There's a labeling comment period open right now, and it's the kind that puts small producers at a disadvantage if they skip it — not because the proposal is hostile, but because the language in these things is usually written by people who've never had to explain their own label to a state inspector standing at the counter. The window on this one closes at the end of the month. The Standards Committee has been drafting a member comment and wants your specific label language in it before that draft goes final.
The proposal itself is narrow: it would tighten what counts as an acceptable description of moisture content and aging duration on packaging for cheeses that don't fit a standard-of-identity category cleanly — which, if you make anything even slightly outside the traditional mold, is probably you. Right now, a lot of small creameries describe their product in language that's accurate but informal ("aged at least 60 days, sometimes longer depending on the wheel"), and the proposed rule would require something closer to a fixed number. That sounds tidy on paper. In practice, it collides with how affinage actually works, where a rind's readiness is a judgment call, not a calendar entry. One member wrote in this week to say her label has used a range for a decade precisely because her cave doesn't run on a fixed clock, and a fixed number would make her technically noncompliant on her own product.
What the committee is asking members to send in
Not opinions. Examples. If your label currently uses a range instead of a fixed aging number, and you've got a reason rooted in how your product actually develops, that's the exact kind of specific, concrete detail that makes a comment land instead of getting filed as one more "please don't" letter. The committee has seen enough of both to know the difference. A one-paragraph comment describing your actual practice, with your actual label language attached, does more work than a page of general objection.
This is also a good moment to be honest about where the current federal dairy picture sits. Milk production forecasts for the year came in a touch lower than expected this month, while the broader price outlook has held up better than the last two winters, easing some of the feed-cost pressure that's been squeezing members since 2022. That combination means most of you have a little more bandwidth to spend twenty minutes on a comment letter than you did last February. Use it while you have it.
Aging language isn't the only thing at stake
Buried in the same proposal is a smaller provision about moisture-content disclosure for washed-rind and bloomy styles, which matters more than it sounds like it should. A handful of members who make in that category have told us their current labels already comply, more or less by accident, and a couple have told us they'd need new packaging runs entirely. If you're not sure which camp you're in, pull your current label and compare it against the moisture-disclosure language in the notice — it's a fifteen-minute read, not a legal review.
None of this is advice about what your label legally has to say today; the current rules stand until this process finishes, whichever way it goes. It's an invitation to say something before the rule is finished being written rather than after, which is the only point in the process where a small producer's actual practice can still change the outcome.
Send your comment, or a draft of one, to the Standards Committee through the member portal. If you'd rather talk it through first, a few committee members are holding office hours this week specifically to help members translate their real labeling practice into comment language that holds up.
The International Cheese Federation (ICF) and More Cheese are entirely fictional. This post is demonstration content created for MemberJunction. All people, organizations, events, courses, certifications, figures, and quotations in it are invented, and nothing here represents a real association, a real business, a real person, or real professional advice.