Pakistan Dairy Industry
Pakistan Dairy Industry
Pakistan Dairy Industry
A publication of
Pakistan Dairy Development Company
Dairy Pakistan Township, Kot Lakhpat Lahore, Pakistan, Telephone: + 92 42 55142 145 Fax :(042) 5781909
Sponsored By:
&
Geoff Walker
Chief Executive Officer
Pakistan Dairy Development Company
State Cement Corporation Building, Township Kot Lakhpat,
Lahore - Pakistan
E-mail: [email protected]
Web Site: www.dairypakistan.com
Phone: 042-6132368, 042-8434971
Mobile: 0334-4228774
1
Acknowledgements
The authors of this White Paper wish to thank all the associated organizations, and their staff,
for their many and varied contributions. Firstly, however, it is necessary to thank the Minister
of Industries, Production and Special Initiatives, The Honorable Jahangir Tareen, without
whose drive, energy and vision, Pakistan Dairy Development Company would not exist. We
would like to acknowledge in particular the support of Mr. Roland Decorvet, Managing
Director of Nestle Pakistan Ltd and Mr. Pär Söderlund, Managing Director of Tetra Pak
Pakistan Ltd for sponsoring the study. Our thanks also to Mr. S. Fakhar Ahmed of Nestle
Pakistan Ltd for being a key member of the team responsible for this White Paper.
Special thanks to the following for all their support & Contribution
J E Austin
Members of the Dairy Strategic Working Group
Ministry of Food, Agriculture and Livestock
Team members form Nestle Pakistan Ltd
Small and Medium Enterprises Development Authority (SMEDA)
Tetra Pak (Pakistan) Ltd
USAID
Individuals not associated with any of the above organizations but who deserve
acknowledgement include Messrs. Tony Christianson and Suleman Ghani.
Many others have also contributed advice and feedback; our thanks go them.
Geoff Walker
Chief Executive Officer
2
TABLE OF CONTENTS Pg
Para No. Description
EXECUTIVE SUMARY 6
CHAPTER-1
1.0 Introducing Dairy Pakistan - A Pathway to Progress 16
1.1 Dairy Pakistan Governance and Management (Brief) 16
1.2 Farm Management and Dairying Research Institute 18
CHAPTER-2
2.0 Overview of Pakistan’s Milk Economy- Present Scenario 19
2.1 Milk Production 19
2.2 Structure of Dairy Farming in Pakistan (Comparative to other countries) 20
2.3 Smallholding Farms 21
2.4 Economies of Scale and Mechanized Farms 23
2.5 Milk Collection and Distribution system 24
2.6 Processed Milk Industry (Business Environment and Constraints) 26
2.7 Processors and Consumers 29
2.8 Adulteration and Hygiene Issues 30
2.9 Seasonality 30
2.10 Milk Pricing & Profitability in a Competitive World 30
2.11 External Influences 31
CHAPTER-3
3.0 White Revolution (Dhoodh Darya) 33
3.1 Specific Targets of the White Revolution 37
3.2 Modus Operandi to Unlock the Potential – The Eight-point Strategic Agenda of the
White Revolution. 37
3.2.1 The most important point of the Strategic Agenda of the White Revolution will be the
successful implementation of the Dairy Development Projects. 37
3.2.2 Creating Rural Entrepreneurs 37
3.2.3 Developing the Value Added Market – innovation in health, pleasure and presentation 38
3.2.4 Organizing the informal sector into documented formal economy and to formalize the role
of the middlemen 39
3.2.5 Propagating quality and implementation of pasteurization laws: 39
3.2.6 Mapping Increased Supply Pockets and special incentives for NWFP and AJK 39
3.2.7 Attracting foreign investments and joint ventures and encouraging Existing Processors 39
to increase investment in the sector
3.2.8 Dairy Pakistan - creating a monitoring and implementation Mechanism for the White Revolution 39
3.3 White Revolution (Dhoodh Darya) promises to empower rural Pakistan 39
CHAPTER-4
4.0 Strategy in Action – Strategic Initiatives by Dairy Pakistan 43
4.1 Small Holder Dairy Project 43
4.2 Dairy Technology Program 43
4.3 Diversified and Accessible Dairy Micro-financing Committee: 43
4.4 Dairy Quality Standardization and Monitoring Mechanism 44
4.5 Dairy Media Campaign – “Dhoodh Darya” 44
4.6 Dairy Business Advocacy Program: 45
4.7 Dairy Cold Chain and Innovative Protective Materials 45
3
CHAPTER-5
5.0 The tax, the tariff and the trade’’- Policy needs analysis for the Dairy Sector – a case for 46
Business advocacy
5.1 Zero Rating Of Sales Tax On Dairy Products 46
5.2 Zero Rating Of Customs Duty On Raw Materials For Packaging Supplies To Dairy Industry 47
5.3 Processing Equipment, Plant and Machinery 48
5.4 Dairy Farming and Extension Services 49
5.5 Import of Semen 50
5.6 Import of Vaccines: 50
5.7 Tariff Rationalization for the dairy sector 51
CHAPTER-6
6.0 Creating Dairy Entrepreneurs, Empowering Small Holding Farmers and Developing 52
Dairy Infra-structure
6.1 Milk Collection Tanks 52
6.2 Model Dairy Farms 53
6.3 Farmer Technical Training Program 55
6.4 Farm Management and Dairying Research Institute 56
6.5 Mobile Milk Collection Units program 57
6.6 Review of Support Services Technical (Animal health care) Training 59
6.7 Farm Input Stores for farmer Small Holding Farmer Facilitation 59
6.8 Livestock Housing 61
6.9 Biogas 61
6.10 Indigenous Breeds 61
6.11 The Value of Buffalo Milk 62
6.12 Boosting Herd Numbers and Genetic Diversity through Imports 63
6.13 Developing Milk Pockets 63
CHAPTER-7
7.0 Business Model Program 65
7.1 Creation of Rural Entrepreneurs 65
7.2 Finance and the Middleman 65
CHAPTER-8
8.0 Cold Chain vs. Warm Chain 67
8.1 Approaches 67
8.2 Integrated approach 68
CHAPTER-9
9.0 Increasing the National Herd Size and Genetic Potential Through Animal Imports 71
CHAPTER-10
10.0 Adulteration and Hygiene Issues for Milk and Proposal for Pasteurization Law 72
10.1 Summary 72
10.2 Adulteration and Hygiene Issue 72
10.3 Strict Compliance for quality and implementation of Pasteurization laws 72
10.4 Dairy Quality Standardization and Monitoring Mechanism 72
10.5 Dairy Food Safety Standards and Pasteurization 73
CHAPTER-11
11.0 Conclusion 74
ANNEXURE Proposed Pasteurisation Law 77
ANNEXURE Dairy Safety Standards for milks and milk products 84
4
ACRONYMS
USD: US Dollars
GAWALLA: A person who collects milk from the farmers and supplies to cities
5
Executive Summary
This will enable farmers to successfully sustain themselves as private entrepreneurs in the "White
Revolution". The benefit will initially be for the local Pakistani market and in long term, the possibility of
developing linkages with other markets in other regions will be explored.
The White Revolution is targeted to achieve an annual production of 40 billion liters of milk by 2015; it
aims to create an additional 3 million jobs in the formal economy and provide an estimated 350 million
rupees per day in cash flow to farmers in the sector.
Dairying will be practiced across Pakistan, in a manner that contributes to balanced regional
development.
An integrated rural support economy will be in place, with contractors supplying support services.
Education for professional service providers will be broader than at present, producing qualified
experts capable of proving advice to farmers across a range of farming related matters.
Boosted by a greater contribution to GDP from dairying, rural infrastructure will be much improved
from the present.
Large farms and milk colonies will be generating part of their own energy needs through biogas.
The linkage between the dairy industry and micro-finance providers will enhance the living standards
of millions of smallholder farmers.
An industry with a greater proportion of milk handled by the formal sector, and with consumers
more aware of product quality standards, will be attractive to foreign investors.
At the highest level, it is considered that the problems that need to be faced if a developed dairy industry
is to be built are as follows:
Profitability
Quality
Meeting the needs of the “the 95%”
Note:
1-It is expected that with improved and demonstrable profitability, further investment in farming will
solve issues relating a shortage of milk. Thus, the need to increase milk production, especially over
summer, is considered a secondary rather than a primary matter.
2-“The 95%” is the approximate proportion of the population, which struggles to afford current
presentations supplied by the market by the formal sector.
9
Strategic Recommendations
Via Dairy Pakistan’s Model Farm program, identify best practice farm management systems, taking
into account regional variation and farm sizes, and disseminate these practices through the industry.
o Critically, these farm management systems must enhance profitability.
Via Dairy Pakistan’s Cooling Tank program, working in conjunction with several other initiatives,
improve the quality of milk delivered to consumers and processors.
Through both incentives and penalties, discourage adulteration and encourage respect for milk
throughout the supply chain.
Identify a model for delivering cost effective pasteurized milk to a
much higher proportion of Pakistan’s population, and implement.
Improve the service offered by supporting functions, and
improve access to these support services:
o By reviewing professional education methods and
improving if necessary.
o By building upon present training initiatives.
Critically, Dairy Pakistan must cater to a wide variety of stakeholders, including Government, donor
agencies, processors, people working within the industry, consumers and no doubt most importantly the
dairy farmers of Pakistan. Strategies will be modified and change over time, but the goal of driving the
development of the dairy industry to the satisfaction of these stakeholders, in a balanced and fair manner,
must remain paramount.
10
Proposed Projects
Dairy Development Projects are designed to deliver a number of specific development models through
investment in infrastructure and human capital. That is
3. 2100 mobile milk collection units will be provided under the rural entrepreneurship program.
4. A Farm Management and Dairying Research Institute will be established under “Dairy Pakistan"
with a focus to do research & development and disseminate research based practical measures, which
are adoptable at the grass root level farmers; Projected analysis reveals that if only 5% of 15,000,000
farmers increase their yield by 50% (to 6.3 kg) the total milk supply will increase by 1,575,000 kg per
day. This is a long term project and needs specialized planning and deliberation.
7. Farm Input Stores for farmers: In order to ensure availability of balanced nutrition for 1.5 million
animals, a total of 690 bulk farm input stores will be established resulting in improving milk yield per
animal (Micro credit facilitation will be provided).
10. Indigenous Breeds: Modern breeding methods and research will be focused under this project to
protect indigenous breeds while improving the milk yield of these breeds.
Readers are reminded about the three main problems to be solved if a developed dairy
sector
The following diagram illustrates firstly how the identified programs will help to solve the
problems, and secondly indicate how the programs act in concert – individual programs will not
supply an easy solution.
12
Model
Farms Cooling
Tanks Pasteurization
Mobile
Milk
Collection
Farmer Bulk
Vocational Vending
Training
Commercial
Farms
Rural
Entrepreneurs Milk
Farm Pockets
Input
Stores
13
Governments will carry out a media campaign called the Dhoodh Darya Media Campaign – (DMC) for a
period of five years 2006-2011. The information campaign will educate the consumers on health risks of
unhygienic loose milk encourage farmers or groups of farmers to develop a cold supply chain and adopt
best farm practices to economically benefit from production of more milk and developing better quality
supply mechanism.
The financial as well as technical support required and available will be highlighted through media
campaign so as to enable all stakeholders to benefit from the dairy development agenda.
Policy Support
A good level of policy support is also requested from the government for developing the dairy sector.
The main recommendations are as follows,
a) Zero Rating tax regime for value added dairy products, to allow specific dairy related inputs to be tax
and duty-free.
b) To allow import of raw and packaging material at 0% duty currently based at 25%. Special incentives
to be provided to licensing, quality productions, setting up of corporate dairy farms and a special tax
incentive to be given for setting up processing units in earthquake hit AJK and NWFP, this will
create livelihood opportunities in the regions and increase milk supply pockets.
Conclusion
It is important to note that development of the dairy industry is a journey of many small steps.
Cognizance must be given to the present state of the industry and the consumer habits. It is not possible
to leap to developed world dairying – the basics must be focused on first, and then a logical progression
followed.
It should also be recognized that the identified programmes build upon each other. There is no one
program, which will provide a permanent and effective solution. Rather, effort and progress must be
spread across a broad front.
The White Revolution is an opportunity to deliver change and modernization to the dairy industry, and
therefore unlock the potential of the dairy industry of Pakistan. This White Paper is intended to illustrate
how the combination of many programs can drive development of the dairy industry. Successful
development will benefit the many millions of farmers, and the even more millions of milk consumers.
14
Dairy Pakistan
Vision 2015
Implementation of a complete
dairy development model with
fully matured institutions and Dairy Census & Situation
procedures (mentioned on next Analysis
page)
Services
Retail/Whole 24%
Sale
19% Others
16%
Manufacturing Agriculture
18% 23%
33 Mio Tons
Sind
23%
Punjab
63%
7.59
20.79
NWFP
Balochistan 12%
2%
3.96
0.66
16
CHAPTER-1
Dairy Pakistan is a company registered under section 32 of the companies Ordinance 1984. The
company since its inception in 2005 has helped organize the Dairy Sector by providing it with one voice,
gaining support from relevant government Ministries, commissioning several studies and reports on
various agendas, including the instant strategy paper for the whole sector. New roles and tasks have been
prescribed to the Company. The following programs will be carried out under the auspices of the
Company.
To promote development and upgrading of the dairy supply chain in Pakistan by supporting and
facilitating the farmers, processors and other stakeholders across the value chain.
To support growth of the dairy sector by way of supporting and facilitating business development
services for enterprises across the dairy value chain.
To promote milk and other value added dairy products.
To formulate, with the necessary consultation among stakeholders, an Industry Development
Strategy and to coordinate and drive implementation of the same.
To initiate and support the entire dairy value chain to enhance sector competitiveness through
innovation and research.
To facilitate and support new technologies for improving productivity of enterprises across the dairy
value chain for greater sector competitiveness.
Institutional capacity is critical to the ability of Dairy Pakistan to lead development of the dairy industry as
described in this paper. It must be recognized, however, that Dairy Pakistan can only build its resources at
a rate consistent with available funding and with projects agreed to be supported by funding providers. It
is the intention of Dairy Pakistan to utilize the greatest possible proportion of the available funding in its
early years on actual development programs rather than on its own structure. Therefore, Dairy Pakistan
intends to take a stepwise and modular approach to build the necessary human resources as required by
the pace of the development program.
As an example of the modular approach, within the Model Farm program, Dairy Pakistan foresees that
additional team leaders can be recruited as necessary, with farm production officers then recruited to
support the team leader. It is anticipated that one Team Leader can manage 10 Farm Production Officers,
and each Officer can supervise 10 Model Farms; thus appointment of a new Team Leader can result in
100 new model farms per year. With experience, it is expected that the number of farms managed by each
Farm Production Officer will increase. The same holds for the Cooling Tank Program.
17
As an example of the stepwise approach, designed to keep costs down in order to free resources for
development program, is found with functions such as Human Resources – Dairy Pakistan will outsource
this function until its staff numbers warrant bringing the function in-house.
Clearly, support functions will be built upon at the necessary pace to manage the intended growth of
Dairy Pakistan.
The planned organogram, if support and funding is gained for all the projects within this paper is as
follows:
CEO
GM Farm Production
GM Technical
GM Business Models
CHAPTER -2
Hence, there is an imperative need to re-engineer Pakistan’s dairy industry; both at farm and processor
level. This paper seeks to investigate the tools that could bring about such change. We believe achieving
the strategic change outlined in this paper for the dairy industry may prove challenging for at least some
sectors. Major effort is required to achieve the scale and cost competitiveness necessary to continue to
successfully compete in a globalising and demanding world, while at the same time the interests of the
millions of smallholder farmers must be catered for, and a more prosperous future made available to
them.
It is important conditions are in place to ensure decisions about The major challenge is to up-
scale, the number and product portfolio of processing plants grade small holding farmers by
are made in a rational manner; this is needed to maintain price solving their productivity and
competitiveness and market growth. Small niche players will farm management constraints,
also have substantial growth opportunity in the Pakistani dairy and at the same time
market and their growth will be an added asset. In the absence, substantially increasing the
at present, of a cold chain; presentation and packaging number of commercial farms.
methodologies will be explored for longer shelf life of
products.
Lastly, investing in dairy infrastructure and the dairy workforce in rural and urban areas cannot be
overemphasized. Without doubt such developments will revolutionize rural Pakistan and improve the
quality of life of millions of farmers. An improved dairy infrastructure less dependant on the middlemen
will support the farmer to connect directly to processors and the consumer.
With this backdrop we seek to investigate the current state of affairs of Pakistan’s dairy sector.
1The source of all figures on the page is EDS Tetra Pak 2004,Pakistan Economic review 2005, Calculations by Dairy SWOG
2Pakistan Economic Survey 2004-05 based on 27 Billion Liters worth Rs 540 Billion @ Rs 20 per liter milk average price (Market price
year 2005- 2006).
