Archive for Canadian dairy quota

Milcobel’s €8 Clause in 2026: €62,000, or Three Times That?

Four of the world’s ten largest dairy companies are farmer-owned. All four are running the same playbook Lactalis has been running — and the fine print is where members find out what that costs.

EXECUTIVE SUMMARY

  • The €8 clause nobody has defined. Milcobel’s merger proposal pays €8 per 100 kilograms to members who stay three years with FrieslandCampina. Nine months after the deal closed, no public document says whether that lands once or annually — on 760,000 litres, roughly €62,000 versus about €186,000 across the term. It also isn’t clear whether a one-time payment would be calculated on one year’s volume or on cumulative supply, which would close the gap entirely.
  • The macro split. The world’s 20 largest dairy companies turned over USD 267 billion in 2025, up 5.4%. USDA NASS put U.S. producer returns at $21.19/cwt — down 6.1% nominal and 8.5% real. On 400 cows at the national 24,390-lb average, that’s about $133,657 off the top line.
  • Governance moved with the money. FrieslandCampina’s Members’ Council votes one vote per ten million kilos of district milk, and its district count has gone 21 to 14 to 16 since 2009. Milcobel’s merger passed unanimously among 70 delegates; FrieslandCampina’s percentage has never been published. In June, the ICA circulated draft language inserting “normally” into one-member-one-vote.
  • The 14-year capital lag. DFA’s board issued $29.6 million in patronage on September 3, 2026 — 7.5¢/cwt, or roughly $7,317 on that same 400-cow herd. It covered 2012 earnings. If you’re modelling patronage into cash flow, model the delay with it.
dairy cooperative consolidation

€8 per 100 kilograms, for three years, to members who stay. That’s Milcobel’s retention clause, and nine months into the merged cooperative nobody has published whether it pays once or annually. On a 760,000-litre operation, one reading is worth roughly €62,000 and the other nearly three times that. If you ship to DFA, Land O’Lakes, Agropur or any co-op that’s merged in the last decade, the same question sits in your own agreement — and 2025 was the year U.S. producer returns fell 6.1% while the world’s biggest dairy companies grew 5.4%.

A long-standing Milcobel member described that calculation to The Bullvine last December, a week before the vote that folded her Belgian cooperative into Dutch giant FrieslandCampina. A second member, in West Flanders, ran it from the other end.

“They’re offering us €8 per hundred kilos to stay three years,” the first said. “That’s real money. But my nearest plant is on the closure list.”

“The next closest facility is 47 kilometers further,” the second said. “That’s going to add real money to my hauling costs every year.”

There’s the trap. Commit three years to a processing network that may not include your plant, or walk away from the payment. Both members asked not to be named. Both were describing their own operations.

What We Could and Couldn’t Verify: The €8 rate and the three-year condition come from the published merger proposal. Whether the payment is made once or annually is not established in any public document — the whole reason it leads this story — and neither is the volume basis it would be calculated on. We found no documented instance of a Milcobel or FrieslandCampina member facing consequences for speaking publicly, and no published plant-closure list. The cooperative has used the language of network optimization rather than announcing closures. The closure-list characterization is the member’s own reading of her situation. Nestlé’s Top 20 turnover figure is carried by dairy trade press covering the RaboResearch release and isn’t independently cross-confirmed. DFA’s $23.1 billion comes from the Dairy Foods Top 100, a separate North American ranking, not RaboResearch’s own line item. The ICA’s June 2026 draft revision is quoted verbatim below. We haven’t established what prompted the change, and the draft doesn’t mention dairy.

The Divergence in One Table

Metric (2024 → 2025)Top 20 Global Dairy ProcessorsU.S. Producer Farmgate
Topline movement+5.4% — USD 267B combined turnover (RaboResearch, Aug 2026)−3.7% — $48.9B gross cash receipts (USDA NASS, Apr 30, 2026)
Price / return realizationNo group margin published; growth driven by M&A and a stated pivot to protein, functional nutrition and high-value ingredients−6.1% — $21.19/cwt nominal; −8.5% real on BLS CPI-U (313.7 → 321.9)
Output volumeNot reported as a group figure; Arla–DMK–DOC alone carries a pro forma pool of 19.4B kg+2.6% — 232B lbs produced; 24,390 lbs per cow, up 218 lbs

Two things worth naming before the analysis. Revenue growth isn’t profit growth, and a good chunk of that 5.4% comes from mergers stacking two companies’ revenue under one banner rather than anyone selling milk at a better price. And U.S. output rose while returns fell — more milk, less money per hundredweight.

Running the Numbers: Your Herd Against That Table

Every input below is sourced so you can run it against your own statements.

Sourced inputs — USDA NASS, Milk Production, Disposition, and Income 2025 Summary, released April 30, 2026, U.S. national:

  • Producer returns, 2025: $21.19/cwt, 6.1% below 2024 (NASS wording)
  • Implied 2024 figure: roughly $22.56/cwt — a decline of about $1.37/cwt
  • Rate per cow, 2025: 24,390 lbs
  • Deflator: BLS CPI-U annual averages, 313.7 → 321.9, +2.6%
  • Real 2025 return in 2024 dollars: $21.19 ÷ 1.026 = $20.65

Scenario — 400 cows at the NASS national per-cow average:

  • 400 × 24,390 lbs = 9,756,000 lbs
  • ÷ 100 = 97,560 cwt marketed
  • 97,560 cwt × $1.37 = $133,657

Swap in your own cow count, production average, and regional basis, and the figure moves. The direction won’t.

Now put the Belgian arithmetic beside it. The West Flanders member’s 47 kilometres is a permanent cost added to every load, running against a payment that stops after three years even on the most generous reading. Whatever her hauling rate is per kilometre, multiply it by two for the round trip, then by her annual load count, then by three. That’s what the €8 has to beat if the payment recurs annually — and roughly three times what it has to beat if it’s paid once on a single year’s volume. She can’t finish that calculation either, because nobody has published which one it is.

Why Canada’s Farmgate Went the Other Way — And What It Costs to Get In

Not every system moved the same direction in that window. The Canadian Dairy Commission’s National Pricing Formula produced a 2.3255% farmgate increase effective February 1, 2026, following a 0.0237% decrease the prior year. The mechanism is the whole difference: supply management prices milk off a national cost-of-production formula — the CDC calculated 2024 cost of production, indexed to the three months ending August 2025, at $92.82 per hectolitre — rather than off global commodity markets. That insulates Canadian farmgate returns from the swing the table above shows.

