1. The Issue
Since February of 1994, recombinant Bovine Somatotropine (rBST) has been used commercially in the US to enhance milk productivity. In December of 1999, the European Union decided to continue the 1990 ban on the placing on the market and administration of rBST. However, detailed measures for the application of this decision in terms of trade with third countries have not been adopted. In both regions, this new agricultural biotechnology has generated much political debate. Despite some similar outcomes of various scientific studies, government responses to rBST have varied due to political, cultural and economic factors. While rBST is not yet the subject of a trade dispute between the European Union and the United States like the one on hormones used on beef cattle it could erupt as a future trade issue.2. Description
Bovine Somatotropin (BST), also known as bovine growth hormone (BGH), is a natural protein produced by the pituitary gland of all cattle. 1 Biotechnology has enabled scientists to produce recombinant form of this protein called rBST. The term rBST has been used to refer to BST that is produced using fermentation technology and injected into dairy cows to increase efficiency of milk production.2 Scientists have found that supplementing cows' natural levels of BST improves the efficiency of milk producers. The mammary glands of such dairy cows take more nutrients from the bloodstream and produce more milk, which results approximately in a 10% increase.
Prompted by the commercial benefits of rBST, four large pharmaceutical companies (Monsanto, Eli-Lily, American Cyanamid and Upjohn) started programs to develop a commercial rBST product. The first company to produce rBST for sale purposes was Monsanto. Monsanto markets BST, produced by genetically engineered bacteria under the name Posilac. It was patented, and was approved for use from the US Food and Drug Administration in 1993 for the purpose of augmenting milk production in dairy cows, satisfied that the necessary safety and efficacy tests have been met. Despite the strong oposition from small dairy farmers in Wisconsin, which resulted to a 90-day moratorium on the sale of rBST, the commercial sale of the product begun in February 3, 1994.
In 1990, the European Union imposed a moratorium on the use of animal growth hormones. The decision was based on the fact that European farmers were already producing too much milk and beef, and there was no need for greater production. In 1994, the Council of the European Union decided to concinue the ban on the use and sale of rBST until December of 1999. The EU decision was based on three considerations. First, the introduction of rBST would not be in line with the reform of the Common Agricultural Policy (CAP), as it would negatively affect dairy and beef markets. Second there were increased concerns about the impact of rBST use on the health of cows. Third, a strong aversion to the use of rBST prevailed among consumers. 3
Several events taking place in past years could explain the European aversion towards the rBST. Part of the explanation has to do with the outbreak of the BSE crisis [Bovine Spongiform Encephalopathy] in the UK known as the mad cow disease. The BSE crisis has resulted to a decline in public trust based on the British government's inability to meet the public's expectation for the protection from the BSE. BSE has made people in Europe very sensitive to new technologies in the food supply industry and very wary of the scientists and government attempts to reassure t hem. The Americans have more trust in their regulatory agencies. The BSE crisis in combination with recent food safety incidents such as the Coca-Cola scare and dioxin contaminated chicken in Belgium further undermined public confidence in the competence of both national and EU regulatory officials. 4
The fact that rBST is a hormone has caused additional health worries in Europe, even though BST occurs in milk naturally. "The European ban on the use of all hormones in animal production, together with some incidents of illegal use that appeared in the newspapers, have made the European consumer very sensitive to the word 'hormone' itself." 5
Taking under consideration the increased level of European aversion towards hormones, scientific research from European experts as well as the opinion of the Committee for Veterinary Medical Products, on December 17th , 1999 the European Council adopted decision 99/879/EC concerning the placing on the market and administration of BST and repealing Decision 90/218/EEC. According to this decision, "members states shall ensure that the placing on the market of Bovine Somatotropine on Community territory or within their jurisdiction for the purposes of its marketing and administration thereof to dairy cows by any means whatsoever shall be prohibited." However, Article 3 of the same decision states that "the prohibition provided for in article 1 shall not affect the production of bovine Somatotropine in the member states, or imports, for the purposes of its exports to third countries." For the time being, the European Union has not elaborated on further implications of the above decision. It seems the contradictory nature of the above decision suggests that the issue remains under debate. So far the United States has not specifically addressed the issue of rBST as a separate issue in its trade relation with the European Union. However, there are several factors that could act as deterrence for the US to proceed in such steps.
Primarily, despite the FDA approval concerns over the BST health effects have not eased in the United States. In January of 1999, Canada banned the use of BST based on its negative impacts on cattle welfare. Although the FDA did not publish information about the potential health affects of the product, the Canadian findings created a series of public reaction in the United States. The International Center for Technology assessment along with 21 public interest groups petitioned the FDA to prohibit the BST use until additional safety research is conducted. The organization along with the interest groups further stated that failure of the regulatory body to comply would result to the filling of a lawsuit. 6
In addition to the domestic reaction, ambiguity and concern over the safety and use of rBST has grown beyond the borders of the two continents. In June of 1999, the UN's main food safety body, the Codex Alimentarious Commission decided not to endorse the safety of rBST. Despite increased pressure from the United States the Commission refused to adopt a standard on whether to allow maximum residue limit for rBST in milk and decided to delay its decision until a consensus could be reached. 7 The Codex decision gives more flexibility to national governments to decide whether to allow the use of BST in their countries. The European Union along with 110 countries supported this decision and sees it as a victory for the health and the safety of the consumers.
Consumers International as well as the Consumers Union, publisher of consumers resports, believe that the hormones have not been proven to be safe. The adoption of a standard would have asserted the safety of the hormone and countries refusing to imports dairy BST products could be brought before the World Trade Organization as creating a trade barrier. 8
Genetic modification in milk production has been a very controversial issue, attracting a lot of media coverage as new scientific studies suggest that the use of rBST's raise serious concerns. Among others, perhaps the most important concern is the safety of the milk from rBST treated cows for human consumption. At the same time, questions such as the rBST impact on natural environment, its socioeconomic impact, animal welfare, and ethics have also been subject to debate.
In the United States, most scientists agree that the use of rBST is not a significant threat to human health. Yet, new scientific evidence in Europe suggests that giving rBST to cows can cause fivefold rise in the levels of a protein called insulin-like growth factor 1 (IGF-1). While IFG-1 is essential for normal development of human tissues, such as the gut, studies suggest that that heightened levels of the protein hormone carry increased risk of prostate cancer in men and breast cancer in women. 9 It is also argued that it is possible that IGF-1 prevents a cancerous cell from performing apoptosis-a cellular suicide whose purpose is to prevent the formation of colonies of cancerous cells. Furthermore, the European Union Veterinary committee has reported that use of rBST in dairy cows is probably linked with high resistance to antibiotics and induction of allergic reactions in humans. 11
These results are contrary to the views of the FDA that rejects the idea that IGF-1 coming from the milk of rBST treated cows poses any increased risk of cancer. The FDA makes a twofold argument. For the most part, the increase in IGF-1 in the bodies of people who consume the suspect milk is less than 0.1%. Secondly this increase is limited to the gut of consumers. Critics of this argument argue against both points saying that the increase is significant and that it may be possible for IGF-1 to pass through the gut wall and end up in the blood stream. 10
The above-mentioned concerns were further addressed by the Joint FAO/WHO Expert Committee on Food Additives (JECFA), an independent scientific body whose recommendations to FAO and WHO are relied upon by governments and international organizations on scientific matters such as food additive safety and usage, tolerable levels of contaminants, and reside levels of veterinary drugs in foods. In March of 1998, the Committee affirmed that "there are no food safety health concerns related to BST residues in products such as milk and meat from treated animals." 12 Specifically the Committee concluded that the use of antibiotics to treat mastitis as well as the potential for drug residues in milk could be managed through practices currently in use by the dairy industry and by following label directions for use.
In the European Union the issue of animal welfare and animal rights has been attracting a lot of attention. There have been a number of scientific studies mainly conducted by the EU Veterinary Committee to assess the impact of the rBST on the animal welfare. According to a review by European Union veterinary experts, animals treated with rBGH may have a 50% greater risk of lameness, fertility problems and a 25% greater chance o f developing mastitis, an udder inflammation. The Director of Compassion in World Farming concluded that putting even more pressure on the already stressed, high-yielding modern cow, is an unnecessary risk to her health and welfare. A number of signs such as anemia, and raised levels of fatty acids show that the BST pushes cows to total metabolic exhaustion and predisposes them to disease. 13
In the case of rBST, the environmental concerns are related to the intensification of dairy farming and the concomitant concentrated emission of minerals and ammonia.
