By SHERRY BUNTING
Special for Farmshine
The checkoff’s first sustainability report on 2050 net-zero goals says U.S. dairy is making “environmental progress,” but many farmers see something else unfolding.
They see a growing system of effectively mandatory — not voluntary — farm data collection, greenhouse gas (GHG) emissions tracking, baseline setting, cradle-to-processor-gate lifecycle assessment, benchmarking, and supply-chain governance built with the mandatory dollars they paid through checkoff.
The 2023-24 U.S. Dairy Sustainability Report published by Dairy Management Inc. (DMI) and its Innovation Center for U.S. Dairy at the end of 2025 outlines how processors, cooperatives, retailers, brands, researchers, and environmental NGOs are coordinating sustainability reporting across the dairy supply chain.
It says companies representing 77% of U.S. milk production are now part of DMI’s Stewardship Commitment. It is voluntary for processors and co-ops to sign on, but once they do, compliance pressure moves down to the dairy farmers supplying the milk.
This system was not built overnight. In December of 2009, DMI created the Innovation Center as a 501(c)(6) under the legal tax name Dairy Center for Strategic Innovation and Collaboration Inc. — years before Scope 3 climate reporting became a thing, and more than a decade before “net-zero.”
What began at that time is described as “precompetitive” coordination — bringing those entities together to build sustainability goals, metrics and reporting systems.
The dairy industry was not simply swept into the Scope 3 movement by outside forces or overseas customers. The checkoff program facilitated the early architecture that ushered in the supply-chain climate reporting now requiring farm-level emissions tracking for dairy farms when their milk buyer adopts FARM ES.
This and more are spelled out in the U.S. Dairy Stewardship Commitment Handbook for processors published by DMI’s Innovation Center in Jan. 2026, while the Sustainability Report shows FARM Environmental Stewardship (ES) as the vehicle for the data collection and tracking tied to DMI’s net-zero goals.
Dairy farmers care about the environment and always look for ways to improve and do more with less, but many did not expect their checkoff dollars to build a sustainability governance system requiring them to hand over detailed data for emissions baselines and future expectations about how their farms operate.
For years, farmers were told net zero (or GHG neutrality) was voluntary, but as processors and cooperatives adopt FARM ES, the pressure to comply lands at the farm gate. Many farmers feel they are being asked to finance and comply with a system they never knowingly voted to build.
One Wisconsin dairy farmer, Abby Swan, known as @DevaCowlover on X, has posted videos questioning the “voluntary” nature of the data collection and the checkoff’s role. Her concerns drew enough attention that USDA Secretary Brooke Rollins met with her during a Wisconsin visit in early May.
A March survey by the American Dairy Coalition found that Abby is not alone. Many farmers fear losing milk market access if they do not provide the detailed information. Some said they were told the reporting will be required to sell milk or that “any pushback will be met with punishment.” In some cases, data collectors wanted direct access to herd management software like DairyComp.
That leaves some basic questions: What does “voluntary” really mean? Who owns the farm data? Who can access it? How will it be used? Could individual farm baselines affect milk payment, loans, insurance, or market access?
As sustainability metrics become embedded into milk procurement and supplier scorecards, critics worry the system will increasingly reward scale, standardization, and centralized supply chains while reducing room for independent production styles or regional differences.
The Sustainability Report repeatedly emphasizes benchmarking, lifecycle assessment, reporting systems, and “shared accountability” across the dairy supply chain. DMI even asked USDA in April to collect more detailed herd, feed, manure, cropping, soil, and water-use data from individual dairy farms and report it at the county level to improve their sustainability modeling and emissions estimates.
Supporters say the checkoff positioned dairy ahead of future market demands and protected the industry from fragmented outside regulation. Critics argue it instead normalized the supply-chain leverage systems now pressuring farms to comply.
Programs such as FARM ES, sustainability scorecards, lifecycle accounting, and processor climate commitments evolved from nearly two decades of coordinated strategy tied to the same “market transformation” and “supply-chain leverage” model promoted globally by NGOs like the World Wildlife Fund (WWF Fig. 1).
In fact, the checkoff’s early partnership with WWF launched the Innovation Center. This was confirmed by former DMI CEO Tom Gallagher, who acknowledged during a 2020 teleconference with dairy farmers that DMI had a 10-year memorandum of understanding with WWF until 2019.
During that decade, WWF worked with the Innovation Center on sustainability goals, precompetitive coordination using the supply-chain leverage strategy (Fig. 1) and development of the GHG calculator for FARM ES.
USDA oversees all checkoff programs, and much of this coordination now reshaping dairy was built during the three terms of former USDA Secretary Tom Vilsack, spanning 2009 to 2024 and interrupted only by his four years as a top-paid dairy checkoff executive (2017-20).
Fast-forward to 2026: The ESG and Scope 3 movement is already losing momentum politically and economically, yet the checkoff-funded dairy sustainability infrastructure continues to accelerate, raising concerns the industry is moving toward a European-green-deal compliance model.
Supporters say this is needed to satisfy global customers and protect exports, which now account for more than 20% of U.S. milk production. However, if this reporting is so valuable, why are U.S. cheese and butter prices 40% to 70% below the global index? Low U.S. prices move exports overseas — not emissions reporting systems.
In fact, even Europe is reassessing and softening parts of its climate reporting rollout due to political, legal, and economic pushback with evidence that concerns over competitiveness are emerging.
Serious questions are also being raised about the GHG science itself. While some scientists compare cows to tailpipes, others note cattle are part of a natural cycle that turns vegetation people cannot eat into nutrient-dense food. Without cattle, vegetation still rots or burns and releases emissions — just without the food production benefit cows provide.
Scientists also describe methane as a short-term gas that breaks down over time, not a long-term gas that continually accumulates, and they argue cattle recycle existing carbon. However, the Sustainability Report uses the “tailpipe” metric even though scientists developed another method specifically to measure livestock methane differently.
That raises another big question: Should mandatory checkoff dollars be used to build sustainability governance systems based on disputed tailpipe-style climate science that require farmers to hand over detailed data with little clarity about what comes next?
From emissions estimates and baselines to reporting and compliance, none of this is free. The costs are borne by farmers and consumers.
At the same time, the agricultural data being collected has marketplace value to processors, global food giants, and foreign-owned companies building a detailed picture of American dairy and agricultural infrastructure, shifting even more market power and leverage away from farms while they receive no compensation for providing their piece of the data-set.
Years ago, some farmers challenged the constitutionality of the checkoff in court, arguing they should not be forced to fund speech they disagreed with or that goes against their interests. Those cases were ultimately decided on the basis that checkoff speech is government speech. Yet government messaging today on cows, methane, climate, sustainability, and farm data collection is anything but clear.
So, whose speech are farmers paying for? Whose agenda did they unwittingly fund the architecture for? Who really controls the system built with farmer data and farmer money?
And who truly benefits… Probably not consumers, because all these layers add cost and complexity; probably not farmers, even though they appear to be footing the bill; and least of all the cows, because they were never the problem.
Food for thought: It has been mentioned that Artificial Intelligence plays a role in the emissions modeling and estimating. Maybe the GHG emissions and water usage of computing all of this should be data-collected, baselined, benchmarked, and lifecycle-assessed while the cows keep doing what they’ve always done, only better and better every year because of dairy farmers, not Dairy FARM ES.