20
TABLE- 2.A
Overall, the contribution of dairying to the national economy is of the order of Rs.540 billion (with 97%
as informal non-documented economic activity), and is expected to grow at 4% per year under current
scenario. If the process is accelerated with process improvement and focus improvements identified
through this White Paper, a growth level of 20% can be achieved.
Being a highly perishable commodity and produced primarily in the heart of the rural environment, milk
reaches the consumer only with much difficulty and increased cost. Urban usage of milk is only 30% with
the formal milk processing industry handling only 2 to 3 % (around 1 billion liters) of total milk
production of the country. For the other 97%, a multi-layered distribution system of middlemen has
evolved for milk supply. An estimated 20% of current milk production is lost from income generation
due to fragile infrastructure facilities required for a highly perishable commodity like milk. As a result of
these factors, Pakistan is a net importer of milk and milk products. An important goal for the dairy
industry of Pakistan is to meet the needs of the people of Pakistan, such that while imports are welcome
they are not necessary.
Small and marginal land-holding farmers and landless labourers dominate milk production in Pakistan.
These small holding farmers usually practice dairy farming as a by-product of the crop sector.
overshadowed. This has hampered the growth of a specialized sector with specific dairy innovative
techniques.
The vast majority (about 70%) of dairy farmers in Pakistan are smallholding farmers. Up to 43%
of dairying households in Pakistan maintain herd sizes of one to two animals while another 28% of the
households maintain herds ranging from three to four animals3. Some 90% of milk production comes
from smallholding farmers. Many believe that only large mechanized farms are the solution to increased
profitability and quality. While this is true for many US, EU and other developed countries having
achieved a level of farm mechanization, the challenge is to achieve the goals of profitability and quality
while recognizing the situation in Pakistan.
In Pakistan, a two-tiered action plan is required: to develop systems, which provide profitability
for the smallholder and maintain quality through the supply chain, while assisting the
development of larger scale commercial farms. We believe the co-existence of both kinds of farms is
the reality of dairying in Pakistan and development efforts must provide solutions for both smallholders
and commercial farmers. The Chinese model of farm development may provide a good example.
Milk production in China is very diverse. There are large farms, usually owned by dairy processors
that utilize some of the latest management, feeding, and milking technologies. These farms do not,
however, account for the bulk of milk production in China. Smallholding production co-exists with large
farms.
In China, either small farmers bring their cows to the station or the cows are housed near the
milking facility – to allow cows managed by households to be milked by machine and have the
milk go directly to a refrigerated bulk tank. There are also a growing number of medium-sized
specialized household farms with 200-10004 cows. These are often private farmers within reasonable
transportation distances from major consuming areas. These farmers also have mechanized milking, cold
storage, and highly productive animals (5000-7000 litres/head/year). Hand milking and un-refrigerated
milk collection continues, but less and less of the resulting milk is making its way into urban areas and
into the processing sector.
3 Livestock Census 1996, Agricultural Census Organization, Statistics Division, Government of Pakistan.
4 Medium sized is in the context of Chinese farm size
5 IFCN International Farm Comparison Network
22
It is said that farms having land to grow crops and forage (PK-3 and PK-10R) were relatively most
competitive. The PK-10R farm is said to be most viable farm size, and has the potential of challenging
competitors in export markets6. Such farms make effective use of technological advances in breeding
practices, e.g., artificial insemination, to improve their herd quality. Some of them have also installed their
own pasteurization or processing equipment. However, there are only 23% of farmers who fall in the
PK-10R category, whereas 70% of the farmers have less than four animals.
Low animal productivity, lack of balanced animal feed, poor animal hygiene, lack of water
availability and lack of new animal-breeding methodologies are some of the problems inherent
in smallholding farm economics.
Lack of drinking water for animals is a big problem. It is said that if only
water was readily available to the animals, productivity could increase by as
much as 7%. This demonstrates that even simple infrastructure and
management solutions could lead to improved productivity.
8The program should develop farmers having good genetic material pool. It will help to select good genetic material initially from the total
champions. Each farmer should have a minimum 200 adult female animals. A total 100 farmers for each breed may be selected in the country.
The program should be designed to provide benefits to all stakeholders namely farmers, insemination companies, GoP and the milk industry.
24
The large-scale rural farms producing on a commercial basis in Pakistan are among the lowest cost farms
in the world, driven by low cost of labor and feed. This has been reported in IFCN9 2004. While still
limited in number, the big commercial farms of Pakistan have major economic benefits. Existing
commercial farms need to boost their current level of mechanization, automation and refrigeration (cold
chains), in order to be more productive. By providing the scale and capacity to invest, the large farms will
assist existing and emerging product and market opportunities for Pakistan’s Dairy sector.
2.5 Milk Collection and Distribution system
While the structure of the dairy processing industry has improved dramatically, milk collection
and distribution is fragmented compared to systems found in other countries. There is a need to
improve the supply chain from farmer to consumer in Pakistan.
There is very limited data available on the routes to market or the distribution channels
employed in Pakistan. Most of the milk produced in the farms is consumed at the household level. The
surplus is marketed at the local markets in form of liquid milk or purchased by milk collectors and
transported to urban areas through different distribution channels.
The milk supply and marketing chain involves different players such as milk collectors (dodhis),
traditional cream manufacturers and "Khoya" (milk concentrate for local sweets) makers and
retailers. (The traditional cream and khoya is often very unhygienic and is made in dirty work
conditions hence is a danger to human health). Dodhis or milk collectors play an important role in
collection and the marketing chain of the dairy sector of Pakistan. The dhodhi community may even
reach a million in number. Based on their
financial and technical abilities, they can be
classified in three groups of small, medium and
large-scale milk collectors. The small-scale milk
collectors collect an amount of 200-400 kg
milk per day from different farms, often in
remote areas. Some of them make long-term
contracts at a predetermined price offering a
share of the milk price in advance to the
farmers. In small towns, they may directly market the milk, but in larger urban
areas, they sell the milk to the large collectors. Medium scale milk collectors collect
400-800 kg milk per day in a manner similar to the small milk collectors, but on a
larger scale. This group may carry out door to door milk delivery and marketing in some nearby urban
markets using different means of transportation. Large-scale milk collectors collect 1.5 to 3 tons of
milk/day, purchased often from the small and medium scale collectors and act as middlemen between
them and retail shopkeepers. Large scale milk adulteration is practiced mostly by this group of large scale
milk collectors.
The rural supply chain for processed milk industry has three patterns: milk collection through third-party
milk collectors; self-collection system of dairy plants and farmer cooperatives. Third party collection and
self-collection are the more prevalent collection systems, whereas to date dairy co-operative systems have
failed to succeed in Pakistan. The Figure 2-D10 below highlights the collection and distribution pattern of
rural Pakistan.
9
International Farm Network Comparison, 2005
10 The State of Pakistan’s Dairy, Abid A. Burki, Mushtaq A. Khan, Faisal Bari, July 2000
25
Consumers
Of the total milk sold by the farmers, 15 - 19% is thought to be wasted en route-to-market due to
spoilage from a lack of proper cooling, storage, and transport systems. There is an imperative need to
prevent the wastage of milk, which is the result of a poor cold chain. Milk being a highly perishable
commodity does not give many choices for storage or channels; consequently, the unorganized
middlemen as a speedy substitute to a cold chain dominate the supply chain. Both investment and
regulation are required to develop the cold chain, which will help consolidate the milk collection system.
The cold chain infrastructure is envisaged as a means to create rural entrepreneurs in the rural economy.
Improved supply chains may reduce milk collection costs faced by the processing industry, presently
averaging around 16% of the factory gate costs (with the remainder being the price paid for the milk). We
also believe dairy farmers should be encouraged to become more flexible in collection hours to allow
longer hours for collection of milk that will ensure cold chain tankers run as economically as possible.
This brings us to the most complicated issue of Pakistan’s Dairy supply chain namely; achieving
a “Level Playing Field” between the middlemen Dhodhis and the processors. At present,
middlemen play a critical role in the Pakistan dairy industry: Without them, a far smaller proportion of
milk would find its way from the farmer to the consumer. To varying extents, processors rely on dhodhis
collecting milk and transporting it to collection centers. It is well known that adulteration of milk occurs
in Pakistan on a broad scale. The general view is that much of this adulteration occurs after the farm gate
and before processors receive it, i.e. when the milk is in the control of middlemen. Further, it is probable
that middlemen do not pay tax as per the more formal sectors of the industry.
Better regulation and enforcement could be established to make adulteration less easy and punished
to a greater extent.
Dairy Pakistan and other industry participants could fund a marketing campaign to educate
consumers on the dangers of loose milk.
Zero rating of the industry will reduce some of the advantages achieved by the tax avoidance thought
to be practiced by at least some middlemen.
Dairy Pakistan’s Cooling Tank program will result in more collection centers being established, thus
improving access for farmers who wish to deliver milk to processors directly.
Farmers delivering directly need to earn a higher price for their milk than those supplying through
middlemen.
Often in developing countries (and indeed in developed countries), a regulatory approach creates as
many problems as it solves. Regulation can be a source of corruption. Adequate regulation is already
in place, which should, in theory, protect milk quality. Further regulation is unlikely to change present
practices.
A marketing campaign may be successful over a prolonged period, but within the constraints of
present limited funding availability for Dairy Pakistan, it is probable that higher priorities should be
met first. Dairy Pakistan will, however, play a co-coordinating role with other industry participants,
should they wish to fund such a marketing campaign.
Zero rating is an important step in achieving a level playing field.
Dairy Pakistan’s Cooling Tank Program is another important step.
It should be noted that the intent of Dairy Pakistan is not to cut all middlemen out of the
industry; however, illegal actions such as adulteration and desirably tax avoidance should be
made more difficult to undertake. Middlemen who wish to respect milk, the farmers who provide it
and the consumers who drink it, are a welcome part of the industry. However, none of the above or even
all of the above steps is likely to succeed in changing the role of middlemen, for there is another
important function they provide, and that is the provision of credit. Dairy Pakistan intends to explore
with institutions, both national and international, the alignment of the operation of collection centres with
the provision of micro-credit. Only with such credit facilitation will genuine alternatives to the middlemen
exist. It is probable that present interest rates on credit supplied by middlemen are onerous, so the
suggested integration between the operations of collection centres and credit provision could have a
major impact on the welfare of especially small farmers.
Smaller processors manufacturing traditional sweets (Nirala) or organic product lines can create
success stories both in domestic and possible export markets. We feel much attention and focus is
given to the large plants, while niche players should also be encouraged. A technology-led and innovative
product mix approach can create a high margin niche in dairy plants.
Due to the lack of a cold chain and refrigeration systems in Pakistan, pasteurized milk has had
substantial market failure. On the other hand UHT and powdered milk with longer shelf life
have proved to be good alternatives to expensive cold chains. A successful example of pasteurized
milk is India, the reason being a well designed and effective cold chain. It is interesting to note that some
of the deepest rural areas of India are connected to the consumer through railway based cool tanks. In
China, in most urban centers UHT is preferred, but in more outlying areas milk powder may be
consumed for convenience. The adoption of UHT technology and new packaging
technologies in China has enabled the transport of milk from northern provinces
to the population centers. Companies like Yili and Mengniu (based in Inner
Mongolia) were able to rapidly enter markets on the coast and in the south. In
Pakistan, UHT and powdered milk is likely to be the only means of providing an
alternative to “loose milk”, especially in NWFP and Balochistan.
Of the different types of processed liquid milk, UHT milk packs are by far
the most popular products. The contribution of UHT processed milk to real
GDP in Pakistan has gradually increased from only 0.117% in 1994-95 to 0.201%
in 2001-0211 shown in Table 2-E. Moreover, the share of UHT processed milk in
livestock GDP has also gone up to 2.2%, and is consistently growing.
Undoubtedly, capacity utilization of the processing sector is effected negatively by seasonal milk
supply. While difficult to quantify accurately, it is clear that there is a cost associated with the lower
11
The State of Pakistan’s Dairy, Abid A. Burki, Mushtaq A. Khan, Faisal Bari, July 200
28
capacity utilization that is borne by the processors. Put simply, those with higher capacity utilization levels
are able to make their investment in plant and equipment work harder for them, and produce greater
quantities of product. In some cases, lower capacity utilization (shown in TABLE 2-F below) enables
processors to switch between products in response to short term market trends. Improved capacity
utilisation will arise from higher milk production over summer, which will occur as a result of better farm
management and more cows.
TABLE 2-F
Processor Capacity13
Processors Capacity Capacity Utilization Average
(Million liters) Monthly
Flush Lean
Additionally, Metro, Carrefour and Makro are expected to enter Pakistan’s retail sector. This
should give an additional boost to dairy marketing. From an advertising and marketing point of view,
changes in retail formats, in particular due to the emergence of these supermarkets, will create new
marketing channels for companies from outside the region to access consumers in Pakistan. Advertising
and promotion of dairy products will intensify, and there will be both increased challenge and opportunity
for the processors to improve product portfolios.
A product category penetration report from 2005 shows that in the food basket, the highest
penetration is achieved by tea 97%, loose milk 93% and rice 92%14. This trend shows the scope and
opportunity of milk as a staple diet higher than even rice. The report further suggests that powdered milk
and UHT are likely to be two winners for urban milk demand. In other words the processor industry
should concentrate in the value added segment.
The key focus should be to add value to base products by various means and to create points of
difference in the products wherever possible. This is achieved through a number of measures including:
Branding, (Pakistani local UHT producers and ethnic sweet producers have followed MNCs in
effective branding; this trend should continue and spread more in smaller players).
Flavor: innovations and research in improved flavor
Functionality: Consumer interest in diet and health relationship, aging populations, and advances in
food technology all create opportunity. China's dairy industry has been very successful at creating
such functional products; designer milk powders – special fortified formulations for infants, young
children, teenagers, adults, and seniors – and these products are able to capture segments of the
market that consume dairy products for their health benefits.
Segmentation/customization: specific food designs for Pakistani consumers in rural and urban areas
(processors should not rule out the potential of the rural dairy market). Dairy consumption should
grow as retailing improves in rural areas, rural incomes rise, and availability and the variety of dairy
products continues to improve. However, it could be a very gradual process, taking years for the
average rural household to reach the ability to pay for processed dairy products that consumers in
urban areas had when dairy consumption took off a decade ago.
Development of specific food solutions, for health, diet control etc.
Organic products; this is a potential growth area but completely neglected by the processors in
Pakistan.
Packaging; improved packaging solutions will be the key to introducing the above trends in the local
market.
The optimal product portfolio for each individual market will clearly depend on that market’s stage of
development and sophistication. At the risk of being overly optimist, we believe value added products are
likely to be long-term winners and even functional and organic foods have the potential of 2-5% growth
till 2015.
14
Research carried out by AC Neilsen 2005
30
Regulation may help to control the adulteration but the root cause of such adulteration is the lack of
developed milk collection/logistical systems. Only a small percentage of the milk is properly collected.
2.9 Seasonality
Production of milk falls to 55% of peak production at its lowest point in mid-June, while the
demand increases 60% during this time compared to December when the milk supply is ample.
The huge difference between lean and flush seasons is a significant problem. During the lean season,
when the availability of the milk is very limited, the price goes up. During lean periods there is insufficient
milk on the market and some of the processors have to close down their factories. The raw milk quality is
not good and that makes the shelf life of the packed milk very limited. Farmers have adjusted their
calving patterns for the lowest cost production and hence concentrate calving for winter milking. Counter
cyclically, dairy consumption increases during summer with higher consumption of yogurt, ice cream, and
other refreshing dairy products.
The seasonal fluctuation in milk production occurs due to lower water and fodder availability, and
importantly the prevalence of buffaloes in the national herd.
2.10 Milk Pricing & Profitability in a Competitive World
While different payment measures and fluctuating exchange rates mean that direct comparisons are not
available, it is known that the price presently paid for milk in New Zealand, Australia, Argentina, Brazil
and Uruguay is of the order of $US0.18 per litre. Given the costs of transport and customs tariffs, this
means that for domestic products to be competitive with imports in a sustainable manner, milk may need
to be produced in Pakistan at perhaps Rs14.7/l at the processor's gate. With present milk collection
costs, this implies a farmgate price of less than Rs12.3/l, if the milk is collected from the farmer – any
costs associated with the activities of middlemen must either form part of the 16% allowed in this
calculation for collection costs, or further reduce the farmgate price received by the farmer. It should be
noted that if customs tariffs on dairy products were reduced below present official rates for any reason,
the price at which milk must be produced would need to reduce by a similar proportion. (Note: the above
calculation is for cow’s milk; the price for buffalo milk can be determined by adjustments for additional
milk solids). It should be noted that the above is a theoretical calculation, in order to provide a caution
that it is unwise to think that the profitability of dairy farming can solved by increasing the price to the
farmer without taking into account the international environment. The actual price paid is, of course, a
reflection of supply and demand factors, including seasonal factors.