Yet, it would be an over simplification of the issue to suggest that health and environmental concerns are the sole factors complicating dairy trade between the two partners. Differences between the two continents concerning milk have been long standing stemming in part from differences in the political economy of agriculture across the Atlantic. American governments have been seeking to protect the economic interests of farmers by encouraging technological improvements in order to increase agricultural productivity. On the other hand, the European Union has sought to protect the economic welfare of farmers by discouraging the introduction of technologies designed to increase production.Decisions concerning the use and sale of rBST in Europe are closely related to the future of milk production quota system as well as EU's Common Agricultural Policy (CAP).
The Common Agricultural Policy ( CAP) was established in 1962. The CAP was specifically designed to increase the Community's agricultural production, to ensure a fair standard of living for the agricultural community, to stabilize markets, to guarantee that supplies are always available to the consumer, and to make these products available at a reasonable price. The CAP is based on three interdependent principles. The first was that there should be a single market in all-agricultural products. In order for this to succeed, common market rules were necessary. Second, as all member states had to prefer goods produced within the community duties were imposed on imports, which in turn became more expensive than competing home products. Third, the financial subsidies to farmers were provided to ensure that no member state was unfairly propping up its own agricultural products. 14
However, the implementation of the CAP brought along a number of negative side effects, which had a direct impact on the EU's trade relationship with its main partners and particularly the United States. Specifically, as the farmers were getting a minimum price for their produce, even if they only sold them as surpluses to be stockpiled by the Community intervention authorities for later sale at subsidized prices on the world markets, a tremendous amount of surpluses were created. Technological advances and intensive production techniques led to overproduction. For instance in Italy milk production increased by half between 1970 and 1990. Furthermore, the unified prices of the products were set according to the country where the product was most expensive which resulted to a gap between world market and EC (now EU) prices.
The EU is currently engaged to another effort to reform its agricultural policy. 15 The CAP reform will have significant implications for the US-EU trade relationships and particularly in the trade of genetically modified products. The reform provides incentives for lower output and emphasis on quality aspects of products and production methods, 16 which will naturally undermine the demand, and therefore consumption of GMOs. US concerns are stemming from the fact that the EU already produces up to 15% more milk than its domestic market requires, and this large surplus drives its continued heavy use of export subsidies. 17 European intitiatives for agricultural reforms including EU efforts to cut the guaranteed prices of the milk by 15% seemed to ease tension between the two partners in regards to the dairy trade. Nonetheless, the organization recently decided to maintain its dairy quotas until at least 2008 and put of dairy reform, under Agenda 2000 until 2005, when support prices will be slightly reduced, quotas somewhat increased and compensations to dairy farmers introduced.
Milk quotas were enforced in April 1984 in order to stop overproduction of milk in Europe. Under the quotas, European farmers are allowed to produce up to a certain maximum amount of milk. For every kilogram of milk in excess of the quotas, a levy has to be paid to the European Commission. This levy is prohibited in nature, as it is more the price farmers receive for their milk. The milk quotas are applied to 819,000 dairy farmers and 4,790 milk buyers. 18 Milk quotas are based on a butterfat content of 3.7%. Member states' deliveries listed in the following tabledo not take into account butterfat adjustment, which could add considerable quantities to deliveries and lead to super levy fines. 19
* Example of butterfat adjustment is also provided in the TED Chocolate case
table.1 EU National Quotas for Milk Deliveries 1997/98 by Member State
Annual increases in quota that will be received by individual member states under the dairy reform
In order to assess the impact of the rBST in the EU, the Agricultural Economics research institute in Netherlands conducted a study including qualitative scenarios for the dairy sector. According to these studies, use of rBST will result to more production and exports, lower internal prices, fewer but bigger dairy holdings, and more regional concentration of production. 20 At the same time, such perceived benefits will inevitably have negative socioeconomic impacts. Primarily, Europe is already in surplus of milk and an increase in production not only will decrease the quality of dairy products but will also result to unemployment, as many small farmers will be forced to leave the sector. Farm policy changes in 1992 and 1999 have aimed at reducing output, thus less dependence on surplus disposal through exports. Focus has been on enhanced quality and not increased output. In addition, economic benefits deriving from trade with third countries are less likely as it becomes uncertain whether consumers in other countries as for instance Japan Canada or Switzerland will accept milk produced with rBST treated cows.
