The number of bacteria in raw cow's milk in Montenegrin dairies in 2023 was more than six times higher than the maximum allowed in the European Union (EU). Thus, the average last year was 635 thousand per milliliter, while according to EU standards it would have to be below 100 thousand. This results from the last, fifth Report on the implementation of the national program for improving the quality of raw milk from November 2023, of the Ministry of Agriculture, Forestry and Water Management (MAFWS).
According to the National Program for the Improvement of the Quality of Raw Milk of the Ministry of Education and Culture launched in 2018, Montenegro was supposed to gradually harmonize the quality with that of the EU. Thus, in the period from 2022 to the end of 2024, it was predicted that the maximum number of bacteria would be 200.000. From next year, milk should, according to that plan, be entirely of European quality, that is, it should not contain more than 100.000 bacteria.
However, despite 2018 million euros being set aside from 2023 to 30 for various measures to improve raw milk, the number of bacteria was higher than planned every year. The number of bacteria, along with the number of somatic cells, is the most important characteristic that determines the quality of raw milk.
The Ministry of Internal Affairs and Communications claims that Montenegro is following the process of harmonization with EU criteria. However, they admit that the Montenegrin livestock farmers from whom they buy the dairies are currently receiving premiums from the Ministry of Agriculture and Forestry for milk that contains up to 600.000 bacteria per milliliter. According to the Ministry of Agriculture and Forestry, part of the milk samples bought by dairies last year contained much more bacteria, but these farmers did not receive premiums from the Ministry.
CIN-CG had insight into one of the reports of the Ministry of Internal Affairs and Communications with the names of dairies and the number of bacteria in their milk samples. Most of the samples were far from the EU criteria, and some even contained over a million bacteria.
Ranko Bogavac, the head of the Directorate for Animal Husbandry of the Ministry of Education, Culture, Sports and Science tells CIN-CG that the allowed number of bacteria in raw milk had to remain higher than the program, in order for the Ministry to provide premiums to a larger number of livestock farmers.
"Without the premium, which is eight cents per liter, they would not be motivated to sell milk to dairies".
With this, as he says, the Ministry of Education and Culture supports the production process in Montenegro.
Bogavac did not answer CIN-CG's question as to why the implementation of the program to improve the quality of raw milk did not result in a decrease in the annual average number of bacteria.
The European Food Safety Agency (EFSA) tells CIN-CG that bacteria in raw milk can cause numerous serious diseases.
"Salmonella, campylobacter, Escherichia coli are some of the particularly dangerous bacteria that can easily be found in raw milk and especially affect children, the elderly population, people with a weaker immune system...", say EFSA.
EFSA explains that the processes of pasteurization and heat treatment destroy a greater number of bacteria. Regardless, the EU requires that the raw milk that comes to the dairies for processing be of perfect quality, which further reduces risks and extends the shelf life of dairy products.
Although the number of bacteria in raw cow's milk is clearly a problem for Montenegro, the number of somatic cells, another important measure that determines the quality of raw milk, mostly meets EU criteria. Thus, this figure, which according to EU standards must be below 400, has already dropped to around 2020 in 340, and will continue to decline in the following years. The number of somatic cells in the milk indicates whether the animal is sick with mastitis, or inflammation of the mammary glands.
The data in the Report are not clearly presented
In the latest Report on the implementation of the national program for improving the quality of raw milk, it is stated that the amount of purchased EU quality raw milk in Montenegro is increasing. However, it is not stated what percentage of the total amount of raw milk that the dairies bought was of EU quality.
Reports from previous years state that there are very high percentages of milk that meet EU standards (below 100 bacteria per milliliter), although this is not the case in practice. According to the Report from 2022, the average number of bacteria per milliliter was over 650 thousand per milliliter, but despite this, it is stated that the percentage of milk that meets EU standards is 86 percent. The average number of bacteria during 2021 was almost 900.000 per milliliter, but it was stated that the amount of milk corresponding to EU standards was over 80 percent.