Dairy Pakistan’s aspiration is to achieve farming and logistical systems, which provide good profitability
to the farmer at the above milk price level. Factors, which will be important if this goal is to be attained,
include the following:
Farming systems, with a particular emphasis on appropriate asset base and fodder enhancement
Reducing losses due to poor quality
Higher volumes per farm and per local area, which reduce milk collection costs.
31
Awareness of the need to compete in a liberalizing world should underpin the approach to all
development throughout the industry.
Various complex calculations have been made to estimate what would happen to world prices,
and consequently to economic conditions in developing countries, if the grossly unfair
agricultural subsidies were removed. The US Department of Agriculture reported in 2001 that full
elimination of global trade-distorting agricultural subsidies would result in an annual world welfare gain of
US$56 billion. According to a World Bank study, full elimination of agricultural subsidies in rich countries
would increase global trade in agriculture by 17%, and agriculture exports from low- and middle-income
countries would rise by 24%. As a result, total annual rural incomes in these countries would increase by
about $ 60 billion, or roughly by 6%.
If Pakistan were to achieve similar gains from the post subsidy regime the time to prepare is now. If so
Pakistan’s White Revolution is very timely, coinciding with the window of opportunities in world trade
and global economic growth that may occur through the Doha Round. While the US, Argentina, Chile
and Uruguay will supply dairy to the American continent, the Indian sub-continent is expected to partially
fill the vacuum created by some sunset sectors.
FIGURE 2-H
Pakistan – 4th Largest Milk Producing Country
33.6 bio
liters
Milk
Production
Industrially
0.52 bio 0.05 bio 4.7 bio 1.27 bio
Processed Milk is liters
8.8% of “Urban liters liters liters
Processed Pasteurized Gowalla Unprocessed
Household Usage” Milk
& Packaged Milk Shops Milk Shops
& 2% of “Available
for Humans”
91.2%
Loose Milk
Source: EDS, Tetra Pak researches 2004
33
CHAPTER-3
3.0 White Revolution (Dhoodh Darya) – to activate the resource potential of rural Pakistan and serve
as a key engine of economic growth, thus radically changing the landscape of Pakistan’s agriculture
economy through dairy development!
The White Revolution (Dhoodh Darya – river of milk) endeavors to be a key engine of economic
growth for the country and undertakes the responsibility to make the most of the potential of
rural Pakistan. To achieve this goal Dairy Pakistan intends to set out a roadmap for all dairy
stakeholders. It promises to embrace the well being of all dairy farmers and their livestock. At the same
time, it focuses on improving the business environment of processors and all other participants in the
supply chain.
It seeks to improve the landscape of rural Pakistan through a progressive and proactive dairy
infrastructure. Improving the economics of smallholding farms and increasing the number of mechanized
farms is the prime objective of the White Revolution. The White Revolution promises to modernize the
conventional dairy farming from a by-product of mixed farming into an efficient agri-enterprise. As a
result, the White Revolution will influence the lives and livelihoods of millions of farmers and enhance
lifestyles in urban Pakistan through quality and innovative product mix.
More affordable
presentations for milk
Rural
Entrepreneurs
Meeting the Co-operatives in
Established
Needs of place, where
Farmers appropriate
Rural
Services
Linked with
collection
centers A Pathway to
Growth
Link with
micro
finance Profit, finance and
Thriving model farms together
Commercial provide growth
Farms impetus
35
Providing Better
Huge boost
Bringing millions Quality Milk to the
to rural
of farmers into the people of Pakistan
development
formal economy
Contribution to More
formal GDP investment
boosted by growth creates more
of milk production
Meeting the Needs jobs and
and by of the Nation higher GDP
formalization
Needs of Pakistan is
consumers can Wider range of
products exporting dairy
be met without products
imports
We believe there is need for radical transformation of the informal dairy sector into a more formal
and organized sector. For this transformation to really happen the sector requires a commercially
driven dairy development program. The key stimuli of such an approach may include:
Stimulating changes at a production level, encouraging technological and especially farm
management advancement on smallholding farms, and an increase in the number of
mechanized farms.
Organizing the milk supply chain and legitimizing the role of milk traders/dhodhis
We feel that should the above-mentioned changes happen in the spirit in which they are being
conceived, the outcome will be a dairy sector that will truly be the engine of economic growth of
Pakistan. Currently without any policy interventions or any available support mechanism, the livestock
sector as shown earlier has performed exceptionally. Once a collective industry-wide effort is made to
change the sector for the better, a new dairy industry of Pakistan will be born. This newborn industry will
capable of delivering significant gain to the economy. It will:
Expand an important source of cash flow to rural Pakistan.
Contribute to foreign exchange through import substitution and some export.
Substantially increase the contribution to the exchequer through an organized and documented dairy
sector.
37
Lead Pakistan’s agriculture economy in the transition phase from a basic rural landscape into
commercially orientated agri-enterprise.
2440 farms model farms will be set up to develop and demonstrate best practice farm management,
with the goal of raising productivity levels by up to 30%.
6330 farm cooling tanks and 2100 mobile milk collection units will be provided to preserve highly
perishable milk.
A Farm Management and Dairying Research institute will be established, including a semen research
centre.
Through a program to assist the creation of rural entrepreneurs, businesses active in fields such as
equipment and service contracting, equipment maintenance and feed/ration provision will be
established or further developed.
Vocational & Technical Training for adequate numbers of farmers and support service workers like
AI technicians and Animal Health workers etc.
Establishment of 700 farm input stores to provide good quality nutritional products at economical
prices to 6000 villages.
Standardized designs for Animal / livestock shelters for providing cost effective and efficient housing
for livestock.
Expansion of biogas production units in dairy concentrations.
Protection and enhancement of indigenous breeds and identification / recording of best local breeds.
Research for the profitability of buffalo milk production.
Introduce pasteurized milk in formats, which make it better quality than “loose milk” while
affordable to the bulk of the population.
3.2 Modus Operandi to Unlock the Potential – The Eight-point Strategic Agenda of the White
Revolution.
We propose an Eight-point strategic agenda that will unleash the potential of the milk economy.
3.2.1 The most important point of the Strategic Agenda of the White Revolution will be the
successful implementation of the Dairy Development Projects. The projects are designed to deliver
specific development models. The models primarily concentrate on investment in dairying infrastructure
and human capital. The setting up of model farms will introduce enhanced farm management techniques
and will improve productivity levels. Similarly the boosting of the cold chain will improve the life of the
perishable milk. The Dairy Institute with a Semen Research Unit will have significant impact. This will be
supported by vocational training facilities for dairy technicians.
3.2.2 Creating Rural Entrepreneurs: Expensive items of farm machinery, which are required on
an occasional basis, may be too costly for all but the largest farms. In other countries which focus
on low cost farming and where government subsidies tend not to be available, over time a system has
developed of local area regional service providers, who own these expensive items and contract their
service to a reasonable numbers of farmers. In this manner, the cost of a large asset is spread over many
farms, bringing mechanization to a larger number of farms than would otherwise be the case. In addition,
often specialized skills can be developed more easily, owing to the smaller number people who will be
engaged in the use of this equipment.
38
Thus in New Zealand and in Australia, local area entrepreneurs (generally known as “contractors”) own
grass cutting and hay baling equipment, and bring these items to individual farms at agreed times and for
agreed rates. The contractor does not rent the equipment, rather he provides the full service, including
using the equipment on the farm.
It is proposed that Dairy Pakistan develop a program involving donor agencies to develop a business
model along these lines. It is proposed that model businesses be established, whose functions can be
transferred to other entrepreneurs upon proving successful under local conditions. Close supervision will
be needed in the first instance, to ensure proper training in the use of specialized equipment, the
entrepreneur learns how to market his services, matters such as insurance for any damage to fences, for
example, are handled in a professional manner, and perhaps most importantly, a pattern of setting rates
which are fair to all parties are set.
With respect to the important topic of maintenance of reasonably sophisticated equipment, it may be
necessary to build upon the creation of regional entrepreneurs at the “contracting” level, with another
hierarchy, that of entrepreneurs operating specialist maintenance centers – clearly, the latter level will
service a number of contractors. The beginnings of a network of regional businesses can be identified.
3.2.3 Developing the Value Added Market – innovation in health, pleasure and presentation
Dairy products have evolved from mere commodities to life-style statements. Pakistan’s dairy revolution
has been precipitated by the surge in consumer empowerment through greater health and quality
consciousness. These value-added life-style enhancing dairy brands currently constitute about 40% of the
dairy market, this profitable segment would cross the 65% mark in the next 8 years and will attract foreign
investment and will reduce imports. One could imagine the contribution to the GDP and the economy
with this rate of growth in the value added sector.
Today, the ability of the processors to boost added value product development is limited by the relative
shortage of milk compared to the demand from their consumers. Processors struggle, especially over
summer, to procure sufficient milk to meet demand for core products such as UHT milk, resulting in the
opportunity to introduce more sophisticated products being much reduced. Thus, an important precursor
to the development of a wider product range is the success of the Model Farm Program and other
programs designed to link more farmers (and hence more milk) to the formal sector.
Given improved availability of better quality milk to the formal sector, development of a wider range of
products will occur. A product group, which is expected to show strong growth in future, is cheese.
Cheese is a highly nutritious product with significant consumer appeal. An improving economy will lead
to increasing demand for cheese products. It is likely that the range of fermented products such as yogurt
will increase also.
If milk production and quality is sufficient to enable exports, then the most likely products to be exported
will be skim milk powder, anhydrous milk fat and casein. Development of added value products such as
casein will be necessary if Pakistan is to capture a useful share of the world market.
Production of added value dairy products requires, in addition to the necessary raw milk, investment in
plant and in human resources.
A useful standard, which the Pakistan dairy industry should set itself, is to match the range of products
available in the consumer markets of the Gulf. This implies development of cheese and fermented
products, improved presentations of butter and whole milk powder, and packed ghee. Further
development of traditional sweets is desirable.
39
3.2.4 Organizing the informal sector into documented formal economy and to formalize the role
of the middlemen: Only around 3% of the total dairy sector is organized and documented. The
remaining 97% is handled by the informal sector.
3.2.5 Propagating quality and implementation of pasteurization laws: Some of the dhodhis or
middlemen of the milk supply chain carry out a successive adulteration process; in the form of water
addition, ice, vegetable oil, etc in order to increase their margins and preserve the milk. There is no
practical punishment or incentive system in milk quality hence the dhodhi is mostly unaccountable. The
regulatory structure currently in vogue in the milk sector is archaic and quite inadequate for modern times
while the ability of government to implement these regulations is also limited. We recommend the
implementation of Food Quality Safety Standards, and the implementation of pasteurization laws to
ensure a White Revolution of quality milk.
3.2.6 Mapping Increased Supply Pockets with special incentives for NWFP and AJK: Pakistan has
huge potential to increase its supply chain pockets. The existing location of supply pockets is Punjab and
Sindh. NWFP and AJK regions are both well poised and in need of regional local supplies. Special
incentives to be provided to licensing, quality productions, setting up of corporate dairy farms and a
special tax incentive to be given for setting up processing units and dairy farms in earthquake hit
AJK and NWFP, this will create livelihood opportunities in the regions and increase milk supply pockets.
Milk pockets should also be assessed for the suitability of co-operative development.
3.2.7 Attracting foreign investments, joint ventures and
encouraging existing processors to increase investment in the
sector. Clearly, foreign investors like Nestle etc change and improve
the whole structure of the dairy sector. For example, Nestle employs
5000 permanent employees and buys milk from 135,000 farmers
throughout the country. More investors like Nestle in the sector are
likely to uplift not only the dairy farm structure but also rural
Pakistan as a whole. While it is important to attract foreign
investment it will remain crucially important to have the existing
processors reinvest in the sector. As drivers of the industry their growth and investment remains of
utmost importance in the short and the medium term.
3.2.8 Dairy Pakistan - creating a monitoring and implementation
Mechanism for the White Revolution: this will be of utmost
importance to enhance the capacity of the implementation process
through Dairy Pakistan. The diagrammatic vision of "Empowering
Rural Pakistan is given in the end of this chapter in figure 3-B.
3.3 “White Revolution (dhoodh darya) promises to empower
rural Pakistan”
The White Revolution envisions
converting the subsidiary occupation of dairy farming into an
instrument of socio-economic development. It is intention of these
programs to place the farmer at the centre of the substantial benefits
arising from dairy development. Large-scale poverty reduction must
be based primarily on harnessing the energy and creativity of poor
people, and on allowing the private sector to achieve its full potential.
Nestle is a good example of how businesses can improve the quality
of living for the poor while at the same time making conscientious
profits.
40
“It is an interesting example of how business, by taking a very long-term view of development
and the interests of various stakeholders, can contribute to poverty reduction and improvement
in nutrition on a very large scale, while at the same time creating significant business success”.
(Please refer to Table 3-A below).
Developing rural
infrastructure through
better cold chains and
improved transportation and communication channels.
Dairy Markaz17 will help unveil the strengths of the large
rural marketplace. With rising rural incomes, there is a need
to discover the strengths of the large rural marketplace of
Pakistan. It is myth to believe that rural consumers are not brand and quality conscious. The share of
branded goods fertilizers, beverages and other consumer goods shows the rural areas are also brand
conscious. Multinationals like Coke and Pepsi have already ventured into the hinterland. Both Coke’s
and Pepsi’s success stories in neighboring rural India show phenomenal growth and product
diversification. In addition to multinationals, many local Indian companies are moving into rural areas
including TATA, Reliance and Hindustan Lever Ltd. Hindustan Lever has a program that creates
incoming-generation capabilities for underprivileged rural woman; improves rural quality of life by
spreading awareness of best practices in health and hygiene; empowers the rural community by
creating access to relevant information through community portals and it also works with NGOs to
spread literacy. The company has created over 15,000 entrepreneurs, most of them women, in 61,400
villages across 12 states.
Revolutionizing Farmer Facilitation – Dairy Markaz communicating farm needs through internet,
local language call centers and B2B meetings. The White Revolution is determined to develop the
rural economy of Pakistan through revolutionary changes. The concept of Dairy Markaz will
encourage interaction between the urban and the rural as a frequent activity. The Markaz will facilitate
business activities through internet, local language call centers or B2B meeting arrangements,
resulting in placing the farmer directly in the market mechanism. Farmers have only an approximate
idea of price trends and have to accept the price offered to them on the day that they bring their
grain/milk to the mandi or the trader. Additionally, farm inputs, veterinary services, medicines etc are
not all the time in close proximity to the farmer. As a result, traders and middlemen exploit both
farmers and buyers through practices that sustain system-wide inefficiencies. A revolutionary model
to introduce small holding farmers to technology driven solutions, for commercial transactions is
envisioned called the Dairy Markaz (details of which are given in Annexure A). The Dairy Markaz will
follow the e-Choupal model of India18 that has reached about 3.5 million farmers and is expanding to
30 villages per day, making it India’s one of most ambitious horizon-widening initiatives. The Dairy Markaz
model will be extended not only to facilitate the farmer through online support but also through call
centers in Punjabi and Sindhi. The lesson is that no dream is unachievable no matter how fanciful.
With a farm population vibrant though unskilled, a rich natural resource (milk) and the power of the
Dairy sector as a labor-intensive activity to absorb jobs, the white revolution is surely going to
transform the landscape of rural Pakistan
FIGURE 3-B
Zero Rating,
Tariffs, Dairy Sector
Gender Sensitization Rationalization,
Infra structure Development Pub Pvt Partnership
Micro-Financing Dairy Food Safety Laws
Rural entrepreneurs
Donors
Government
Dairy Sector
(Rural Pakistan)
CHAPTER-4
CHAPTER-5
5.0 “The tax, the tariff and the trade”- Policy Needs Analysis for the Dairy Sector – A Case for
Business advocacy
A rational tax and tariff policy can either develop a sector or alternatively assist its destruction. There is a
need to change the tax and tariff regime of Pakistan for an efficient and investor friendly dairy sector.
Clearly an unfair tax regime that discriminates between the organized and un-organized sector is a huge
obstacle to re-investment by major companies. Also in light of the industry restructuring that is taking
place and the changes happening due to the multilateral and regional trading system, a complete tariff
rationalization of existing policies is needed. In lieu of the above the following tax and tariff changes are
recommended in budget 2006-2007 to encourage technology up-gradation and investment in value chain
infrastructure of the dairy sector.19.
1. Zero Rating Of Sales Tax On Dairy Products
2. Zero Rating Of Customs Duty On Raw Materials For Packaging Supplies To
3. Dairy Industry
4. Processing Equipment, Plant and Machinery
5. Dairy Farming Extension services
6. Income Tax exemption on new investment in commercial dairy farms
7. Corporate Tax reduction for small Niche Dairy players
8. Zero duty for Import of Semen
9. Zero duty for Import of Veterinary Vaccines
10. Tariff Rationalization
The impact of zero rating will make processed dairy products competitive and increase revenue to GoP in
the form of direct taxes. It is also likely that new players both local and foreign may enter the dairy
industry on rectification of sales tax inconsistency.