On the other hand, biotechnology has become an issue of growing importance in the United States.American-based biotech giants such as Monsanto, American Cyanamid, Eli Lilly, and Upjohn are spending billions into research and development. These companies have substantial interest in the rBST. They have approximately sunk 500m pounds into developing BST, with estimated worldwide sales of 1bn dollars a year. 21 The EU moratorium has been substantial obstacle to this target. Within the United States it is expected that in a few years virtually 100% of the US agricultural commodity exports will be genetically modified or with genetically modified products. 22 Currently, the rBST is currently used on about 30% of the American dairy cattle. 23
The EU has so far approved about 18 GMO products for commercial release. Although there is no clearly established risk, there remains to be uncertainty about the rBST long-term health effects. Specific regulations banning imports of milk from rBST treated cows have not been adopted. Yet, the EU labeling requirements for genetically modified products might affect milk trade. The issue of labeling has been allready icnreasing tension between the two partners. US trade officials worry that labeling might be misleading and may be used to infer that the US products are dangerous, when there is no scientific evidences to indicate risk to human health. 24 On the other hand, EU officials at the view the issue of labeling as a "political reality rather than protectionist ploy," 25 Besides the undeniable trade implications, different paerceptions of food safety continue to mold transatlantic trade policies.
Despite the lack of concrete measures concerning milk from rBST treated cows, the differences in regulatory treatment of GMOs, coupled with the EU's desire - or some would argue necessity- to protect its dairy industry might turn to a very difficult issue to handle in trans-Atlantic relations. While rBST is not yet the subject of a trade dispute between the European Union and the United States like the one on hormones used on beef cattle, it could erupt as a future trade issue.
3. Related Cases
US-EU & BIOTECHNOLOGY BIOTECHNOLOGY EU-US DISPUTES EU & IMPORT BAN EU INTERNAL DISPUTES FOOD REGULATION SOYBEAN BST EUNOISE HOOF MADCOW CODEX MAIZE CANOLA BANANA BOTSWANA CHOCOLATE EUMEAT CASSIS EUGENBAN EULABELING
4. Draft Author:
Athina Balta, April 2000
II. Legal Clusters
5. Discourse and Status:
Disagreement and In progress
6. Forum and Scope:
United Nations and Multilateral
The issue involves primarily the US and the EU. However, the issue has impact on other countries as well. Concerns over the safety of rBST and genetically modified products have grown to an international level. The following are multilateral for a where biotechnology has been dealt with:
7. Decision Breadth:
- Convention on Biodiversity
- CODEX Alimentarious (Codex Committee on Labeling) of the United Nations
- The World Intellectual Property Organization (WIPO)
- The International Conference on Harmonization (ICH)
- The World Trade Organization
8. Legal Standing:
European Union Legislation:
- Council Directive 90/219/EEC of April 23, 1990 on contained use provides EU-wide rules for the use of GMOs, both in research laboratories and industrial facilities
- Council Directive 90/220/EEC of April 23, 1990 on release of GMOs provides EU-wide rules for field trials and marketing of GMOs
- Council Regulation No.258/97 on Novel Foods makes labeling of any product containing GMOs, or that may otherwise be considered "novel" mandatory
- Council Decision 90/218/EEC of April 1990 concerning the placing on the market and administration of bovine somatotropin (BST) Amended by the following measures:-Council Decision 91/61/EEC of 4 February 1991;
-Council Decision 92/98/EEC of 10 February 1992;
-Council Decision 93/718/936/EC of December 1993;
-Council Decision94/936/EC of 20 December 1994
- Council Decision 1999/879/EC of 17 December 1999 concerning the placing on the market and administration of bovine somatotropin (BST) and repealing Decision 90/218/EEC [Described in the history section]
- Convention for the Protection of Animals Kept for Farming Purposes
- The Protocol on Protection and Welfare of Animals
The following Federal Agencies regulate different aspects of GMOs in general: (1) USDA issues permits for field trials and commercial release for production, (2) EPA regulates pesticides used in or on foods and feed, primarily, and (3) FDA regulates safety of domestic and imported foods, except meat and poultry which is regulated by USDA. In the United States there has been a series of legislation regarding genetically modified products. In regards to rBST the following are the most important developments:
- Timeline1980 The Monsanto Company begins BST tests with FDA approval
1981 Monsanto asks permission to test BST on Cows
1985 The FDA rules that milk from rBST treated cows is safe for human Consumption.
1987 Monsanto asks permission to market the drug
1993 The FDA' Veterinary Medicine Advisory Committee approved the use of rBST
1994 rBST goes on Sale
1994 The FDA issues a set of guidelines on labeling milk produced without use of rBSt stating that voluntary labels may not claim milk as "BST free" which was also noting that there is no significant difference between treated and untreated cows.
