Unpasteurised Dairy and Raw-Milk Products

In Australia, selling raw (unpasteurised) drinking milk for human consumption is generally prohibited. Under the FSANZ Food Standards Code, milk and most dairy products must be pasteurised, or undergo an equivalent process that controls pathogens, before retail sale. Raw milk can carry Listeria, Salmonella, Campylobacter and Shiga toxin-producing E. coli, which are especially dangerous for pregnant women, infants, older adults and immunocompromised people. Always confirm current rules with FSANZ and your state or territory food regulator. Key takeaways: Selling raw (unpasteurised) drinking milk for human consumption is generally prohibited across Australia — milk must be pasteurised or equivalently treated under the FSANZ Food Standards Code (Standard 4.2.4).. Raw milk can carry serious pathogens including Listeria monocytogenes, Salmonella, Campylobacter and Shiga toxin-producing E. coli, plus Cryptosporidium and, historically, Brucella, Mycobacterium bovis (TB) and Coxiella burnetii (Q fever).. Pasteurisation (commonly 72°C for at least 15 seconds, or around 63°C for 30 minutes) destroys these vegetative pathogens without sterilising the milk — it is a proven public-health control.. A limited category of raw-milk cheese can be made or imported only where the manufacturing process is shown to control pathogens; most soft, unpasteurised cheeses remain high-risk, especially in pregnancy.. Vulnerable groups — pregnant women, infants and young children, older adults and immunocompromised people — should avoid unpasteurised dairy entirely; confirm current rules with FSANZ and your state or territory regulator.. Pasteurisation methods: Method, Heat and time. High-temperature short-time (HTST) — At least 72°C for at least 15 seconds. Batch / vat (LTLT) — Around 63°C for about 30 minutes. UHT — Higher heat for a long-life, shelf-stable product. Is raw milk legal in Australia? For a food business, the short answer is generally no — raw (unpasteurised) milk cannot be sold for people to drink. Australia's dairy safety framework requires milk and most dairy products to be pasteurised, or to undergo a process that achieves an equivalent reduction of pathogens, before sale for human consumption. This requirement flows through the FSANZ Food Standards Code, particularly Standard 4.2.4 (the Primary Production and Processing Standard for Dairy Products), and is enforced by state and territory dairy authorities and food regulators. Because enforcement, licensing and any narrow exemptions sit with each jurisdiction, always confirm the current position with your state or territory food regulator before stocking, importing or serving any unpasteurised product. Raw drinking milk for human consumption is generally prohibited nationwide. Milk must be pasteurised or equivalently processed before retail sale. Dairy processing is licensed and audited by state/territory dairy authorities. Rules and any exemptions vary by jurisdiction — verify locally. "Bath milk" and other workarounds You may see unpasteurised milk sold as a cosmetic "bath milk" or pet product, labelled "not for human consumption". This is a well-known way people have tried to access raw drinking milk, and it carries the same microbiological risks as any raw milk if someone drinks it. The 2014 death of a young child in Victoria, linked to raw milk sold as bath milk, prompted tighter controls; since 2015 Victoria has required cosmetic raw milk to be pasteurised or to contain a bittering agent to deter drinking. Treating a "cosmetic" product as drinkable is unsafe, and selling raw milk in a way that encourages consumption can breach food law. If a supplier offers raw milk under any of these labels for drinking, do not stock it. "Bath milk" labelled not-for-consumption is still raw milk — same pathogen risk. Victoria has required a bittering agent in cosmetic raw milk since 2015. Selling raw milk to be consumed can breach food-safety and labelling law. What pathogens does raw milk carry? Milk leaves a healthy udder with relatively few bacteria, but it is readily contaminated by faeces, the animal's health status, the milking environment and equipment. Without pasteurisation there is no reliable step to destroy the pathogens that may be present, and the milk can look, smell and taste completely normal while still contaminated. This is why raw milk is treated as a high-risk food and why the microbiological expectations in the Code assume a pasteurisation (or equivalent) step has been applied. Listeria monocytogenes — can grow even at fridge temperatures; a major concern in pregnancy. Salmonella species — cause gastroenteritis, sometimes severe. Campylobacter jejuni — a very common cause of bacterial gastro. Shiga toxin-producing E. coli (STEC, e.g. O157) — can cause haemolytic uraemic syndrome, especially in children. Cryptosporidium — a chlorine-tolerant parasite causing prolonged diarrhoea. Historically Brucella, Mycobacterium bovis (TB) and Coxiella burnetii (Q fever), which pasteurisation was introduced to control. How pasteurisation works Pasteurisation applies a controlled combination of heat and time that destroys the vegetative (living) pathogens found in milk while keeping it drinkable. The two long-established combinations are high-temperature short-time (HTST), commonly at least 72°C held for at least 15 seconds, and the batch or vat method (LTLT), around 63°C held for about 30 minutes. Higher-heat processes such as UHT extend shelf life further. Pasteurisation is not sterilisation: it targets pathogens and most spoilage organisms but does not kill bacterial spores, so pasteurised milk still needs refrigeration and correct date marking. It also does not protect against contamination that happens after