For example, the elimination of incoming call charges and massive reduction in activation charges in lieu
of Customs Duty resulted in phenomenal increase in mobile phone use etc, which in consequence
increased tax revenue in following forms:
Another example is the zero rating of raw materials and parts used in the manufacturing of tractors
increased the annual production of tractors from 25,435 units in 2003-04 to 31,663 units in 2004-05.
(Source: Economic Survey of Pakistan, 2004-05).
The economic benefits of zero rating cannot be underemphasized. A zero tax structure is likely to attract
capital to the industry, increase pace of innovation to meet diversified consumer needs, widen the
industrial base of support services, rural development and of course contribute to the wider poverty
alleviation cause especially in rural areas.
Productive investment in the dairy industry will boost industrial income, and bring small entrepreneurs
into the tax net – resulting in enhanced Government revenues including import substitution of Rs.1
billion of powder milk and cheese in the long run. The contribution of the zero rating to the wider job
economy of the country is presented in Figure 5-A below:
19
Zero Rating and Zero Duty attached in Annexure C & D have been submitted to the GoP on ----
47
FIGURE 5-A
Job creation from Informal to Formal through encouraging productive investment in the sector
5.2 Zero Rating of Customs Duty on Raw Materials for Packaging Supplies To Dairy Industry
Processed milk in Pakistan or elsewhere has to be transported from the processor to the consumer. Due
to the distances in between the markets and the producers and the processors and the consumers the
transportation of the perishable milk is a tedious job. Only packaged milk in Tetra Pak packs is able to
sustain a very long life and serve as the alternative solution to very expensive cold chains. In lieu of the
importance and advantages of packaging a 5% concession is sought to ensure packaging is readily
available at a cost effective price.
The Suggested Amendments With HS Codes And Customs Duty For Items Used For The Manufacture
Of Liquid Food Packaging Material For Local Dairy Industry are provided in Figure 5-B below:
FIGURE 5-B (Packaging recommended for tax exemption)
Existing Proposed
S. No. H.S. Code Description of Commodity Custom Custom
Duty Duty
Rationale for seeking zero custom duty is firstly of course customs duty escalates the cost of production
of formal sector of processed milk and dairy products. It renders the formal sector uncompetitive against
informal sector and except for paper and board; all the items are not manufactured locally. A detailed
proposal as submitted to Government is attached as Annexure D.
Proposed
Existing Structure Structure
Sales
Custom Sale Tax Custom Tax
Description HS Code Duty (%) (%) Duty (%) (%)
Conveyors 8428.3900 5 0 0 0
Cream separators 8421.1100 5 0 0 0
Deaerator 8421.3990 5 0 0 0
Labeling machine 8422.3000 5 0 0 0
Milk Evaporator 8419.3900 5 0 0 0
Air conditioning unit 8415.8200 5 0 0 0
Air Handling Units 8415.8300 5 0 0 0
Air Heater 8419.1900 5 0 0 0
Cooling Tower 8418.6900 5 0 0 0
Homogenizer 8434.2000 5 0 0 0
Laboratory ovens 8516.5000 25 15 5 0
Milko Scans 9027.3000 5 0 0 0
Prefabricated buildings 9406.0000 25 15 5 0
Racking System 7310.2900 25 15 5 0
Tote bins 7310.2900 25 15 5 0
Tubular Heat Exchanger 8419.5000 5 0 5 0
Laboratory glassware 7017.0000 10 to 15 15 0 0
Boilers 8402.0000 5 to 20 0 5 0
Generators 8502.0000 5 to 20 0 0 0
5.5 Import of Semen: Pakistan suffers from poor breeding issues. Presently the import duty on Semen is
5%; a zero rate is requested to make the use of AI affordable for smallholder farmers.
5.6 Import of Vaccines: Animal care surely remains at the heart of all dairy activity. Vaccines are an
important tool of care and protection for the herd. Easily available imported vaccines will support the
farmer by ensuring healthy animals and hence improved productivity. It is important to note that Indian
vaccines are the most suitable vaccines for the local herd. Hence, cost effective good quality Indian
vaccines allowed to be imported at 0%.
51
5.7 Tariff Rationalization for the dairy sector: With the “growing spaghetti bowl” of trade relations
within Asia and globally, there is an imperative need for the dairy sector of Pakistan to identify threats
and opportunities at the import and export level, by understanding the multilateral, regional and bilateral
rules of origins that create or negate competition for dairy products and dairy machinery. In Pakistan’s
context there are a host of regional agreements within Asia-Pacific that need to be reviewed. The core
policy questions that need to be addressed include lists of products that deserve zero-tariff duty in order
to support healthy growth of the dairy sector, primarily packaging and livestock. Additionally, the tariff
structure affecting the dairy sector especially under SAFTA and Pakistan’s preferential agreements may
need a revised rationalization methodology. A Dairy Tariff Rationalization study will be undertaken to
identify the ratio and balance in raw and value added goods, including import duties on dairy
manufacturing equipment.
The tariff rationalization study will also propose a revised duty structure in the wake of export
opportunities under preferential and regional trade agreements.
52
CHAPTER-6
Dairy Development Projects
6.0 Creating Dairy Entrepreneurs, Empowering Small Holding Farmers and Developing Dairy
Infra-structure
Project Implementation
Dairy Pakistan will identify industry participants who wish to participate in this program through
a rigorous application and selection process. There will be project management team under a Project
Manager working out of a Project management Unit (PMU) directly under the management structure of
Dairy Pakistan. The process will provide a subsidy based approach (30% grant and 70% loan facility) for
motivating industry participants for installing chillers with easy credit mechanism (soft loans). The
processors will provide a platform for selection and endorsement by Dairy Pakistan of eligible farmers.
53
The industry will promote and give incentives for the chilled milk supply practice for quality
milk. This will work closely with the proposed Progressive Dairy Entrepreneur. The key activities will
include promoting the use of chillers amongst farmers and facilitating farmers/ dhodies (i.e. village level
milk suppliers) for obtaining chillers on easy terms (either on loan or self financed).
Outputs: (Quantitative)
1. 6330 new chillers of different capacity enhancing the collection, stowage and sales of quality milk.
Impacts
A total of 2 Billion liters of milk will be additionally chilled and sold at a better price of at least Rs1 above
the normal milk and with better quality standards hence creating an additional revenue of Rs2 Billion or
$US33 million per annum or $US100 million over three years. It is further considered that perhaps 10%
of the milk collected in these cooling tanks would otherwise be wasted, so this is an additional benefit of
Rs2.7 billion per year.
Proposed Budget- Farm milk cooling tank / Rural Entrepreneurs development project (3 years
duration)
Description Costs in PKR (millions) Costs in US$ Millions
Funds requested from Donor agency 1540 25.7
which ones
Soft loans equity by farmers 3202 53.4
TOTAL 4742 (PKR Million) 79 (US $ Million)
* Project management costs are included in the grant amount requested from the donors.
6.2 PROJECT PROPOSAL 2 (Model Dairy Farms)
Introducing Modern Farm Management through Model Farms.
The project will upgrade dairy farms (total 2440 dairy farms) for the progressive farmers. It is
mentioned that Pakistan under careful estimates is the 4th largest fresh milk producing country in the
world with annual milk production of 33 Billion liters.
The process will provide awareness and technical support to farmers for adopting best farm
practices and build necessary infrastructure for improved animal care, improved breeding and
overall improved yield of milk. Additionally the introduction of model farms will develop
entrepreneurial skills in them for commercial dairy farming.
Main Objectives:
The main objectives are:
Promote dairy farming under a range of circumstances, from smallholding to commercial
Improve dairy farm efficiency by implementing best farm practices.
Develop/ construct model dairy farms to serve as demonstration farms for awareness and
dissemination of best practices to local farmers.
Drive awareness of profitability.
Provide the opportunity to fine tune farming practices for local conditions, following which farmer
training can take place with a high degree of confidence.
Outputs and deliverables
A total of 2440 model farms will be developed, enhancing milk production by perhaps 30%, or in simple
terms a single cow will produce 4 liters of additional milk on a daily basis.
54
Key activities
a) Improving existing farms into model farms with full management support.
b) Developing the capacity of dairy farmers for getting financial credit from banks etc for their farm
needs.
c) Demonstration of model dairy farms as best practice models and gearing up more farmers towards
modernization.
d) To provide a grant amount of 30% with a soft loan of 70% to progressive farmers for dairy farm
development.
e) Each farm will be equipped with the necessary assets to support modern farm management
techniques:
a) Better quality Animals.
b) Mechanization.
c) Building and shed design.
d) Training.
General Impacts.
a) Poverty Alleviation (more opportunities in the rural areas)
b) Improved quality of dairy farm practices in Pakistan.
c) Improved awareness and participation of farmers.
d) Linkages between Dairy Industry and Farmers.
e) Model farms available for replication and improvement.
g) Additional employment opportunities in Dairy Industry and supporting rural services.
h) A more profitable industry overall, from farmer to processor, and therefore direct and
indirect benefits through rural Pakistan and to the Government through higher taxes on
profit.
Economic Impact:
Total impact after the first 3 years will be an increase in production of perhaps 166 million liters, valued at
Rs2.5 billion to the farmers.
These model farms will serve as platforms where new investors or neighbor farmers can visit and gain
some experience on commercial dairy farming.
Further impacts will be readily generated as farmers adopt new ideas and practices well from fellow
“leader’ farmers.
Beneficiaries.
Small and medium farmers.
Potential investors in the rural areas with good land holdings.
Rural population in general.
Industry and Milk market.
Implementation (Dairy farm Project)
There will be a process of selection of existing dairy farms (for upgrading) and also for establishing new
dairy farms for progressive farmers. These will be short listed on the basis of set criteria under the
supervision of a dairy processor of the region and Dairy Pakistan. A project management unit will be
established under the governance of Dairy Pakistan. The PMU and/or the processor will provide
technical support to the selected farms for their improvement. The other model will be to bring in new
farmers who have lands and are interested in dairy farming. These farmers will be provided with technical
support for developing new model farms. The Model Farm Program will be based on assisting existing
farms, and far fewer Greenfield developments will receive assistance from Dairy Pakistan. The Model
Farm Program (i.e. other than Greenfield) will use an equity based mechanism where 30-50% grant will
be provided to farmers with 50% to 70% soft loans arranged through a financial institution.
55
The 50% grant and 50% soft loan component will be utilized on a smaller number of farms in the initial
stages of the project. Once improved performance is proven, these farms will serve the neighboring
farmers as best practice models and will also promote improved economic factors and greater
profitability. The project PMU will have a number of technical teams with sufficient resources to
undertake this task. Furthermore the dairy industry will also support the process in tangible terms.
Proposed Budget - Model Dairy Farm project: (3 years duration)
Description Costs in PKR Costs in US$ Millions
Millions
Donor agency Grant 2883 48
Loan financing/ soft loans 5214 86.9
TOTAL 8097 (PKR million) 135 (US$ million)
* Project management costs are included in the grant amount.
One possibility is to organize groups of smallholders into co-operatives, such that the provision of assets
becomes economically feasible. In this concept, farmers would need to gather their animals onto a single
farm. Animals would need to be identified separately, as already planned under the Model Farm Program.
Milk production from each animal would also need to be quantified. It would be most efficient if farmers
were to supply labour on a roster basis, although the difficulty of having different milkers for buffaloes is
acknowledged.
A major issue would be land for a co-operative farm.
It is recommended that Dairy Pakistan lead a study into the economics of such a proposal, and if such an
approach is likely to be profitable, then pilot schemes should be undertaken.
It should be noted that a potential partner, who will supply seed finance for a pilot co-operative farm has
been identified, and this partner requires that the pilot consider the way the initiative can be used to
demonstrate development for females.
Meanwhile it is estimated that in order to improve the enabling environment for the development of the
dairy sector and rural economy in Pakistan, the project focused on the “basics” proposes to train a
sizeable number of approximately 10,000 semi-skilled persons, particularly Artificial Insemination (AI)
workers and Animal Health workers (AHW). Additionally more then 200,000 farmers are required to be
addressed through information and dissemination processes on basic farm practices. This will improve
the overall enabling environment of the dairy sector situation in Pakistan at the basic level in
approximately three years time frame. This “basic” training is modeled on the present activities of the
Rural Development Foundation.
Development Objective:
Improved socio-economic conditions for the average dairy farmer in the rural context of Pakistan,
improved skills in terms of human resources associated with dairy sector (domestic and village
entrepreneurs), improved yield of better quality milk available for sale and consumption, sustainability for
dairy farmers through better animal health and good quality animal breeding, development of village level
entrepreneurs, women development for direct participation in dairy farming activities, improved health of
animals (livestock) in the dairy sector and larger volume of dairy farmers connected to the market
mechanism.
Proposed budget to initiate a basic vocational training program.
Description Costs in PKR Millions Costs in US$ Millions
It is proposed that working with stakeholders, Dairy Pakistan review the gaps in the scientific support
available to support dairy industry development, and the benefits that could accrue to the industry
through closing those gaps. It is intended that this review be undertaken with donor agencies, and should
be complete say by 30 June 2007.
Depending on this the outcome of this review, Dairy Pakistan will then develop an action plan to
establish a Farm Management and Dairying Research Institute.
Activities, which the review may determine would prove cost-beneficial to the industry, include the
following:
1. Breeding.
2. Feeding.
3. Milk production economics.
4. Local applied dairy farm mechanization.
5. Semen research and production unit.
6. A training component needs to be built into the establishment of such a facility.
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It is critical that any institute, which is agreed to be established by the stakeholders and by funding
providers, be applied rather than theoretical in nature, and focuses on the dissemination of information of
practical use to the majority of the participants in the Pakistan dairy industry.
Proposed budget for Phase-I of the Institute (Planning and initial establishment)
Project Brief:
The project proposes to develop over 2100 new entrepreneurs employed in milk concentration areas, by.
By enabling them to own a vehicle with chilled infrastructure (Mobile Chiller tank), which will help them
to conserve quality of milk collected from far flung areas and provide it to consumers at a premium price.
The project aims to provide 70% soft loan and 30% grant component to the rural entrepreneurs for
purchasing the vehicles and improve their economic condition by becoming a self employed
entrepreneur.
Dairy Pakistan and leading stake holders from the private dairy sector will manage the process.
Objectives:
The overall objective of the program is to achieve better market prices and lower spoilage losses for the
farmers. The specific objectives include:
To ensure better quality milk to the consumers by providing better chilling facilities
To create rural entrepreneurs who can work in a self-sufficient manner.
To reduce milk spoilage caused by high bacteria load due to high temperature
To improve the price of the milk earned by the farmer through better quality milk and better linkage
to the market.
It is critical that these mobile milk collectors do not abuse their position at the expense of farmers, and
continuing monitoring of their activities will be required.
Activities:
a) Selection of potential rural entrepreneurs with the support of industry and rural institutions.
b) Encourage existing dodhies who are currently in the trade to use these vehicles and provide vehicles
to them.
c) Finalize vehicle designs and vendors.
d) A grant cum soft loan process scheme will be introduced to enable the entrepreneurs to purchase the
vehicle.
e) Connecting the entrepreneurs to the market mechanism
Target Output:
Over 2100 new entrepreneurs employed in milk concentration areas.
Procurement of 500,000 litres of improved quality chilled milk through these vehicles
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Impact (Projected revenue Based): A total of an additional 180 million litres will be chilled and sold at
a better price of at least Rs.1 above the normal milk, with better quality standards. In addition 1%
quantity loss will be avoided by timely chilling. This will create an additional annual revenue of Rs.210
million or US$ 3.5 million or US$ 10.5million in three years and enhancing the annual revenue of 2125
entrepreneurs by Rs.296,000 each. Most importantly, through the funding mechanism, a degree of control
over margins taken by these mini-middlemen may be able to be asserted, giving a fairer and more
transparent return to the farmer.
Duration: 3 Years
Location of the Project: Areas with milk production concentration which is too dispersed to allow for
other more formal methods of milk collection.
Proposed budget:
Brief Introduction and Rationale: Much of Pakistan’s dairy herd is held by farmers having an average
of 2-3 dairy animals/ household scattered in wide areas. Most of the milk is collected by dodhies who go
door to door to collected small quantities and then take them to market. During this whole process from
milking to reaching the consumer can take up to 8 hours, during which milk is not chilled. The quality of
milk deteriorates exponentially when it is held at elevated temperatures. Availability of mobile collection
units with chilling facility to farmers/milk collectors can result in improvement of milk quality and
consequently help farmers fetch a better price for milk.
Project Implementation:
Project Management Unit will identify rural entrepreneurs with the help of dairy processors in milk
potential areas.