Mechanisms for Cooperation:
Evidently, differences in regulation of rBST do not constitute the sole issue of dispute between the two parties. Development of Genetic Modification has given rise to a series of disputes. Under the Transatlantic Economic Partnership (TEP), the United States and the European Union have set up a biotechnology Working group to address bilateral issues relating to GMOs. Expertise and advisory opinions are also offered by a considerable number of other technical groups from the EU and the US. In addition, there have been a number of non-governmental transatlantic dialogues as well as senior level governmental dialogues between the two parties.
Dispute Resolution Mechanism
III. Geographic Clusters
9. Geographic Locations
a. Geographic Domain: [EUROPE]
b. Geographic Site: [WNAMER]
c. Geographic Impact:[USA]
10. Sub-National Factors:
11. Type of Habitat:
IV. Trade Clusters
12. Type of Measure:
13. Direct v. Indirect Impacts:
14. Relation of Trade Measure to Environmental Impact
a. Directly Related to Product: Yes, Milk
b. Indirectly Related to Product: Yes, Meat
c. Not Related to Product: No
d. Related to Process: Yes,Health
15. Trade Product Identification:
16. Economic Data:
Despite a number of disputes over trade regulations, the US and the EU have developed a strong economic relation. Two-way trade and investment flows account for more than one trillion dollars, which directly supports more than six million jobs on both sides of the Atlantic.26 One out of twelve industrial jobs in the United States is in a European owned factory. Europeans are the biggest investors in forty-one of the US states. The EU is a very important market for U.S. agricultural exports in 1998, U.S. agricultural exports to the EU were $8.5 billion and US imported $7.3 billion of products from the EU. 27
In regards to milk trade, the restrictions on rBST dairy products seem to have fewer implications than other products in the trade between the US and the EU. As illustrated in table 3, the United States exports few dairy products and even less fluid milk to Europe.
MILK PRODUCTION IN THE EUROPEAN UNION
The EU is by far the largest producer of cow milk worldwide. In 1995, it accounted for around 26% of world production, estimated by the FAO at 463.5 mio t. The US represents around 15%, Russia around 8.5%, and India some 7%, New Zealand (2.1%), Australia (1.9%), and Canada (1.7%) together account for less than 6% of the world total.28
Milk production is the main farming activity in almost all countries of the EU individually and in the EU as a whole (where it accounts for 18.4% of the total value of agricultural production).29However, most of the EU's output of cow's milk is produced by just a few Member States. The biggest milk producing countries within the European Union are Germany, France, the United Kingdom and the Netherlands. 30The importance of the milk sector is even more apparent when compared with another, closely related, sector, namely beef cattle farming (accounting for 11.9% of the total value of agricultural production). According to European Union estimates, milk production, is expected to be higher for the next two years. The number of dairy cows in the EU is forecast to decline from 21.5 mio animals recorded in 1998 (December survey) to around 18.8 mio animals by the year 2006. 31table.3 Milk Production in the European Union
MILK PRODUCTION IN THE UNITED STATES
Although the US is a major industrialized country it is heavily engaged in dairy production. The US dairy industry is the second largest agricultural commodity sector in the United States, both in an economic and a geographical sense. Internationally, the US is the world largest single country producer of cow' s milk. 32
U.S. milk production for 1999 totaled a record high 162.7 billion pounds which constituted a 3% increase from 1998. The output per cow, at 17,771 pounds, was 582 pounds above the 1998 rate. The average number of milk cows during 1999 was 9.16 million head. For the year of 1999, California, with 30.5 billion pounds, remains the leading milk producer, followed by Wisconsin with 23.1 billion, New York with 12.0 billion, Pennsylvania with 10.9 billion, and Minnesota with 9.5 billion. These five States produced 53 percent of the total U.S. milk output.33
table.4 Milk Cows and Production in the United States (Monthly, 1997-99)
17. Impact of Trade Restriction:
18. Industry Sector:
19. Exporters and Importers:
United States and the European Union
V. Environment Clusters
20. Environmental Problem Type:
21. Name, Type, and Diversity of Species:
Milk Cows [descended from a wild bovine, Auroch]
22. Resource Impact and Effect:
Medium and Product
23. Urgency and Lifetime:
Low and five to ten years
|The Life of a milk cow can be summarized as follows:|
|15 months||Heifer inseminated for first calf|
|24 months||First calf born-starts milking|
|27 months||Inseminated for second calf|
|34 months||Dried off|
|36 months||Second calf born- starts milking|
|*cycle repeats for 5-6 lactations 34|
VI. Other Factors
Yes (See the history section)
26. Trans-Boundary Issues: No
28. Relevant Literature
1. FMI Media Backgrounder: Bovine Growth Hormone or Bovine Somatotropin, http://www.fmi.org/media/bg/bst.html
2. Cornel University-BST Fact Sheet, US Food and Drug Administration Center for Food Safety and Applied Nutrition, FDA Prime Connection, http://vm.cfsan.fda.gov/~ear/CORBST.html
3. Jos Bisjman, Recombinant Bovine Somatotropine in Europe and the USA, Biotechnology and Development Monitor, No. 27,p. 2-5, June 1996
4. John Lanchaster, "Mad Cow Disease" The New York Times Magazine, July 4, 1999:7-8
5. Jos Bisjman, Recombinant Bovine Somatotropine in Europe and the USA, Biotechnology and Development Monitor, No. 27,p. 2-5, June 1996
6. Udder Confusion," The Economist, July 3, 1999: 70-71
7. US and Europe Agree to Disagree on Safety of Dairy Hormone, BioDemocracy and Organic Consumers Association, http://www.purefood.org/rBGH/unorbgh.
