Creamery Butter Manufacturing (U.S.) — NAICS 311512

1. Overview

Creamery butter manufacturing is the business of churning cream into butter — one of the oldest and most commodity-like corners of the U.S. dairy industry. It is a small, highly automated, high-throughput sector: roughly 45 companies operating about 54–58 dedicated plants (depending on year and survey), employing around 4,000 people, yet booking about $8.9 billion in receipts.[1][2] That works out to more than $2 million of revenue per employee, which tells you most of the story — butter is a bulk product made by machines running around the clock, not a labor-intensive craft business.

Why an investor should care: butter demand is in a genuine, multi-decade upswing. Per-person consumption hit an all-time high of 6.8 pounds in 2024, up 21% over the prior decade, as consumers moved back toward "real" dairy fat and away from margarine and seed-oil spreads.[3] But the earnings are cyclical and commodity-driven. Butter trades daily on a futures exchange; the wholesale price ran above $3.50 a pound in late 2023, then collapsed below $2.00 in 2025 as milk supply recovered and inventories piled up.[4][5] Strong secular demand, violent short-term price swings.

Public vs. private ways in: this is mostly a private and cooperative industry. Most U.S. butter is churned by farmer-owned cooperatives (Land O'Lakes, Dairy Farmers of America, California Dairies, Challenge, Darigold, Agri-Mark) whose profits flow back to member-farmers, not to outside shareholders.[6][7][8] There is no U.S.-listed pure-play butter company. The cleanest public exposure is a diversified dairy processor such as Saputo Inc. (Toronto Stock Exchange: SAP), where butter is one line among many, or commodity butter futures for sophisticated investors.[9] The real ownership routes — co-op membership, dairy farms, and private/premium butter brands — are private.

2. What it is and how it's structured

Formally, NAICS (North American Industry Classification System) code 311512 covers establishments primarily engaged in manufacturing creamery butter from milk and/or processed milk products.[10] It sits inside the Dairy Product Manufacturing group (NAICS 3115).

Commercial butter production separates milkfat from cream by churning. The liquid phase exits as buttermilk — a co-product distinct from the cultured beverage ordinarily sold as "buttermilk" — and the fat is worked and texturized into a semi-solid, transferred to a silo, and packed as consumer sticks and solids, foodservice portions, or bulk blocks.[11][12] Integrated dairy processors can improve plant economics by drying skim milk and buttermilk into saleable powders.

The industry makes bulk (industrial) butter sold in 68-pound blocks to food manufacturers and foodservice, and retail "prints" (the familiar 1-pound, four-stick package). Product variants — salted vs. unsalted, European-style (higher butterfat, roughly 82–85%), cultured, whipped, spreadable, and ghee — are where processors add margin above plain commodity butter.

What it excludes (adjacent codes): margarine, margarine-butter blends, and nondairy butter substitutes are classified under Fats and Oils Refining and Blending (NAICS 311225).[10] Cheese plants fall under 311513, dry/condensed milk and milk powder under 311514, and fluid milk and cream bottling under 311511. Butter made as a secondary product at a cheese, fluid-milk, or milk-powder plant may be recorded under that plant's primary NAICS rather than 311512. This classification boundary matters for the size figures below.

Ownership mix: unusually for a manufacturing sector, farmer cooperatives dominate. Land O'Lakes, Dairy Farmers of America, California Dairies (owner of the Challenge brand), Darigold (Northwest Dairy Association), and Agri-Mark (Cabot) are all member-owned co-ops.[6][7][8][13] Grassland Dairy Products, the largest family-owned butter maker, is private.[14] Investor-owned processors (Saputo, France's Lactalis) and importers (Ireland's Ornua, maker of Kerrygold) round out the field.[9][15]

3. How big it is

Federal statistics for the narrowly defined industry (2022 Economic Census and 2023 County Business Patterns):

• Receipts: about $8.88 billion (2022).[2]
• Establishments: 58 (2022 Economic Census); 54 (2023 County Business Patterns).[1][2] The difference reflects different reference periods and survey construction, not necessarily openings or closures.
• Firms: 45 (2022).[2]
• Employment: 3,656 (2022 Economic Census); 4,055 (2023 County Business Patterns).[1][2]
• Annual payroll: about $246 million (2022); about $290 million (2023).[1][2]

