USDA National Milk Testing Strategy and Federal Order: NC Dairy Processor Silo Surveillance

(Updated: May 26, 2026, 11:45 a.m.)

On April 24, 2024, the U.S. Department of Agriculture (USDA) issued a Federal Orderto prevent the spread of Highly Pathogenic Avian Influenza (HPAI). HPAI had at that time been detected in both dairy cattle and poultry. This Federal Order required testing of lactating dairy cattle before interstate movement and mandatory reporting of any positive Influenza A test results in livestock.

On December 6, 2024, USDA announced the start of the National Milk Testing Strategy(NMTS). This initiative built on measures USDA had taken since the beginning of the outbreak of highly pathogenic avian influenza (HPAI H5N1) in dairy cattle. Under this Federal Order USDA expanded surveillance into bulk raw milk at facilities that ship, receive, or transfer unpasteurized milk intended for pasteurization. This Federal Order did not override the April 2024 Federal Order requiring premovement testing. States achieve Unaffected status once required testing confirms that dairy cattle herds show no evidence of HPAI infection and active surveillance maintains that status. A state is considered Provisional Unaffected when it has no confirmed HPAI cases in dairy cattle within the past 30 days but has not maintained unaffected status with active surveillance.

On April 27, 2026, USDA announced updated guidance on interstate movement of lactating dairy cattle. Per this new guidance, lactating dairy cattle moving interstate from a state with Unaffected status will not be required to have negative HPAI milk test results within 7 days of movement.

North Carolina has tested all Grade A dairies in February 2025 and received a Provisional Unaffected status. In order to achieve Unaffected status so that our lactating NC dairy cattle can move interstate without pre-movement HPAI testing, we will be implementing an active silo surveillance program to comply with USDA’s NMTS. For the active surveillance plan, NCDA&CS field staff will obtain monthly silo samples from Grade A milk processing facilities in North Carolina.

If you have any questions, please contact our Veterinary Division office at: 919-707-3250 or email at Joe.Web@ncagr.gov

Memo from NCDA&CS RE updated USDA testing strategy