Apostrophe Placement with Cow's Milk and Goat's Cheese

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The Quick Answer

The milk you buy from a shop is "cow's milk" not "cows' milk."

I cannot drink warm cow's milk.

The apostrophe goes before the "s" because it is the milk of a cow (i.e., of an animal known as a cow). In other words, it is not about how many cows produced the milk. It is about what kind of animal produced the milk. It is the same with "goat's cheese."

I find goat's cheese too overpowering.

cow's milk and goat's cheese (apostrophe placement)

Cow's Milk or Cows' Milk?

Writers are often unsure whether to write "cow's milk" or "cows' milk." This confusion arises because of a rule for the possessive apostrophe, which states that the apostrophe goes before the "s" for a singular possessor (e.g., one dog's kennel) but after the "s" for a plural possessor (e.g., two dogs' kennel).

With milk, however, there is a quirk. It is not about how many cows produced the milk. It is about what kind of animal produced the milk. This is why the milk we put in our coffee is "cow's milk" (the milk of an animal called a cow) and not "cows' milk" (the milk from several cows). For example:

I'm not sure this is cow's milk.
I'm not sure this is cows' milk.

There are, however, times when "cows' milk" is correct. (There's more on this below.)

Cow's Milk

The milk you buy from a shop is "cow's milk." (It translates best as "the milk of a cow" with the idea being "the milk of an animal known as a cow" as opposed to "the milk of a single cow.") For example:

Did you put cow's milk in the jug? It smells a bit like goat's milk.

It is possible for "cow's milk" to be used in a slightly different context (i.e., when you're referring to one specific cow). For example:

I have two cows. This cow's milk is fine, but that cow's milk is watery.

Cows' Milk

Of course, a situation could also arise when you need to talk about the milk of specific cows. For example:

I have two herds of cows. These cows' milk is fine, but those cows' milk is watery.

Goat's Cheese or Goats' Cheese?

The same situation applies to cheese made from goat's milk. Again, it is not about how many goats produced the milk for the cheese. It is about what kind of animal produced the milk for the cheese. In other words, it is "goat's cheese" (from an animal called a goat) and not "goats' cheese" (from several goats). For example: