THIS REPORT CONTAINS ASSESSMENTS OF COMMODITY AND TRADE ISSUES MADE BY USDA STAFF AND NOT NECESSARILY
STATEMENTS OF OFFICIAL U.S. GOVERNMENT POLICY
Required Report: Required - Public Distribution Date: February 14,2020
Report Number: IN2019-0111
Report Name: Dairy and Products Annual
Country: India
Post: New Delhi
Report Category: Dairy and Products
Prepared By: Amit Aradhey
Approved By: Mark Wallace
Report Highlights:
Assuming a normal monsoon season (June-September), India’s fluid milk production is forecast to rise
from an estimated 191 MMT in Calendar Year (CY) 2019 to 195 million metric tons (MMT) in CY 2020 (out-
year). CY 2020 Non-Fat Dry Milk (NFDM) exports are projected at 15,000 metric tons (MT). Butter exports
will improve slightly to 55,000 MT on expectation of moderate export demand. Since milk production is
growing in tandem with domestic consumption, any uptick in future demand for milk-based products may
encourage imports.
Page 2 of 13
Executive Summary
Assuming a normal monsoon season, India’s fluid milk production is forecast to rise from an estimated 191
MMT in CY 2019 to 195 MMT in CY 2020. Increasing disposable incomes per capita, rapid urbanization,
changing lifestyles, dual income households, and other demographic shifts are driving the demand for
processed or value-added dairy products. Out-year NFDM exports are projected at 15,000 MT. Butter
exports will slightly improve to 55,000 MT on expectation of moderate export demand.
Despite the growth, a few challenges must be addressed to optimize growth in the Indian dairy sector. A
few such challenges are low milk productivity of Indian bovine animals relative to those of developed
countries; insufficient feed and fodder resources; poor access of milk producers to the cold chain; and an
inefficient cold chain network.
Since milk production is just enough to meet domestic consumption (fluid and industrial use), any uptick in
future demand for milk-based products may be filled through imports, which are currently restricted for
the United States due to a veterinary health certificate requirement.
Commodities:
Dairy, Milk, Fluid
Dairy, Milk, Nonfat Dry
Dairy, Butter
PRODUCTION
Assuming a normal 2020 monsoon season, India’s fluid milk production is forecast to rise from an
estimated 191 MMT in CY 2019 to 195 MMT in the out-year. Rising population and growing income
inform this milk production forecast. NFDM production levels are estimated at 660,000 MT on growing
domestic demand for reconstituted milk during the lean season and expectations of moderate export
demand. Similarly, combined butter and ghee (clarified butter) production will rise to 6.1 MMT against 5.8
MMT last year on strong consumption demand.
Some 80 million Rural Households are Engaged in Milk Production as a source of their livelihood, the
majority of which are small, marginal farmers and landless. For farmers, startup costs are lower and cash
flow is steadier in dairy farming than with seasonal planted crops. However, unlike the larger herd sizes of
leading milk producing countries in the world, some 95% of milk producers in India hold just 1 to 5 milch
animals per household, which makes this little more than a subsistence-level farming system [Source:
Department of Animal Husbandry and Dairy (DAHD)
1
, Government of India (GOI) Annual Report 2018/19].
Dairy farms sized from 50 to 200 cattle are increasing in some of the major dairy states such as Punjab,
Gujarat, Maharashtra, and Telangana/Andhra Pradesh, although they are still few.
1
It’s separate Ministry now. DAHD comes under Ministry of Fisheries, Animal Husbandry and Dairying, GOI
Page 3 of 13
Six States Contribute 60 Percent of Total Milk Production
According to the latest dairy statistics
2
available from DAHD, GOI, the top six milk-producing states are
Uttar Pradesh (16.3%), Rajasthan (12.6%), Madhya Pradesh (8.5%), Andhra Pradesh (8.5%) Gujarat (7.7%)
and Punjab (6.7%). Together they accounted for 60 percent of total milk production in Indian Fiscal Year
(IFY) 2018/2019 (April-March). Also, the per capita availability of milk in India was estimated at 394
grams/day (national average).
Cross-bred Cattle Contribute 26 Percent of Milk Production
According to the 2019 Livestock Census, the milch cattle population of exotic breeds and cross-breeds has
increased by 32 percent over the last Census (2012) and has significantly contributed to overall milk
production: those breeds have higher milk yield of 7.95 kg/cow against 3.01 kg/cow for indigenous breeds.