It prices entry instead. Ontario quota sits at a policy cap of $24,000 per kilogram of butterfat per day, the same ceiling in force in Quebec, New Brunswick, Nova Scotia and Prince Edward Island. Alberta and Saskatchewan don’t cap at all.

ProvinceMechanismPrice / kg Butterfat / Day
Ontario / P5Policy cap$24,000
AlbertaUncapped market clearing (Oct 2025)$57,115

Sources: Dairy Farmers of Ontario quota exchange summaries; Alberta Milk October 2025 exchange summary.

Watch what happens when you remove the ceiling. Alberta Milk’s October 2025 exchange cleared at $57,115/kg, with 23 successful bids between $58,200 and $60,900 and 30 successful offers between $54,000 and $56,030. That’s roughly 2.4 times Ontario’s capped price for the same asset — the clearest available read on what the cap is holding back.

British Columbia runs a third model worth knowing about, because it’s neither of those. The BC Milk Marketing Board manages a market-clearing price inside a core range of $30,000 to $40,000 per kilogram, with the price permitted to move no more than $1,000 in any month while it sits inside that band — rules that took effect for exchanges from January 1, 2025. Managed drift, not a hard ceiling.

The cap doesn’t make quota cheap; it makes it scarce. Dairy Farmers of Ontario’s March 2026 exchange drew bids from 1,908 producers against 190.60 kg traded, all of it at the ceiling. The November 2025 exchange was cancelled. So was August 2026. Run the ceiling against your own barn and the barrier gets concrete fast: at $24,000/kg, every kilogram of daily butterfat you’d need to add is a $24,000 cheque — assuming an exchange clears at all.

That’s a capital barrier no U.S. or EU producer carries. EU quotas ended in 2015; the U.S. never had them. Canadian farmgate stability is bought, and the purchase price hits the balance sheet instead of the milk cheque.

Our breakdown of why financed Ontario quota at 6% bleeds cash every year runs the servicing math per kilogram — at 6%, every financed kilogram gave back $586 a year.

What Everyone Assumed About Farmer-Owned Processing

Own the plant, control the milk, capture the margin. That’s the founding logic of the cooperative model, and it isn’t wrong — it’s been renegotiated in bylaws while most members were watching milk prices instead.

Here’s the part that breaks the usual framing. That Top 20 list isn’t investor-owned giants circling farmer co-ops. Dairy Farmers of America sits at No. 3 at USD 23.1 billion, just behind Nestlé at USD 23.7 billion. Arla Foods moved to No. 4, passing Danone. FrieslandCampina landed at No. 7 after absorbing Milcobel. Fonterra slipped from 7th to 10th after selling Anchor, Mainland and Kāpiti to Lactalis for NZ$4.22 billion.

Four of the global top ten answer to farmers. And they’re running the same playbook Lactalis has been running — cross-border M&A, exiting commodity categories, and chasing protein and high-value ingredients. RaboResearch’s report frames scale as “a prerequisite for long-term competitiveness,” a line trade coverage attributes to analyst Emma Fuess.

The Arla Number That Doesn’t Say What It Appears To

Worth stopping on Arla, because the calendar complicates the ranking. Arla’s audited 2025 revenue was EUR 15.1 billion, up 9.4% from EUR 13.8 billion in 2024. The merger with Germany’s DMK Group and the Dutch cooperative DOC received unconditional EU Commission approval on May 28, 2026, and took effect June 1, 2026 — after the calendar year the ranking measures. Arla’s own release puts the merged entity at roughly 11,200 farmers, 28,800 employees, local roots in seven countries, and pro forma revenue above EUR 20 billion. In Arla’s H1 2026 results, DMK contributed EUR 409 million — for the single month of June.

So the No. 4 placement rests on a transaction that closed months after the turnover year closed. Pro forma treatment is standard practice, not a methodology complaint. It’s a caution for anyone reading the table as a 2025 snapshot.

The same caution applies to the co-op share of that $267 billion. Publicly available turnover for DFA, Amul, and Fonterra comes to roughly $46 billion — about 17% — and even that floor mixes accounting periods, since the Fonterra component is a 2024-basis figure. Add reasonable proxies for Arla and FrieslandCampina and the share probably sits in the 35–40% range. Probably. Nobody can calculate it precisely without RaboResearch’s full 20-line table on a consistent FX basis, which isn’t public.

What Does Your Co-op Membership Still Buy You?

The economic core hasn’t moved. USDA Rural Development’s framework is blunt: “cooperatives are businesses established for users and do not serve the interests of non-user investors.” Surplus returns as patronage proportional to milk shipped, not shares held. Cooperative earnings get taxed once, not twice.

That machinery still runs. On September 3, 2026, DFA’s board issued $29.6 million in patronage earnings — 7.5 cents per hundredweight — to members who marketed milk through the cooperative in 2012.

Run it on the same 400-cow scenario: 97,560 cwt × $0.075 = $7,317. Hold that beside the $133,657 price swing as a matter of scale, not as a ratio — one is a 2012 earnings allocation, the other a 2024–25 price move, and comparing them as a percentage would flatter neither. It arrives because you shipped milk, not because you bought equity. No investor-owned processor writes that cheque.

Note the lag. A September 2026 allocation covering 2012 earnings. If you’re modelling patronage into cash flow, model fourteen years of delay with it.

Where the Renegotiation Actually Happened

Governance is the piece that changed, and it changed in public. Bylaws, not backrooms.

FrieslandCampina publishes its own formula: members of the Members’ Council “have one vote for every ten million kg of milk that their district supplied to the company during the most recent financial year.” Volume-weighted, at district level. Your influence runs through your district’s aggregate kilos, then through your district’s elected representatives. The Milcobel merger created two new Belgian districts — Milcobel-West (District 15), chaired by Bram Maes, and Milcobel-East (District 16), chaired by Vanessa Tindemans-Van Eynde — each with eight to ten elected farmers.

Watch the district count over time. It tells the story better than any single vote. FrieslandCampina ran 21 districts with ten councillors each as recently as 2009 — a 210-member Members’ Council. A 2021 Members’ Council decision cut districts from 21 to 14, producing a 140-member council. Post-Milcobel, the co-op describes 16 districts with eight councillors each. Fewer, larger districts mean fewer people standing between an individual member and the board.

