What Is Considered Raw Dairy? Products and Risks

Raw dairy refers to any milk or milk-based product that has not been pasteurized, meaning it was never heated to kill bacteria. This includes milk straight from the animal as well as cheese, butter, cream, yogurt, and kefir made from that unheated milk. The defining feature is simple: if the milk was not brought to at least 145 °F for 30 minutes (or 161 °F for 15 seconds, the more common commercial method), the resulting product is considered raw.

How Raw Dairy Differs From Pasteurized

Pasteurization is a controlled heating process with specific time and temperature combinations set by federal regulation. The two most common are heating milk to 145 °F (63 °C) and holding it there for 30 minutes, or heating it to 161 °F (72 °C) for just 15 seconds. Higher-fat products like heavy cream require temperatures 5 °F higher. Ultra-high temperature methods go as high as 212 °F for a fraction of a second.

Raw dairy skips all of this. The milk goes from the animal into a container and eventually to the consumer without any heat treatment. Some producers filter or chill the milk rapidly, but these steps don’t change its raw status. If heat was never applied at pasteurization-level temperatures, it’s raw.

Products That Count as Raw Dairy

Raw milk is the most obvious example, but the category is broader than most people realize. Any product made from unpasteurized milk qualifies:

  • Raw milk: Cow, goat, sheep, water buffalo, and even camel milk can all be sold raw where legal.
  • Raw cream and butter: Separated or churned from unpasteurized milk without heating.
  • Raw cheese: Made by adding cultures and rennet to unpasteurized milk. Many traditional European-style cheeses (Gruyère, Comté, real Parmigiano-Reggiano) are made this way.
  • Raw yogurt and kefir: Cultured from milk that was never pasteurized before fermentation. These are less common commercially but available at some farms and specialty stores.

A product only needs one unpasteurized dairy ingredient to be considered raw. So a cheese made partly from pasteurized milk and partly from raw milk would still fall under raw dairy regulations.

The 60-Day Rule for Raw Cheese

Raw cheese occupies a unique legal space. Federal law in both the United States and Canada allows cheese made from unpasteurized milk to be sold, but only if it has been aged at a temperature of at least 35 °F for a minimum of 60 days from the start of manufacturing. The idea is that the combination of salt, acidity, low moisture, and time reduces harmful bacteria to safe levels.

This is why you can find aged raw-milk cheddar or Parmesan at a regular grocery store, but you won’t find raw-milk brie or camembert made domestically. Soft-ripened cheeses don’t undergo the same lengthy aging, so they must be made from pasteurized milk under U.S. rules. However, some imported soft raw-milk cheeses do appear in specialty shops, and the safety of the 60-day rule for soft cheeses remains debated. An FDA risk assessment found that the aging period can actually give certain bacteria, particularly Listeria, more time to grow in soft cheeses when conditions allow.

What’s in Raw Milk That Pasteurization Changes

Raw milk contains a suite of naturally occurring enzymes that pasteurization partially or fully destroys. Lactoperoxidase is one of the most discussed: it’s an antimicrobial enzyme that catalyzes reactions helping to inhibit bacterial growth in fresh milk. Lipase breaks down fats, and plasmin breaks down casein proteins into smaller peptides and amino acids. Alkaline phosphatase, which is bound to the fat globule membrane, is actually used as a test marker. If it’s still active in a dairy product, the milk wasn’t adequately pasteurized.

On the vitamin side, a meta-analysis of existing research found that pasteurization significantly reduces concentrations of vitamins B1, B2, C, and folate. Vitamins B12 and E also decreased, while vitamin A slightly increased. These losses are real but relatively modest in the context of a full diet, since milk is not a primary source of vitamin C or folate for most people. The minerals, including calcium and phosphorus, are largely unaffected by heat.

Bacterial Risks

The reason pasteurization exists is that raw milk can harbor dangerous pathogens: Salmonella, E. coli (including the particularly dangerous Shiga toxin-producing strains), Listeria, and Campylobacter. These bacteria can be present even when animals appear healthy and farms follow strict hygiene practices, because they live in the gut and environment of dairy animals and can contaminate milk during or after milking.

Pregnant women face an elevated risk from Listeria specifically, which can cause miscarriage, stillbirth, or severe illness in newborns. Young children, older adults, and anyone with a weakened immune system are also more vulnerable to serious complications from these pathogens.

Producers who sell raw milk typically aim for very low bacteria counts. U.S. Grade A milk, even when destined for pasteurization, must have a standard plate count below 100,000 bacteria per milliliter and a somatic cell count (a marker of udder health) below 750,000 cells per milliliter. Farms producing milk for raw consumption often target counts well below these thresholds, though no level of testing can guarantee the absence of pathogens in any individual batch.

Where Raw Dairy Is Legal

Federal law prohibits the interstate sale of raw milk in final packaged form for direct consumption. But states set their own rules for sales within their borders, and the landscape varies widely. As of 2025, 32 states allow raw milk sales in some form, while 18 ban it outright.

The legal arrangements differ significantly from state to state. Some permit retail sales in stores. Others restrict sales to the farm where the milk was produced. Some allow delivery or farmer’s market sales. A number of states use herdshare or cowshare programs, where consumers buy a share of an animal and receive a portion of its milk, technically sidestepping the “sale” of raw milk. Arkansas recently expanded its law to allow raw goat, sheep, and cow milk to be sold directly to consumers at farmers’ markets or via farm delivery. North Dakota extended its provisions to cover raw milk products, not just raw milk itself, though sales to wholesalers and retail stores remain prohibited.

Raw cheese aged 60 days or more is legal nationwide and can be sold across state lines. This is the primary way most Americans encounter raw dairy, often without realizing it, since many imported and artisan cheeses are made from unpasteurized milk.