Concurrently, between the two Censuses, the relative share of cow’s milk versus buffalo milk grew 3
percent to 48 percent. Of that, exotic and crossbreeds contributed 26%; the remaining 22% was produced
by indigenous breeds.
The state of West Bengal now leads the cattle population (9.85%) in India, followed by Uttar Pradesh
(9.7%), Madhya Pradesh (9.7%), Bihar (7.9%), Maharashtra (7.2%) and Rajasthan (7.2%). The 6 states
together constitute fifty percent of India’s total cattle population (20th Livestock Census).
Buffalo Milk Constitutes 49 Percent of Indian Milk Production
Between the last two Livestock Censuses (2019 and 2012), the milch buffalo population increased only
marginally (0.2%), wherein the in-milk buffalo population rose 4.3%, while the ‘dry’ declined 10.2 percent,
the result of selective breeding… An estimated 49 percent of India’s milk production originates from water
buffalo (35 percent indigenous buffalos and 14 percent non-descript buffalos (ones which are not selected
or bred for productivity). Uttar Pradesh has the heaviest concentration of buffalo population at 33%,
followed by Rajasthan (12.4%), and Madhya Pradesh (9.5%).
Water buffaloes are preferred by some farmers since their milk holds higher fat content, which fetches
higher prices at market. (Milk prices are determined by volume, fat, and solids-not-fat, or SNF content.)
Also, throughout India water buffaloes may be sold for slaughter; by contrast the slaughter of cattle is
banned in most Indian states, which makes the maintenance of expired cows a costly but unproductive
asset. By contrast, expired goats can be sold for slaughter. Perhaps for that reason, although their share
of milk production is only 3 percent, is growing in states like Rajasthan (13.8%) and West Bengal (10.9%).
Some Key Factors Affecting Milk Productivity
Key factors affecting the productivity of dairy cows include low genetic potential of Indian bovines, lack of
nutritious and balanced feed rations, and inadequate veterinary services. Per DAHD’s latest annual report
(IFY 2018-19), the average milk yield in India, including indigenous cattle, crossbreeds, exotic cattle, and
2
For Indian financial year 2018/19
Page 4 of 13
water buffalo is 3.7, 7.6, 11.5 and 6.2 kilogram per day, respectively. Those figures contrast dramatically
with production figures in the United Kingdom (22 kg per day) and the United States (30 kg per day). In
addition, the availability of feed and fodder is another major challenge; improved availability of feed and
fodder will improve productivity of bovine animals.
According to GOI’s report, by 2020 India may face significant deficits of dry fodder, green fodder, and
concentrates to the extent of 11, 35 and 45 percent against estimated demand of 468, 213 and 81 MMT,
respectively. Currently only four percent of the cropping area is under fodder cultivation. That number
may not increase substantially due to competing use of agricultural land for food and other cash crops
(Source: National Action Plan on Fodder and Feed Security, DAHD, GOI). The use of compound cattle feed
is just 8-10 MMT against the total feed requirement of around 80 MMT.
Fluid Milk Prices
Industry sources note that dairy cooperatives set farm gate fluid milk prices. These prices generally are
benchmarks for private players procuring milk in the region. The dairy cooperatives consider factors such
as increases in costs for feed, fodder and other inputs when revising farm gate milk prices. Though the
retail price of milk has gone up, cost of production has gone up even higher. After settling lower CY 2018
(Figure 1), the input cost of fodder, mustard, and cottonseed oil cake increased at a compound annual
growth rate of 10 percent, 4 percent, and 24 percent, respectively, while milk prices
3
increased by only 2.5
percent. To offset some of the loss in profits, State governments do give subsidies (e.g., as cash transfer
to bank accounts) to improve producers’ margins.
In the last few months, milk supply across various states did not meet demand: erratic rainfall distribution
had driven feed and fodder prices higher, cow productivity declined, and farm gate milk prices rose
accordingly in response to the supply shock.
3
Indicative: The average retail price of for milk in Delhi-NCR during December 2019 reportedly ranged between INR 39 to
55 per liter ($0.55 to $0.78 per liter) for different grades (double toned to full cream milk). Generally speaking, water
buffalo milk (six percent fat and nine percent SNF) sells at a premium over cow’s milk, which is four percent fat and eight-
and-a-half percent SNF.
Page 5 of 13
Figure 1. India: Rising Feed Costs and Milk Prices (Fiscal Year-April-March)
Source: Ministry of Commerce and Industry, Government of India
Production Policies and Programs
DAHD and various State governments implement programs for breed improvement, dairy development,
feed and fodder resources development, and animal disease control. DAHD supports states to implement
a national control program for diseases such as Foot-and-Mouth Disease and Brucellosis. It also monitors
animal diseases across the country through a web-based national disease reporting system.
Under Rashtriya Gokul Mission, the department focuses on development and conservation of indigenous
breeds
4
such as Tharparkar, Gir, Red Sindhi, Rathi, Kankrej and Sahiwal to increase the genetic potential of
the unregistered bovine population and milk productivity. It also supports state governments to subsidize
the cost of animal insurance to the milk producers.
The National Dairy Development Board (NDDB) also has developed an Information Network for Animal
Productivity and Health (INAPH), an information technology application to collect data on breeding,
nutrition, and health services. The animals registered in the network are also ear tagged with a unique
identification number.
4
The bovine genetic resource of India is represented by 41 registered indigenous breeds of cattle and 13 registered buffalo
breeds. Indigenous bovine are considered to be robust and resilient and are particularly suited to the climate and environment
of their respective breeding tracts. The milk of indigenous animals is high in fat and SNF content. (Source: DAHD)
Page 6 of 13
The GOI is pushing to strengthen infrastructure for the production of quality milk, as well as for
procurement, processing, and marketing of milk and milk products through the following Dairy
Development Schemes:
National Program for Dairy Development (NPDD), which now has two components 1) National
program for bovine breeding 2) and National program for dairy development. Focus is on
strengthening of milk production, procurement, processing and marketing by the State
implementing agency.
National Dairy Plan (NDP Phase-I
5
) is a multi-state initiative to increase productivity of milch
animals through breed improvement and animal nutrition. It also aims to provide rural milk
producers with greater access to the organized milk-processing sector. The NDP Phase-2 is likely
this year (2020) with primary focus on developing milk processing infrastructure and establishment
of milk quality testing equipment at critical points of procurement areas (media report citing
NDDB).
Dairy Entrepreneurship Development Scheme (DEDS) implemented through National Bank for
Agriculture and Rural Development (NABARD) for self-employment and infrastructure
development of the dairy sector.
Scheme to support to Dairy Cooperatives and Farmer Producer Organizations engaged in dairy
activity. It is implemented by NDDB with objective to provide soft loan to state dairy cooperatives
(working capital) and provide stable market access to dairy farmers while ensuring timely payment
and remunerative price for procuring milk.
Dairy Processing and Infrastructure Development Fund (DIDF) introduced in Dec 2017. Objective is
to modernize milk processing facilities for manufacturing high value-added milk products.
The issue of ensuring availability of safe, wholesome, and high-quality food, including milk and milk
products, comes under purview of Food Safety & Standards Act 2006, which is implemented by Food
Safety & Standards Authority of India through the Food Safety Commissioners in the respective states.
This Department regularly reviews the milk supply situation in the country with NDDB and State Milk
Federations. Concerns and actions about adulteration of milk are taken in consultation with the Food
Safety and Standards Authority of India (FSSAI).
CONSUMPTION
The CY 2020 fluid milk consumption is projected at 81 MMT, up 2.5 percent in comparison to the previous
year on rising population and growing income. For the largely vegetarian population, in addition to pulses,
dairy and dairy products are the primary source of proteins for nearly all consumer groups in India. Driven
by population and income increases, CY 2020 NFDM and butter consumption is forecast to increase to
640,000 MT and 6 MMT, respectively. The consumption of other value-added dairy products is also
5
An externally aided project expected to end sometime in November 2019
Page 7 of 13
growing. The demand for ghee (clarified butter) and butter, for example, is still robust (ghee is one of the
most consumed value-added dairy products).
The demand for fermented dairy products such as yoghurt, yoghurt drinks, processed cheese, cheese (e.g.,
mozzarella, spread, flavored and spiced), and ice-cream is also growing substantially, particularly among
the urban middle and high income consumer segments (see Distribution and Processing Section below).
