USDA dairy checklist, row by row

The APHIS permit and the government veterinary certificate on a milk product's checklist, the question that decides which applies, and how to record each.

Every row of a product's USDA dairy checklist, in the order the checklist shows them, with the regulation's full wording, who does the work, when it applies and each way to record it. The checklist itself keeps only the row's name, its citation and the buttons to record it.

INFO: USDA's animal-health agency (APHIS) checks imported milk products for foot-and-mouth disease; only cheese, butter and butteroil are exempt. Which paper you need depends on where the milk came from — answer the question on each row. Aleph does not decide a country's disease status: APHIS's list does. This is not a USDA dairy import licence.

APHIS permit, received before importing (9 CFR 94.16(b)(3), for each product). Milk and milk products of ruminants and swine originating in, or shipped from, a region where APHIS considers foot-and-mouth disease to exist may be imported only if "the importer first applies to and receives written permission from the Administrator" of APHIS (9 CFR 94.2(b), 94.16(b)(3)). APHIS considers the disease to exist in every region it has not declared free (94.1(a)). This also covers a product made in a free region from milk produced in a region that is not (94.16(d)). Cheese, butter and butteroil are exempt (94.16(a)); shelf-stable concentrated liquid, and dry milk sent to an APHIS-approved establishment, have their own routes (94.16(b)(1)–(2)).

Whose work it is: You, the importer, apply to APHIS for the permit before the product ships. Upload it here with its expiry date.

Applies only when (9 CFR 94.2(b)): Was any of the milk in this product — including cream, milk powder or other milk ingredients — produced in, or was the product processed in or shipped from, a region that is NOT on APHIS's list of regions free of foot-and-mouth disease? APHIS treats every region not on that list as affected (9 CFR 94.1(a)). Check the list: https://www.aphis.usda.gov/animalhealth/disease-status-of-regions

Ways to meet it (any one):

  • The APHIS permit on file — upload one of: Import Permit.
  • Exempt, or another route in 94.16 — Confirm this product is exempt (cheese, butter or butteroil — 9 CFR 94.16(a)) or enters under 94.16(b)(1) (concentrated liquid, heat-processed in a hermetically sealed container, shelf stable without refrigeration) or 94.16(b)(2) (dry milk consigned to an APHIS-approved establishment), and say which. Your note is the record, so it is required.

Source: 9 CFR 94.16(b)(3) — 9 CFR part 94 (USDA APHIS), eCFR issue 2026-10-20 — §§ 94.1(a), 94.2(b) and 94.16 read verbatim. §94.16: 40 FR 44123, Sept. 25, 1975, as amended.. Read 2026-10-22.

Government veterinarian's certificate with each shipment (9 CFR 94.16(d), for each product). Except for milk products imported from Canada, a milk product imported from a region APHIS lists as free of foot-and-mouth disease "must be accompanied by a certificate endorsed by a full-time, salaried veterinarian employed by the region of export." The certificate names the region where the milk was produced and the region where the product was processed, and states that the product has never been in a region where the disease exists, except when moved under seal (9 CFR 94.16(d)). Every shipment needs its own. A shipment that passes through a region where the disease exists must also travel under serially numbered official seals (94.16(c)).

Whose work it is: Your exporter gets it from their government's veterinary service for every shipment. Upload one here to keep a copy.

Applies only when (9 CFR 94.16(d)): Is this product imported from somewhere other than Canada? Milk products imported from Canada need no veterinary certificate (9 CFR 94.16(d)).

How it is met:

  • A shipment's certificate on file — upload one of: Government Veterinary Certificate (milk products).

Source: 9 CFR 94.16(d) — 9 CFR part 94 (USDA APHIS), eCFR issue 2026-10-20 — §§ 94.1(a), 94.2(b) and 94.16 read verbatim. §94.16: 40 FR 44123, Sept. 25, 1975, as amended.. Read 2026-10-22.

