Selling Raw Milk

Please be aware that much of the information provided here is in summary format and should not be construed as a substitute for requesting information from the relevant governing authorities.

NEW GUIDELINES FOR THE SALE OF RAW MILK IN IRELAND

Members of Raw Milk Ireland have worked alongside officials from DAFM and FSAI since 2015 to develop a set of guidelines which could be approved by all parties.

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Retail / Food-service

Selling raw milk is now legal in Ireland and for sellers/retailers, the same laws governing the same of any foodstuffs now apply. We advise that you ensure the milk is from a reputable local farm and that you ensure it is labelled, stored and segregated appropriately to ensure that consumers have all the relevant information at point of purchase. New industry led guidelines are in place as of Autumn 2018, these include a mandatory advice label which will need to appear on the bottle or on a sign where the milk is not in pre-packaged bottle or container; as well as a strict testing regime and implementation of high hygiene levels on the farm and for milking. It is our advice that you check that your supplier has signed up to these guidelines.

Farmers

Farmers intending to sell any quantity of raw milk in excess of 30 litres per week must register with the Department of Agriculture.
It is important to note that to minimise any potential risks, extra safety procedures should be applied at farm level as well as throughout milking, bottling and storage systems. Also that by selling milk direct to consumers or other food businesses, there is automatically a significant extra burden of regulatory responsibility - as is the case for all food business operators...

Information for Farmers Selling Raw Milk

Regulations

Currently the legal regulations in place for the sale of raw milk are governed by the same regulations as were already laid out in the general EU Food & Feed Hygiene Regulations of 2004, which have applied to all dairy farmers selling milk since their introduction to law in Ireland in 2006. The main extra requirements for raw milk production within these regulations are twice yearly herd tests for TB and criteria for levels of Somatic Cell Count and Total Bacteria Count.
The main (front) label must also state clearly that it is Raw Milk.

As of October 2018 - Industry Guidelines have been introduced which place a significantly higher burden on producers of raw milk to ensure that their product is as safely produced as is possible.

Registration Process

You can download a registration form from
DAFM Website Milk Hygiene Section
("Registration Form for the Supply of Raw Milk..." , listed under "Trader Notices")

You can also request a form by phoning the Milk Hygiene division on 057 8694358

Guidelines for the production of raw milk
are now available here

The specifics in EU regulations have been in place for any farmer selling raw milk (for use in cheese production, for example) for some time, and after the introduction of the SI in 2014, also apply to those selling more than 30 litres per week of liquid raw milk for direct human consumption.
Throughout late 2016 and in to 2018, additional guidelines, with significant consultation with industry for the sale of raw milk were approved by DAFM in consultation with FSAI
The new guidelines include:
- Stricter controls across all aspects of production.
- Implementation of a robust food safety plan and procedures including detailed HACCP plans with specific requirements.
- Shelf Life advisory based on FSAI recommendations and food law.
- Stringent  testing regime for process hygiene criteria and pathogens.
- An extra advisory label is mandatory for all producers who have signed up to the guidelines.

“This milk has not been heat treated and may contain harmful bacteria. The FSAI strongly advises that , unless it is boiled first,
it should not be consumed by children, pregnant women, older people or those who are unwell or have chronic illness

Further Documentation

Regulation 852/2004 The Hygiene of Foodstuffs
This is a more general set of regulations which applies to all food business operators selling food stuffs

Regulation 853/2004 Laying down specific hygiene rules for food of animal origin
This is the more specific regulation applying to those selling foodstuffs of animal origin, such as milk, and is the document which lays out the specific EU legal criteria for raw milk.

We also have available an edited document showing just the parts of  the above legal regulations pertaining to raw milk, but please note that this summary is not a legal document and is intended instead to be a helpful summary.  Note also that many aspects in this have now been superseded by stipulations in the Industry Guidelines. You can view the summary here: RMI - Summary & Excerpts EU Hygiene Regs

EU Industry Guide for Good Hygiene Practices in the production of artisanal cheese and dairy products
This guide had input from across industry in the EU and was approved by all local authorities and at EU level. It contains significant information on cheese, but also contains relevant sections for Raw Milk, including sample HACCP plans/sections.

Brief Background on the Legality of Selling Raw Milk for Direct Human Consumption

Owing to a exemption within the EU Hygiene regulations of 2004, it has been legal for Irish farmers to sell small quantities of raw milk to local retailers or from the farm gate since 2006 (this is when these regulations came into force in the Irish Statute Book). This exemption for small quantities, sold locally meant that farmers did not need to operate under the EU regulations as laid out.

In 2011, the government indicated that they wished to correct this situation and introduce a ban. However, following several years of negotiation by members of Raw Milk Ireland, in 2014, they indicated that they would instead consider introducing regulations.

With the introduction of a new legal amendment in 2015 (view Statutory Instrument here) The Department of Agriculture with the collaboration of Raw Milk Ireland, sought to define the terms small and local, which allowed for the original exemption.
The statutory instrument defines small quantities as 30 litres per week and local as within a radius of 20km from the farm.

To clarify this means that the exempt farmers (those producing under 30 litres per week) do not need to operate under the criteria in the EU Regulations. But it then brings farmers producing over 30 litres into the sphere of having to operate under the regulations.
Thus it is perfectly legal to sell raw milk, Farmers do need to register with the Department of Agriculture if they wish to do so.

Further industry led guidelines with more specific and stringent criteria for the sale of raw milk for direct human consumption have been discussed, we expect they will come in to force by 2018.

Please contact us for any further information, and if you wish to be listed in the "where to buy" section of the website.

If you are interested in becoming a part of Raw Milk Ireland, which involves receiving regulatory updates and input in to same, as well as ongoing help and advice with a variety of aspects of your business, then you can contact us for further information. As a group, we intend to put in place a charter for membership which will include specific standards and criteria and above all else a commitment to producing the highest possible quality of milk.