Since milk production is just enough to meet current domestic consumption, any uptick in future demand
for milk-based products likely must be filled through imports.
Demand Drivers
Increasing disposable incomes, rapid urbanization, changing lifestyles, dual income households, and other
demographic shifts are driving the demand for processed or value-added dairy products. Additionally, the
expanding organized retail sector is helping drive sales of processed dairy products (15-20 percent annual
growth). Also, in addition to being rich with other nutrients, milk is the primary source of animal protein
for the largely vegetarian population of the country.
Milk Distribution and Processing
Presently, the total installed capacity of milk processing in India is 66.3 million liters per day at Indian
dairy cooperatives, (operating at 65 percent capacity), 73.3 million liters/day at private sector companies,
and 2.5 million liters/day at producer companies, (Indian Dairy Vision-2022). Unlike the unorganized ad
hoc milk sector, these companies have wide procurement and distribution networks, which include milk
collection centers and chilling centers at the village level.
The milk collected at these centers is processed in dairy plants, which involves pasteurization,
standardization, branding, packaging, and preparation of value-added products. Of total Indian milk
production, an estimated 48 percent is either consumed at the producer level or sold to small outlets in
the rural area; the remaining 52 percent is what is processed and made available for sale to consumers in
urban areas (Source: DAHD, GOI).
a) Marketable Surplus:
Of this 52 percent, currently about 40 percent milk sales are handled by the organized sector
(cooperatives and the private sector); the remaining 60 percent is handled by the unorganized sector. By
2022, the GOI’s National Action Plan for Dairy Development seeks to double organized milk handling from
20 percent to 41 percent of total milk production, which should give milk farmers greater access to the
organized milk-processing sector and ultimately greater incomes.
According to industry estimates, an estimated 70 percent of processed milk is sold as fluid milk and the
remainder is used in manufacture of value-added milk and milk products. Of many such products, the
market for packaged milk is one of the faster growing segments. It is marketed as pasteurized milk (either
as a mix of cow and buffalo milk or in pure form, more details below) in various percentages of fat
Page 8 of 13
content
6
. Concerns about milk safety and quality
7
drive strong demand for packaged, ultra-high
temperature (UHT) milk, which is sold in aseptic packaging and comes with a longer shelf life.
b) Milk Collection and Food Safety:
Most of the private and cooperative dairies do not have separate collection systems for cow and water
buffalo milk, so their packaged milk product is mostly a mix of the two; only a few processors market pure
cow milk. The collection of milk from predominantly small-sized dairy farms in India is a huge challenge
and still requires investment in infrastructure and procurement systems. Food safety remains a major
challenge since a large part of India’s total milk production is handled and marketed by small vendors who
have limited exposure to efficient handling of milk and lack the capital or incentives to comply with
regulations which increase their cost of production.
c) GOI Schemes:
To address the food safety issues and improve the quality of milk in the supply chain, the GOI is already
implementing a program on improving milk quality and ensuring food safety at the farm and village level.
One such scheme is titled, “Strengthening Infrastructure for Quality and Clean Milk Production”.
Additionally, the creation of a separate Dairy Processing and Infrastructure Development Fund (DPIDF)
following the 2017 Union Budget announcement was to create a milk-processing infrastructure during the
period April 2017 through April 2020. GOI’s Ministry of Food Processing Industries also provides subsidies
to the private sector and dairy cooperatives to build cold chain infrastructure.
TRADE
Exports
India consumes almost all its domestic dairy production, but some value-added dairy products such as
NFDM, cheese, and lactose products, as well as casein, butter, and ice cream are exported when prices are
competitive and overseas demand is strong. Rising domestic milk production in 2020 and anticipated firm
international demand for NFDM will drive exports from 10,000 MT in 2019 to 15,000 MT in the out-year.
The January-October 2019 trade data indicate that India exported SMPs worth $16.9 million on shipments
of 8,370 MT, which is 56% below the corresponding period in 2018 on lower than expected purchases
from regular buyers such as Bangladesh (the largest buyer), Afghanistan, Malaysia, Pakistan, and UAE. Post
has revised the export estimate down to 10,000 MT.
6
Available variants in the market include: full cream milk (6 percent fat and 9.0 percent solid not fat (snf)), standardized milk
(4.5 percent fat and 8.5 percent snf), toned milk (3 percent fat and 8.5 percent snf), double toned milk (1.5 percent fat and 9
percent snf) and skim milk (not more than 0.5 percent fat and 8.7 percent snf).