Fonterra shows the same trajectory over a longer runway, through a New Zealand-specific structure with no direct U.S. equivalent. Trading Among Farmers passed with 66.45% support in June 2012. Flexible Shareholding passed with 85.16% in December 2021, on 82.65% participation, widening the shareholding range from 33% to as much as 400% of the production requirement. The Lactalis brand sale passed with 88.47% in October 2025, on 80.59% participation by milk solids.

Those aren’t close calls. Members voted for this, repeatedly, by wide margins. Any honest reading has to sit with that.

The U.S. Government Accountability Office flagged the mechanism in 2019, six years before either merger closed: as co-ops consolidate, “farmers… can have different expectations,” and voting structures “can create power imbalances based on farm size.”

Turnout is its own variable — when Holstein Canada rewrote its governance, the rewrite passed with 0.8% of members voting.

The Turn: 70 Delegates and One Unpublished Percentage

Here’s the data point that reframes everything above.

Milcobel’s Extraordinary General Meeting approved the merger unanimously — among 70 representative member dairy farmers in attendance. FrieslandCampina’s Members’ Council approved it “by a large majority.” No percentage appears in the joint release, in any subsequent coverage, or anywhere else in the public record. Approval thresholds were reported as two-thirds at FrieslandCampina and three-quarters at Milcobel. The merger took effect January 1, 2026, after EU Commission clearance in October 2025.

Unanimous among 70 delegates isn’t the same measurement as consensus among roughly 16,000 members. No farm-size breakdown of any of these votes is public — not at Fonterra, not at FrieslandCampina — so nobody outside those boardrooms can say which members’ preferences carried the day.

Two members isn’t a pattern, and we’re not calling it one. But it’s a fair question for any co-op to be able to answer:

Can a member raise a costed operational concern under their own name without weighing what it costs them?

Which is why the Fonterra landslides don’t settle anything. An 85% or 88% result measures agreement inside the electorate that earlier votes built. Weight the ballot by kilos and capital, and the room answers to whoever ships and finances the most milk.

Is the Cooperative Principle Itself Being Rewritten?

Here’s what almost nobody in the barn has seen yet. The International Cooperative Alliance’s 1995 Statement on the Cooperative Identity — the document that defines what a cooperative is — sets out Democratic Member Control as the second principle: “In primary co-operatives members have equal voting rights (one member, one vote) and co-operatives at other levels are also organised in a democratic manner.”

Note the escape hatch that’s been in the text since 1995. Federated and secondary cooperatives aren’t held to one-member-one-vote; they need only be “organised in a democratic manner.”

Now look at what the ICA circulated in a revised discussion draft dated June 9, 2026. The second principle becomes: “In primary co-operatives, members normally have equal voting rights (one member, one vote). Cooperatives at other levels and those with discrete classes of members are organised on a suitable democratic basis determined by their members.” (Emphasis added on “normally.”)

One word inserted. One clause added for “those with discrete classes of members.” If adopted, the wording would sit more comfortably alongside the volume-weighted structures FrieslandCampina and Fonterra already run. It’s a discussion draft, not adopted text. Worth watching.

The check still comes by the kilo. What changed is how loud your kilo talks in the room where the next merger gets decided.

Is Your Milk Price Statement Telling You What You Think It Is?

FrieslandCampina publishes a monthly integral milk price, and three consecutive months of 2026 show why any single month tells you very little. June: guaranteed price €41.50/100kg, integral price €45.21. July: guaranteed €41.25, integral €44.96. August: guaranteed €42.50, integral €46.21.

The mechanics matter more than the month. FrieslandCampina calculates monthly payment from the value of protein and fat in a fixed 5:4 ratio, referenced at 3.57% protein and 4.49% fat, excluding VAT. In August, the protein value rose to €593.41 per 100kg from €575.96 in July, and the fat value to €474.73 from €460.77. The integral figure then adds sustainability and quantum surcharges, plus a monthly seasonal bonus or discount set for the calendar year, which is why you can’t simply add a guaranteed price to a headline premium and expect to land on the published number.

Two things to carry to your own statement, whatever co-op you ship to. Separate the guaranteed or base price from the conditional premium. Then subtract the deductions that apply regardless of your score.

And check what you actually earn against the advertised ceiling. FrieslandCampina’s average Foqus planet sustainability premium paid was €2.63/100kg for the 2023 performance year, against a €3.50 maximum at the time — members captured 75% of the ceiling on average in 2023. The maximum has since risen to €4.00. We don’t have a current-year average to compare it to, so we can’t say whether that capture rate has improved or slipped.

Canadian producers are running the same exercise on a reweighting with a date on it. Farm Credit Canada’s 2026 Dairy Outlook puts it plainly: beginning in 2026, in both the P5 in eastern Canada and the Western Milk Pool, a greater dollar amount is placed on protein components. The Western boards have published their ratio — BC Milk, Alberta Milk, SaskMilk and Dairy Farmers of Manitoba move to 70% butterfat, 25% protein and 5% other solids effective April 1, 2026, up from 10% protein. FCC also notes Ontario butterfat composition has risen about 0.9% a year over the last six years. A decade of breeding toward fat, meeting a pool that’s rebalancing toward protein.

Processor network decisions land fast when they land — our reporting on what happened when AMPI’s Paynesville plant went dark is the closest North American parallel to what those two Belgian members described.

The 30/90/365-Day Playbook for Members Facing a Co-op Vote

30 Days — Urgent Checks

Pin Down Whether the Retention Payment Is Annual or One-Time

  • The Trap: €8/100kg for staying three years reads one way to a member and another way on a balance sheet. On 760,000 litres, that’s roughly €62,000 — or about €186,000 if it recurs annually.
  • Action: Written request to member relations asking for the payment clause verbatim. Look for two things: the words “annually” or “one-time,” and the volume basis the calculation runs on.
  • Trigger: You’ve already booked a loyalty or retention payment into a cash-flow projection without seeing that clause in writing.
  • Risk: Verbal confirmation from a field rep isn’t a contract term and won’t survive a dispute. And a one-time payment struck on cumulative three-year supply is a different number again from one struck on a single year.

Calculate Your Voting Weight in Kilograms

  • The Trap: Volume-weighted voting means your influence is arithmetic, not membership.
  • Action: Divide annual kilos shipped by your co-op’s per-vote threshold. FrieslandCampina’s is ten million kg at district level; Fonterra’s Share Standard runs one share per kg of milk solids.
  • Trigger: The threshold isn’t findable in published bylaws — that absence is your first phone call.
  • Risk: Your own figure may look small enough to dismiss. The point isn’t your weight; it’s which farm sizes the structure favours.

