From August 2025, the department started to implement new risk management measures for the import of dairy products for human consumption. These measures were recommended in the final report of the Import risk review for dairy products for human consumption (the dairy review). See more on the risk review process and final report.
This included negotiation of new health certificates with trading partners.
We continue to negotiate with overseas government authorities to develop new health certification for dairy products, including cheese, permitted for import.
Next steps of the implementation
Stage 2 of implementing the recommendations of the dairy review will commence on 1 September 2026.
Permits will be issued with the import conditions listed in the dairy review (new conditions). Permits will have an appendix with the health certificate statements from prior to the dairy review (old conditions). Those health certificates will continue to be accepted for goods that are imported on or before 31 August 2028.
The inclusion of the appendix will support trade while the negotiations to develop new health certification continues.
In a small number of cases, where bespoke or country-specific health certificates have applied, it may be necessary to issue 2 permits:
- a permit that is valid for 2-years with the new conditions, and
- a permit with the old conditions, valid until 31 August 2028.
There will not be additional fees if this is required.
Cheese
If a cheese product cannot meet the new conditions, but it does meet the old conditions, a permit with only the old conditions will be issued with an expiry date of 31 August 2028.
It is in the best interest of the importer to consult early with the manufacturer to amend the production processes if they wish to continue to import these goods after 31 August 2026.
Note that once a trading partner agrees to certificates under new conditions, they may no longer be able to issue certificates under the old conditions.
Updated production questionnaires
Importers must provide the latest production questionnaire to the manufacturer of their goods to assist in prompt assessment of permit applications. Providing superseded versions of questionnaires will result in a delay in assessment and a request to provide additional information.
Production questionnaires are available to download from the BICON commodity case Dairy.
Summary of new measures
Existing requirements have been amended and new conditions added. These changes are also listed in section 5 of the dairy review.
Key amendments
- References to countries recognised by the World Organisation for Animal Health (WOAH) as free from foot-and-mouth disease (FMD), without vaccination, are no longer accepted.
- Certification requires sourcing and manufacturing countries to be on the Director of Biosecurity’s FMD-Free Country List.
- Pasteurisation of the dairy ingredient or dairy product is now permitted, rather than of the milk only. This does not apply to cheese.
- Butter will no longer be considered separately from other dairy products and will subject to conditions for dairy.
Key new requirements that have been implemented
- Ovine and caprine dairy products must be sourced from and manufactured in countries free of peste des petits ruminants virus in addition to FMD, sheeppox and goatpox.
- Dairy must be processed and manufactured at facilities that have implemented a quality assurance system and are approved by the competent authority for food safety in that country.
- Batch (or low-temperature long-time) pasteurisation has been added as an approved heat treatment for all dairy products of bovine, ovine and caprine origin listed on the respective disease-free country list.
- Thermisation and high temperature curd cook has been added as an alternative treatment option for cheese from FMD-free countries.
- New requirements have been added for cheese from countries not on the Director of Biosecurity’s FMD-free country list, including additional treatment and ripening requirements in section 5.2.1 of the dairy review.
Quality control systems
For dairy products permitted for import into Australia under the new conditions, the goods must be produced under a quality assurance program that is in place for the production and manufacture of dairy products for human consumption.
A quality assurance program is a system of procedures designed to ensure food products are safe and meet specified quality standards throughout the entire production process. This is from primary production to the collection, transport and processing of the product.
There is no single quality assurance system implemented across all countries or production facilities. Each country or production facility may have their own quality assurance system. For example, a HACCP or ISO system, or Food Safety System Certification 22000 (FSSC). The department has not mandated a specific quality assurance system; however, each production facility must have an appropriate system in place to ensure food quality.
Manufacturing facilities that are ‘registered, approved, or recognised as required for food safety by the relevant national authority’ means the certification or licensing process that allows a facility to manufacture and/or sell food legally in their jurisdiction. This may include local approvals (e.g. state, councils, regions) that are recognised nationally.
The department does not register, recognise or approve manufacturing facilities for food safety in other countries for the production or processing of dairy products for export to Australia.
In countries listed on the approved country lists, facilities must be registered, recognised, or approved by the relevant national food safety authority. You should contact the manufacturer or national authority to confirm this status.
- Approved country list for bovine dairy: FMD-Free Country List.
- Approved country list for ovine and caprine dairy: List of countries approved for the import of ovine and caprine dairy products.
Importing dairy products from non-FMD free countries
Before any assessment can begin, a formal request must come from the competent authority (government) of the exporting country, the country of manufacture, or the source country. A resource intensive assessment, as described below, is required and may take some time to complete.
Applying for an import permit does not speed up the assessment. If a permit application exceeds the legislated timeframe for assessment, it will be refused.
The competent authority of the exporting country must provide evidence to us. This evidence must show they have sufficient oversight to manage biosecurity risks and ensure the goods meet our import conditions.
This includes necessary information about the supply chain, such as:
- heat treatment or processing applied during manufacturing of the dairy products
- risk management processes at manufacturing facilities to prevent substitution or contamination of a product or production line.
We have developed a fact sheet for the process. See the fact sheet on dairy products for human consumption import risk review page.
Key dates
Timeline text
See key dates for the implementation process.
Time points
31 August 2025 – Stage 1
- We began issuing dairy permits with 2 sets of import conditions.
31 August 2026
- We will stop issuing permits with dual conditions.
1 September 2026 – Stage 2
- Permits will be issued with the new conditions.
- Permits will contain an appendix with the old health certificate statements that will be accepted for goods that arrive on or before 31 August 2028.
31 August 2028 – Stage 3
- The last import permits granted with the old conditions and accompanying health certificates will expire.
1 September 2028 – Finalisation of the implementation of the dairy review
- Completion of dairy review implementation. Only goods that meet import conditions listed in the review and new health certificates will be accepted.
Contact us
For more information on the implementation of the dairy review, email imports@aff.gov.au.