For reference, the U.S. Small Business Administration classifies a butter maker as a "small business" only if it has 750 or fewer employees — a high bar that reflects how capital-intensive these plants are.[16]

Physical output is far larger than the plant count suggests: total U.S. butter production reached 2.39 billion pounds in 2025, up 6.7% from 2024, which itself set a record at 2.24 billion pounds.[17][18] California accounts for about 28–32% of production depending on the year, followed by Wisconsin, Idaho, Texas, and New York.[19]

An important undercount caveat: federal business statistics classify each plant by its primary product, so the establishment count captures only facilities whose main output is butter. A great deal of U.S. butter is churned as a co-product at plants that are primarily cheese, milk-powder, or fluid-milk operations and are counted under other NAICS codes. So the establishment count understates how many facilities actually make butter, and the receipts figure blends butter with the other products these plants sell. Unlike some industries, the undercount here is not about missing tiny or informal operators — the sector is genuinely concentrated in a handful of large firms (see Section 8) — it is about product-based classification.

4. The investable universe

There is no U.S.-listed company whose business is mainly butter. Exposure comes through diversified dairy processors, foreign-listed cooperatives, or private/co-op ownership.

For public-market investors specifically: the most direct listed plays are Saputo (TSX: SAP) and, for global butter/anhydrous-milkfat trade, New Zealand's Fonterra (NZX/ASX: FCG), a cooperative with listed units and the Anchor brand.[9] Both are diversified, so butter is a minority of revenue. Vital Farms (NASDAQ: VITL) offers minor premium-butter exposure, but butter was only $26.3 million of its $733 million in 2025 revenue — it is principally an egg company with a small butter business.[22] The purest financial exposure to the butter price itself is CME (Chicago Mercantile Exchange) Cash-Settled Butter futures — an institutional/hedging instrument, not a buy-and-hold equity. Each futures contract references 20,000 pounds and settles against USDA's monthly weighted-average butter price; CME also lists Class IV milk futures.[23] Note that the retail shelf leaders are private label (store brands, #1 by sales), Kerrygold (#2), and Land O'Lakes (top branded domestic), none of which is a stand-alone U.S. stock.[24][15]

5. How the money works

Butter making is a commodity spread business. A churn plant buys cream (or separates cream from farmer milk), and its gross margin is essentially the gap between the finished butter price and the butterfat (cream) it cost to make, minus the processing cost. In dairy-pricing language that processing cost is the "make allowance."

Milkfat is the dominant economic input. USDA's retail-price work assumes that one pound of butter contains 0.803 pounds of fat and 0.01 pounds of skim solids. In 2024, payments to dairy farmers represented 57% of the retail butter price, illustrating how much of the value chain is tied to the raw milk component even before packaging, labor, freight, refrigeration, and retail margin.[25]

Four levers drive profitability:

• The butter price. Butter is quoted daily on the CME spot market and graded on flavor and quality; U.S. Grade AA is the top grade under USDA's voluntary grading program.[26] The price is volatile: it averaged about $2.86/lb in 2024 and $2.59/lb in 2023, spiked above $3.50 in October 2023, then fell below $2.00 in 2025, reaching roughly $1.72 by late September 2025 — down about 37% year-over-year.[4][5]
• Butterfat input cost. In Federal Milk Marketing Order areas, milk used for butter is Class IV. USDA's mandatory weekly survey of qualifying bulk butter sales feeds directly into regulated milk-component prices, so the industry's selling price and its regulated cream or butterfat cost are mechanically linked — reducing the usefulness of a simple "butter price up equals margin up" thesis.[27] Cream supply is seasonal and competes with ice-cream makers (summer) and cheese plants. Cheap cream in the spring "flush" boosts butter output and can flood the market.
• Throughput / capacity utilization. Fixed plant costs are spread over volume, so churns are most profitable running full. The revenue-per-employee figure above (>$2M) reflects how automated and scale-driven this is.[1][2] Low utilization is especially damaging because continuous churns, packaging lines, refrigeration, and wastewater systems carry substantial fixed costs.
• Product mix and branding. Branded butter (Land O'Lakes), premium and grass-fed (Kerrygold), European-style, and value-added forms earn a premium over commodity/private-label butter.[6][24]

The cooperative wrinkle: for the co-ops that dominate this industry, the "profit" largely takes the form of a higher milk price and patronage dividends paid back to farmer-members, rather than reported corporate earnings. Land O'Lakes, for example, returned $164 million in cash patronage to members in its latest year, and its dairy-foods unit posted $64 million of pre-tax profit, up 33%.[6][20] That structure is exactly why the equity-investable universe is thin.

