The 2025 Grade "A" Pasteurized Milk Ordinance (PMO), posted June 2026, is the 34th revision of the model ordinance states adopt for milk and milk products. A plant can join the Interstate Milk Shippers (IMS) List with sanitation and enforcement ratings of 90% or more, or through HACCP audits.
This guide is for QA managers at Grade "A" plants and at dairies abroad, including in the Gulf, that want to supply the US.
What changed in the 2025 PMO?
FDA lists the 2025 PMO, dated June 2026, on its NCIMS Model Documents page. It replaces the 2023 PMO, dated February 2025. FDA enforces milk sanitation only on interstate carriers and interstate shipments, and the state agency enforces the rest once the state adopts the ordinance.
The National Conference on Interstate Milk Shipments (NCIMS) recommends changes every two years. Its 39th conference met in Minneapolis on 11 to 16 April 2025. Two changes are confirmed as new against the 2023 text. Item 16p now allows pasteurised liquid cream to be added after pasteurisation to mechanically strained non-fat yogurt, if the cream is pasteurised in the same facility.
The second is a new formal definition of the term direct loading: milk loaded onto a tank truck without a farm bulk tank or silo. Delegates also passed proposals that move direct-load wording into items 9r, 14r and 18r and that update farm bulk tank washing. State summaries list further changes not checked here. Check which edition your state has adopted, because a new PMO applies only after adoption.
Which dairy products are not Grade "A"?
The 2025 PMO excludes ice cream and other frozen desserts, butter, puddings, infant formula and every cheese except cottage cheese and dry curd cottage cheese. It also excludes products in which other fats replace milkfat, and coffee- or tea-based drinks made mainly of coffee, tea or water.
Grade "A" covers the 21 CFR Part 131 milks and milk products, except sweetened condensed milk. It adds cottage cheese, whey products, combination packs and other products with at least 2.0% milk protein and 65% milk or milk products by weight. Condensed or dried products count only when used in Grade "A" products or labelled Grade "A".
A yogurt line and a butter line under one roof sit under different rules. Butter, ice cream and most cheese made for the US fall under FDA's general food rules, including 21 CFR 117, rather than the PMO.
What do inspectors and rating officers check?
The state agency inspects each milk plant at least once every 3 months, and aseptic and retort plants at least every 6 months. Over any 6 consecutive months, it takes at least 4 samples in 4 separate months.
| Requirement | Where it sits | What is checked |
|---|---|---|
| Pasteurisation | PMO Item 16p, Appendix I | Recording charts, test reports, seals. Batch 63 °C for 30 minutes, continuous flow 72 °C for 15 seconds |
| Pasteurised milk standards | PMO Section 7, Table 1 | Sample results: 7 °C or less, bacteria up to 20,000/mL, coliforms up to 10/mL |
| Cultured product cooling | PMO Item 17p | pH and fill-temperature records, for example yogurt at pH 4.80 or below at filling |
| Sanitation rating | NCIMS Procedures | SRO rating at least every 24 months, SCR of 90% or more |
| Food safety plan | PMO Appendix T | PCQI-prepared plan, recall plan, hazard analysis, reanalysis every 3 years |
| HACCP alternative | PMO Appendix K | Agency agreement, prerequisite programmes, HACCP Plan, record reviews within 7 working days |
| Plant outside the US (ICP route) | Procedures Section IX | TPC Letter of Intent, annual Memorandum of Agreement, English documents |
A State Rating Officer (SRO) certified by FDA rates the shipper. First listing on the IMS List needs a sanitation compliance rating (SCR) and an enforcement rating (ER) of 90% or more, and the shipper's written permission.
If the SCR falls below 90%, the listing is withdrawn, with written notice dated within 5 working days. A low ER does not remove the listing at once, but the shipper must be re-rated within 6 months or is withdrawn. FDA also check-rates listed shippers and updates the electronic list at least monthly.
Where do Appendix K HACCP and Appendix T fit?
Appendix T makes the PMO, its appendices and your plant-specific procedures your food safety plan under 21 CFR 117.126, as far as they address all the hazards you identify. For hazards the PMO does not cover, you add preventive controls, a supply-chain programme, monitoring, corrective action and verification. A preventive controls qualified individual (PCQI) prepares or oversees the plan. PMO plants have had to comply since 17 September 2018.
The hazard analysis includes drug residues, allergens and hazards introduced for economic gain. Appendix T inspections may be as rare as once every 36 months, by inspectors trained on FD378 or FD254.