These entrepreneurs will be provided with vehicles fitted with milk tanks. The tanks will be insulated and
also will have a chilling unit attached which can be operated by plugging in with electricity. The vehicles
will get chilled at any plug-in facility before leaving for collection in the area and keep the milk chilled up
to 6 hours before it reaches the consumers or collection facility of any dairy company. The collected milk
will be deposited at the collection center where a milk chiller will be installed to maintain milk
temperature. Following vehicle types will be used:
1. Motor bike
2. Qing Qi
3. Pickup / Hilux
Sustainability of the project: The project will be self-sufficient in the long run through better price
earned by the farmers/collectors.
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6.6 PROJECT PROPOSAL-6 Review of Support Services Technical (Animal Health Care)
Training
There are a number of institutes providing technical training for dairy industry human resources. It is
essential that the efforts of these training institutes (which are taken to include professional education as
well as more vocational training) are co-ordinated and where desirable reviewed for effectiveness. In
keeping with the decision of GoP to establish Dairy Pakistan, dairy industry training may need some
leadership from the private sector in order to provide assurance that the needs of the industry are
achieved. Under such a model, a voice needs to be identified to represent the smallholders. It is possible
that owing to its contact with good numbers of farmers arising through the Model Farm Program, that
Dairy Pakistan may be able to fulfill this role to some extent, at least on the vocational training level
applicable to smallholders.
As noted earlier, it is intended by Dairy Pakistan that the Model Farm Program be used to prove
appropriate farm management techniques. It is essential that the body of training providers be in a sound
position to disseminate the lessons of the Model Farm Program as these start to flow. The Training Sub-
Group of the Dairy SWOG no doubt has an important role to play in the integration of effort of training
providers.
The large numbers of veterinarians in Pakistan represents a huge base of knowledge. It is considered
desirable that a review of the training of these veterinarians is undertaken, in order that the benefit they
bring to the dairy industry is maximized. Such a review can be useful only with a commitment from
concerned parties that this is desirable, and that any recommendations will be implemented without bias
and concern relating to past practices and their efficacy.
b) In the second phase, a concept of mobile veterinary clinics be introduced for reaching far flung areas
and provide accessibility to poor farmers for getting professional veterinary advise for their animals.
6.7 PROJECT PROPOSAL -7 Farm Input Stores for farmer Small Holding Farmer Facilitation
Project Brief: The project proposes to develop over 690 farm input stores, which will provide quality
animal nutritional products to farmers in approximately 6,000 villages at economical prices.
The project aims to provide 50% grant and 50% soft loan component to implementing organizations, to
cover for operating cost and initial investment cost. This process can be instrumental in development of
dairy sector in Pakistan.
60
Green fodder availability is the most basic feeding need of the dairy animals, however hardly 10% of the
required quantity of fodder is grown in Pakistan. A large number of cattle are grazed on marginal lands,
canal banks and roadsides. Stall-feeding includes large amounts of wheat straw which has no nutritional
value. Concentrate use is also very limited.
Objectives:
The overall objective of the program will be to improve farmer economics by improving milk yields
through balanced nutrition.
Key Activities:
Selection of entrepreneurs interested in running the bulk units
Identification of sources of input purchases
Awareness creation about balanced and high quality animal nutrition in the farmers
Technical services in collaboration with dairy companies and NGOs
Target Output:
Setting up of 115 bulk farm input stores & 575 farm input stores resulting in:
Availability of balanced nutrition of 115,000 animals
Yield Improvement of 1 lit/animal resulting in additional production of 115,000 lit/day or 34.5 mil
lit/year of milk
Project Implementation:
One module of farm input store will consist of a bulk store and 5 retail stores. Local entrepreneurs will be
encouraged to establish these modules. The module will be headed by a store manager, who will sit at the
bulk store and do inventory planning, stock management etc. Each farm input store will cover 10 villages.
The locations of farm input stores will be decided in consultation with agri-services departments of dairy
companies. The stores will start with supply of nutritional inputs; however the scope can be expanded to
medicines and farm equipment as well. Demand generation for the products will be done by the field staff
of the concerned dairy companies. The financing requirements include the purchase of land, vehicle for
material movement, working capital requirement and miscellaneous other items.
Timing
It will be necessary to use the Model Farm Program to determine the most appropriate items for such
stores to stock, including seasonal and regional differences. Therefore, the Farm Input Store program will
be phased until after the Model Farm program has been running for say two to three years.
Proposed budget:
Description Cost in PKR Millions Cost in USD millions
Funds requested from Donor 428 7.14
agency as Grant
Equity/Loan Financing 429 7.145
TOTAL 857 14.285
* Includes US$ 1.43 mln as service charges for PDDC from the grant amount
The development of standard designs, and importantly the knowledge and understanding which would
underpin design is needed, to enable the provision of sound recommendations to farmers. Specifically the
shelter needs of indigenous versus exotic cattle, and of buffaloes versus cows, must be proven on a
profitability and animal welfare basis. In addition the relative economics of installing different water
dousing and fan cooling systems should be investigated.
It is further noted that construction methodology must also be “localized”, meaning that design must
taken into account the cost effectiveness of materials available locally, in order that the most efficient use
of capital occurs.
From these investigations, appropriate guidelines and construction blueprints should be developed and
circulated/made available to relevant institutions/organizations, the construction industry, and farmers.
It is proposed that Dairy Pakistan work with interested parties to determine the economics of producing
biogas at locations where large volumes of dung are concentrated. It is possible that even large farms may
have sufficient volume of dung to make biogas production viable.
Dairy Pakistan will seek support from relevant agencies to develop a project under which pure native
breeds are firstly maintained and secondly milk production within these indigenous breeds is developed at
the genetic level.
There are a number of indigenous cattle breeds used for milk production in Pakistan. The most common
are Sahiwal and Red Sindhi, dual-purpose meat and milk breeds such as Tharparkar, Cholistani, and
Kankrej, and multiple crosses in between commonly referred to as 'desi' breeds.
These indigenous animals have evolved over 5-6,000 years under Pakistani environmental and managerial
conditions. They can be characterized by high levels of heat tolerance, disease resistance, and milk fat
content. They manage to survive and produce milk on rudimentary, low quality diets, often without water
of adequate quality and/or quantity, and in the absence of appropriate husbandry.
Although cast aside in importance due to their typically low milk yields by international standards, they
are well adapted and valuable breeds for milk production in Pakistan.
The key principle of any livestock breeding system is to maintain and enhance those traits of economic
importance. Current breeding practices on many Pakistani dairy farms are focused on crossbreeding
indigenous Bos indicus breeds with Bos taurus breeds from overseas, principally Holstein Friesian. This
produces crossbred progeny with a combination of higher milk yields and environmental adaptations.
When the progeny of such breeding practices have trait performance higher than the average of both
parents, it is termed heterosis, or hybrid vigor. Generations of these first crosses are commonly referred
to as F1, with successive crossing of progeny to the same sire breed leading to F2, F3 generations, and so
forth. With each successive generation the hybrid vigor expected from crossing diminishes, eventually
declining to an insignificant level, i.e. there is very little genetic diversity remaining between sire and dam.
Indiscriminate crossbreeding, both towards Holstein Friesian and between desi breeds, risks the loss of
desirable genetic traits, particularly from the indigenous cattle population.
To maximize heterosis in successive generations of animals under cross breeding programs, the use of 2
or 3 breed rotational crossing is required. This is often referred to as 'criss-cross' breeding. In simplest
terms it involves the alternate use of different sire breeds between each generation. This technique is a
well-proven and widely internationally used method for maintaining hybrid vigor in crossbreeding
programs. For this system to be successful, purebred sires from the relevant breeds must be used. In
Pakistan this requires the maintenance of purebred herds of indigenous cattle specifically for the purpose
of generating sires for crossbreeding and maintaining a genetic resource of desirable traits.
Steps must be taken to ensure that indigenous breeds of cattle are preserved in Pakistan to maintain purity
for crossbreeding and to ensure that thousands of years of genetic evolution in particular traits are not
lost in a few short decades.
There are several existing facilities in Pakistan that are maintaining purebred herds of indigenous cattle for
the purpose of semen production, e.g. Red Sindhi at Tando Jam, Sindh, and Sahiwal at Bahadarnagar,
Punjab. A review of these facilities and other facilities is urgently required to determine efficiency and
ensure practices are aligned to the objectives of the dairy industry. Co-ordination and collaboration
between these facilities, and with other relevant institutions, departments, organizations, and farmers
must be achieved. A needs analysis relative to achieving industry goals should be undertaken to determine
any resources required.
6.12 Project Proposal 12 – Boosting Herd Numbers and Genetic Diversity through Imports and
Establishment of a Commercial Breeding Farm
Based on the difficulty processors have had with securing milk supplies to meet the demands of their
consumers, it is reasonable to consider that along with the other management issues discussed in this
paper, quite probably there are insufficient animal numbers in Pakistan to provide the necessary milk
volumes. In addition, there is a tendency for the best animals to be lost to the gene pool of Pakistan.
These dual needs suggest a case for the import of reasonable numbers of animals.
The most efficient way to do this would be to import by ship load (approximately 1,400 cows) – this is
beyond the means of all apart from perhaps a very few farmers. It is considered therefore that Dairy
Pakistan review demand for the import of cows, and consolidates purchases from a number of farmers, in
order that efficiency of scale and thus cost reductions are achieved.
With respect to a commercial breeding farm, this would focus on breeding animals for sale to dairy
farmers. Unlike some other breeding establishments in Pakistan, it would focus on supplying reasonably
large numbers of above average animals, rather than pure breeds or high potential animals. The breeding
programme would focus on traits desirable in a low cost dairying environment and hence support the
broader goals of Dairy Pakistan.
It is proposed to undertake a series of projects to evaluate the feasibility of developing such pockets. The
projects may include the following:
How to develop co-operatives, which may be responsible for local milk collection, cooling tank
centre operation and marketing.
Identify the smallest scale pasteurization equipment available, and operating costs for such processing
plant.
Determine whether bulk vending of pasteurized milk from such pockets would meet consumer
expectations.
Determine the economics of milk pocket development, in a manner that provides a template against
which identified or potential pockets can be evaluated for suitability for development.
Such a program, if economic, will expand areas of milk production and collection, and connect the farmer
to the market, in more isolated areas of Pakistan, thus spreading the fruits of dairy development to a
broader area and larger numbers of farmers.
It should be noted that this program may well identify areas where the development of co-operatives
could well assist overall dairy development, along with the simultaneous enhancement of dairy farm
households. It is likely that a model approach be taken, i.e. close study of a potential milk pocket should
be undertaken to expand knowledge of such pockets.
Project Phasing
Some of the projects described above are dependent on lessons gained in the course of other program,
notably the model farm project. In addition, Dairy Pakistan needs to build institutional capability in order
to successfully lead these programs. Therefore, phasing of projects will be required. The initial period
covered by this phasing is three years, as this is the extent of funding presently committed to Dairy
Pakistan. The view of Dairy Pakistan on phasing is as follows:
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CHAPTER 7
It is proposed that Dairy Pakistan develop a program involving donor agencies to develop a business
model along these lines. It is proposed that model businesses be established, whose functions can be
transferred to other entrepreneurs upon proving successful under local conditions. Close supervision will
be needed in the first instance, to ensure proper training in the use of specialized equipment, the
entrepreneur learns how to market his services, matters such as insurance for any damage to fences, for
example, are handled in a professional manner, and perhaps most importantly, a pattern of setting rates
which are fair to all parties are set.
With respect to the important topic of maintenance of reasonably sophisticated equipment, it may be
necessary to build upon the creation of regional entrepreneurs at the “contracting” level, with another
hierarchy, that of entrepreneurs operating specialist maintenance centres – clearly, the latter level will
service a number of contractors. The beginnings of a network of regional businesses can be identified.
Farmers have a lengthy relationship with middlemen, and perhaps they are perceived as being more
reliable than other participants in the industry (or at least other program that have tried to convince
them to supply to alternatives to their middleman).
If the perception that most adulteration occurs by some middlemen is not 100% accurate, and some
farmers are doing this also, then such farmers will tend to supply middlemen as the risks of detection
are likely to be considerably lower.
Middlemen also provide credit to the farmers.
It is considered that the third of these possibilities is the most likely reason that farmers continue to
supply middlemen. It is a logical progression, therefore, that while program such as the establishment of
more collection centres through the Cooling Tank program is a necessary condition to allow more milk to
be handled through the formal sector and in more hygienic ways, this is not by itself sufficient to change
present supply patterns in a major way. These collection centres need to be linked to the provision of
alternative finance sources if they are to become a more real choice for farmers.
66
Dairy Pakistan will work with sources of finance to develop a business model under which alternative
finance can be made available to farmers supplying milk to collection centres.
It noted that it is incumbent upon all processors, without exception, to treat suppliers fairly and ensure
payment is made to them on time. If this is not achieved, then the link between middlemen and farmer
will remain as strong.
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CHAPTER 8
The prevalence of often very poor quality loose milk sold to consumers is of major concern.
Loose milk may be a health hazard, and it would be fair to say that typically more loose milk than
packaged milk would suffer from adulteration. Many factors contribute to this prevalence of un-
pasteurized milk:
The strength of the dhodhis in milk collection (clearly, if processors collected all the milk, then there
would be none available for loose milk sales).
Traditional links between gawallas and consuming households.
The absence of a cold-chain.
o This at least in part reflects the difficulty of making investments in pasteurizing plants and
cold chain profitable, when the competition is loose milk.
The unfair advantages in terms of tax and adulteration enjoyed by the informal sector over the formal
sector.
A lack of awareness among consumers of the health risks of loose milk, offset by the practice of
boiling milk prior to consumption.
o This could be extended to include the observation that in general consumers probably are
not aware of the extent to which adulteration is practiced, and that what is perceived as “the
way milk should be” may be far from what good quality milk is when respected through the
supply chain.
The desire for cream line milk, in order that cream can be skimmed for separate household use.
The cost of packaging used in present warm chain presentations, which tends to reduce the available
consumer pool which can afford better quality packaged milk.
Achieving progress in this complex matter is not easy. A discussion on suggested methodologies follows,
a) Firstly, it is noted that the entire processing capacity of the formal dairy sector is less than the milk sold
in Lahore each day, without taking the rest of the nation into account. Very large investment would be
required before pasteurized milk could be supplied to a large proportion of the population of Pakistan.
The main investment budget would include setting up pasteurization plants and cold chains distribution.
A breakdown of likely costs for such a project would be as follows:
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The total cost for a minimum 50 basic pasteurization plants is estimated at Rs1.153 billion. With
an average consumption rate of 250 grams, it is estimated that one plant capable of processing 25,000
litres per day will meet the needs of about 100,000 consumers. Assuming if an average sales territory for
the pasteurized milk plant has 100 shops, it would mean that for every plant the projected cost of shop
refrigerators would be Rs.3 million. In other words the total cost per plant along with the cold chain will
amount to Rs. 26.05 million. Assuming that pasteurization law was to be implemented in ten mid-level
cities of Pakistan, we estimate a minimum number of 50 pasteurization plants. The total cost for a
minimum 50 plants plus related in-store refrigeration is estimated at Rs. 1.303 billion (approximately).
b) Secondly, industry participants who have studied the matter consider that pasteurized milk tends to be
around Rs5/litre more expensive than loose milk. This is sufficient to affect consumer demand.
c) Thirdly, media campaigns are expensive and would take a long time to influence consumer behaviour
to any marked extent.
d) Fourthly, reliance upon regulatory measures may not be as effective as hoped. Even the most
optimistic commentator would agree that not all laws and regulations are observed to the extent that the
promulgating authority hoped.
Given the latter point, it is concluded that if superior quality milk is to be provided to a good proportion
of consumers, then an approach based solely on regulation (namely a Minimum Pasteurization Law) is
unlikely to be effective. A mixture of market and product development, in conjunction with regulation is
likely to be needed.
8.2 Integrated approach
Rather than sole reliance on a regulatory approach, we return to our theme of integration – the key is to
integrate as many actions as possible if progress is to be made in the supply of pasteurized milk to a good
proportion of the Pakistan population. It is considered that the guiding principles of a program to build a
market for pasteurized milk should include the following:
Identification of appropriate technology and logistical solutions, which can provide pasteurized milk
at a price close to that loose milk.
69
Recognition that if consumers do not wish to pay additional for better quality milk, this is a marketing
issue, and that attempting to reduce consumer choice by trying to regulate loose milk out of existence
may not be successful.
Supporting regulation.
This chapter proceeds to review a more market and product development approach, while the
regulatory approach is discussed in more detail in Chapter 10.
It is recommended that Dairy Pakistan review with stakeholders how pasteurized milk can be
successfully introduced. Some logistical solutions, based on a concept used for many years in India,
warrant study. Perhaps trials based on specific localities will be required.
In India, most notably in Delhi, pasteurized milk is sold in bulk,
through outlets operated mainly by Mother Dairy. This scheme has
been operational for many years, and was launched with the
support of India’s National Dairy Development Board. Milk is
pasteurized at dairy factories, then chilled and pumped into tankers
for transport to the bulk vending outlets. At the outlet, the milk is
pumped into tanks from which consumers draw milk. Consumers
bring their own vessels for carrying the milk back to their homes.
