Fille milk is skim milk that has been reconstituted with fats from sources other than dairy cows. Dairy milk from cows is of a certain quality, taste and texture that lends itself to the production of ice cream, sour cream, whipping cream, half-and-half among other dairy products. Removing milk fat and replacing it with other fats such as coconut oil or palm oil became a cost saving measure used by industry in the early 20th century. The United States Congress eventually banned such practices via the "Filled Milk Act" of March 4, 1923 (c. 262, 42 Stat. 1486, 21 U.S.C. § 61–63, which prohibited the shipment in interstate commerce of skimmed milk compounded with any fat or oil other than milk fat, so as to resemble milk or cream.