Dairy farmers across the country are increasingly being asked to provide detailed operational data to cooperatives, proprietary processors and supply-chain partners for sustainability and Scope 3 greenhouse gas (GHG) reporting. These requests can include herd records, feed and manure data, cropping practices, energy use, fuel consumption and other aspects of farm business management.
Many farmers say these requests are time-consuming and involve sensitive business information. This is occurring even though federal agencies, including U.S. Securities and Exchange Commission (SEC) and the EPA under both the Biden and Trump administrations stepped back from Scope 3 requirements, citing concerns that they are outside a company's direct control, controversial and difficult to regulate and verify.
Farmers contacting the American Dairy Coalition (ADC) say programs tied to the dairy checkoff program's Innovation Center for U.S. Dairy and Net Zero Initiative through the FARM ES program appear to be expanding beyond their original voluntary intent. These efforts aim for net-zero emissions by 2050. However, farmers report that once processors and supply-chain partners adopt these programs, participation becomes effectively required for those marketing milk. Today, more than 80% of U.S. milk production is represented by cooperatives and plants enrolled in FARM.
At the same time, farmers point to ongoing scientific debate about how methane is measured. They emphasize that dairy cattle are part of a natural cycle, not a one-way new emissions source, and say measurement methods should reflect that difference.
To better understand these concerns, ADC conducted an anonymous survey of members and non-member producers across key dairy regions from Feb. 24 through March 14. Responses came mainly from the Upper Midwest (with 70% of responses from Wisconsin) as well as the Northeast/Mid-Atlantic region. The results show widespread concern about how farm data is being requested, handled and used.
A majority of respondents (72%) said they have been asked to provide detailed farm-level data, while 77% said participation is not truly voluntary in practice.
Farmers described varying levels of pressure: 25% said requests were “strongly encouraged,” 32% said they were told participation is required to sell milk, and 20% reported concern about penalties or loss of contract.
At the same time, 87% said they did not believe they signed a data-sharing agreement, and another 13% were unsure – pointing to a lack of clarity and informed consent.
Concerns about trust and fairness are also significant: 80% of respondents said they do not trust their data is secure, and 92% reported receiving no compensation for providing it. More than one-third (36%) believe they have already undergone sustainability-related audits, with another 15% unsure, indicating confusion about how these programs are being implemented.
Farmers were unified on key principles: 100% said farmers should own and control their farm data, and 85% support federal action to ensure transparency, set limits and require fair compensation when such data is collected.
While farmers were told these programs would remain voluntary and that data would be used in aggregated form, survey results suggest many do not see that happening in practice. These findings suggest a need for clear guardrails, stronger farmer protections and greater accountability in how farm data is collected and used.
Producer comments
Dairy farmers had opportunities to comment within the anonymous survey, and some chose to provide responses through ADC’s confidential intake line. Many took the opportunity to offer comments or pose additional questions.
Direct thoughts and questions raised by survey respondents:
- Once they have my data and calculate a baseline for my farm, they will come back the next year and regulate me here and there and everywhere.
- Do we even know if they have the right concept of how to measure methane from cattle?
- What process or leverage do I have to protect my farm from corrective action to reduce emissions they calculate from my information?
- The data could be used against my farm in the future. What protection do I have for how they process my data?
- “Any pushback will be met with punishment.”
- What if the third-party collecting the data for my milk buyer is a competitor of a company or co-op I do business with?
- If the U.S. government doesn’t recognize this, who do I go to for representation if there’s a problem?
- They say it is voluntary, so when did farmers give their consent?
- We have become the low-cost cheese and butter seller on global markets, by a lot, so how is this helping?
- If the U.S. is negotiating trade agreements, can’t U.S. ag commodities be exempted from the extreme EU climate rules?
- Will this affect anti-competitive market conditions for selling milk and buying inputs or even getting access to credit?
- What about the security of our farms and our food supply? We’re providing sensitive information and we don’t know where it is going or who is seeing it or what can be done with it.