From the consumer perspective, this system delivers good quality
pasteurized milk at an affordable price.
Tanker for transport of chilled, pasteurized milk to bulk vending outlets (Delhi).
Chilled, pasteurized milk being pumped into a tank at the outlet. A token-operated bulk vending filling system.
A variant of the outlet based approach comes with the use of motorcycle or bicycle based salespeople,
who sell pasteurized milk from smaller, mobile tanks.
Bicycle mounted tank for distribution of pasteurized milk, Delhi.
The integration of a pasteurized milk program with other Dairy Pakistan program should be noted:
(a) Pasteurization of milk can only be done by the formal sector; hence the Cooling Tank and Mobile
Milk Collector Program boost the opportunity for the development of a pasteurized milk sector. In
turn, these programs depend on the microfinance initiative to achieve maximum success.
(b) The Milk Pocket Development Program should provide an opportunity to market pasteurized milk.
(c) Raw milk of improved quality will be needed if the less rigorous heat treatment of pasteurization
(compared with UHT) is to provide a satisfactory product. The Model Farm, Cooling Tank, Milk
Pocket Development and Mobile Milk Collection program all assist the goal of improved milk
quality.
The large capital investment associated with the introduction of pasteurized milk should be noted. It
should also be recognized that a reasonable quality pasteurized milk will only be achieved if the quality of
the raw milk supplied to the plant is satisfactory, i.e. much better than what is supplied to processing
plants today.
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CHAPTER 9
Animal Numbers
9.0 Increasing the National Herd Size and Genetic Potential Through Animal Imports and a
Dedicated Breeding Farm
Imports of cows may be desirable for a number of reasons:
1. Pre-feasibility studies conducted by Dairy Pakistan suggest that imported cows may prove to the
most profitable animals for dairy farming. This theoretical analysis needs to be tested under local
conditions of disease prevalence and heat stress.
2. Boosting the national herd with higher yielding animal will assist the drive to increase milk
production.
3. Importing animals can improve the genetic pool available to the industry.
4. Importing animals can provide a useful means to kick start milk production undertaken as a
result of new investment in the industry.
The role that Dairy Pakistan could play in animal imports is not yet clear. Nevertheless, it is apparent that
importing in larger (sea freight) numbers will be more economical than if they are imported in smaller (air
freight) numbers. At the very least, a co-ordination role is needed in order to gain the scale associated
with sea freight.
The import of a reasonably large (1,400) number of cows at one time results in the need for a
staging/quarantine area, where cows can be cared for very well until adapted to local conditions. Such a
staging area may well provide an opportunity for training in the care of more sensitive animals.
One of the features of the present situation in Pakistan, driven perhaps by an overall shortage of milk
relative to demand, is that the best animals are sought by farmers in the milk colony of Karachi. Aided by
a higher price for milk than found in other locations, such farmers are able to out-bid others for the
better animals. Ultimately, these superior animals and their offspring are used for meat, after their highest
yielding seasons are behind them. Hence these superior genetics tend to be lost to the national herd at a
greater rate than the less desirable genetics of animals not purchased for the milk colony. Imports of
animals may negate this trend to some extent. The longer term solution to this matter is of course greater
overall milk production and in particular the establishment of a co-coordinated approach to breeding
policies.
One role for Dairy Pakistan in this program would be to identify the most economic source of animal
imports (most economic meaning not only cost of animal purchase but also performance under local
conditions and the envisaged low cost dairying model), and to co-ordinate with suppliers from the
selected origins.
Assistance will be sought from donor countries, especially those supplying animals under commercial
conditions, on the establishment of staging areas and the use of such an area for training purposes.
A dual track strategy should be followed with respect to establishing commercial breeding farms.
Somewhat differently from the case of most breeding initiatives, this would focus more on achieving the
supply of a reasonable number of animals with above average traits (most breeders focus on a smaller
number of very high quality animals). The traits selected for at this commercial farm should be those,
which support low cost dairying under Pakistani conditions.
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CHAPTER 10
10.0 Adulteration and Hygiene Issues for Milk and Proposal for Pasteurization Law
10.1 Summary:
A Dairy Food Safety Standards & Pasteurization Law is recommended to be introduced as amendments
to 1965 Pure Food Rules Pakistan; the new amendments will give confidence to the players of the supply
chain in the benefits of getting registered, receiving requisite license for dairy facilitation activities and
complying with a mandatory Milk Source Tracking Label. The proposed amendment will promote a
premium-driven quality route.
High rates of adulteration and severely unhygienic practices need to be regulated, premium for
quality needs to be addressed: Adulteration of milk is one of the most serious issues that the dairy
sector of Pakistan is today facing, causing not only major economic losses for the processing industry, but
also major health risks for the consumers. Due to the spread of small holding farmers and consequent
supply chain complexities, milk handling processes in the traditional system are extremely unhygienic and
there is no enforcement of standards. This results in poor quality products. In order to keep milk
temporarily fresh, middlemen commonly add ice to the milk, which results in dilution of milk solids by up
to 30% and often microbiological contamination from poor quality water being used in the manufacture
of ice. Compounding the problem, middlemen attempt to counter the dilution by adding vegetable oil,
whey powder and other ingredients to extend the solid content of the milk. Antibiotics and peroxide are
also often used as preservatives.
Regulation can assist the control of adulteration but the root cause of such adulteration is lack of
developed milk collection system and the processing industry. Only a small percentage of the milk is
properly collected.
10.3 Strict compliance for quality and implementation of pasteurization laws: The dhodhis or the
middlemen of the milk supply chain carry out a successive adulteration process; in the form of water
addition, ice, vegetable oil, air exposure etc in order to increase their margins and preserve the milk. There
is no punishment or incentive system in milk quality hence the dhodhi is mostly unaccountable. The
regulatory structure currently in place in the milk sector is archaic and quite inadequate for modern times
while the ability of government to implement these regulations is also limited. We recommend the
implementation of Dairy Food Safety Standards, and the implementation of pasteurization laws to ensure
a White Revolution of quality milk, details of which are provided below.
10.4 Dairy Quality Standardization and Monitoring Mechanism
Pakistan does not enjoy a high level of food safety; it faces the challenge of continually improving food
safety and reducing food-borne illness. Globally, food-borne illness is a growing public health problem
because of changes in the way food is produced and manufactured, changes in consumer requirements.
The Government of Pakistan through the Ministry of Health and its relevant Ministries in the Provinces
should approach the management of food safety seriously. Governments have agreed that food safety
should be addressed throughout the food supply chain (i.e. from paddock-to-plate). This approach aims
to maintain or improve public health and safety and ensure that consumers continue to have the highest
confidence in the safety of the food they consume, without imposing undue costs on industry. The dairy
industry across the world is a highly regulated sector and practices high levels of food safety management.
At the moment, Pakistan does not have food safety management systems or rules under Food Rules
1965. The Food Rules 1965 need to be revised under the light of newly proposed pasteurization law and
Dairy Food safety standards.
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Dairy Food Safety Standards & Pasteurization Laws will be introduced as amendments to 1965 Food
Laws of Pakistan (Provincial) or through PSQCA (Pakistan Standards and Quality Control Authority) at a
federal level. The new amendments in 1965 food rules or adoption by PSQCA, will give confidence to the
players of the supply chain in the benefits of getting registered, receiving requisite license for dairy
facilitation activities and complying with a mandatory Milk Source Tracking Label. The proposed
amendment will promote a premium-driven quality route.
Dairy products are a rich and convenient source of nutrients for people. The purpose of a Food
Safety Standard is to provide guidance to ensure the safety and suitability of milk and milk
products. All foods have the potential to cause food borne illness, and milk and milk products are no
exception; indeed owing to the liquid nature of milk and its suitability as food for microbes as well as
humans, the risks to the degradation of milk are even greater than for many products. Moreover, the
milking procedure, subsequent pooling and the storage of milk carry the risks of further contamination
from man or the environment or growth of inherent pathogens. Potential also exists for the
contamination of milk with residues of veterinary drugs, pesticides and other chemical contaminants.
In light of the prevalent conditions of low quality and adulteration, there is imminent need for a
regulation on dairy food safety and a law discouraging loose un-pasteurized milk.
CHAPTER 11
Conclusion
The paper has also highlighted the role that finance may play in the relationship between farmers and
middlemen, and it is important that alignment between the formal sector and micro-finance provides is
achieved, such that the formal sector can match the service provide by informal market participants.
The Government of Pakistan, along with international providers of finance and development aid,
recognize that Pakistan’s dairy sector is capable of making an important contribution to national and
especially rural development. The industry has many important backers willing to assist the growth and
improvement of an industry, which can play a vital role for Pakistan. Dairy Pakistan and its members
remain its strongest supporters.
This paper identifies that a successful dairy sector requires numerous contributing elements to be in place.
It must be appreciated that boosting one or two of these elements without enhancing others is unlikely to
be effective. For example, increasing animal numbers but not providing farmers with the management
tools to maintain animal health and feed provision will not provide anything other than temporary
benefit. The support of the Government of Pakistan in the establishment of Dairy Pakistan indicates that
the Government is aware of both the need for and benefits arising from development of a dairy industry
of better overall effectiveness and quality. With so much support and desire from a range of institutions
to drive development, it is perhaps useful to consider which of the many areas needing improvement
should be the responsibility of which institution. It is also useful to note that the Government has
established Dairy Pakistan as a public-private partnership, in recognition that the public sector can do
some things best, while the private sector may do other things better. Clearly, only Government can
provide the necessary infrastructure to rural Pakistan. It is considered, therefore, that the priority for
direct Government action should be the provision of infrastructure such as reliable electricity, and
adequate roads and water supply. Similarly, only Government can provide the necessary regulations
pertaining to food standards and hygiene. Therefore, another priority is for Government, working with
industry, to upgrade food standards to reflect modern practices. Again, only Government can set
educational standards and be the chief financial supporter of educational facilities. It is considered that
aspects of education pertaining to dairying could be reviewed and perhaps modernized.
Government provides key support for many other initiatives: at some stage it may be useful for
Government and other participants to determine how this support is delivered to ensure the maximum
benefit. It is considered that the public-private model of Dairy Pakistan may prove to be an important
conduit for successful implementation of development support to the dairy industry.
The importance of this discussion lies in the need to develop a number of elements at similar times: there
is no point in supplying cooling tanks to farmers without reliable electricity supplies; there is no point in
donating animals to farmers who cannot or do not know how to feed them appropriately; there is
reduced benefit in developing a cluster of efficient and profitable dairy farms in an area with roads which
are impassable during the rainy season. The list of combinations such as these could go on considerably,
but the point is clear – an integrated approach requiring development across numerous fronts is essential.
Some of the important fronts have been highlighted in this paper; it is clear that any successful and
profitable dairy industry requires a myriad of contributing elements. A non-exhaustive list of these may be
as follows:
Secure land tenure.
Availability of appropriate feed and water.
A rural road network so that milk can be collected from sometimes remote locations.
A reliable electricity supply.
Farm management techniques appropriate to local conditions, dispersed through the farming
community.
A holistic approach to animal health.
A means of achieving genetic gain.
Credit formation.
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It is generally accepted that Pakistan demonstrates insufficient of these requirements. Despite this,
Pakistan has the world’s 4th largest milk production, estimated to reach 33 million tones of milk per year.
This is a great achievement under difficult conditions. Much effort and determination will be required to
achieve the integration of well-meant programs, which are otherwise doomed to deliver less than their
potential.
It is also important to note that development of the dairy industry is a journey of many small steps.
Cognizance must be given to the present state of the industry and the consumer habits. It is not possible
to leap to developed world dairying – the basics must be focused on first, and then a logical progression
followed.
The White Revolution is an opportunity to deliver change and modernization to the dairy industry, and
therefore unlock the potential of the dairy industry of Pakistan. This White Paper is intended to illustrate
how the combination of many programs can drive development of the dairy industry. Successful
development will benefit the many millions of farmers, and the even more millions of milk consumers.
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ANNEXURE- A
Proposed Pasteurization Law and its background
Background:
At the heart of the debate between consumption of raw milk and pasteurization laws are the two
divergent view points, those who want to shift to a predominantly cold-chain, pasteurized milk
system and those who seek to improve the current ‘warm-chain’ raw-milk system that accounts
for 91.2% of all marketed milk. The questions surrounding the two main approaches have implications
for geographically and economically marginal producers, the large processors of pasteurized milk,
informal marketing agents, unlicensed milk retailers and mobile milkmen, the relative rewards for
smallholder producers, processors and informal distributors and lastly the price and availability of ‘quality’
milk to consumers.
Those who favor a cold-chain (to keep the milk at 4 to 6c during whole supply chain) industry with
pasteurized milk, characterize the current situation of raw milk production as chaotic
distribution; with stagnant production and demand; leading to poor returns to producers and continued
use of raw milk that carries considerable health risks for consumers through poor handling and
adulteration.
However, those who support improvements to the informal warm-chain system as opposed to
pasteurization cold chain system maintain that the investment needed for a cold chain in a
country like Pakistan is enormous and the poor level of monitoring mechanism carried out
through very limited resource pool of food inspectors does not allow the implementation of
pasteurization laws. The supporters of the warm chain claim that the efficient, quick and relatively low
cost system of getting milk from producer to consumer should not be dismantled. Dairy marketing
policies in developing countries have often relied on standards derived from industrialized countries
where large-scale production systems, cold chain pathways, and milk pasteurization are key features.
However, some of these standards may be inappropriate in developing countries, owing to climate, poor
infrastructure, taste factors and large distances. In Pakistan, as in most developing countries, consumers
prefer unpasteurized milk and are often not willing to pay the extra costs associated with packaging and
processing. The almost universal practice of boiling milk destroys harmful disease pathogens and largely
eliminates public health risks.
law for raw milk at farm or middleman level. Milk is brought to the industry and
pasteurized/processed/UHT. In short while in most countries sale of loose raw milk is prohibited,
however, there is no pasteurization law as such.
In the context of Pakistan a pasteurization law should be applied in stages. We propose the following
three-pronged methodology for the application of such standards in the milk supply chain of the country:
Pasteurization Policy
Along with the Media Campaign a study will be commissioned to design a detailed implementation plan
for pasteurization laws in Pakistan. The detailed study should be carried out within the timeframe and
parameters given in the table below:
Pasteurisation Law Implementation Plan
2006: A detailed study on Pasteurisation Implementation Plan should be commissioned as the first step forward. While
the study is still being carried out provisions on pasteurisation laws should be proposed in the West Pakistan Pure Food
Rules, 1965, provincial amendments. This should be proposed initially based on the pattern of Voluntary Adoption, in
the second stage ten mid level cities of Lahore to be included and lastly the law to be applied to the whole of country.
Another study should be commissioned on the investment required for Pasteurisation plants all over the country along
with the ancillary cold chain. By end 2006 the proposed Dhoodh Darya Media Campaign on consumer and farmer
education should be launched. The recommendations of the two studies commissioned should be reviewed.
2007-2010: Based on the recommendations provided by the two above-mentioned studies, a coordinated effort by the
Federal Government, the Provincial government and the private sector should be made to initiate the investment process
both in setting up pasteurization plants with interested entrepreneurs and in providing the requisite cold chain
concentrating on the ten mid level cities of Pakistan namely: Sialkot, Kasur, Okara, Pakpattan, Chiniot, Jaranwala,
Hyderabad, Sukkhur and ---
2011-2013: By amending the West Pakistan Pure Food Rules, 1965, to include pasteurisation provisions, the law
will become a good pilot project to test the implementation of such a law. Union and District level government will be
engaged for the smooth implementation of the law both for pasteurised milk producers and the consumers. In addition to
the PL a Code on Monitoring Mechanism for such a law will be designed and implemented in the ten cities. An
independent monitors team will be appointed to document and monitor the implementation of pasteurisation law in the
ten cities. A report on the outcome of the experience will be submitted in December 2013.
2014: Under the guidance of the report submitted in December 2013 on the experience of the implementation of
pasteurisation law will be reviewed. Based on the outcome and the experience an independent and complete pasteurisation
law bill will be designed for implementation.
However, as noted previously, huge investment is required for the implementation of the pasteurization
laws in Pakistan. The main investment budget would include setting up pasteurization plants and cold
chains including developing the capacity of the Government for monitoring.
Pasteurization law
Pasteurization: The terms Pasteurization, ',Pasteurized" and their grammatical variations shall be taken
to refer to the Process of heating every particle of milk or milk products to at least 63°C and holding it at
such temperature continuously for at least. 30 minutes (Batch pasteurization) or heating it to at least 72
°C and holding it at such temperatures for at least 15 seconds (for continuous flow pasteurization) or any
other approved temperature-time combination equivalent thereto, that will serve to give a negative
phosphates test, followed immediately by cooling to a temperature of not more than 40C.
