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CoBank: Dairy Industry Eager for Reforms to FMMO
Pennsylvania Ag Connection - 01/20/2023

U.S. dairy producers and processors are paying close attention to preliminary discussions about the 2023 Farm Bill in anticipation of critical reforms to Federal Milk Marketing Orders (FMMOs). Prevailing consensus within the industry is that the FMMOs currently in place do not reflect today's market environment, which could increasingly have detrimental consequences for dairy processors and farmers alike.

Key among the industry's concerns are so-called "make allowances," an important part of FMMOs that have not been updated since 2008, and were based on data from as far back as 2006. Make allowances are an estimate of dairy processors' cost of converting milk into dairy products. Many of those production costs, including labor and energy, have skyrocketed since make allowances were last updated 15 years ago.

According to a new research brief from CoBank's Knowledge Exchange, the discrepancy between the make allowances currently in place and actual manufacturing costs sends inaccurate price signals to the marketplace, potentially leading to a misallocation of capital and resources.

"Inadequate make allowances may lead to underinvestment in dairy processing facilities or result in over investment in low-cost plants," said Tanner Ehmke, lead dairy economist for CoBank. "Ultimately, that could result in limited market access for U.S. dairy products and allow international export competitors to meet the rising global demand for high-value dairy products."

Aside from milk and other milk components, which are the highest input cost for dairy product manufacturers, plants also spend money on labor, energy, packaging, transportation and other inputs to create finished products. The combined costs of labor and utilities like energy account for at least one-third, and up to one-half, of total production costs for dairy manufacturers.

While current make allowances in FMMOs have remained static since implemented in 2008, prices for industrial electric power rose 64% from 2006 to 2022, according to U.S. Bureau of Labor Statistics. Industrial natural gas prices fell 11% but were highly volatile. Labor costs in dairy product manufacturing climbed 48% per unit of production from 2006 to 2021.

"Cost structures among dairy processors or handlers will continue to change, requiring more frequent adjustments to make allowances over time," said Ehmke. "And while updating make allowances does not guarantee more investment in new processing assets with every handler, failing to update them may result in lost market access and diminished growth opportunities for the U.S. dairy industry long term."

Make allowances are also used to set the monthly minimum prices that regulated processors must pay for farm milk. While the first effect of increasing make allowances would be to lower prices paid to farmers, reducing the industry's vulnerability to international competitors and export market access offers important long-term benefits.

Read the brief, Updating Make Allowances is Central to the Future of Federal Milk Marketing Orders at

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