processing, so cold-chain and hygiene controls remain essential. HTST: at least 72°C for at least 15 seconds. Batch/vat (LTLT): around 63°C for about 30 minutes. UHT applies higher heat for a long-life, shelf-stable product. Pasteurised milk still needs refrigeration at 5°C or below and clean handling. Raw-milk cheese: the narrow exception There is a limited, tightly controlled category of cheese that can be made from unpasteurised milk. The Code permits certain raw-milk cheeses only where the manufacturing process — for example the moisture, acidity (pH), salt and curing conditions of very hard, long-matured cheeses — is demonstrated to control pathogens to an equivalent standard, or where the milk receives a specified heat treatment short of full pasteurisation. The requirements for these specified cheeses (once set out separately in Standard 4.2.4A) now sit within Standard 4.2.4. Some raw-milk cheeses are also imported under approved conditions. This is not a general licence to sell any unpasteurised cheese: most soft and semi-soft raw-milk cheeses remain high-risk. If a cheese is unpasteurised, verify it is a legally permitted product and treat it as high-risk for vulnerable customers. Only specified raw-milk cheeses are permitted, under strict process controls. Very hard, long-matured cheeses can achieve pathogen control through pH, moisture, salt and ageing. Soft/semi-soft unpasteurised cheeses generally remain high-risk. Check the label and supplier documentation to confirm a product is compliant. Vulnerable groups and your duty of care Some customers face much higher risk from any unpasteurised dairy. Pregnant women are particularly vulnerable to Listeria, which can cause miscarriage, stillbirth or serious newborn illness even when the mother feels only mildly unwell. Infants and young children are at greater risk of severe outcomes from STEC, including haemolytic uraemic syndrome, a serious complication that can cause kidney failure. Older adults and people who are immunocompromised (for example through chemotherapy, organ transplant or chronic illness) are also more susceptible to severe infection. Health guidance consistently advises these groups to avoid raw milk and soft or unpasteurised cheeses. If you serve settings such as aged care, childcare, hospitals or maternity services, unpasteurised dairy should not be on the menu. Pregnant women: avoid raw milk and soft/unpasteurised cheeses (Listeria). Infants and young children: higher risk of severe STEC illness. Older adults and immunocompromised people: greater risk of severe infection. Aged care, childcare, hospitals and maternity services should exclude unpasteurised dairy. Practical controls for food businesses Treat unpasteurised dairy as a supplier-approval and menu-design issue, not just a cooking one — you cannot "cook out" the risk in the way you would for many other high-risk foods. Make sure every dairy line you buy is pasteurised or a legally permitted, documented raw-milk product, and keep the paperwork that proves it. Maintain the cold chain, apply correct date marking and, where you serve vulnerable groups, flag or exclude any higher-risk items. Depending on your business type and jurisdiction, food safety obligations under Standard 3.2.2 (and, where it applies, the food safety management requirements of Standard 3.2.2A) mean you should be able to demonstrate how you manage such products as part of your food safety practices. Worked examples: A supplier offers cheaper 'bath milk': A cafe is offered unpasteurised milk labelled 'bath milk — not for human consumption' at a low price. Because it is still raw milk with the same pathogen risk if anyone drinks it, and selling raw milk in a way that encourages consumption can breach food law, the cafe declines and sticks to pasteurised supply with certificates on file. Menu for an aged-care setting: A caterer serving an aged-care facility excludes raw milk and soft or unpasteurised cheeses from the menu entirely, because older adults are more susceptible to severe infection. Any harder, long-matured raw-milk cheese is only used if confirmed as a legally permitted product, and higher-risk cheeses are clearly identified for vulnerable customers. Checklist: All milk stocked is pasteurised or an equivalently treated product. Any raw-milk cheese is confirmed as a legally permitted, documented product. No raw milk sold or served for drinking, including "bath milk". Supplier approvals, specifications and certificates on file. Dairy stored and displayed at 5°C or below with correct date marking. Unpasteurised/soft raw-milk cheeses excluded where vulnerable groups are served. Higher-risk cheeses clearly identified for customers. Staff trained to identify and refuse non-compliant dairy. Common mistakes: Assuming "bath milk" or "pet milk" is a legal way to sell raw drinking milk. Believing that fresh, local or organic raw milk is safe because the farm looks clean. Thinking all unpasteurised cheese is banned — or, conversely, that all of it is allowed. Serving soft or unpasteurised cheeses to pregnant women, infants, older adults or immunocompromised customers. Treating pasteurised milk as shelf-stable and neglecting refrigeration and date marking. Failing to keep supplier documentation proving products are pasteurised or compliant. State and territory notes: VIC: Since 2015, Victoria has required cosmetic raw milk ('bath milk') to be pasteurised or to contain a bittering agent to deter drinking, following a child's death linked to raw milk sold as bath milk. All states/territories: Enforcement, licensing and any narrow exemptions sit with each jurisdiction; confirm the current position with your state or territory food regulator before stocking, importing or serving any unpasteurised product.