CFDA, page-167

thats correct.....however it is all theoretical at this point....no one has applied to change and existing registered formula yet........
the source of the milk is not a critical aspect of SMAR/CFDA registration.
there would not be a major change in the nuritional composition of a registered formula by changing from non-organic to organic........

if you had an exclusive "jersay sourced milk" for example and changed to an exclusively holstein sourced herd"....for example if oyu were making a single species sourced milk as a marketing differentiator.....the change from one cow type to another may not even required a change in registration......

but once again, this is a non-issue for WHA at the moment as they dont (1) have their CFDA yet and (2) organic is 18 months away at the earliest.......