7
In November 2019, the FSSAI has issued a 12-point action plan to ensure the safety and quality of milk and milk products in
the country. The action plan mainly focuses on testing and continued surveillance, preventive and corrective action for
implementation and monitoring, and consumer engagement.
Page 9 of 13
Total butter exports in 2020 are expected to rise from 50,000 MT in 2019 to 55,000 MT, due to modest
demand from traditional and new buyers. Trade data from Jan-Oct 2019 indicate total sales at 39,700 MT,
at estimated value of $168 million. Principal buyers include Egypt, UAE, Saudi Arabia, Australia and the
United States of America.
Imports
India’s major dairy product imports include milk powder, fats and oils, casein, butter, whey, cheese, and
lactose. Post forecasts negligible imports of NFDM and butter in 2020 due to growing domestic
production. Historically, India has only imported milk powder and butter in limited quantities when it was
apparent that domestic production was insufficient or to help control inflation. Trade data for Jan-Oct
2019 shows the combined import of NFDM and butter will be close to 1000 MT with value just over $4
million. In 2018, both NFDM and butter imports for 2018 fell for the third-consecutive year to a little less
than 1000 MT, valued at $3.4 million.
India’s veterinary health certificate requirements currently restrict dairy imports from the United States of
America. India continues to insist on religious and cultural grounds that dairy products be derived from
animals which have never received any feed produced from internal organs, blood meal, and tissues of
ruminant origin.
Trade Policy
Currently, several trade restrictions limit market access for U.S. food products. Imports of most
livestock and livestock-derived food products (including milk and milk products) were effectively
banned due to established Indian import requirements (India Exporter Guide: IN2019-0105).
On November 28, 2019, FSSAI published a notification on ‘revised’ standards of milk and milk
products in the Official Gazette of India. The implementation date is July 1, 2020 (More info at
IN2019-0102). FSSAI promulgated the draft standards of milk and dairy products notified earlier to
the World Trade Organization (WTO) in December 2015 for comments. The regulation came into
effect on October 13, 2017 (GAIN IN7129)
8
. The Food Safety and Standards Regulation is applicable
equally to both domestic and imported foods. Some labelling and compliance issues that came up
between now and then were reported (GAIN IN-9009).
The import of milk and dairy products into India requires a sanitary import permit
9
from DAHD and
a veterinary health certificate from the exporting country’s veterinary authority. India’s import
certification requirements for milk and dairy products are available on the DAHD website
(http://dahd.nic.in/trade). India applies in-quota tariff rate (TRQ) of 15 percent for imports of NFDM
8
Milk, flavored milk, evaporated or concentrated milk, sweetened condensed milk, khoya, cream and malai, milk fats including
anhydrous milk fat, anhydrous butter oil, butter oil and ghee, butter, milk powder and cream powder, dairy whitener, whey
powder, fermented milk products, ice-cream, kulfi, chocolate ice cream, soft ice cream, milk ice or milk lolly, dried ice cream
mix, frozen dessert or confections, chhana and paneer, cheese and cheese products, edible casein products, lactose, and infant
foods (GAIN IN7129)
9
http://dadf.gov.in/sites/default/filess/SIP-Validity0001.pdf
Page 10 of 13
and imports above the TRQ are levied tariffs of 60 percent. More information on tariff structure is
available on Table 1.
The revised procedures for import/export of bovine germplasm (revised April 2016) are reportedly
less restrictive and are available on the following link revised guidelines. However, import of
bovine germplasm requires multiple approvals at the state and federal level, which restricts trade
significantly. The veterinary health certificate for import of various livestock products is available on
Animal Quarantine and Veterinary Services, DAHD, GOI. The following links lead to information
regarding the various sanitary import requirements (bovine semen, bovine embryo from USA and
bovine semen from USA).
According to the notification from the Director General of Foreign Trade (DGFT), GOI, China’s milk
and milk products (including chocolates and chocolate products, candies, confectionary, and food
preparations made with fluid milk or dairy solids as an ingredient) may not be imported until all
laboratories at the port of entry have been upgraded to test for melamine (DGFT Notice 1/2015-
2020).
