National Standard for the Production of Milk from Grass-fed Cows

Frequently Asked Questions

This page is intended for producers

1. What is the DFC National Standard for the Production of Milk from Grass-fed Cows?

The DFC National Standard for the Production of Milk from Grass-fed Cows is a new national standard for milk labelled as “grass-fed.” The standard also establishes a certification process for farms that produce grass-fed milk.

Under the new standard, grass or forage must make up a minimum of 75% of a cow’s diet, with the remaining 25% consisting of grains and supplements, which are essential to the cows’ health. To ensure they meet the program requirements, farms must be certified and audited by qualified third-party certification bodies identified by DFC.

The standard was established in consultation with dairy producers, provincial dairy associations, dairy processors and representatives from Dairy Processors’ associations, ruminant nutritionist experts and university researchers. The program also follows Canadian Food Inspection Agency guidance for this type of claim.

2. Why is it necessary?

The national standard was developed in response to growing consumer demand for grass-fed milk. The creation of a national standard will allow for greater consistency in participating provinces, with measures to ensure the grass-fed standard is being met.

3. Does this program follow CFIA guidelines?

Yes. The program also follows Canadian Food Inspection Agency guidance for this type of claim.

4. What consultation has been done with producers and processors?

Producers and processors were consulted throughout the development of the DFC National Standard for the Production of Milk from Grass-fed Cows and had the opportunity to provide their input to DFC.

5. What validation/certification will be done?

Grass-fed farms will be audited by an accredited certification body to ensure compliance with the standard. In addition to the annual on-site inspection, farms can be subject to an unannounced inspection. In addition to these audits, milk from grass-fed farms are subject to a minimum of six tests for biomarkers per year (one every two months), which will be facilitated by the provincial association.

6. This is a pilot project. What does that mean?

The new standard is being launched as a one-year pilot project as approved by the DFC board in September 2019. During that period, farmers that elect to produce grass-fed milk using the DFC national standard, must adhere to the new standard. For those farmers that participate in the program, milk will be tested at regular intervals by a laboratory certified by their provincial board (6x per year, approximately every 2 months).

DFC will collect data for potential improvements during the pilot period,  including diet, efficacy of the biomarker testing and other program elements. DFC will report back and provided a recommendation to the board in September 2020 where the guidelines and standard would be re-evaluated.

7. I agree with milk testing in principle, but what are the biomarker benchmarks trying to accomplish?

The principal behind milk testing of the biomarkers is having a tool to validate if cows under the grass-fed protocol are, indeed, eating at least 75% of forage. Coupled with documentation the testing will also provide additional evidence on the efficacy of biomarkers for grass-fed through the year.

Feeding Protocol

1. Why are grain supplements allowed at all, and how was the 75% grass or forage feed : 25% grain feed ratio determined?

Many other countries require 100% grass or 100% pasture in their feeding protocol, but this is not possible in Canada due to our winters. Cows produce a lot of milk and require a minimum level of grains and supplements to ensure they have the energy and nutrients they require for optimal health and milk production. Cows deficient in energy or protein may develop health issues. Grain supplements help ensure the cows meet their nutrient requirements. The 75-25 ratio was determined in consultation with ruminant nutrition experts and will be monitored during the pilot period. Every farmer should consult with a professional expert to ensure the quality of the feed under the 75/25 standard for their farm does in fact meet the nutritional needs of the herd.

2. Why is forage permitted in the standard for grass-fed?

Forage is actually the edible vegetative parts of plants, such as grass and other than separated grains, that can provide feed for grazing animals, or that can be harvested for feeding.

3. Why did you decide to implement a prohibited feeds list?

To ensure that cows are eating at least 75% grass/forage, we need to assure the integrity of the biomarker results by prohibiting certain feeds have an adverse effect on the biomarkers.

4. Why is soybean meal acceptable but not soybean?

Full fat soybean, sunflower and safflowers are rich in linoleic acid so they will increase the ratio of Omega 6 : Omega 3.

Solvent-extracted meals like soybean meal, on the other hand, do not have this negative effect (because the oil is extracted) and are therefore safe to use.

Expeller-pressed meals may contain too much residual oil (6 to 8%) and should be used cautiously.

5. Can/should we allow for different levels of concentrate during winter vs. summer?

This percentage of grains and supplements can increase to a maximum of 30% of the total dry matter intake with a written recommendation from a Ruminant Nutritionist or the herd veterinarian. This would be coupled with an assessment of the quality of the forage being fed during wither the summer or winter months.

6. Why is there a limit on Linseed of 1 kg/day, especially when linseed clearly, very effectively, improves Omega 6: Omega 3 ratio?

Again, to ensure that cows are eating at least 75% grass/forage, we need to assure the integrity of the biomarker results by prohibiting certain feeds have an adverse effect on the biomarkers. A limit was imposed on linseed as it can adversely affect the biomarker results.

Pasture Management, Grazing, Confinement and Stock Piled Forages

1. Why is the grazing area per animal identical to the grazing area in the Organic Standard? I would expect that a grass-fed standard has more acres devoted to grazing.

The Organic Standard uses “animal unit”. It was determined that the minimum requirement for the pilot should be comparable to the organic standard, in terms of providing a sufficient level of area for ongoing grazing.

Animal Health and Welfare

1. Regarding the Animal Care Assessment under proAction, would I need a “fast tracking”? For example, my date of Mandatory Compliance is July, 2019 would I need to “fast track” my Compliance, i.e. visit from FSR and Holstein Canada – animal assessment?”

No, you can maintain your current validation month and be compliant with proAction requirements.

Testing and Auditing

 1. What biomarkers will be tested and how often?

The authentication of milk that is produced under the grass-fed standard is based on the feeding protocol and specific biomarkers, i.e. the 18:2 n-6/18:3 n-3 (Omega 6/Omega 3 ratio). The ratio will be tested at a minimum of six times per year at regular intervals.

2. Who will pay the cost of testing?

Producers will pay the costs for the testing of biomarker testing.

3. What happens if a producer "fails" a biomarker test? (i.e. how many positive tests do they need before they can ship "grass-fed" again?)

Biomarkers level are a monitoring tool for the feeding protocol, if a producer "fails" a biomarker test, this could trigger a review of the feeding protocol, pasture management plan, or any other document required as determined by the certification body. This may also trigger an additional on-site inspection if determined to be necessary by the certification body. Any identified non-conformities with the standard would have to be rectified before the grass-fed farm could begin re-shipping milk under the program.

4. Who will be performing the third-party audits? At what frequency? What training will they receive that qualifies them?

An accredited certification body (CB) will perform at least one on-site and document audit per year. The accredited CBs must meet certain requirements established by DFC (including, being certified by CFIA to perform organic certification, compliance with ISO standards, etc.)

The list of accredited CBs will be published on DFC’s website.

5. Should the auditor (certifying body) have a say in making sure the standard is clear in understanding and the intents are satisfied?

Yes, and the process for any concerns over interpretation of the standard are laid out in the Operating Guidelines of the Program.

6. Should there be a transition period to access the program?

Yes. Producers who want to start on the program must submit documents for review by a CB, as well as undergo an initial on-site inspection. Once completed, they must meet the biomarker levels on 2 consecutive bulk tank tests (over 2 months) prior to being certified as grass-fed.

7. Does the producer have to keep records?

Yes, and be kept for 5 years.

8. Who pays for certification costs?

Producers will be charged a fee by the accredited CB of their choice.

Cost of Production/Premium

1. What is the premium for producing grass-fed milk?

The premium for producing milk from grass-fed cows will be determined by each provincial board in consultation with relevant processor.