Run Your Butterfat-to-Protein Ratio Against the April 1 Reweighting

  • The Trap: If you ship into the Western Milk Pool and your last twelve months of components lean harder on fat than the new 70/25/5 split rewards, the change is a pay cut you can see coming.
  • Action: Pull your component averages from twelve months of statements. Compare your fat and protein percentages against your co-op’s current and post-April-1 weightings.
  • Trigger: Your protein percentage sitting flat or declining while butterfat climbs — the pattern FCC reports at roughly 0.9% a year in Ontario.
  • Risk: One year of data can hide seasonal swing. Use twelve months, not three.

90 Days — Structural Adjustments

Price Hauling Impact Against Plant Consolidation

  • The Trap: A 47-km reroute is a permanent deduction running against a temporary retention bonus.
  • Action: Multiply [round-trip km] × [hauling rate/km] × [loads/year] × 3. That’s the three-year figure the payment has to beat if it’s annual — triple it if the payment is one-time on a single year’s volume.
  • Net it out before you compare offers: Subtract that hauling total from the gross retention payment first. The number left over is what you’re actually being paid to stay — and it’s the only figure worth setting against a competing processor’s bid.
  • Trigger: Co-op communications citing “network optimization” or asset rationalization.
  • Risk: No public FrieslandCampina closure list was located, and co-ops rarely release them early. Model the worst-case distance now and rebuild when something official publishes.

Split Twelve Months of Statements Into Three Buckets

  • The Trap: A single blended milk price hides which portion you actually control.
  • Action: Separate base or guaranteed price, premiums you genuinely earned, and deductions taken regardless of performance. One year of statements, about an hour.
  • Trigger: Realized premium capture below 75% of the advertised maximum — the benchmark FrieslandCampina members hit in 2023.
  • Risk: Premium structures reset annually, so this is a yearly job, not a one-off.

Confirm Your Patronage Lag Before You Bank On It

  • The Trap: Patronage is real money on an unreal timeline.
  • Action: Ask member services when the last allocation was issued and which earnings year it covered.
  • Trigger: DFA’s September 2026 allocation covered 2012. A lag longer than you assumed means patronage doesn’t belong in near-term projections.
  • Risk: Allocation timing is a board decision, not a schedule. Don’t model it as recurring income.

365 Days — Strategic Positioning

Track Where New Capacity Lands Relative to Your Farm

  • The Signal: Announced capacity in your hauling radius, concentrated in a category your components already suit, is leverage in a supply conversation.
  • Action: Map announced projects against your shipping distance. IDFA reports more than $11 billion in U.S. capacity investment across 2025–2028 — cheese leading at $3.2 billion, yogurt and cultured at $2.81 billion, butter and powders at $1.6 billion.
  • Trigger: A new facility inside your current hauling radius serving a category you can hit on components.
  • Risk: Announced isn’t built. Industrial Info Resources counts 499 projects worth over $14.5 billion using a different methodology — don’t stack the two totals. Neither dataset separates co-op from investor-owned from foreign-owned.

Match Your Component Strategy to Where the Pool Is Moving

  • The Signal: The Top 20 is pivoting to protein, functional nutrition, and high-value ingredients. FrieslandCampina’s own formula already prices protein above fat at a fixed 5:4 ratio, and FCC reports both the P5 and the Western Milk Pool putting more dollars on protein beginning in 2026.
  • Action: Take your component averages and your co-op’s published strategy to your genetics conversation. Decide whether your sire selection points where the premium is heading.
  • Trigger: A component pricing ratio change with an effective date, or a public category commitment from your co-op.
  • Risk: Strategies rarely outlast breeding cycles. Build in the possibility of a pivot before you commit a sire lineup to it.

Decide Where You Want to Be Standing When the Farm Count Settles

  • The Signal: Consolidation trajectory and co-op governance math are two halves of the same question about your next decade.
  • Action: Read our projection on who’s still milking by 2035 against your own succession horizon.
  • Trigger: A succession decision, a major capital commitment, or a merger vote inside the next five years.
  • Risk: Projections are projections. Treat the direction as information and the dates as arguable.

What This Means for Your Operation

Four of the world’s ten biggest dairy companies answer to farmers, and scale genuinely strengthened those cooperatives’ balance sheets. S&P upgraded DFA to BBB+ in April 2026. A co-op with capital can build plants instead of stranding member milk behind an undercapitalized one, and that’s not a small thing to hold onto.

You gain that. What you give up is measured in voting weight and in multi-year commitments attached to payments whose structure isn’t publicly documented. Neither side of that trade is illegitimate. But only one side shows up on your milk cheque, and it isn’t the governance side.

Nine months after the merger took effect, no public document clarifies whether the €8 arrives once or three times, or what volume it’s struck on. If your co-op is currently courting a merger partner, don’t wait nine months past the vote to find out what the fine print meant.

So pull your own agreements this week. What do your co-op’s bylaws actually say about your voting weight if a merger doubles the milk pool around you — and does the retention or loyalty payment in your own contract specify “per year,” or just a number?

Key Takeaways

  • Get your retention clause in writing before you model a euro of it. Milcobel’s €8/100kg reads as roughly €62,000 on 760,000 litres — or about €186,000 if it recurs. Nobody’s published which, or what volume it’s struck on.
  • If your co-op weights votes by volume, your influence is arithmetic. FrieslandCampina runs one vote per ten million kilos of district milk, and the district count has gone 21 to 14 to 16 since 2009. Do the division on your own kilos.
  • Producer returns fell to $21.19/cwt while the Top 20 grew 5.4%. On 400 cows at the national 24,390-lb average, that’s about $133,657 — and DFA’s 7.5¢/cwt patronage covered 2012 earnings, so don’t book patronage as near-term cash.
  • Canada bought farmgate stability and pays for it on the balance sheet. Ontario quota caps at $24,000/kg while uncapped Alberta cleared $57,115, and DFO cancelled two exchanges in nine months.
  • Both Canadian pools are putting more money on protein starting in 2026, and the Western boards move to 25% protein weighting on April 1. If you’ve bred toward fat, pull twelve months of components before then.

Complete references and supporting documentation are available upon request by contacting the editorial team at editor@thebullvine.com.