On February 1, 2020, Finance Minister Nirmala Sitharaman presented the Government of India’s
(GOI) annual budget for Indian Fiscal Year (IFY) 2020/21. The GOI, with immediate effect, increased
tariffs on several food and agricultural products, including dairy products. Basic import duty on
butter, ghee and butter oil (HS Code 0405) has been raised from 30 percent to 40 percent. This year,
the GOI’s Tax Research Unit issued this hyperlinked ‘notice’ to India’s Customs Commissioners of
various tariff changes as part of the Finance Bill 2020.
The above notice omits preferential duty rate for imports of products under the tariff rate quota
for ‘milk and cream’. The following entry was omitted vide notification No. 1/2020-Customs dated
February 12, 2020. Omitted entry Vide S. No of Notification No. 50/2017 Customs dated June 30,
2017, a concessional Basic Customs Duty (BCD) of 15% was prescribed on milk and cream (in powder
or granules or other solid forms) falling under sub-heading 040210 or tariff item 0402 2100, up to an
aggregate of 10,000 MT of total imports of such good in a financial year.
Kindly Note: Please see Table 1 below for more information on tariff structure on various dairy items, as
compiled from CBIC, Dept of Revenue, GOI.
Page 11 of 13
Source: www.cbic.gov.in
Page 12 of 13
PRODUCTION, SUPPLY AND DEMAND DATA STATISTICS
Table 2. India: Commodity, Dairy, Milk, Fluid, PSD, 1000 MT
Dairy, Milk, Fluid
2018
2019
2020
Market Begin Year
Apr 2018
Apr 2019
Apr 2020
India
USDA Official
New Post
USDA Official
New Post
USDA Official
New Post
Cows In Milk
58500
52482
60600
54600
62400
56450
Cows Milk Production
87800
89800
91300
92000
95200
94000
Other Milk Production
98000
97900
102900
99000
107000
101000
Total Production
185800
187700
194200
191000
202200
195000
Other Imports
0
0
0
0
0
0
Total Imports
0
0
0
0
0
0
Total Supply
185800
187700
194200
191000
202200
195000
Other Exports
9
9
10
10
0
10
Total Exports
9
9
10
10
0
10
Fluid Use Dom. Consum.
76180
77000
77680
79000
80800
81000
Factory Use Consum.
109611
110691
116510
111990
121400
113990
Feed Use Dom. Consum.
0
0
0
0
0
0
Total Dom. Consumption
185791
187691
194190
190990
202200
194990
Total Distribution
185800
187700
194200
191000
202200
195000
Table 3. India: Commodity, Dairy, Milk, Nonfat Dry, PSD, 1000 MT
Dairy, Milk, Nonfat Dry
2018
2019
2020
Market Begin Year
Jan 2018
Jan 2019
Jan 2020
India
USDA Official
New Post
USDA Official
New Post
USDA Official
New Post
Beginning Stocks
30
30
15
15
30
35
Production
600
600
635
630
670
660
Other Imports
0
0
0
0
0
1
Total Imports
0
0
0
0
0
1
Total Supply
630
630
650
645
700
696
Other Exports
43
43
10
10
15
15
Total Exports
43
43
10
10
15
15
Human Dom. Consumption
572
572
610
600
640
640
Other Use, Losses
0
0
0
0
0
0
Total Dom. Consumption
572
572
610
600
640
640
Total Use
615
615
620
610
655
655
Ending Stocks
15
15
30
35
45
41
Total Distribution
630
630
650
645
700
696
Table 4. India: Commodity, Dairy, Butter, PSD
Dairy, Butter
2018
2019
2020
Market Begin Year
Apr 2018
Apr 2019
Apr 2020
Page 13 of 13
India
USDA Official
New Post
USDA Official
New Post
USDA Official
New Post
Beginning Stocks
9
9
0
0
0
0
Production
5600
5600
5850
5850
6100
6100
Other Imports
1
1
0
0
0
0
Total Imports
1
1
0
0
0
0
Total Supply
5610
5610
5850
5850
6100
6100
Other Exports
33
33
50
50
45
55
Total Exports
33
33
50
50
45
55
Domestic Consumption
5577
5577
5800
5800
6055
6038
Total Use
5610
5610
5850
5850
6100
6093
Ending Stocks
0
0
0
0
0
7
Total Distribution
5610
5610
5850
5850
6100
6100
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