Egg in the product — check whether APHIS needs a permit (9 CFR 94.6(c), for each product). APHIS restricts eggs (other than hatching eggs) of poultry and other birds that were laid in, are imported from, or pass through a region where Newcastle disease or highly pathogenic avian influenza is considered to exist (9 CFR 94.6(c)). Eggs that "have been cooked or processed" may be imported only when APHIS determines they will not introduce those diseases, and "must be accompanied by a permit obtained from APHIS prior to the importation" (94.6(c)(4)). APHIS keeps its lists of those regions on its website (94.6(a)). The regulation does not say whether this reaches egg already inside a finished food such as ice cream, so this product may need an APHIS permit — check with APHIS or your broker.

Whose work it is: Ask APHIS (its VS Permitting Assistant) or your customs broker, and record the answer here.

Applies only when (9 CFR 94.6(c)): Does this product contain egg (for example egg yolk)?

How it is met:

  • Checked with APHIS or the broker — Record what APHIS or your broker told you about the egg in this product — for example a permit number, or that no permit is needed and who said so. Your note is the record, so it is required.

Source: 9 CFR 94.6(c) — 9 CFR part 94 (USDA APHIS), eCFR issue 2026-10-20 — § 94.6(a) and (c) (39 FR 39546, Nov. 8, 1974, as amended) read verbatim.. Read 2026-10-22.

Gelatin in the product — check APHIS's gelatin rules (9 CFR 94.23(e), for each product). Gelatin derived from bovines may be imported only if it meets the source and processing conditions in 9 CFR 94.23(b)–(d) and is "accompanied to the United States by an original certificate signed by a full-time salaried veterinary officer of the national government of the exporting region" (94.23(e)), or under an APHIS permit (94.23(f)). Gelatin derived from horses, swine or non-bovine ruminants "must be accompanied at the time of importation into the United States by an official certificate issued by a veterinarian employed by the national government of the region of origin," stating the species (94.26). The regulation does not say whether these reach gelatin already inside a finished food, so this product may need an APHIS permit — check with APHIS or your broker. Depending on the gelatin's source, a veterinary certificate may be the route instead.

Whose work it is: Ask your supplier which animal the gelatin comes from, then ask APHIS or your customs broker, and record the answer here.

Applies only when (9 CFR 94.23(a)): Does this product contain gelatin?

How it is met:

  • Checked with APHIS or the broker — Record which animal the gelatin comes from and what APHIS or your broker told you — for example a permit or certificate, or that none is needed and who said so. Your note is the record, so it is required.

Source: 9 CFR 94.23(e) — 9 CFR part 94 (USDA APHIS), eCFR issue 2026-10-20 — § 94.23 (78 FR 72999, Dec. 4, 2013, as amended) and § 94.26 (86 FR 68862, Dec. 3, 2021) read verbatim.. Read 2026-10-22.

NOP Import Certificate for each shipment (7 CFR 205.273(d), for each product). "Each shipment of organic agricultural products imported into the United States must be certified pursuant to subpart E of this part, labeled pursuant to subpart D of this part, be declared as organic to U.S. Customs and Border Protection, and be associated with valid NOP Import Certificate data" (7 CFR 205.273). The exporter requests the certificate from a certifying agent before export, and the agent issues it through the Organic Integrity Database (205.273(a)–(b)). On receiving the shipment, the organic importer must ensure it is accompanied by accurate NOP Import Certificate data (205.273(d)). An operation that handles — which includes importing — products sold, labeled or represented as organic must itself be certified, unless exempt (205.100(a), 205.101; "handle", 205.2).

Whose work it is: Your exporter asks its certifying agent for the certificate before each shipment, and its data goes into the customs entry. Upload a copy here.

Applies only when (7 CFR 205.100(a)): Is this product sold, labeled or represented as organic?

How it is met:

  • A shipment's NOP Import Certificate on file — upload one of: NOP Import Certificate for organic products.

Source: 7 CFR 205.273(d) — 7 CFR part 205 (USDA National Organic Program), eCFR issue 2026-10-20 — § 205.273 (88 FR 3622, Jan. 19, 2023), § 205.100(a) and the definition of "handle" in § 205.2 read verbatim.. Read 2026-10-22.

INFO: This lists what the checklist records. It is not legal advice, and a row recorded in Aleph is not a finding that the product complies.