One more feedback loop investors should know: butter and nonfat dry milk together set the U.S. "Class IV" farm milk price under federal formulas, so the finished butter price directly determines what dairy farmers get paid for milkfat.[28]

A note on margins: the current Class IV formula includes a butter manufacturing allowance of $0.2272 per finished pound and a butterfat recovery factor of 91%.[28] The allowance is an administrative formula input intended to represent conversion cost; it is not a reported industry margin, a guaranteed processor spread, or evidence that all plants can manufacture at that cost. No authoritative current EBITDA margin, operating margin, or return-on-capital series for NAICS 311512 is publicly available — Census publishes shipments and payroll but not an industry income statement, while the large cooperatives and private firms generally do not disclose butter-segment profitability.

6. What drives demand

• The secular "butter is back" trend. After decades of decline, per-capita butter consumption has risen about 2.3 pounds since 2000 and hit a record 6.8 pounds in 2024 (up from 6.5 in 2023).[3] Consumers increasingly prefer natural animal fat over margarine and worry about seed/vegetable oils and trans fats. In 2005, per-capita margarine availability had already fallen below butter availability despite margarine's lower retail price.[29]
• Baking and the holiday peak. The fourth quarter (Thanksgiving–Christmas baking) is the demand high point; foodservice and restaurant use is a large year-round channel.
• Premiumization. Grass-fed, European-style, cultured, organic, and artisanal butter are the fastest-growing segments and command higher prices, even as private label grows at the value end.[24]
• Health narrative. Low-carb, keto, and "whole-food" diets favor butter; any renewed public-health push against saturated fat is the swing risk in the other direction.
• Exports. U.S. butter exports rose 7% to 31,042 metric tons in 2024, while anhydrous milkfat exports more than doubled to 13,754 metric tons.[30] Export competitiveness changes rapidly with U.S., European, and Oceania prices, currencies, tariffs, and freight.
• Population, income, and food-away-from-home spending set the baseline.

7. Regulation

• Standard of identity. By a 1923 Act of Congress and FDA (Food and Drug Administration) rules, anything sold as "butter" in the U.S. must contain at least 80% milkfat.[31][32] This is enforced through federal labeling law.
• Grading. The USDA (U.S. Department of Agriculture) Agricultural Marketing Service runs a voluntary grading program (Grade AA/A/B) based on flavor, body, color, and salt — a separate concept from the statutory standard of identity — and updated its butter-plant records requirements in a 2025 final rule.[26][33]
• Milk pricing. Butter and nonfat dry milk prices feed the Class IV price under Federal Milk Marketing Orders (FMMOs). USDA's 2025 FMMO modernization — the first update to processing "make allowances" since 2008 — raised the butter make allowance to about $0.2272/lb and set a 91% butterfat recovery factor, effective June 2025. Higher make allowances slightly lower the minimum regulated milk price, shifting a bit of value from farmers toward processors.[28]
• Food safety. Cream and butter fall under the FDA Grade "A" Pasteurized Milk Ordinance, the Food Safety Modernization Act (FSMA), and state dairy inspection. Registered food facilities generally must comply with FSMA current good manufacturing practices, written hazard analysis, and risk-based preventive controls; operation under the Pasteurized Milk Ordinance does not by itself satisfy every FSMA requirement.[34]
• Wastewater. Dairy processing generates high-strength wastewater from product losses, tank and pipe cleaning, spoiled product, and detergents. EPA regulates the butter subcategory under 40 CFR Part 405 for biochemical oxygen demand, suspended solids, and pH, making wastewater capacity a practical constraint on plant expansions.[35]
• Trade. Imported butter faces tariffs and tariff-rate quotas. In 2025 the U.S. imposed a 10% baseline tariff plus higher country rates — roughly 20% on European Union goods, which raised the landed cost of Kerrygold and other EU butters relative to New Zealand product.[15][36]
• Farm support. USDA's Dairy Margin Coverage program and periodic government dairy purchases provide a soft floor for the broader dairy complex.

