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Founded in 2011 with a mission to explore how low-temperature drying technology could transform the quality of raw milk proteins, Tamarack Biotics has spent over a decade redefining what’s possible in pasteurisation. Now, the company has achieved a major milestone with FDA approval for its pioneering TruActive process. In this interview, CEO Bob Comstock (pictured left) shares how Tamarack Biotics, in partnership with BioSafeLight, is using cutting-edge UV light technology to eliminate harmful pathogens – all while preserving the natural nutrition and flavour that traditional heat-based methods often destroy.

Founded back in 2011, what initially inspired Tamarack's creation, and its focus specifically on low-temperature drying and raw milk proteins?

We sent a sample of raw milk dried at very low temperatures to UC Davis, and they were amazed that the thermally sensitive components that are normally destroyed by spray drying had survived our low-temperature drying process.

How did the partnership with BioSafeLight come about, and what made their UV technology stand out to you?

I knew the chief engineer of BioSafeLight from his earlier days at SurePure, with whom we initially partnered. The BSL technology offered the ability to achieve a high UV dose without damaging milk’s taste. We then optimised the BSL technology for milk through our own computational fluid dynamics (CFD) study. 

Can you walk us through how the TruActive UV-based treatment works?

What makes it so different from traditional thermal pasteurisation?

UV light inactivates a specific component in DNA and RNA, so bacterial and viral pathogens can’t reproduce. The milk remains very cold, so no thermal damage to the bioactive compounds occurs.  Heat destroys most of these compounds. In fact, milk is the only food that regulations require confirming damage to the food to ensure its safety. 

Tamarack’s process retains over 93% of immune-active proteins compared to just 8% in thermally pasteurised products. How significant is this difference in terms of functional health benefits?

We continue to conduct clinical trials to demonstrate the health benefits created through the availability of these bioactive compounds. UC Davis demonstrated restoration of immune function in the elderly, which makes sense as the same mechanisms involved when a mother imparts immunity to her infant can also positively impact the immune health of elderly people. 

You’ve stated this isn’t ‘just another pasteurisation method’ – what does that mean in terms of how manufacturers and consumers should view TruActive?

We are the first company to receive FDA approval for an alternative to heat for pasteurising milk. Our UV process is safer (kills the bad bugs better), more sustainable (saves energy, chemical cleaning and water), but most importantly preserves the nutritional value of raw milk. We believe the entire dairy industry will eventually convert to UV pasteurisation. 

You currently offer three TruActive products. Can you tell us more about them, and how they’re being used by manufacturers today?

We have produced more than three products at pilot scale, but initially, we believe the dairy industry will adopt UV pasteurisation for extracts such as lactoferrin and the immunoglobulins, as well as whey protein concentrates and milk protein concentrates. Until we complete the final FDA hurdle, we can’t produce anything for commercial use. 

What are your expansion plans in the dairy space – particularly with products like cheese, yogurt, kefir or colostrum?

We are already partnering with leading dairy companies in the production of all dairy ingredients, including liquid milk, yogurt, cheese, etc. Once we receive the final FDA affirmation, we plan to hit the ground running. 

There’s growing interest in functional dairy. Could you share more about clinical studies? What are the most exciting findings so far?

We have ongoing clinical trials for preventing children from developing allergies, improving microbiome and gut health and even sports nutrition investigations into performance and recovery, with a leading research hospital.

How do TruActive products support health outcomes like childhood allergy prevention, elderly vaccine response or athletic recovery?

Milk’s bioactivity is truly amazing, and we continue to be surprised by the outcomes of these clinical trials. There are hundreds of proteins in milk, and their collective functionality strongly modulates our immune systems. We don’t believe there are any magical compounds in milk, but rather these thermally sensitive compounds synergistically work to create healthier outcomes. 

Gaining FDA acceptance in June 2025 is a huge step – congratulations. What did that process involve, and what does it unlock for Tamarack going forward?

Our UV process is now considered legal pasteurisation of raw skim milk. We continue to expand the approval to cover colostrum, whole milk, and even extend the shelf life of milk. Gaining this approval involved proving our UV process inactivated all possible pathogens that could likely be found in milk. This was a long and difficult process as many pathogens are very dangerous and difficult to even get access to for testing.

You’re currently under review by EU regulators. How are you preparing for entry into the European market? What opportunities do you see there?

Yes, we will enter the European market with partners and we are talking to most of the major European dairy ingredient producers. 

The TruActive process uses significantly less energy than thermal methods. Can you quantify the sustainability benefits, and why should this matter to F&B and dairy manufacturers?

There are significant energy reductions in terms of steam and electricity usage as well as CIP chemicals and water savings. When you thermally pasteurise milk, you must heat it to 72ºC (162ºF) for 15 seconds, which requires considerable steam, and then you must cool it back to 4ºC (39ºF), which requires considerable electrical energy. 

As the milk isn’t heated, fouling during dairy processing doesn’t occur. This is a huge headache for dairy ingredient producers today, and they must routinely shut down to perform cleaning and anti-fouling processes. With UV pasteurisation, fouling just doesn’t occur. 

Are you seeing any particular shifts in consumer behaviour or brand innovation that align with what Tamarack is offering?

We definitely recognise the trend toward more natural, minimally processed foods and will gain traction as UV light retains the natural state of raw milk. We believe TruActive will be able to fit into the future of dairy manufacturing and that everyone will eventually use these UV processes.

Where do you see the biggest growth opportunities for UV-treated dairy products over the next five years, and what is next for Tamarack Biotics?

Initially, in the extracts such as lactoferrin, immunoglobulins and osteopontin, but also all of the protein concentrate powders, which are used in so many dairy products today. We are working with many partners to prepare for the final FDA approval and product launches.