A landmark clarification. A long time coming. And a reminder that the path forward has always required more than just reading the headlines.
On June 17, 2026, U.S. Citizenship and Immigration Services issued Policy Memorandum PM-602-0200, formally titled Guidance on Temporary or Seasonal Need for H-2A Petitions for Dairying. With good reason, the memo arrived with much fanfare from the industry, with many celebrating the administration’s efforts to expand H-2A program eligibility to a sector that has historically been left in the cold.
But as always, the devil is in the details; beyond the headlines is a significant amount of nuance that dairy employers – and their agents or attorneys – will have to navigate. In that regard, this week’s announcement is less of a groundbreaking policy shift and more of an affirmation of existing rules.
It has always been a misnomer to say that the dairy industry is not eligible for the H-2A program. At másLabor, we often hear this talking point presented as a categorical truth. But the reality is more complicated – the H-2A program requires employers to demonstrate a temporary or seasonal need, and under the current regulatory framework, very few dairies can satisfy the standard.
But “very few” is not “zero.” Indeed, over the years másLabor has worked with several dairy operations to successfully secure labor certifications. The strategy we used? The same one outlined in the new USCIS policy memo.