8. Competitive dynamics and consolidation

This is one of the more concentrated food-manufacturing industries in the country. The four largest firms account for 78% of receipts, the top eight for 92%, and the top twenty for over 99%.[2] A handful of large churns effectively set the market; the government suppressed the precise Herfindahl-Hirschman concentration index for this industry, but the ratios make clear it is high.[2][37]

Census does not identify the firms behind that 78%, and no defensible current company-by-company national market-share table is publicly available. The visible field nevertheless has several clear leaders: California Dairies Inc. claims 480 million pounds annually and 20% of total U.S. butter production.[8] Land O'Lakes, DFA, AMPI, and Grassland round out the major producers.

Structurally the field splits three ways: farmer cooperatives that dominate volume (Land O'Lakes, DFA, California Dairies, Darigold, Agri-Mark); investor-owned processors (Saputo, Lactalis); and premium importers (Ornua/Kerrygold, Fonterra/Anchor).[6][7][9][15] Consolidation has been steady across dairy processing generally, driven by scale economics — bigger, more automated churns are lower-cost — and the industry is in the middle of a broad capacity build-out, with dairy processors investing more than $11 billion across new and expanded U.S. plants.[3]

Competitive pressure comes from two directions at once: private-label store brands squeezing branded margins at the low end, and imported grass-fed premium butter (Kerrygold reached record U.S. household penetration in 2024) at the high end.[15][24]

9. Risks

• Commodity price volatility. The 2025 crash below $2.00/lb after the 2023 peak above $3.50 shows how fast margins and milk checks can compress.[4][5]
• Oversupply cycles. Recovering milk output and cheap cream can flood the market; U.S. butter cold-storage stocks jumped to about 305 million pounds in February 2025, the highest for that month since 2021, pressuring prices.[4]
• Input and cost risk. Cream/butterfat cost, feed prices, herd size, energy, packaging, and labor all move margins. The largest economic risk is that processors may be unable to reprice branded, private-label, or foodservice contracts as quickly as regulated cream and commodity costs change; conversely, falling butter prices can create inventory losses.
• Labor availability. Dairy relies heavily on foreign-born labor, while most livestock operations cannot use the seasonal H-2A program for regular year-round positions. Processing plants face their own skilled-maintenance, sanitation, and shift-work constraints.[38]
• Animal-health shocks. The 2024 spread of highly pathogenic avian influenza (H5N1) into U.S. dairy cattle is an emerging supply-side risk to monitor.
• Food-safety failures. Recalls, lost customer approvals, and brand damage can result from contamination or compliance failures.[34]
• Trade policy. Tariffs cut two ways — they shield domestic churns from imports but invite retaliation against U.S. dairy exports and raise consumer prices.[36]
• Regulatory pricing changes. FMMO make-allowance updates and formula changes shift value between farmers and processors.[28]
• Substitution risk. Margarine, vegetable-oil spreads, and plant-based products compete economically, as do bakery and packaged-food reformulations. Those substitutes are not part of NAICS 311512 but are relevant competitors.
• Demand-narrative reversal. A renewed official push against saturated fat could slow the consumption uptrend.
• Thin investability. The co-op-dominated structure means public investors have limited, indirect access and little transparency into pure butter economics.

10. How to invest and the outlook

Public-market routes (indirect). No U.S.-listed pure-play exists. The most direct listed exposure is Saputo Inc. (TSX: SAP), a large diversified dairy processor with butter and butter-blend lines, and — for global butter/anhydrous-milkfat trade — Fonterra (NZX/ASX: FCG).[9] Both dilute butter within a broad dairy business. Vital Farms (NASDAQ: VITL) offers minor premium-butter exposure but is principally an egg company.[22] Broad agriculture and food ETFs offer only faint exposure. For traders and hedgers, CME Cash-Settled Butter futures are the purest instrument tied to the butter price itself, but they are a commodity position, not an equity; dairy-contract liquidity can be thinner than in major grain and livestock markets.[23]

Private and cooperative routes (where the real economics live). Because farmer co-ops churn most U.S. butter, the primary "ownership" of butter profits is co-op membership and dairy-farm ownership.[6][7] Private-equity and venture money targets premium and artisanal butter brands, foodservice and bakery ingredient suppliers, and processing capacity. Owning cream supply — dairy operations and farmland — is the upstream play. The central underwriting questions for private-market exposure are secured cream supply, customer concentration, branded versus commodity mix, churn and packaging utilization, wastewater headroom, co-product realization, and whether selling-price formulas reset quickly enough to protect the butterfat spread.

