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USDA Outlines Derogation Renewal Process for EU Health Certificates

Jul 31, 2013

The U.S. Department of Agriculture’s Agricultural Marketing Service recently published guidelines for farms that want to renew requests for derogations, or exemptions, under the European Union Health Certificate Program. The derogations allow milk from farms having difficulty meeting the EU regulations for somatic cell counts to be used in dairy products exported to the European Union.

The major difference between the United States and EU milk requirements is the maximum limit on somatic cell and standard plate counts for raw milk. Although the federal threshold in the United States is 750,000 cells per milliliter of milk, the standard set by the Pasteurized Milk Ordinance, the national average based on the Dairy Herd Improvement Association and USDA Federal Milk Market records are around 300,000. The EU threshold is set at 400,000.

The derogation allowed by the program is conditional; farms must take action to improve their counts or demonstrate that the non-compliant counts were caused by normal seasonal variations. The new renewal guidelines apply only to non-seasonal derogations, which are valid for one year; seasonal derogations cover a period of three years. See European Health Certificate Program, VII. Renewing Derogations, pages 8-11, for more details.

Dairy processors whose products may be going to the EU for export should request Certificates of Conformance from their milk suppliers verifying compliance with the EU regulations.

The guidelines also continue a derogation allowing the use of milk from farms that exceed EU somatic cell and plate count requirements if, during processing, the milk or milk products are (i) pasteurized or (ii) made into raw milk cheese that will be aged at least 60 days before being placed on the market.

For more information, contact Clay Hough, IDFA senior group vice president, at

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