The Irish Creamery Milk Suppliers’ Association (ICMSA) has today (Thursday, October 27) called on the Minister for Housing, Local Government and Heritage, Darragh O’Brien and the Minister for Agriculture, Food and Marine, Charlie McConalogue to suspend the cow banding proposal for 2023 under the Nitrates Action Programme.

The association claims that it is clear that the system is not sufficiently prepared to implement the new regime in 2023, and farmers have not been sufficiently informed of the impending changes. 

The NAP came into operation in 2006. It was developed to improve dairy farm sustainability, while also preventing pollution of water course and protecting air quality.


Currently the excretion rate for all dairy cows is 89kg of organic nitrogen (N)/cow. But under the proposed NAP revisions, higher yielding cows will be given a higher level of N excretion due to their larger feed intake requirements. 

The bands will be based on milk yield replacing the current 89kg of organic N/cow.

The Department of Agriculture Food and Marine (DAFM) is consulting the industry on the establishment of three tiers of excretion band.

BandsMilk yieldsExcretion rate
Band 1<4,500kg of milk80kg organic N/cow
Band 24,500-6,500kg of milk92kg organic N/cow
Band 3>6,500kg of milk106kg organic N/cow
Source: DAFM

President of the ICMSA, Pat McCormack has said that with two months left in 2022, dairy farmers have not been given the required information to make decisions for 2023.

The association feels that these are decisions which will have a “major impact” on farmers’ future in dairy farming.

“The changes under the Nitrates [Action Programme] will directly hit farmers incomes and it is simply unacceptable the way farmers are being treated on this matter,” McCormack said.

“ICMSA has been receiving calls from dairy farmers in a panicked situation where they are being informed for the first time by their advisors that they will have to reduce cow numbers in 2023, or get additional land and this is simply not good enough.

“The suggestion that farmers may be placed in ‘band 3’ and will have to prove otherwise, shows a complete lack of respect for family dairy farmers and if the ministers are serious about bringing farmers with them, they should immediately suspend cow banding for 2023,” he added.

Slurry export

The ICMSA wants the ministers to develop a “fair regime following proper consultation with farmer representatives” which would allow farmers sufficient time to adjust their farming practices if required.

“In addition, the nitrogen (N) figure for slurry export is quite clearly incorrect and this needs to be corrected so that farmers have another viable option to address the nitrate levels on their farms,” McCormack stated.

“The government seems intent on introducing a forensic level of checking on farms, farmers are justifiably very angry at the approach that is being adopted, an approach that is going to slash the incomes of many farmers.

“The ministers need to pause, suspend cow banding for 2023 and allow time so that farmers are given sufficient time to consider practical options, rather than make panicked decisions which is going to be the result of the current government approach,” McCormack said.