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Canada’s Cheese Quota Filled 99% in 2024. Your DFO Exchange Filled Zero.

Three of four DFO exchanges have been cancelled since May. In May, 1,978 producers bid; eighteen had quota to sell. The tariff fight can’t reach your cheque. That can.

Executive Summary: Dairy Farmers of Ontario cancelled the May, July and August 2026 quota exchanges for insufficient quota offered — in May, 1,978 producers bid on 26,153.61 kg of butterfat while eighteen offered 138.39 kg, roughly $628 million in bids against $3.3 million of supply at the $24,000 cap. March cleared 190.60 kg against 25,628 kg bid, a 0.744% buyer success rate, which works out to about a tenth of a kilogram per bidder if it had spread evenly. Meanwhile Canada’s USMCA all-cheeses tariff-rate quota filled to 99% in 2024, so the 50% Section 338 tariff that landed Aug. 22 can’t push more cheese north — the fight is over who holds the import permits, not how much crosses. For P5 quota holders, that permit fight has no documented path to your milk cheque: the National Pricing Formula runs on cost of production and CPI, and cheese import rent isn’t an input, which means the $22.4–$34.4 million in duty that allocation holders skip accrues to processors and distributors, not producers. If expansion quota sits in your 2027 capital plan, that’s a financing-timing conversation with your lender now, not a spring problem. Watch Oct. 1, when Global Affairs Canada publishes the Notice to Importers for the 2027 cheese year — if eligibility still reads processor, further processor, distributor with retailers excluded, the rule rolls forward another year, and U.S. pressure hasn’t moved Ottawa.

DFO quota exchange

If you’re adjusting your 2027 expansion plans around U.S. cheese tariff headlines, you’re watching the wrong border.

Canada’s USMCA all-cheeses tariff-rate quota was filled to 99% in 2024, per Global Affairs Canada data published in USDA Foreign Agricultural Service’s Canada Dairy and Products Annual (Report CA2025-0038, Nov. 21, 2025). The 50% Section 338 tariff that hit Canadian goods at 12:01 a.m. on Aug. 22, 2026 won’t move more cheese north. There’s no room left.

This USMCA cheese quota dispute in dairy 2026 is a fight over import permits, not milk supply. For a P5 quota holder, that means it doesn’t reach your cheque — and it won’t soon.

Here’s what does reach you. Across the four monthly quota exchanges from May through August 2026, Dairy Farmers of Ontario cancelled three for insufficient quota offered for sale. In May, 1,978 producers placed bids on 26,153.61 kg of butterfat per day. Eighteen producers offered 138.39 kg. At the $24,000 cap, that’s roughly $628 million in bids against $3.3 million in available supply.

Three cancellations in four months. That’s your constraint. Not Washington.

What Three Cancelled DFO Exchanges Cost an Expanding Ontario Herd

Ontario and the other P5 provinces — Quebec, New Brunswick, Nova Scotia, PEI — cap quota at CA$24,000 per kilogram of butterfat per day. It is a provincial policy ceiling, not a market-clearing price, and not driven by import competition.

That cap has a history worth knowing. The P5 provinces built a quota pricing mechanism in December 2008 as values climbed. Ontario and Quebec capped at $25,000/kg in 2010, and Quebec cut its ceiling to $24,000 in February 2016 (Library of Parliament, Canada’s Supply Management System). The $24,000 figure now applies across all five P5 provinces, confirmed as current in DFO’s August 2025 markets report and again in Dairynomics, milkproducer.ca, Apr. 27, 2026. British Columbia sits outside the pool at $35,500 — proof the number is a policy choice, not market physics.

The March 19, 2026 exchange cleared, barely. DFO reported 1,908 producers bidding to buy against 18 offering to sell. Of 25,628 kg bid, 190.60 kg actually traded — a 0.744% average buyer success rate, DFO’s own figure, calculated on kilograms cleared rather than producers served. Everything traded at the cap.

Then May was cancelled under policy. June ran. July cancelled. August cancelled.

Running the Numbers

Start with what DFO published across three exchanges and work it two ways.

ExchangeProducers BiddingKg BidKg ClearedBuyer Success Rate
January 20261,82825,266.37250.100.734%
March 20261,90825,628.00190.600.744%
May 20261,97826,153.610 — Cancelled
July 20260 — Cancelled
August 20260 — Cancelled

DFO monthly quota exchange summaries. January figures from DFO’s posted summary dated Jan. 2, 2026; that exchange settled in phases, with 182.60 kg moving through allotment rounds and 2.50 kg through proration at 0.021%.

Run the arithmetic. March: 25,628 kg × $24,000 = $615.1 million in bids, chasing 190.60 kg × $24,000 = $4.57 million in quota. Divide cleared volume by bidders — 190.60 ÷ 1,908 = 0.0999 kg per bidder, if it had spread evenly. It didn’t; DFO allocates by allotment rounds first, then proration.

January was marginally better and still thin: 250.10 ÷ 1,828 = 0.137 kg per bidder.

Scale it to a herd. Ontario’s provincial average butterfat composition ran 4.4655 kg/hL in February 2026 (Dairynomics, Apr. 27, 2026). A herd needing one additional kilogram of butterfat per day faces $24,000 of capital at the cap, before financing. Two consecutive cleared exchanges would have delivered roughly a quarter of that kilogram to the average bidder.

Then May, July, and August delivered nothing at all.

So the practical math for an expanding Ontario operation isn’t a price question. It’s an availability question, and the answer was “no market” in three of those four months. Whatever your 2027 plan assumes about buying quota on the exchange, test it against a market that cleared 250 kg in January, 190 kg in March, and was cancelled three times between May and August.

[VISUAL: bar chart of cleared kilograms by month, January through August 2026, with cancelled months shown as zero bars against a flat line for total kilograms bid.]

Related reading: why new Ontario quota at 6% bleeds cash

Why the 42% Fill Rate Everyone’s Citing Describes the Wrong Quota

Now the trade fight, and why it’s the wrong thing to watch.

The number running through trade press — including The Bullvine’s own earlier coverage — is that Canada’s dairy TRQs sit badly underfilled. Roughly 42% across 14 categories. Something like $200 million in blocked access.

Real number. Also an aggregate, and aggregates bury things.