When asked by CIN-CG how such calculations are possible, the competent departments did not know how to answer. The Ministry claims that the Directorate for Food Safety, Veterinary and Phytosanitary Affairs (UBH) is responsible for this calculation. However, UBH said that the given figures are calculated by the Dairy Laboratory of the University of Montenegro. The Laboratory, on the other hand, claims that they do not calculate the percentage of milk that meets EU standards, but only analyze the submitted samples.
"In order to prevent corruption in the analysis process, we must not know from which producer the sample of milk being tested comes from, nor how many liters of milk are tested with that sample. Therefore, we cannot know what percentage of milk complies with EU standards", this laboratory explains to CIN-CG.
Only the Ministry has data on literage, they said.
However, the Ministry of Education and Culture claims that they are not in charge of the calculation methodology for milk conforming to EU standards, but that it is calculated by UBH. They said that they did not know what kind of methodology was involved, and that there was a possibility that the data was not presented in an appropriate way.
Since 2019, the Government of Montenegro has adopted reports written in this way every year. Data presented in this way could pose a problem, given that, after approval by the Government, they are submitted to the European Commission every year. Over the past years, UBH's field of work has been marked as one of those that receive the most praise from the European Commission, and progress in the field of improving the quality of raw milk has been highlighted in every report.
Biljana Blečić, the deputy director of UBH for the veterinary sector, claims for CIN-CG that 90 percent of the milk purchased by dairies is certainly of EU quality, that is, the number of bacteria below 100.000 and somatic cells below 400. When asked on what basis she claims this, when reports say the opposite, and why products are not exported to the EU, she says that regardless of the quality, the EU requires the manufacturer to have a parallel production line that would only export products to the EU.
"It's not worth it to them," she says.
She also did not know how to explain to CIN-CG journalists what methodology is used to calculate the data in the annual reports.
The number of controlled milk samples is decreasing
Since 2018, when the Ministry of Education and Culture started the program to improve the quality of raw milk, the number of controlled milk samples has been decreasing. This is shown by the reports on the implementation of the program. Thus, in 2023 there were twice as many samples as in 2018, when the program began. The Ministry of Internal Affairs and Communications claims that due to cyber attacks and loss of data, it is not known how much raw milk was purchased by dairies last year, so it is not possible to know whether the amount of raw milk itself has significantly decreased over the years.
According to the Rulebook on monitoring food of animal origin, it is necessary to take at least three hundred samples of raw cow's milk annually, which will be tested for various substances, such as drugs, pesticides, mycotoxins. Seventy percent of the samples must be tested for the presence of veterinary drugs, each for at least four types of drugs.
The Center for Ecotoxicological Testing (CETI) is in charge of these tests by order of UBH.
Compared to 2022, the number of samples tested for antibiotics dropped significantly last year. CETIJ told CIN-CG that during 2022, 243 samples were submitted for state monitoring of raw milk to control the presence of antibiotics, while only 2023 were submitted during 32. All samples from both years were negative for the presence of antibiotics. During both 2023 and 2022, about thirty samples were submitted for testing for the presence of pesticides in raw milk, all of which were negative.
During 2023, there were 26 samples tested, four of which tested positive for aflatoxins, carcinogenic toxins that come from fungi. During 2022, out of 27 samples, four were also positive, while in 2021, there were four samples positive for aflatoxin out of a total of 14 taken. In Montenegro, the permitted concentration of aflatoxin is harmonized with the EU, and should not exceed 0,05 micrograms per liter.
In January, TV Vijesti reported that the General Secretariat for Meat and Food Safety of the EU (Di Dzi Sante) warned in an internal report for Montenegro that the quality of food in the country is questionable, due to failures in the work of CETIJA and UBH. This European institution visited CETI 2022, after they realized that the institution had a very low number of positive samples for toxins in the samples being tested. This cast doubt on the testing methodology.
Di Ji Sante stated in the report on the visit that the implementation of controls is poor, the validity of the samples is questionable, but also that the number of controlled samples is lower than planned.