Territorial application: For the initial five years the implementation of the law will be restricted to the
following ten cities:
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Punjab
Sialkot (a prosperous business hub, with many foreign visitors), Kasur (contiguity to Lahore)
Sindh
Sukkhur, Hyderabad
License:
Every milk collector, milk distributor, bulk milk hauler / sampler, milk tank truck, milk transportation
company and each milk plant, receiving station, transfer station milk tank truck cleaning facility operator
shall hold a valid license. The license for a milk tank truck(s) may be issued to the milk transportation
company. It shall be unlawful for any person who does not possess a license from the Regulatory
Authority to manufacture bring into, send into, or receive into for sale, or offer for sale therein or to have
in storage any milk or milk products defined in this Act. Licenses shall not be transferable with respect to
persons and/or locations.
Duration of License:
A licensee shall unless sooner suspended or cancelled will be enforce for such period as the Government
may prescribe; provided that if an application for a fresh license is made before the expiry of the period
of validity of the license, the license shall continue to be in force until orders are passed on the
application.
Renewal of License:
The Regulatory Authority will make the renewal of the License after the lapse of the period of the License
on application by the License holder for the period required by the License holder but not exceeding 2
years on the payment prescribed by the Regulatory Authority.
Suspension of License:
The Regulatory Authority shall suspend such license, whenever it has reason to believe that a public
health hazard exists; or whenever the license holder has violated any of the requirements of this Act; or
the licensee has ceased to carry on business of the nature specified in the license, or whenever the
applicant or licensee as the case may be has been convicted of an offence in relation to the requirement
specified by the Act, or whenever the license holder has interfered with the Regulatory Authority in the
performance of its duties. Provided, that the Regulatory Authority shall, in all cases, except where the
milk or milk product involved creates, or appears to create, an imminent hazard to the public health; or in
any case of a willful refusal to license authorized inspection/audit, serve upon the holder a written notice
of intent to suspend license.
Reinstatement of Licenses:
Any license holder whose license has been suspended may make written application for the reinstatement
of his license.
i. If the suspension is due to a violation of any of bacterial, chemical contaminant/adulteration
or deviation in cooling temperature standards the concerned Body, within one week after the
receipt of notification for reinstatement of license, shall issue a temporary license after inspecting
the conditions responsible for the violation have been corrected.
Milk tracing label: Labeling of packed pasteurized milk would be mandatory; highlighting producers’
name, address, packing date and expiry date.
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Shelf life:
Must be max 4 days from the date of packing
Monitoring:
i. An inspector shall at all reasonable hours, have access to all public or private sales room,
warehouses, factories, stores, where milk is offered for sale or deposited for the purpose of sale
and seize or procure samples.
ii. Seize or procure samples of milk at the place of delivery or other place during transit, or upon
the premises of elsewhere in the possession of any person for the purpose of carriage.
iii. The inspector shall inspect frequently, as may be prescribed by the Food Authority or the
Regulatory Authority, all establishment licensed for the manufacture, storage, or sale of an article
of milk within the area assigned to him.
iv. To satisfy himself that the conditions of the licenses are being observed.
v. To maintain a record of inspection made and action taken by him in performance of his duties.
vi. To make such inquiries and inspections as may be necessary to detect the manufacture, storage or
sale of milk in contravention of the law.
Appointment of inspectors:
Government may appoint inspectors in respect of milk and milk products, and an inspector so appointed
shall have jurisdiction in such area as Government may direct, provided that health officer of local
authority and such officers in service of the Government, as Government may by notification in the
Official Gazette specify shall be ex-officio inspectors in respect of all food within the area under their
respective jurisdiction. The existing food inspector appointed under Pure Food Ordinance 1960, shall
continue to exercise the power to file a complaint for contravention or breach of any of the provision of
this Act. Section 36 of the Pure Food Rules 1965, regarding the duty of the Food Authority to employ
one inspector for every 10,000 of population or a part thereof should be amended to the effect that the
there should be one food inspector for every 3000 population for effective implementation of
pasteurization laws.
Eligibility of Inspector:
No person shall be appointed to be an inspector unless he:
(i) In case inspector holds a suitable qualification in food science or related fields.
(ii) Nothing in this Act shall affect the appointment of inspectors made before coming into
force of this Act.
i. Impure or unwholesome milk drawn from animals affected with any disease of
livestock whether contagious, infections or otherwise capable of causing the milk to
become unwholesome.
ii. Milk drawn from animals within 30 days before or 10 days after parturition.
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Regulatory Authority:
There should be a body i.e. Regulatory Authority etc. who manages the matters in relation to issue or
renewal of the Application for licenses. Monitor strictly the pasteurization laws.
Note the huge opportunity for corruption inherent in this structure, and how similar regulations in India
severely impeded the development of the dairy industry there. This aspect needs to be addressed with
special focus during implementation and in continuality
The registrar will also publish periodically a register of persons, who would be provided incentives and
issue certificate of registration in accordance with the provisions of the
Registration and Certification law. The regular registration and certification of the middlemen will be
meticulously monitored and analyzed for future action by Dairy Pakistan.
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Financing
Financing of the Dairy Regulatory and Monitoring Authority will be managed by money allotted by the
Government for the purpose of the proposed law; all fees and other charges payable under this proposed
law; such donations, grants and bequeaths as the authority may from time to time receive from
stockholders or organizations; income derived from investments; proceeds derived from sale of assets;
and contribution from fees collected on importation of milk and milk products; any other source of
income identified by the authority and legally acquired.
Note:
“Dairy food safety standards” are attached as Annexure B
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. ANNEXURE-B
Dairy Safety Standards For Milks and Milk Products
Table of Contents
Sr # Contents Page #
1 Introduction 01
2 Objectives 01
3 Scope 01
4 Terms & Definitions 01
5 Relative roles of producers, manufacturers, distributors, 04
retailers, transporters, consumers and Govt. authorities
6 Principals applying to the production, processing & handling of 05
all milk & milk products
7 Hygiene at farm level 06
8 Handling, storage & transport of milk 08
9 Documentation & record keeping 11
10 Milk reception at factory 11
11 Sampling of milk 11
12 Control of food hazards 12
13 Establishment, design & facilities 13
14 Distribution of finished products 13
15 Establishment of shelf life 14
16 Microbiological & other specifications 14
17 Incoming of milk 14
18 Water 15
19 Incoming materials (other than milk) requirements 15
20 Establishment, maintenance & sanitation 15
21 Labeling of dairy products 16
22 Awareness about hygiene 16
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1. Introduction
Dairy products are a rich and convenient source of nutrients for customer / consumers. The
purpose of this Food Safety Standard is to provide guidance to ensure the safety and suitability of
milk and milk products to protect consumers’ health and to facilitate trade. All foods have the
potential to cause food borne illness, and milk and milk products are no exception as dairy animals
may carry human pathogens. Such pathogens present in milk may increase the risk of causing food
borne illness. Moreover, the milking procedure, subsequent pooling and the storage of milk carry
the risks of further contamination from man or the environment or growth of inherent pathogens.
Furthermore, the composition of many milk products makes them good media for the outgrowth
of pathogenic microorganisms. Potential also exists for the contamination of milk with residues of
veterinary drugs, pesticides and other chemical contaminants.
Provide guidance in implementing the proper hygienic control of milk and milk products
throughout the food chain for its suitability & safety to ensure public health when consumed.
B Analytical Techniques
Provide analytical techniques to be employed for milk and its products analysis.
2. Objective
The objective of this Standard is to apply the recommendations to the particular case of milk and milk
products. It also provides guidance towards meeting the requirements contained in the Dairy Food Safety
Standards.
3. Scope
This is the secretion from the mammary gland derived from milking of healthy Halal milch
animals. It shall be free from colostrums.
It shall be the milk obtained from one or more cows. It shall not contain less than 3.5% of milk fat, and not less
than 8.5% of milk solids other than milk fat.
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It shall be the milk obtained by one or more buffaloes. It shall contain not less than 5.0% of milk fat and not less than
9.0% of milk solids other than milk fat.
It shall be the milk obtained from one or more goats. It shall contain not less than 3.5% of milk fat and not less than 8.0%
of milk solids other than milk fat.
It shall be the milk obtained by one or more sheep. It shall contain not less than 6.0% of milk fat and not less than 9.0% of
milk solids other than milk fat.
It shall be the milk obtained by one or more camels. It shall not contain less than 3.0% of milk fat naturally homogenized
and not less than 10.0% of milk solids other than milk fat.
It means milk, standardized to contain not less than 12.4% of milk solids, including not less than 3.5% of
milk fat provided that the term standardized refers to standardization of fat contents.
Milk which is subjected to such temperature and pressure which will ensure breakup of the fat globules into much smaller
particles & to such an extent that, after forty eight hours (to be stored at 4c) or for 6 hours at 20c of quiescent storage no
visible cream separation occurs on milk.
4.9 Pasteurization
The terms Pasteurization, “Pasteurized" and their grammatical variations shall be taken to refer to the
Process of heating every particle of milk or milk products to at least 63°C and holding it at such
temperature continuously for at least 30 minutes or heating it to at least 72°C and holding it at such
temperatures for at least 15 seconds or any other approved temperature time combination equivalent
there to, that will serve to give a negative phosphatase test and cooled immediately to a temperature of
not more than 200C.
4.10 Sterilization
The term "Sterilization", "Sterilized" and their grammatical variations, shall be taken to the process
of heating continuously every particle of milk to at least 100°C for such length of time sufficient to
kill organisms present and contained for delivery in hermetically sealed containers. It also means
heating milk "continuously" to a temperature of 115°C for 15 minutes or 145°C for 3 seconds, or
equivalent approved temperature time combination to ensure preservation at room temperature,
for a period of not less than 1.5 days from the date of manufacture, Sterilized milk shall show
absence of albumin negative by Turbidity test.
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UHT stands for” Ultra Heat Treatment” also called long life milk. UHT treatment is normally in the range of 135 to
150 °C in combination with the appropriate holding times necessary to achieve commercial sterility.
Homogenized product prepared from milk fat, non-fat milk solids and water. It shall be pasteurized and
shall confirm
d) Turbidity negative
g) Coliform < 10
Milk which after the extraction of milk fat by mechanical or other process contains such fat in quantity
less than 3%. It shall contain not loss than 9.0 percent of milk solids other than milk fat.
The fluid product resulting from the removal of a considerable portion of water from full cream milk,
with or without sugar and include the articles commonly known as dried milk or milk powder. It shall
conform to the following
The product obtained from halal milch animals or from standardized milk by the partial removal
of water & after addition of sugar. The fat and / or protein content of the milk may have been
adjusted only to comply with compositional requirements by the addition and / or withdrawal of
milk constituents in such a way as not to alter the whey protein to casein ratio of the milk being
adjusted. It shall conform to the following
f) Coliform negative
A fluid product resulting from the removal of a considerable portion of the water from skimmed
milk, with or without sugar. It shall conform to the following
Milk concentrated to the form of powder or solid by the removal of water. It shall conform to the
following with allowed food additives
f) Solubility index not less than 85.0% in case of roller dried milk
g) Solubility index not less than 98.0% in case of spray dried milk
f) Solubility index not less than 85.0% in case of roller dried milk
g) Solubility index not less than 98.0% in case of spray dried milk
It is separated milk concentrated to the form of powder or solid by the removal of water. It shall conform to the following with
allowed food additives:
Means with Min 6.5% milk fat or vegetable fat, Min 3% Milk solids (SNF), and other permitted additives.
Means with Min 15% milk fat or vegetable fat, Min 30% Milk solids (SNF), and other permitted
additives.
A product obtained by the addition of syrup or flavor made from wholesome ingredients, by
whatever name called, may contain nuts (whole, fragmented or ground) chocolate, coffee or any
other permitted flavor, permitted color, with or without other permitted food additives and sugar.
It shall be boiled, pasteurized or sterilized / UHT. The flavored milk shall have the same min. %
of milk fat and milk solids not fat as the milk from which it is prepared. The type of milk shall be
clearly and conspicuously indicated on the label in a prominent position.
There shall be written in the label on a package containing flavored milk, the word “Flavored
milk” or the name of the flavor conjoined with the words “flavored milk”. These words shall form
the 1st line of the label and no other words shall appear in the same line.
It shall contain not less than 40% of milk fat with or without permitted food additives.
It shall contain not less than 10% of milk fat with or without permitted food additives
4.26 Butter
It is a fatty product derived exclusively from milk and / or products obtained from milk,
principally in the form of an emulsion of the type water-in-oil with or without permitted additives.
It should conform to the following
The clarified fat derived from milk or curd and free from added coloring matter or preservative,
with permitted anti-oxidants. It shall have a characteristics pleasant natural color & flavor; it shall
conform to the following
c) FFA (as oleic acid) not more than 2.0% without anti-oxidant and 0.4 % with anti-oxidant)
4.28 Cheese
A substance known as cheese and made exclusively from milk or cream or both, with or without
addition of salt or of innocuous preservative or of innocuous coloring matter,
a) Milk fat not less than 40.0% (by weight of dried cheese)
A soft /granular cheese prepared from the curd obtained by adding coagulating agent under the
influence of the harmless bacterial culture to pasteurized skim milk. It shall contain not more than
80% moisture.
A product obtained by the lactic acid fermentation and contains fat in quantity less than 3%. It
shall contain not less than 9.0 % of milk solids other than milk fat
4.33 Ice Cream, Fruit Ice Cream, Malai-ki-barfi, Khoya-ki-Barfi, Malai ki Kulki, KHOYA-
KI-KULFI, KULFA, CONE ICE CREAM
The pure clean frozen product made from a combination of milk or cream or other milk products,
with or without eggs, but with water, sugar and harmless flavoring and harmless coloring, and with
or without added stabilizer, and with or without fruit, fruit juices, nuts, cocoa, coffee or chocolate,
syrup, cake of confections, ice cream by whatever name it is called, shall contain not less than
10%, by weight of milk fat, not less than 36% of total solids and not more than 0.5% of stabilizer
& fulfill the following:
a) Provided that when the ice cream contains fruits or nuts or both, the contents of milk fat may
be reduced proportionately but not less than 8.0% of milk fat,
b) Provided further that ice cream shall not weigh less than 4.5 lbs / gallon.
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4.34 Khoya
A product derived from halal milch animals by evaporation of a part of the water from the milk by
a process of indirect continuous stirred heating and it shall conform the following
A sweet prepared from khoya and sugar with or without other ingredients except starch. It shall
conform the following
Although the responsibility lies with the manufacturer for ensuring that the foods manufactured are safe
and suitable, there is a continuum of effective efforts or controls needed by other parties, including milk
producers, to assure the safety and suitability of milk products.
The interrelationship and impact of one segment of the food chain on another segment is important to
ensure that potential gaps in the continuum are dealt with thorough communication and interaction
between the milk producer, the manufacturer, the distributor and the retailer. While it is principally the
responsibility of the manufacturer to conduct the hazard analysis within the context of developing,
implementing and maintaining a control system based on HACCP.
5.1 Responsibilities:
To achieve an effective continuum, the various parties should pay attention, in particular, to the following
responsibilities.
5.1.1 Milk Farmers should ensure that good agricultural, hygienic and animal husbandry practices are
employed at the farm level. These practices should be adopted, as appropriate, to any specific safety-
related needs specified and communicated by the manufacturer.
5.1.2 Manufacturers should utilize good manufacturing and good hygienic practices to control hazards
during primary production. Manufacturer should clearly and effectively communicate handling
instructions to transporter, distributor and retailer. System for traceability of products must be established
and maintained in order to have control over products. Records must be maintained as appropriate.
5.1.3 Distributors, transporters and retailers should assure that milk and milk products under their control are
handled and stored properly in accordance with GMP,s.
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5.1.4 Consumers should accept the responsibility of ensuring that milk and milk products in their
possession are handled and stored properly in a way that it is safe in use till its consumption and is
/ are handled according to the GMP,s / GSP,s.
The following overarching principles apply to the production, processing and handling of milk and
milk products starting as mentioned below;
6.1 From raw material production to the point of consumption, dairy products should be
subjected to a combination of adequate control measures, and these control measures should be
shown to achieve the appropriate level of public health protection.
6.2 Good hygienic practices should be applied throughout the food chain so that milk and milk
products are safe and suitable for their intended use.
6.3 Hygienic practices for milk and milk products should be implemented within the context of
HACCP.
Milk should not contain any contaminant / adulterant at a level that jeopardizes the level of public
health protection, when presented to / used by to the consumer.
Contamination of milk from animal and environmental sources during primary production should
be minimized.
The microbial load of milk should be as low as achievable, using good milk production practices,
taking into account the technological requirements for subsequent processing.
7.2.1 Water and other environmental factors should be managed in a way that minimizes the
potential for the transmission of any type of hazards (e.g. physical, chemical or microbiological)
directly or indirectly into the milk.
7.2.2 When water is used for the cleaning of the udder and equipments for milking and storage of
milk, it should be of such quality that it does not adversely affect the safety and suitability of the
milk.