Trade AgreementAll Cheeses (2024 Fill)Industrial Cheese (2024 Fill)
USMCA (U.S.)99%59%
WTO95%
CETA (EU)95%79%
CPTPP98%1%

Global Affairs Canada data via USDA FAS Report CA2025-0038, Nov. 21, 2025. CPTPP mozzarella and prepared cheese filled 46% in the same year. Al Mussell at the C.D. Howe Institute found roughly 97–99% across all four systems for 2025 in an Aug. 18, 2026 working paper, drawing on the same GAC source.

Industrial cheese feeds further processing. It never hits a retail cooler. The Globe and Mail flagged the pattern on July 14, 2025, reporting 83% of the cheese-of-all-types allotment filled in 2024 — highest of any category.

Two things keep the correction honest. Fill rates were genuinely low in earlier periods — Dairy Farmers of Canada’s own Quarterly Skim put CETA cheese at 43% as of July 31, 2022. And the composite spans categories that behave nothing alike, from CPTPP industrial cheese at 1% to USMCA all-cheeses at 99%. The aggregate measured something true in its year, then traveled into a conversation about retail cheese where it doesn’t apply.

Related reading: the $200M access gap is worth a nickel

What Is the U.S. Actually Asking For in the CUSMA Cheese Quota Dispute?

Eligibility. Not volume.

USMCA allocations go to Canadian processors, further processors, and distributors, awarded on historical market share from the prior Oct. 1–Sept. 30 reference period. The Notice to Importers puts it plainly, as reproduced in the panel record: “Retailers are not eligible for an allocation.”

CETA runs differently. USDA FAS documents a 50/50 split — dairy processors, about 45 companies, on one side; distributors and retailers, about 175 companies, on the other. Within each class, 30% of volume goes to small and medium companies, 20% to large ones.

Read that second class carefully. Distributors and retailers together hold half the CETA all-cheeses quota, and FAS doesn’t separate the two. So the defensible framing is that CETA admits retailers to a class worth half the quota while USMCA bars them outright. How much of that half lands with grocers rather than distributors isn’t in the public data, and the proclamation’s discrimination argument is only as strong as that unpublished number.

That asymmetry is what the July 20, 2026 proclamation is built on.

The most useful voice here belongs to someone already inside the system. Joe Dal Ferro runs Finica Food Specialties in Mississauga and chairs the International Cheese Council of Canada. Finica appears on Global Affairs Canada’s 2026 CETA Cheese of All Types quota holders list, published Jan. 26, 2026 — so he holds quota under a system he’s arguing should admit more competitors. He’s given his reasons publicly and consistently: fairness, consumer variety, and free-market principle.

“This is unfair and goes against the spirit of the trade agreement and free market economics,” Dal Ferro told the Globe and Mail on July 14, 2025, speaking as ICCC chair. Processors holding quota, he said in that same reporting, “are not interested in providing variety to the Canadian consumer.”

Dairy Farmers of Canada reads it differently. As the tariff deadline approached, DFC warned publicly against further concessions on dairy market access, arguing food sovereignty shouldn’t be traded away — reported by CityNews Edmonton on Aug. 6, 2026. Two Canadian industry bodies, opposite conclusions, both on the record.

Dal Ferro walked through the mechanics for Grocery Business on Mar. 20, 2025. “The Canadian government allocates quotas for importers to bring in American cheese. So if an importer is a holder of quotas, there is zero duty on the cheese. It’s only when an importer goes over the quota access or if an importer is not a holder of a quota for cheeses from the US that you then pay the 245% tariff.”

His number checks out, and the schedule is harsher than a single percentage suggests. Canada’s Customs Tariff sets the over-access rate for heading 04.06 at 245.5%, with a per-kilogram floor varying by cheese type — not less than $3.58/kg on grated cheddar, $4.52/kg on fresh cheese, $5.08/kg on Parmesan and Provolone types, $5.33/kg on blue-veined, $5.50/kg on Brie types. Global Affairs Canada’s WTO cheese notice confirms it: ship without a specific import permit, and you’re classified at 245.5% plus the floor.

That floor is why Dal Ferro called over-quota transactions “nearly impossible.” On premium product, the minimum duty alone can run past the cheese’s landed value.

State his position plainly. Dal Ferro chairs an importers’ association. The ICCC filed its submission in the CPTPP cheese TRQ dispute on May 19, 2023, under his name as chair. His members gain from broader access. That doesn’t make him wrong — it makes him a party with an interest, which isn’t the same as a neutral analyst.

Who Actually Has Skin in This Game, If Not the Farm

Exposure sits one layer above the barn, and it’s quantifiable.

Holding a permit is worth money because it lets you skip costs. Import cheese with an allocation and you pay nothing. Import the same cheese without one and you pay 245.5% plus the floor. That gap, multiplied by volume, is the import rent — and it lands on whoever holds the paper.

Two of three inputs are solid. Volume: USMCA all-cheeses access for 2026 is 6,313 tonnes, rising to 7,113 by 2038 (USDA FAS, CA2025-0038). At the 99% fill recorded in 2024, roughly 6,250 tonnes enter duty-free. Rate: 245.5% with those per-kilogram floors.

Landed cost per tonne is the missing term — Statistics Canada and GAC report volume and value at aggregate levels that don’t isolate USMCA-permit cheese.

Bracket it with the floors instead. Grated cheddar carries a minimum over-access duty of $3.58/kg, or $3,580 per tonne before the ad valorem calculation applies at all. Across 6,250 tonnes, that’s about $22.4 million in duty avoided at the low end. On Brie types at $5.50/kg, roughly $34.4 million. Product mix decides where inside that band the real number sits, and the 245.5% component pushes it higher wherever landed value clears the floor.

Floor estimate, not the rent. True rent is larger and unknowable from public sources.

That $22.4–$34.4 million band is what allocation holders collectively don’t pay. It accrues to processors and distributors. Not to producers.

The wider trade at stake is modest. Canadian cheese exports to the U.S. run around US$80 million, Canadian imports of U.S. dairy products around US$400 million, per Mussell’s Aug. 18, 2026 analysis — recent annual figures, no single year specified, and the US$400 million covers dairy broadly rather than cheese alone. The Section 338 dairy proclamation covers 52 HTSUS subheadings representing US$97.2 million of 2024 imports, per White & Case analysis dated July 24, 2026, cited by Peacock Tariff Consulting on Aug. 5, 2026.