It is alleged that the CETI laboratory does not meet EU requirements in terms of staff training, documentation handling, validation methods, quality control measurement and reporting. They also stated that retail control is insufficient, and that there is no record of the treatment of animals on certain farms.
Few inspectors for the extensive work
In Montenegro, milk producers are divided into two categories, which the state supports with two subsidy programs. One is intended for producers from whom dairies buy raw milk, and the other concerns those who make cheese and cream from milk on their own farms.
In our country, there are about 930 registered agricultural producers from whom dairies buy milk, and there are about 2200 registered producers of cheese and cream.
In order to properly implement the Raw Milk Quality Improvement Program, inspectors employed by UBH must visit all farms and dairies. Supervision of food of animal origin and control of the health status of animals is carried out by veterinary inspectors, and there are only six of them at UBH.
"Everyone is closer to retirement than to the beginning of their career," explains Blečić.
In Montenegro, there are 27 dairies approved for operation, which inspectors control according to the annual plan.
"It is important to visit each facility at least four times," says Blečić.
Veterinarians are also responsible for the control of milking parlors on farms that sell milk to dairies. In these cases, the most important thing is to establish a health control system for milking teats, explains Blečić. "Once a year, milking teats are tested for infectious diseases that are transmitted to humans through dairy products, tuberculosis, brucellosis and zoonosis", explains Blečić.
There are also additional monitoring, controls on milking, transport to the dairy, quality during processing, and then from the store, etc. In addition to all farms and dairies, veterinary inspectors should control all catering facilities, especially during the summer tourist season when the risks of infectious diseases are the highest, they supervise animal feed and the facilities where it is produced.
The import of raw milk is controlled by food safety inspectors at the border crossings, and only one inspector works at each crossing, a total of seven of them.
"They have equipped rooms and prepared laboratories where certain physical controls are carried out, what can be registered with the senses", explains Blečić.
What cannot be checked on site is sent to laboratories, she says.
However, the data requested by CIN-CG on the number of milk samples checked at border crossings, nor the annual control plan of dairies, were not submitted.
When asked how it is possible for such a small number of inspectors in the sector to control the entire country, Blečić claims that it is possible to organize control.
Blečić explains that the veterinary inspection does not control unregistered producers of dairy products such as cheese and cream, but that they do not have the legal right to sell products on the market. When asked whether there is still a risk that such products end up on the market, Blečić claims that inspectors are doing everything in their power to prevent such a thing.
"They were especially active during the corona and visited all the markets in the country".
However, as he says, there were only two of them on the field, which definitely indicates a capacity problem in that sector.
This problem will continue because the new, young cadre of veterinarians is not interested in the civil service, but prefers to work in the private sector, which is more profitable. Another problem is that there is no veterinary faculty in Montenegro.
And if the integration process intensifies, there will be much stricter requirements and much more serious plans and people will be needed in order to meet the strict standards in this area.
Decrease in the number of controls on aflatoxins in drinking milk
Compared to 2022, during 2023, the control of drinking milk for aflatoxins decreased significantly. Thus, in 2022, CETI examined 142 samples, and in 2023, only 41. Of the controlled samples in 2022, there were five of them that had an elevated level of aflatoxin, including producers from the region: Imlek from Serbia, Milkland and MiggNatura from Bosnia and Herzegovina. UBH told CIN-CG that all problematic series were then withdrawn. Last year, only goat's milk was problematic.
Ten years ago, there was a great panic in the region, when it was announced that the levels of aflatoxin in milk in the region were five times higher than the EU standard. Aflatoxin is a toxin that remains in milk even after pasteurization and heat treatment. Then, in 2013, when aflatoxin was very high in imported milk, Montenegro withdrew several lines. However, the BBC wrote last year that the permitted level of aflatoxin in milk in Serbia is still five times higher than the EU standard, which was supposed to change from 2024. A large amount of imported milk is bought in Montenegro, especially from Serbia and Bosnia and Herzegovina.
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