Appendix K is a voluntary HACCP alternative to traditional inspection, piloted by NCIMS from 1999. A plant can join only if its regulatory agency agrees, and both sides commit resources in writing. Regulatory audits then replace routine inspections.
The programme applies the seven HACCP principles, which our Codex HACCP guide explains. A trained qualified individual validates the HACCP Plan within 12 months of starting and at least annually after that. Records are kept for 2 years or the product's shelf life, whichever is longer. Drug residue testing, labelling and milk from sources rated 90% or more, or HACCP listed, still apply.
How does a plant outside the US get IMS listed?
Importing without a listing is not in itself a breach of federal food law, FDA memorandum M-I-00-4 notes. The pull comes from the states. PMO Section 11 lets them accept Grade "A" milk from outside their inspection only from rated or listed sources, or from a country FDA finds equivalent.
There are four routes. The memorandum, dated April 2000, sets three: a contract with an NCIMS member state's regulatory and rating agency, full NCIMS membership for the country, or an FDA equivalence evaluation of the country's system.
The fourth is the International Certification Program (ICP), set up by NCIMS in 2013. A Third-Party Certifier (TPC) applies the Grade "A" programme to the milk company. A Memorandum of Agreement with the TPC serves as the company's permit and is renewed every year. Documents must be in English or translated, and if the TPC stops oversight, the company is withdrawn at once.
The July 2026 IMS List names two TPCs: Harold Wainess & Associates and Milk Regulatory Consultants. It shows foreign milk shippers only from Canada, Colombia, the Dominican Republic and Mexico. No GCC dairy is listed as a milk shipper.
The only GCC entries are two Saudi packaging plants, Elopak in Dammam and SIG in Riyadh, listed as makers of single-service containers and closures. Cheese, butter and ice cream are outside the PMO, so a Gulf exporter of those follows FDA's general import rules. Milk or cream may also need a Federal Import Milk Act permit (21 CFR 1210.20).
Where does camel milk fit in the PMO?
The PMO defines camel milk as milk from healthy camels, practically free of colostrum, and counts it as milk. Somatic cell counts above 750,000/mL must be confirmed by the Pyronine Y-Methyl-Green stain method, run by certified analysts. Camels fall outside the USDA brucellosis and TB programmes, so a state-administered programme must find the herd free of brucellosis and/or TB.
The PMO lets milk from animals it does not yet cover be labelled Grade "A" and IMS listed once FDA accepts validated test methods for that animal (memorandum M-a-98). Check camel milk's status in M-a-98, or with FDA or your rating agency, before you plan a Grade "A" camel product.
For Gulf farm-level rules, see our guide to ADAFSA Code of Practice No. 30. The Codex CXC 57-2004 milk hygiene code is the international counterpart to the PMO.
How AGS can help
The U.S. Grade A Dairy HACCP Management System (PMO 2025 Revision & NCIMS) has 285 documents in editable Microsoft Word and Excel. It includes a PMO Compliance Matrix, a Grade A vs Manufacturing Grade Decision Guide and a PMO Dairy Plant Gap Assessment. It also has a Dairy Pasteurization Control Program, a Regulatory Seal Register and a Cultured Product pH Critical Factor Record for Item 17p. It has no documents for foreign-plant routes, the ICP or dairy farms.
Frequently asked questions
Does anyone certify a dairy HACCP plan?
No. Under Appendix K the regulatory agency audits the HACCP system and reports on Form FDA 2359m. A HACCP listing also needs the plant's permission to publish, on Form 2359o.
Is the PMO pasteurisation table the same as the federal one?
Almost. 21 CFR 1240.61 sets the same times and temperatures and adds 3 °C for fat of 10% or more or added sweeteners. The PMO also adds 3 °C when total solids reach 18% or more.
Does the traceability rule apply to PMO cottage cheese?
No. FDA exempted cottage cheese regulated under the PMO from the food traceability rule by a notice of 20 February 2026 (91 FR 8256). FDA will not enforce the traceability rule before 20 July 2028 in any case.
When will the next PMO revision come out?
No date is published. The 40th NCIMS conference meets in St Louis on 20 to 25 April 2027, and changes passed there would feed a later revision.
AGS provides independent documentation toolkits. This guide and the referenced kit are not affiliated with, endorsed by or approved by the US Food and Drug Administration, NCIMS or any state regulatory agency. It is general information, not legal or regulatory advice.
Reviewed October 2026. Facts checked against the sources current at publication.
