Vorzugsmilch has existed in German-speaking countries in Europe since the 1930s. People don’t want to use the word ‘Vorzugsmilch’ (anymore), because ‘bevorzugen’, or preferring the raw milk to pasteurised milk, has not received recognition, despite numerous experimental and epidemiological studies. All milk is the same; milk = milk. Nowadays, it is more about freedom of choice; consumers can choose which milk they want to drink, or offer to their children, and the dairy farmer who wants to supply such milk must meet verifiable safety, transparency and hygiene requirements.

On 1 January 2025, the Netherlands will come up with virtually a copy of the requirements of the German ‘Vorzugsmilchgesetz’ (= law). More stringent in some respects, simpler in others.

The law was published in the Official Gazette on 24 June 2024. Below are the articles related to raw milk sales. New for the Netherlands, raw milk may be delivered packaged to consumers, but only directly to consumers or via a direct buyer/shop, not a distribution center. The chain must be short. So, no raw milk at the big supermarket chains. Milk taps on the farm will continue to exist, but this milk must also be checked and labelled in the same way (date and time of milking).

Section 5, Article 8 deals with the legislation around providing and maintaining the safety of raw milk and raw cream (below, we will refer to raw milk only for convenience). Article 8 is worded as follows, omitting Articles 3 and 4, which deal with sending frozen milk below:

1. Raw milk intended for human consumption is delivered to consumers only on the farm where it is extracted or to local retailers delivering directly to consumers.
2. The livestock farmer may deliver to consumers from the farm in 2 ways:
   1. if raw milk is delivered unrefrigerated: within two hours after milking;
   1. if the raw milk is cooled immediately after milking to a temperature not exceeding 4°C and kept at that temperature until delivery: within 72 hours of extraction.
3. … (omitted)
4. … (omitted)
5. Raw milk intended for direct human consumption complies with:
   1. certain bacteriological criteria (see below), and controls
6. The dairy farmer shall have raw milk tested for total aerobic plate count at 30°C at least twice a month.
7. The examination referred to in point 6 shall take place at the end of the storage period of the milk, but no later than 72 hours after production. This examination may take place earlier if it can be justified that the plate count will also meet the criterion mentioned in the Annex at the end of the storage period.
8. The dairy farmer shall have raw milk tested at least once a month for Salmonella, Campylobacter and Shiga-toxin-producing E. coli (STEC). The frequency of this examination may be halved if the results meet the criteria referred to in point 5 for six consecutive months.
9. The livestock farmer shall keep records of the investigations referred to in points 6 and 8 for two years and shall keep it available to the supervisor. A point was added to Article 8:
10. Registration obligation: the dairy farmer reports to Our Minister by means of an electronic form, if raw milk is produced in this way. The COKZ will supervise.

An article is inserted after Article 8:

1. The dairy farmer shall ensure that on packaged raw milk, the date and time of extraction of the raw milk is indicated. This does not apply, if the milk is sold from the milk tank.
2. The dairy farmer shall ensure that on the packaging of raw milk or on the cooling tank or milk tap itself, the following is clearly legible:
   1. RAW MILK * USE ON DAY OF PURCHASE * DON’T GIVE HARMFUL BACTERIA A CHANCE * BOIL BEFORE USE RECOMMENDED.
3. Notwithstanding point 2, the indication ‘USE ON THE DAY OF PURCHASE’ is not mandatory if the packaging bears a date of minimum durability or a use-by date.

The above aerobic germ count should not exceed 25,000 germs/ml milk (cow, buffalo), or 50,000 (camel, dromedary, horse or donkey) and 100,000 (goat, sheep and other species). STEC must be absent in a 25ml milk sample. Something similar applies to Campylobacter and Salmonella.

Perspective

The law provides opportunities to offer raw milk in urban areas. One can think of packaged raw milk delivered directly to consumers by a dairy farmer, as some German dairy farms do. But there is also the possibility of delivering packaged raw milk directly to shops or coffee bars.

To do for farmers

For the farmer, this means that he/she must set up an internal control system, as is done by, for example, the US dairy farms affiliated to RAWMI. By checking the bacterial count and how many Enterobacteriaceae / E.coli are present in the raw milk, you can keep an eye on hygiene on the farm. With a good hygiene plan in practice, there is no fear, when once or twice a month control samples are taken by the COKZ. After direct cooling of the milk below 3-4 ^oC and packing only 1 milking, if possible, from selected cows, much in terms of safety can be achieved. Knowledge and experience, where dairy farmers should pay attention to in terms of farm hygiene, are known.

There are a few salient points different from Germany. In Germany, the vet also must check the health status of the herd. Also, other zoonoses may be checked for. Examination of the Vorzugsmilk delivered takes place monthly and raw milk may be delivered to cities through a distributor. However, Kindergarten delivery and delivery to elderly are forbidden. Finally, the Germans also pay attention to certain criteria around udder infection in cows.