9. When Science Takes Its place in the Dairy Case, (Capital Times(Madison, WI)) Mike Ivey; 03-23-1999 10. Jos Bisjman, Recombinant Bovine Somatotropine in Europe and the USA, Biotechnology and Development Monitor, No. 27,p. 2-5, June 1996
11. US and Europe Row over milk (Independent) Charles Arthur Technology editor: 03-22-1999
12. "Milk and Meat from BST Treated Cows Presents No Danger to Humans Says Committee Report Released by the UN Food and Agriculture Organization" FAO Press Release 98/17
13. Food and drink: The milking of the Cash Cow: Should big, (Independent) Joanna Blythman: 01-29-1994
14. European Commission, How does the European Union Manage Agriculture and Fisheries?, Luxembourg: Office for Official Publications of the European Communities, 1996
15. Earlier reforms were made in 1979, 1988 and 1992
16. EU Environmental Policy: Genetically Modified Organisms (GMOs)
17. World Trade Organization Agriculture Agreement: Thomas M. Suber (Congressional testimony) 03-23-1999
18. Attaché Query Detail, Executive Summary, http://www.fas.usda.gov/scriptsg/gain_display_report.exe?Rep_ID=25454374.0
20. Jos Bisjman, Recombinant Bovine Somatotropine in Europe and the USA, Biotechnology and Development Monitor, No. 27,p. 2-5, June 1996
21. Food and Drink: The milking of the Cash Cow: Should big, (Independent) Joanna Blythman; 01-29-1994
22. US-European Union Trade Issues: Stuart E.Eizentstat (Congressional Testimony); 03-15-1999
23. "Udder Confusion, The Economist; July 3, 1999
24. US-European Union Trade Issues: Stuart E.Eizentstat (Congressional Testimony); 03-15-1999
25. The European Union Speeches, Consumer Federation of America Panel on Genetically Engineered Foods: The Debate over Labeling, Remarks by Charlotte Hebebrand, Trade Section, Delegation of the European Commission National Food Policy Conference 2000 Washington, DC, April `7th, 2000
26. US-European Union Trade Issues: Stuart E.Eizentstat (Congressional Testimony); 03-15-1999
27. U.S. - EUROPEAN UNION TRADE ISSUES: ALLEN F. JOHNSON (Congressional Testimony); 03-15-1999
28. CAP 2000, Situation and Outlook: Dairy Sector, http://europa.eu.int/comm/dg06/publi/cap2000/dairy/dairy_en/1-15.htm
29. Reform of the Common Agricultural Policy, Common Organization of the Market in Milk and Products, http://europa.eu.int/scadplus/leg/en/lvb/l60010.htm
30. Attaché Query Detail, http://www.fas.usda.gov/scriptsg/gain_display_report.exe? Rep_ID=25454374.0
31. CAP Reports, Prospects for Agricultural Markets 1999-2006, Executive Summary, http://europa.eu.int/comm/dg06/publi/caprep/prospects/index_en.htm
32. World Trade Organization Agriculture Agreement: Thomas M Suber (Congressional Testimony): 03-23-1999
33. US Department of Agriculture, Crop and Livestock Reports, March 2000
34. Dairy Science and Technology Milk Production and Biosynthesis, University of Guelph, Ontario, Canada