7.2.3 Precautions should be adopted to ensure that milking animals do not consume or have access
to contaminated water or other environmental contaminants likely to cause diseases transmissible
to humans or contaminate milk.
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7.2.4 Milking operations should minimize the introduction of food-borne pathogens and foreign
matter from the skin of animal or milkman (in case of manual milking) and general milking
environment as well as chemical residues from cleaning and disinfection routines.
The design, layout and provision of holding areas should not adversely affect the health of
animals. Holding areas should be kept clean and maintained in a manner that minimizes the risk of
animal infection or contamination of the milk.
Milking areas should be kept free of undesirable animals such as, poultry and other animals whose
presence may result in contamination of milk.
Premises where milking is performed should be easy to clean, especially in areas subject to soiling
or infection, e.g. they should have:
7.3.1 Flooring constructed to facilitate draining of liquids and adequate means of disposing of
waste
7.3.3 An appropriate and adequate supply of water of a suitable quality for use when milking and
in cleaning the udder of the animals and equipments/utensils used for milking
7.3.4 Effective separation from all sources of contamination such as lavatories (if used) and
manure heaps
The health status of milking animals and herds should be managed in such a manner that addresses
the hazards of concern for human health. Milk should come from healthy animals so that it does not
adversely affect the safety and suitability of the end product. Milk should be drawn from halal milch animals
that;
7.4.1 Adequate measures should be implemented in order to prevent udder infections, through;
1. The correct use of milking utensils (e.g. daily cleaning after use, disinfection).
2. The hygiene of milking (e.g. udder cleaning or disinfection procedures).
3. The management of the animal holding areas (e.g. cleaning procedures, design and size of
areas).
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Milk having any of the following / s shall not be sold or supplied to the public or a dairy company;
1. Milk from an animal with a confirmed clinical disease (if unsure of the health status of an
animal check with your veterinarian) such as;
a) Brucellosis
b) Salmonellosis
c) Tuberculosis
d) Listeriosis
e) Yersiniosis
f) Leptospirosis
1. With consideration given to the end use of the milk, forage and feed for lactating animals
should not introduce, directly or indirectly, contaminants into milk in amounts that present
health risk to the consumer or adversely affect the suitability of milk or milk products.
2. Pests should be controlled, and in a way that does not result in unacceptable levels of residues,
such as pesticides, in the milk. Site plan may be used as to demonstrate the control over pest
control activities.
3. Animals should only be treated with veterinary drugs authorized by the Govt. authority for the
specific use and in a manner that will not adversely impact on the safety and suitability of the
milk, including adherence to the withdrawal period specified.
4. Residues of veterinary drugs in milk should not exceed levels that would present an
unacceptable risk to the consumer.
5. Good animal husbandry procedures should be used to reduce the likelihood of animal disease
and thus reduce the use of veterinary drugs.
6. Only those medicinal products and medicinal premixes should be used that have been
authorized by Govt. authority for inclusion in animal feed.
7. Milk from animals that have been treated with veterinary drugs that can be transferred to milk
should be discarded until the withdrawal period specified for the particular veterinary drug has
been achieved.
In particular, during any milking, consideration should be given to minimizing and / or preventing
contamination from the milk production environment and maintaining personal hygiene.
Farm dairy occupiers must ensure that, directly after milking, raw milk is filtered and
1. Immediately cooled
2. Cooled down to 4°C or below after completion of milking
3. Kept at or below 8°C until collected, or until the next milking.
With consideration given to the end use of the milk, handling, storage and transport of milk
should be conducted in a manner that will avoid contamination and minimize any increase in the
microbiological load of milk.
Milking utensils, vessels, equipments and storage tanks should be designed, constructed and
maintained in such a way that they can be adequately cleaned and do not constitute a significant
source of contamination of milk.
1. Milk storage tanks and cans should be designed, constructed, maintained and used in a
manner that will avoid the introduction of contaminants into milk and minimize the growth of
microorganisms in milk.
2. Milk storage tanks and cans should be so designed & constructed to ensure complete drainage
in order to avoid contamination of the milk when it is stored. Time and temperature control is
important during storage and transport of milk and depends highly on the type and
effectiveness of the control measures applied during and after processing. Therefore, the
needs for time/temperature control at farm level should be clearly communicated by the
manufacturer of the milk products.
3. Surfaces of milk storage tanks, cans and associated equipment intended to come into contact
with milk should be easy to clean and disinfect, corrosion resistant and not capable of
transferring substances to milk in quantities that will present a health risk to the consumer.
4. Milk tanks and cans should not be used to store any harmful substance that may subsequently
contaminate milk. If milk storage tanks and cans are used to store foods other than milk,
precautions should be taken to prevent any subsequent milk contamination.
5. Storage tanks and cans should be cleaned and disinfected regularly with sufficient frequency to
minimize or prevent contamination of milk.
6. Storage tanks or portions of storage tanks that are outdoors should be adequately protected or
designed such that they prevent access of insects, rodents and dust in order to prevent
contamination of milk.
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7. There should be a periodic verification process to ensure that milk storage equipment is
properly maintained and in good working condition.
8. Reuse of any utensil, vessel, equipment must be avoided which has already been used for any
material / chemical, injurious to human health and is potential source to milk contamination.
All livestock and poultry shall be housed, fed and controlled at specified distances from the farm
dairy and its water supply. These areas shall be cleaned and well maintained.
Livestock and poultry shall be housed, fed and controlled no closer than the following distances
from the milking area, milk receiving area and milk storage room/area, tanker access loop and
water supply;Effluent ponds and offal holes 45 meters
Silage 45 meters
Dead animals 45 meters
Poultry 20 meters
Livestock housing 20 meters
Loafing barns and other buildings 20 meters
Hay barns and hay 20 meters
Feed pad 20 meters
1. Milk should be collected, transported and delivered without undue delay, and in a manner that avoids
an introduction of contaminants into milk and minimizes the growth of microorganisms in the milk.
2. Milk should be transported in intact stainless steel or aluminum containers.
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3. Personnel and vehicular access to the place of collection should be adequate for the suitable hygienic
handling of milk. In particular, access to the place of collection should be clear of manure, silage, etc.
4. Prior to collection, the milk transporter or collection / chilling center operator should check the
individual producer’s milk to ensure that the milk does not present obvious indications of spoilage
and deterioration. If the milk shows indications of spoilage and deterioration, it should not be
collected.
5. Collection and chilling centers, if employed, should be designed and operated in such a manner that
minimizes or prevents the contamination / deterioration of milk.
6. Milk should be collected under hygienic conditions to avoid contamination of milk. In particular, the
milk transporter or collection center operator should, where appropriate, take samples in such a way
to avoid contamination of the milk and should ensure that the milk has the adequate storage/in-take
temperature prior to reception.
1. The milk transporter should receive adequate training in the hygienic handling of raw milk.
2. Milk transporters should wear clean clothing.
3. Persons at risk of transferring pathogens to milk should not perform milk-hauling operations.
4. Appropriate medical follow-up should be done in the case of an infected worker.
5. Milk transporters should perform their duties in a hygienic manner so that their activities will
not result in contamination of milk.
6. The driver should not enter the stables or other places where animals are kept or places where
there is manure.
7. If the driver clothing and footwear are contaminated with manure, the soiled clothes and
footwear should be changed or cleaned before work is continued.
8. The tanker driver should not enter the processing areas of the dairy plant. Conditions should
be arranged to allow necessary communication with the staff of the dairy, delivery of milk
samples, dressing, rest breaks, etc. without direct contact taking place with the dairy
processing areas or with staff members involved with processing milk and milk products.
1. Transport temperature and time should be such that milk is transported to the dairy or to the
collection/chilling center in a manner that minimizes any detrimental effect on the safety and
suitability of milk. The temperature at storage and transportation should be maintained
between 4-8oC.
2. The time and temperature conditions for the collection and transport of milk from the farm
should be established taking into account the effectiveness of the control system in place
during and after processing, the hygienic condition of the milk and the intended duration of
storage.
Records should be kept, as necessary, to enhance the ability to verify the effectiveness of the
control systems. With respect to food safety, records should be kept where necessary on;
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Reception operator or inspectors or the person who is responsible for the inspection of milk and milk
transport should check the following;
10.1 Transport
11.1 When milk is received at factory, the sampling should be done as per following procedure.
1. Sterile all sampling tools, for example spoons, plunger, bottles, test tubes etc.
2. Hands should be washed, dry and properly disinfectant to avoid any contamination risk.
3. Sampling person should follow all GMP’s while taking sample, clean uniform, wearing cap etc.
4. Mix the milk thoroughly with the help of sterile plunger.
5. Collection of sample from tanker or any utensil with sterile spoon etc.
6. Closing of lid/cap of the sampling bottle/test tube.
7. Cleaning of sampling bottle and writing of the following description on it;
8. Sampling Time
9. Sampling Date
10. Tanker number or location
11. Sampling person name.
12. Storage of collected sample in refrigerator set at 4oC+1 or Icebox for further delivery. The milk
samples should not the kept for longer period in refrigerator or icebox.
11.2.1 When milk is received at factory or processing plant, the inspector or receiver should check
the followings parameters;
Organoleptic
Fat min. 5 .0 % for buffalo milk & min 3.5% for cow’s milk or mix
milk with min 5% of fat
SNF > 7.5 %
Total Solids > 12.4 %
Acidity 0.10-0.15 %
Refractive Index control Limits 1.452-1.458
Dirt Test negative
Adulterants negative
Antibiotics negative
Aflatoxin M1 < 0.5 ppb
TPC < 15 millions / ml (At reception in factory)
1. It is important that control measures are applied during both primary production and processing to
minimize or prevent the microbiological, chemical or physical contamination of milk. In addition, special
attention should be given during the processing of different milk products so that inadvertent cross-
contamination does not occur, including with respect to ingredients that may contain allergenic
substances.
2. HACCP should be implemented and maintained specifically at factory, farmer and supply chain in
reference to the Codex guidelines for HACCP as appropriate.
3. Individual control measures should be selected and applied in such combination as to achieve a
sufficient performance as to result in end products with acceptable levels of hazards. Acceptable levels of
contaminants in the end product should be identified and be based upon;
4. Food safety objectives, end product criteria and similar regulatory requirements, as applicable;
a) Acceptable levels derived from the purchaser constituting the subsequent link of the food chain
and/or
b) The maximum levels found acceptable by the manufacturer, taking into account acceptable levels
agreed with the customer and/or regulatory measures established by public health authorities.
1. Hazard identification can be separated into two distinctly different parts, the identification of all
potential hazards and the evaluation of the identified potential hazards to determine which are
considered to have severe adverse health effects and /or are reasonably likely to occur and therefore
need to be controlled through the implementation of effective control measures.
2. To ensure a comprehensive approach, various step(s) in the manufacturing process, from
material selection through processing and distribution, where a hazard may occur or be introduced
should be identified.
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3. Further, any additional hazards that can be introduced into the milk product during and after
processing (e.g. environmental contamination, human contamination) should also be considered.
During such considerations, the effectiveness of preventive measures taking place in the
manufacturing environment (e.g., environmental and equipment sanitation programs, employee
practices, pest control programs, etc.) should be evaluated to determine the likelihood of occurrence
of potential hazards.
1. Equipment should be designed and installed such that as far as possible dead ends or dead spots
in milk cans / utensils & milk pipelines do not occur.
2. From milk production through to finished products, products should be stored at appropriate
temperatures and for appropriate times such that the growth or development of a food safety hazard
will be minimized and the product’s suitability will not be adversely affected.
3. Incoming milk when arriving at the dairy plant, and provided that further processing does not
allow otherwise, the milk should be cooled and maintained at such temperatures as necessary to
minimize any increase of the microbial load of the milk.
4. The principle of "first arrived, first processed" should apply.
5. Intermediate products that are stored prior to further processing should, unless further
processing does not allow it, be kept under such conditions that limit/prevent microbial growth or be
further processed within a short time period.
6. There should be adequate stock rotation, based on the principle of “first in, first out”.
1. It is essential that milk and milk products be kept at an appropriate temperature in order to
maintain their safety and suitability from the time it is packaged until it is consumed or prepared for
consumption.
2. It is the responsibility of the manufacturer to determine the shelf life of the product and the
conditions for storage.
3. The storage temperature should be sufficient to maintain product safety and suitability
throughout the intended shelf life.
4. Regular and effective monitoring of temperatures of storage areas, transport vehicles and store
display cases should be carried out where:
a. The product is stored, and
b. The product is being transported, within the product load, which could be done by using
temperature indicating and recording systems;
c. The product is being presented for retail sale.
5. Particular attention should be paid throughout storage and distribution to:
6. Periods of defrosting of refrigeration units;
7. Temperature abuse; and
8. Overloading the cold storage facility.
9. Products that can be stored at ambient temperatures, should be protected against external agents
and contamination, e.g., direct sun radiation, excessive heating, moisture, external contaminants, etc. from
rapid temperature changes which could adversely affect the integrity of the product container or the
safety and suitability of the product.
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15.2 The shelf life of milk products may be limited by microbial changes (e.g. deterioration by
pathogenic and spoilage microorganisms to unacceptable levels).
1. When establishing product shelf life, it is the responsibility of the manufacturer to assure and, as
necessary, to demonstrate, that the safety and suitability of the milk product can be retained throughout
the maximum period specified, taking into consideration the potential for reasonably anticipated
temperature abuse during manufacture, storage, distribution, sale and handling by the consumer.
2. These temperature abuses may allow the growth of pathogenic microorganisms, if present, unless
appropriate intrinsic factors are applied to prevent such growth.
1. The milk used for the manufacture of products covered by this Standard should be evaluated
based on sampling of milk from individual farms or milk collection centers. Upon receiving, the milk
should be subject to visual inspection to detect unacceptable conditions.
2. Any-non-compliance with the above mentioned criteria, and in particular with regards to
pathogens, should result in immediate corrective actions at the farm level and in the manufacturing
establishment, for example: rejection of the milk for the processing of raw milk products; corrective
actions on the milking procedure (cleaning and sanitation procedures of the milking equipment, cleaning
or sanitation procedures of the udder, etc.,); quality of feed; the hygienic quality of the water supply;
practices in animal holding areas; individual check of animals to find the animal(s) that may be the carrier;
isolation of that animal from the herd as necessary. Corrective actions should be identified and
implemented, and specific assistance to the dairy farm may need to be provided.
Establish incoming milk criteria that take into account the end use of the milk and the conditions under
which the milk was produced.
1. Corrective action taken for non-compliance with incoming milk criteria should be commensurate
with the potential risks presented by the non-compliance.
Microbiological criteria may be necessary to be established at different points in the process for carrying
out the design of control measure combinations and for the verification that the control system has been
implemented correctly
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1. The flow of the product and of the ingredients within equipment and through the processing
facility should maintain a forward progression from raw material receipt to finished product packaging so
as to avoid cross contamination.
2. There should be adequate separation of areas with different levels of contamination risk.
Preventive measures should be implemented to minimize risks of contaminating milk and milk products
with physical and chemical hazards and foreign substances.
18. WATER
1. Dairy processing establishments should have potable water available, which prior to its first use,
should meet the criteria specified by the Govt. authorities having jurisdiction and shall be regularly
monitored. Reference of PSQCA drinking water standard no .
2. Reused / recycled water shall be treated and maintained in such a condition that no risk to the safety
and suitability of food results from its use.
3. Reused / recycled water shall not be used / mixed in products.
1. Ingredients used for the processing of milk products should be purchased according to
specifications, and their compliance with these specifications should be verified.
2. Raw materials should, where appropriate, be inspected and sorted before processing. Any claims
that raw materials meet safety and suitability specifications should be verified periodically.
20.1 All food product contact surfaces in piping and equipment, including areas that are difficult to clean
such as by-pass valves, sampling valves, and overflow siphons in fillers shall be adequately cleaned.
All equipment and utensils used in processing should, as necessary, be cleaned and disinfected, rinsed
with water, which is safe and suitable for its intended purpose. Follow the CIP for the plant. A routine
program to verify the adequacy of cleaning should be in place
In the case of refrigerated products, the vehicle product compartment should be cooled prior to loading
and the product compartment should be kept at an appropriate temperature at all times, including during
unloading.
The registered number or name and address are that of final manufacturing dairy factory, and no other
number is used. Where the product is processed by more than one manufacturer, the registered number
or name and address of the final manufacturer is used on the final packaging
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Lot identification, such as a bag number, box number or quality unit number; or
The date of expiry
Net wt
22.1 Training programs Govt. with the assistance of different organizations/stake holders shall
initiate the preliminary awareness program for milk producers and personnel involved in the
collection and transport and retail of milk to train them as necessary and have appropriate skills in
the areas listed below:
Reference cited:
ISBN 0-908946-00-7, New Zealand Dairy Board, Wellington, New Zealand, November 1998
Committee
Nestle Pakistan
Director
Director
Karachi
Deputy Director
Karachi