And that needs to stop.

The last three FDA commissioners, serving both Republicans and Democrats, all recognized the problem — all that’s left is action. Regardless of one’s feelings about specific ingredients or the values they bring to specific foods, being transparent about what something is and what it isn’t, is an important principle from which to build.

Truth in labeling. Not hard to say. And long past time to do.

NMPF Urges Sped-Up FDA Approval of Climate Friendly Feed Additives

ARLINGTON, VA — NMPF called on the U.S. Food and Drug Administration to use existing legal authority to modernize its regulations allowing for faster approval of animal-feed additives that reduce greenhouse gas emissions, submitting comments to the agency today that highlighted the need for urgent action to enhance dairy’s role as a climate solution.

“Innovative and voluntary solutions are needed to reduce greenhouse gas (GHG) emissions, including methane,” said Dr. Jamie Jonker, NMPF’s chief science officer, in the comments submitted today. “Enteric emissions directly from cows currently account for roughly one third of all GHG emissions from dairy farms and present an important area of opportunity for methane reductions. Feed composition changes can directly or indirectly reduce enteric emissions resulting from livestock.”

While animal-feed additives are a promising path toward a net-zero future for dairy as outlined in industry goals, the pace of their approval lags that of competitors such as the European Union due to current FDA processes. By streamlining bureaucracy and allowing feed-additives to be treated as foods rather than as drugs, the United States can maintain and advance its global leadership in sustainability, Jonker wrote.

Through the U.S. Dairy Net Zero Initiative, a collaboration across dairy organizations, dairy-farm research is advancing new technology and new market development opportunities to make sustainability practices more accessible and affordable to farms of all sizes, including enteric methane reduction.

“One of the greatest opportunities that exists for U.S. dairy farmers is their ability to provide real solutions to many of today’s biggest environmental challenges like GHG emissions,” Jonker wrote. “Embracing new practices and technologies is key to making America’s dairy farmers an environmental solution while providing wholesome and nutritious dairy products to the U.S. and the world.”

For more on how dairy is advancing its stewardship and best practices, visit the National Dairy FARM (Farmers Assuring Responsible Management) Program’s Environmental Stewardship page.

NMPF Pushes Back on FDA Over Proposed Traceability Rule

NMPF filed comments Feb. 22 urging FDA to withdraw a proposed traceability rule that identifies what foods are high-risk and would warrant additional recordkeeping requirements to improve their traceability.

FDA proposed that all cheeses other than hard cheese should be considered high-risk foods.  FDA’s risk-ranking model, under the proposal, would place “pasteurized cheese, other than hard” as the riskiest of all foods in the marketplace — even above cheese made from raw milk, a finding NMPF thought was absurd.

This questionable ranking was partly caused by FDA adding a new criterion to its risk ranking model beyond what Congress had instructed it to do in the Food Safety Modernization Act, landmark food-safety legislation that became law in 2011. FDA added consumption data to the model, which had the effect of increasing a food’s risk rating due to its popularity. NMPF stated in its comments that popularity and risk do not go hand-in-hand — nor can FDA override what Congress has directed.

The comments also took issue with the agency’s interpretation that cheese made with pasteurized milk is not a food that has been subjected to a kill step, and therefore that full recordkeeping provisions should apply. Food subjected to a kill step has significantly fewer recordkeeping requirements, according to the proposed rule.

This rule, if put into effect, would increase consumer confusion, as FDA has long told consumers to choose pasteurized cheeses over raw-milk cheeses based on food safety concerns.

NMPF reviewed comments filed by the International Dairy Foods Association and supported their filing in its comments.

FDA Must Enforce Fake-Dairy Rules, NMPF Tells Agency Ombudsman in New Advocacy Phase

With FDA giving little indication of promised action on proper labeling of imitation dairy products, the National Milk Producers Federation today asked the agency’s ombudsman to ensure that rules are properly enforced.

“Allowing unlawfully labeled ‘plant-based’ imitation dairy foods to proliferate poses an immediate and growing risk to public health; it is a clear dereliction of the FDA’s duty to enforce federal law and agency regulations,” wrote NMPF President and CEO Jim Mulhern in the letter, sent to Dr. Laurie Lenkel, ombudsman for the U.S. Food and Drug Administration. “The FDA’s Office of the Ombudsman must intervene to break the bureaucratic logjam that is adversely affecting consumers. Doing so would fit squarely within the Office’s own mission to ensure even-handed application of FDA policy and procedures.”

The FDA ombudsman, based in the agency commissioner’s office, “serves as a neutral and independent resource for members of FDA-regulated industries when they experience problems with the regulatory process,” according to the agency. NMPF is urging the ombudsman’s office to take appropriate action to remedy the FDA’s lax approach to enforcing its own rules on the use of dairy terms on products containing no dairy ingredients, which have proven impacts on public health – a new phase of advocacy brought about by the agency’s regrettable inaction. The American Academy of Pediatrics and other organizations have offered evidence of nutritional deficiencies caused by confusion over the contents of plant-based versus dairy beverages.

NMPF last year released its own road map offering solutions to how public health, product integrity and free speech could be protected through updated regulations. NMPF also supports the DAIRY PRIDE Act, a potential legislative prod for FDA action, and has asked FDA commissioner Dr. Stephen Hahn to follow up on the pledge he made nearly one year ago to make fake-dairy labeling a high-priority issue at FDA.