Spanish scientists have proposed additional requirements for the marketing of raw milk but have not gone as far as to ban it.

European regulation allows unpasteurized milk for direct human consumption to be placed on the market without treatment to kill bacteria, parasites and viruses. The current situation in Spain follows this legislation with no additional requirements so raw milk can be sold regardless of volume.

The Spanish Agency for Food Safety and Nutrition (AESAN) asked its Scientific Committee to assess whether risk management measures related to raw milk intended for direct human consumption are adequate to provide a high level of consumer protection. Or if it was necessary to prohibit raw milk sold in this way in Spain.

Proposed measures include microbiological criteria, mandatory packaging of milk and indicating on the label: “Raw milk without thermal treatment: boil before consumption” and “Maintain refrigerated at temperatures between 1 and 4 degrees C (34 to 39 degrees F).

“It is recommended that a warning be included in the label, to avoid that consuming raw milk without following the measures required poses a health risk,” according to the committee.

Adequate additional requirements
Experts ruled these steps are adequate to provide a high level of protection to consumers of the product and that it was an improvement on the current situation. It was also recommended that a shelf life of three days be established. Proposals will be incorporated into a draft law.

France, Italy, Austria, Finland and Latvia have managed marketing of raw milk with additional requirements on information for the consumer, limiting sales systems, and establishing microbiological criteria. Placing raw milk or cream on the market for direct consumption in Scotland is banned.

In 2018, the government in Catalonia decided to allow the direct sale of raw cow’s milk from producers to consumers. Seventeen U.S. states permit direct raw milk sales from farms to consumers.

Marketing of raw milk for direct sale to consumers in Spain can be made by authorized firms registered with the General Sanitary Registry of Food Businesses (RGSEAA).

Protecting vulnerable groups
The microbiological criteria proposed covers absence of Campylobacter, E. coli O157, Listeria monocytogenes and Salmonella in 25 millilitres in five units that make up a sample.

“The proposed criteria focus on the main microbiological risks linked to foodborne diseases from the consumption of raw milk in the last few years in Europe. The sampling plan and proposed limits lead to a low prevalence of said pathogens in the product. In the case of large batches, a sampling could be carried out for each batch,” according to the committee.

Raw milk must always be packaged for sale to the end-consumer. Packaging must be closed immediately after filling, with a closing device that prevents contamination and must be designed so that once open, the state of the product can be easily judged.

Food establishments that serve meals to vulnerable groups such as hospitals, daycares, schools and retirement homes, cannot use raw milk as an ingredient.

Owners of milk production holdings cannot directly supply raw milk to the end-consumer, or retail businesses that directly supply end-consumers, except when they comply with the other rules.

EU regulation allows at least 400,000 somatic cells per milliliter and up to 100,000 colony forming units per milliliter of bacteria in raw milk for producers. The Spanish committee said it was important to establish hygiene criteria stipulating somatic cells to be less than or equal to 300,000 per milliliter and bacteria at 30 degrees C (86 degrees F) less than or equal to 50,000 per milliliter for cow’s milk. For sheep’s milk, a value less than or equal to 250,000 bacteria at 30 degrees C per milliliter must be demanded, they said.

“Greater hygiene in the direct sale of raw milk to consumers is extremely important and must be included in the regulation, which would mean that only milk production holdings with high overall hygiene can sell this milk,” added the committee.

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