 At the time, liquid milk was not widely available or very popular in cities because of the rarity of refrigeration and the problems of transportation and storage.In 1923, the United States Congress banned the interstate sale of filled milk "in imitation or semblance of milk, cream, or skimmed milk" via the "Filled Milk Act" of March 4, 1923 (c. 262, 42 Stat.1486, , in response to intense lobbying by the dairy industry, attempting to protect its market against competition by cheaper foreign fat.