The U.S. is already Canada’s second-largest cheese supplier by volume. January through August 2025: 14,196 tonnes, 36.3% of total Canadian cheese imports, up 6.8% year over year. EU-27 held 49.7% at 19,392 tonnes. Total imports: 39,055 tonnes, up 8.7% — Trade Data Monitor figures via USDA FAS.

And the roster of permit holders is about to shift. Lactalis Canada announced a definitive agreement on July 15, 2026, to acquire Agropur Cooperative’s fine cheese division — the OKA, Monsieur Gustav and L’Extra brands, two production facilities at Oka and Saint-Hyacinthe, roughly 400 workers, and Agropur’s fine cheese import activities. CBC reported the division generates roughly $200 million annually. Financial terms weren’t disclosed.

The deal hasn’t closed. Both companies confirmed the transaction remains subject to customary closing conditions and approval by Competition Bureau Canada. Lactalis described it as adding to a portfolio that already includes Galbani, Président, Cracker Barrel, Black Diamond and P’tit Québec, and nothing in the public record links it to the trade action.

What matters either way: if it clears, the companies holding cheese import rights change — and 2027 allocations get calculated on market share from a reference period that includes this transition.

Why the Trade Fight Can’t Reach Your Milk Cheque

Mussell’s answer is no, and the reasoning runs through the pricing formula.

He concludes there’s no direct mechanism for reduced processor margins to lower raw milk prices. USDA FAS documents why the structure blocks it: Canadian milk component prices are set by the National Pricing Formula — “50 percent based on changes in the cost of production and 50 percent on changes in the Consumer Price Index” — determined at year-end and effective Feb. 1.

Cost of production and CPI. Cheese import rent isn’t an input. A processor losing import margin has no channel to push it down.

Not everyone frames access that way. The Canadian Centre for Policy Alternatives estimated on May 25, 2026, that CUSMA represents an annual loss to domestic producers equivalent to 8.4% of milk production — an argument that market access carries real producer cost even where no line-item mechanism exists. Mussell’s point is narrower and mechanical: this particular permit fight has no documented path to your cheque.

Three scenarios, one outcome where it counts:

VariableRetailer Access ShiftStatus Quo HoldsDFO Exchange Freeze
Permit rent ($22.4–$34.4M band)Shifts toward grocersAccrues to processors and distributorsIrrelevant to trade file
Processor marginCompression, unquantifiedStableNo effect
Farm-gate milk priceZero documented mechanismZero documented mechanismZero documented mechanism
P5 quota valueZero documented mechanismZero documented mechanismCapped at $24,000/kg, unmoved
Exchange quota availabilityUnaffectedUnaffectedNone — 3 of 4 months, May–Aug 2026

Read the bottom two rows. Both trade columns are empty where it matters to you, and the third column is the only one with a number attached. Note what that last row does and doesn’t say: the exchange quota was unavailable. Incentive days, component strategy, and productivity gains per cow stayed open the whole time.

Here’s the farm-side calculation, in words, because one input is structurally absent:

(processor margin change from an eligibility shift) × (pass-through rate to the National Pricing Formula) × (quota capitalization multiple) = quota value effect per kg BF

The middle term breaks the chain. The NPF runs on cost of production and CPI, so the pass-through rate is zero and zeroes the product. Any other figure needs an assumption that no published source supports.

There’s no herd-scoped version of this particular calculation, and that absence is the finding rather than a gap in the reporting. Anyone publishing a per-cwt or per-kilogram farm impact from the trade dispute is filling that hole with a guess. The DFO exchange math earlier in this piece is different — that’s real, published, and it’s the number that touches your balance sheet.

Where the permit actually travels

StageUnder USMCAUnder CETA
Import right issuedGlobal Affairs CanadaGlobal Affairs Canada
Allocation basisHistorical market share, Oct. 1–Sept. 3050/50 processor vs. distributor-retailer class
ProcessorEligibleEligible (~45 companies)
Further processorEligibleEligible
DistributorEligibleEligible (~175 companies with retailers)
RetailerBlockedEligible
Retail shelfReached via processor or distributorReached directly or via distributor

That single blocked row is the entire basis of the July 20 proclamation.

The Statutory Problem Two Georgetown Scholars Raised

Section 338 of the Tariff Act of 1930, at 19 U.S.C. § 1338, permits duties up to 50% where the President finds a country “discriminates in fact against the commerce of the United States… in such manner as to place the commerce of the United States at a disadvantage compared with the commerce of any foreign country.”

July 20, 2026 was the first invocation in 96 years, per White & Case’s July 24, 2026 analysis.

Why this matters for the Oct. 1 notice: two tribunals have already ruled, and neither left Ottawa under any treaty obligation to change eligibility.

The treaty record

  • December 2021, USMCA panel — found Canada’s practice of reserving 85–100% of dairy TRQ pools for processors inconsistent with CUSMA. Canada revised.
  • Nov. 10, 2023, second USMCA panel — report issued, public Nov. 24. Split 2-1 on the retailer question specifically.
  • Per USTR’s own release: “Two of the three panelists found that Canada’s measures do not breach any of the USMCA commitments that the United States cited. One panelist, however, agreed with a principal U.S. claim challenging Canada’s narrow definition of eligible applicants.” The dissenter “agreed with the United States that by excluding retailers and others, Canada was breaching its commitment to make its dairy TRQs available to all applicants active in the Canadian food or agriculture sector.”
  • Global Affairs Canada’s record: the panel “ruled in Canada’s favour on all claims,” and Canada “is not required to make any changes.” CUSMA provides no appeal.
  • New Zealand’s CPTPP challenge — per Agriculture and Agri-Food Canada’s question-period note, the panel found against Canada on 2 of 6 claims: Canada violated its obligation to let importers “utilize TRQ quantities fully,” and processor-reserved pools violated the obligation not to “limit access to an allocation to processors.” On retailers, the majority held that “Canada’s exclusion of retailers from TRQ eligibility falls within Canada’s discretion.”
  • Canada’s response to that ruling: it was “very pleased” the panel “recognized that Canada has a margin of discretion in setting its TRQ allocation policies, including determining who is eligible.”

Washington’s claim against that record

One arbitrator of three agreed with the U.S. core complaint. A one-vote margin on the retailer question — and that’s the foundation for invoking a statute untouched since 1930.

