Most people think low milk prices to dairy farmers are the natural, but an unfortunate, result of overproduction. In reality, the US is a net importer of dairy products. We import not simply specialty cheese; we also import more and more generic cheese. One relatively recent import enters the US under current trade rules not as a dairy product but as an industrial chemical.
Loopholes in the General Agreement on Tariffs and Trade (GATT) have allowed imported Milk Protein Concentrates (MPCs) to pour into this country from all over the world. Since all MPCs are imported, some suggest that we have only to raise the tariff and all will be well. Solutions are not that simple, and the use of MPCs is built on is a swamp of safety questions.
What are MPCs? There is no standard of identity. Milk protein concentrate is usually considered to be a dry form from a technology known as ultrafiltration. In the ultrafiltration process, skim milk is pumped past a filter or membrane designed to separate out most of the water, lactose and other solids, leaving behind a product which is mostly protein and known as "retentate." This retentate is then dried until it is a powder. Protein levels vary with the amount of concentration. Generally, protein is from 40 to 80%.
But not all MPCs are made from this new technology. Some MPCs are simply old-fashioned casein and nonfat dry milk. Some might have additional lactose and any number of several forms of dry whey. No one has any breakdown of type or composition of these products.
What we do know is that in the six years between the GATT agreement in 1994 and 2000, imports of MPCs increased 600%. Imports doubled between 1998 and 1999, reaching a peak in 2000. Final figures are not in for 2001 but, they are expected to be close to the 1999 numbers.
MPCs have become a common ingredient in "sports drinks", dietary supplements, including some for infants and a wide range of other products. "Milk Duds" and Dr. Atkins "Shake Mix" are just two products containing MPCs. Caution has been thrown to the wind.
They have, however, become a hot topic with dairy farmers. MPCs reduce farm milk price and put at risk milk's pure reputation. Domestically produced powdered milk has been used for a number years to "standardize" the protein levels of milk for cheese. Corporations making cheese now often substitute cheap imported MPCs for domestic powdered milk. The government is now a major buyer of domestic powdered milk which is indirectly subsidizing imported MPCs.
Adding MPCs to the cheese vat produces an inferior cheese. Never mind that, there is a big payoff for corporations in two ways. Cheese yield is increased which allows them to be more "competitive" by selling to the likes of Wal-Mart for less. Since farm milk price has a direct correlation with cash cheese price on the Chicago Mercantile Exchange, use of MPCs drives down all milk pricing to farmers. To say the rewards to the processors is huge is an understatement.
It is not surprising that there is a major effort to confuse the issue. Virtually everyone agrees that MPCs cannot be used in a cheese &emdash; a standard of identity. Yet Kraft "Singles" is just such a cheese and yet listed in the ingredients is MPC with impunity. Many will say confidently that it can be used in non-standard cheese or added legally to cheese starter. This is not true.
The Food and Drug Administration (FDA), which has legal responsibility, has simply withheld enforcement and oversight. When pushed the FDA will admit a proper "Generally Regarded As Safe" (GRAS) determination has to be made for each use. That is virtually impossible since there is no precise criteria for just exactly what MPCs are.
Adding to the impossibility of GRAS determination is that MPCs are coming in from all over the globe. While we import much of the MPCs from New Zealand and Europe, we have no way to be certain of where they originated. We import MPCs from Belarus and the Ukraine which are likely to be contaminated with radiation from Chernobyl. We import MPCs from countries with horrible sanitary conditions.
Countries seem to not mind when corporations use their country for repackaging, or as it is called transshipping. No apparent harm is done and the big payoff is, as usual, a few local jobs. Corporations engage in this not only to gain a favorable tariff rate, but more importantly to disguise the country of origin.
In case you think there is no way unsafe MPCs could enter this country, consider a GAO report (GAO-98-103). It states, on page 26:
"FDA relies primarily on port-of-entry inspections and tests to ensure the safety of imported foods. Because such port-of-entry inspection and testing has been widely discredited as an effective means for ensuring safety, FDA cannot realistically ensure that unsafe foods are kept out of US commerce. Even if FDA could inspect more shipments at the ports of entry than it currently does, such an approach would still lack assurance that imported foods are picked, processed, and packed under sanitary conditions."
MPCs have not poured into the US because of loopholes in GATT. Corporate bottom lines circle the globe every day looking for new loopholes while the regulators look the other way. That, however is not the only requirement. Necessary to the task is that most people don't even know what MPCs are or where they originate. Those few who do are kept mostly quiet through confusion. High up the rungs of the corporate ladder this strategy of profit enhancement is part of what has become normal. It is assumed and accepted that those at the top will be the winners and those below will absorb all risk.
The processor lobby is attempting to change the legal definition of milk through a petition to the FDA. That must not be allowed to happen. FDA's responsibility is to the public, not industry.