Near-term drivers and outlook (forward-looking). Underlying demand looks structurally strong: consumption keeps setting records and butterfat is the most valued milk component.[3] But 2025 illustrated the cyclical risk — ample milk, cheap cream, heavy inventories, and a sharp price fall that squeezed farm milk checks even as processors' make allowances rose. The next few years likely reward low-cost, high-throughput operators and premium/branded players, while commodity producers ride the price cycle. Investors should watch the CME butter price, cold-storage stocks, Class IV milk prices, the phased FMMO changes, tariff developments on imported butter, and any H5N1 impact on milk supply. Judgments about direction here are inherently forward-looking; the reported record is one of strong demand paired with sharp, recurring price swings.

---

Sources

1. U.S. Census Bureau, County Business Patterns 2023 (NAICS 311512: establishments, employment, annual payroll). https://www.census.gov/programs-surveys/cbp.html
2. U.S. Census Bureau, 2022 Economic Census — Concentration Ratios / Selected Statistics (NAICS 311512: receipts, firm count, establishments, employment, payroll, CR4/CR8/CR20/CR50). https://www.census.gov/programs-surveys/economic-census.html
3. International Dairy Foods Association (IDFA), "You Butter Believe It: Butter Consumption Hits Historic High," 2025. https://www.idfa.org/news/you-butter-believe-it-butter-consumption-hits-historic-high-as-yogurt-cottage-cheese-and-ice-cream-notch-growth-in-2024
4. Jacoby, "The butterfat boom: genetics, supply, and the price squeeze," 2025 (CME butter averages; cold-storage stocks). https://www.jacoby.com/butterfat-boom/
5. Cheese Reporter, "USDA Lowers Most 2025, 2026 Dairy Price Forecasts; CME Butter Price Falls Below $2.00," 2025. https://cheesereporter.com/news/2025/09/12/usda-lowers-most-2025-2026-dairy-price-forecasts-cme-butter-price-falls-below-2-00/
6. Star Tribune, "Butter's popularity boosts Land O'Lakes profit" and "Land O'Lakes delivers a profit for its dairy unit," 2024–2025. https://www.startribune.com/land-olakes-butter/601667192
7. Zippia, "8 Largest Butter Brands in the United States," 2024 (cooperative structures; DFA). https://www.zippia.com/advice/largest-butter-brands/
8. California Dairies Inc., Products — Butter (claims 480 million lbs/year, 20% of U.S. production). https://www.californiadairies.com/products/butter/
9. Wikipedia, "Saputo Inc." (TSX: SAP; butter and butter blends; scale), 2025. https://en.wikipedia.org/wiki/Saputo_Inc
10. NAICS Association, "NAICS Code 311512 — Creamery Butter Manufacturing" (definition and cross-references), 2022. https://www.naics.com/naics-code-description/?code=311512
11. USDA Agricultural Marketing Service, "Butter Grading Information" (manufacturing process description). https://www.ams.usda.gov/grades-standards/butter-grades-and-standards/butter-grading-info
12. USDA Agricultural Thesaurus (buttermilk as co-product). https://lod.nal.usda.gov/nalt/en/page/20627
13. Butter Bell, "Top 5 Butter Brands in the US in 2024" (Challenge, Cabot/Agri-Mark, Darigold histories). https://butterbell.com/blogs/blog/top-5-butter-brands-in-the-us-in-2024
14. Grassland Dairy, "Crafting butter for five generations" (family-owned, Greenwood, WI, since 1904). https://www.grassland.com/
15. Irish Times, "Kerrygold owner Ornua reports €3.4bn revenue while warning of looming tariff shock," 2025. https://www.irishtimes.com/business/2025/04/16/kerrygold-owner-ornua-reports-34bn-revenue-while-warning-of-looming-tariff-shock/
16. U.S. Small Business Administration, Table of Small Business Size Standards (NAICS 311512: 750 employees), 2023. https://www.sba.gov/document/support-table-size-standards
17. USDA National Agricultural Statistics Service (NASS), Dairy Products 2025 Summary, April 2026 (2.39 billion lb, +6.7%). https://www.nass.usda.gov/Publications/Todays_Reports/reports/daryan26.pdf
18. USDA National Agricultural Statistics Service (NASS), Dairy Products 2024 Summary, April 2025 (2.24 billion lb, +5.9%). https://www.nass.usda.gov/Publications/Todays_Reports/reports/daryan25.pdf
19. World Population Review, "Butter Production by State," 2026 (California share; state ranking). https://worldpopulationreview.com/state-rankings/butter-production-by-state
20. Dairy Foods, "Land O'Lakes reports strength in Branded Butter and Foodservice businesses," 2025 (dairy-foods profit; patronage). https://www.dairyfoods.com/articles/97272-land-olakes-reports-strength-in-branded-butter-and-foodservice-businesses
21. Associated Milk Producers Inc., "AMPI Distributes Cash in March," 2019 (120 million lbs butter production). https://www.ampi.com/news/ampi-distributes-cash-in-march
22. Vital Farms, Form 10-K for fiscal year 2025 (butter revenue $26.3M; egg-focused business). https://www.sec.gov/Archives/edgar/data/1579733/000119312526073423/vitl-20251228.htm
23. CME Group, Cash-Settled Butter Futures Rulebook and Dairy Contract Overview. https://www.cmegroup.com/rulebook/CME/II/50/56/56.pdf
24. Statista, "Leading U.S. refrigerated butter brands 2025, based on sales" (private label #1, Kerrygold, Land O'Lakes). https://www.statista.com/statistics/188755/top-refrigerated-butter-brands/
25. USDA Economic Research Service, "Farm Share of Retail Butter Price," 2024 (57% farm share). https://www.ers.usda.gov/data-products/charts-of-note/112838
26. USDA Agricultural Marketing Service, "Butter Grades and Standards / Butter Grading Information" (Grade AA). https://www.ams.usda.gov/grades-standards/butter-grades-and-standards
27. USDA Agricultural Marketing Service, Dairy Mandatory Market Reporting (NDPSR; weekly butter price survey). https://www.ams.usda.gov/rules-regulations/mmr/dmr
28. USDA Agricultural Marketing Service, "USDA Issues Final Rule on Amendments to the Federal Milk Marketing Orders," 2025 (Class IV; butter make allowance $0.2272; 91% recovery). https://www.ams.usda.gov/content/usda-issues-final-rule-amendments-federal-milk-marketing-orders
29. USDA Economic Research Service, "Butter and Margarine Availability Over the Last Century," 2016. https://www.ers.usda.gov/amber-waves/2016/july/butter-and-margarine-availability-over-the-last-century
30. U.S. Dairy Export Council, 2024 Year in Review (butter exports 31,042 MT; AMF exports 13,754 MT). https://www.usdec.org/newsroom/news-releases/news-releases/news-release-2/6/2025
31. Oklahoma State University Extension, "Butter: Chemical and Physical Properties" (1923 Act of Congress; 80% milkfat minimum). https://extension.okstate.edu/fact-sheets/butter-chemical-and-physical-properties-and-health-effects-fapc-253
32. FDA, Butter Compliance Policy Guide (80% milkfat standard of identity). https://www.fda.gov/media/71967/download
33. Cheese Reporter, "USDA Final Rule Amends Butter Plant Records Requirement," 2025. https://cheesereporter.com/news/2025/01/17/usda-final-rule-amends-butter-plant-records-requirement-for-dairy-grading-inspection-program/
34. FDA, FSMA Final Rule for Preventive Controls for Human Food (CGMP, hazard analysis, dairy/PMO guidance). https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-preventive-controls-human-food
35. EPA, Dairy Products Processing Effluent Guidelines (40 CFR Part 405; butter subcategory). https://www.epa.gov/eg/dairy-products-processing-effluent-guidelines
36. RTÉ, "Exports of Kerrygold frontloaded ahead of US tariffs," 2025 (record Irish butter imports; 2025 tariffs). https://www.rte.ie/news/business/2025/0416/1507847-strong-performance-by-kerrygold-for-ornua-in-2024/
37. Iowa State CARD, Summary of 2022 Economic Census Concentration Data (CR4/HHI suppression). https://www.card.iastate.edu/files/publications/pdf/26PB51.pdf
38. USDA Economic Research Service, "Farm Labor" (foreign-born labor in dairy; H-2A limitations). https://ers.usda.gov/topics/farm-economy/farm-labor