The legal vulnerability

Georgetown scholars Peter Harrell and Jennifer Hillman published a critique on Aug. 3, 2026 via the Volokh Conspiracy at Reason. Three arguments, each narrow:

  • The comparative-language problem. Canada applies the processor-and-distributor restriction to every trading partner except the EU. Treatment identical to nearly every other country isn’t discrimination against the United States under the statute’s own wording. “Canada’s dairy practices do not treat American goods differently than those from ‘every foreign country,'” they wrote.
  • The self-negotiation problem. “It is incongruous, to say the least, for the United States to denounce as discriminatory the very terms it agreed to.” The U.S. negotiated those terms. Congress approved them.
  • The procedural gap. No evidence shows the International Trade Commission conducted fact-finding before the proclamations, despite Section 338(g) assigning that duty to the ITC’s predecessor. Peacock Tariff Consulting reported on Aug. 5, 2026, that the Congressional Research Service raised the same point independently.

What it means for your October read

Ottawa won twice, faces no appeal, and holds a documented margin of discretion on eligibility. Nothing in the treaty record compels a change.

Negotiation is the other channel, and it’s live. Talks collapsed Aug. 21, tariffs took effect Aug. 22, and Canadian counter-tariffs land Sept. 8. Eligibility could still move as a bargaining concession regardless of what two tribunals held — so the question isn’t whether litigation forced Ottawa’s hand. It’s whether pressure does what litigation couldn’t. No legal outcome is asserted here; the litigation is live.

The 30/90/365-Day Playbook for P5 Quota Holders

Every outlet will run the retaliation countdown. Canada’s counter-tariffs take effect Sept. 8, 2026, per CBC and ABC7 News reporting from Aug. 21. Real event. Doesn’t touch quota eligibility, and doesn’t touch your exchange.

Cheese TRQs run on the calendar year, separate from the August-start dairy year governing butter and milk powders. Per Global Affairs Canada’s “Key dates and access quantities 2026-2027”:

  • 2027 cheese TRQ application window opens Oct. 1, 2026
  • Application deadline: Nov. 15, 2026
  • Market-share reference period: Oct. 1, 2025 to Sept. 30, 2026 — closes Sept. 30
  • USMCA all-cheeses 2026 access: 6,313 tonnes
  • Unused USMCA cheese quota return deadline: Sept. 1

30-Day Actions

  • Pull the last four DFO exchange summaries and count cleared kilograms, not bids. Requires ten minutes in DFO’s quota exchange archive.
  • Red-flag trigger: if expansion quota sits in your 2027 capital plan and three of the last four exchanges cleared nothing, that’s a financing-timing decision now, not a spring problem. Talk to your lender before the next exchange, not after.
  • Read the Notice to Importers published with the Oct. 1 window. One thing to check: whether eligibility still reads processor, further processor, distributor, retailers excluded.
  • Where it backfires: treating the trade file as a milk-price signal. The National Pricing Formula has no input for it. Don’t reprice your risk off a document that can’t reach your cheque.

90-Day Actions

  • Re-run your expansion model against quota availability rather than quota price. Requires your production data, your lender’s amortization assumptions, and DFO’s cleared-volume history. The $24,000 cap has held since Quebec’s 2016 reduction and applies across all five P5 provinces; the supply behind it doesn’t hold.
  • If you ship to a processor holding USMCA or CETA cheese allocations, ask at the next producer meeting whether import activity is material to plant margin. Requires a direct question and a processor willing to answer.
  • Threshold: if your plant supplies or competes with Agropur’s fine cheese lines, watch the Competition Bureau file. That review determines whether those import activities move to Lactalis and when.
  • Where it backfires: consolidation moves faster than producer meetings, and a pending deal isn’t closed. Don’t restructure anything on an announcement.

365-Day Moves

  • Decide whether your growth plan depends on exchange quota at all. Requires an honest look at incentive days, component strategy, and whether added butterfat per cow beats added kilograms you can’t buy. The P5 boards approved payment policy changes effective April 1, 2026, to increase protein production — that’s a lever that doesn’t require an exchange.
  • Opportunity signal: if DFO exchanges resume clearing volume for three consecutive months while your margin over feed holds, that’s the window to move on quota you’ve been unable to source.
  • Watch whether Canada touches eligibility or only mechanics. Following the July 2025 New Zealand settlement, GAC moved the CPTPP calendar-year return date to May 1, added a chronic-return penalty at returns above 30% of allocation for two consecutive years, and introduced an underfill mechanism switching TRQs below 60% utilization for three straight years from market share to on-demand allocation. Every one of those hit administration. None hit eligibility.

Related reading: nickel versus $3M risk on both sides of the border

Key Takeaways

  • Canada’s USMCA cheese quota filled 99% in 2024, so the 50% tariff can’t push more product north. The fight is over who holds the permits, and under the National Pricing Formula, that fight has no documented path to your milk cheque.
  • Your real constraint is the DFO exchange. May, July, and August 2026 were all cancelled for insufficient quota offered — in May, 1,978 producers bid against 18 sellers, $628 million chasing $3.3 million at the $24,000 cap.
  • March cleared 190.60 kg out of 25,628 kg bid, a 0.744% buyer success rate. If expansion quota sits in your 2027 plan, that’s a lender conversation now, not a spring problem.
  • Watch Oct. 1, when Global Affairs Canada posts the Notice to Importers for the 2027 cheese year. If eligibility still reads processor, further processor, distributor, with retailers excluded, nothing moves, and the rule rolls forward another year.

What’s Actually Constraining Your 2027 Plan

Dal Ferro has made the same argument in a parliamentary committee appearance in March 2023, the ICCC’s CPTPP filing in May 2023, a trade-press interview in March 2025, and the Globe and Mail in July 2025. Four appearances, one position. Dairy Farmers of Canada has spent the same period arguing the opposite. The eligibility rule either changes in the Oct. 1 notice or it doesn’t — and the reference period that decides who gets what closes Sept. 30.

The insulation cuts both ways. Canada’s pricing formula keeps a trade fight from reaching your cheque, which is protection. It also means no upside flows to you if U.S. access tightens and domestic processors capture more of the market. Shielded from the loss, cut out of the gain.

Meanwhile, 1,978 producers bid on quota in May and got a cancellation notice. Same in July. Same in August.

So run the check that matters. Pull your last four DFO exchange summaries and add up the kilograms that actually cleared — not the kilograms bid. If your 2027 expansion plan assumes you can buy quota on that exchange, what does the cleared-volume history say about when, and how much? 

Complete references and supporting documentation are available upon request by contacting the editorial team at editor@thebullvine.com.

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