The federal food-safety regulator reopened its comment period this summer on a question that sounds narrow but isn't: how much ultrafiltered milk can go into a cheese before it stops being made the way the standard says it should be made. If you make a standardized cheese and you've ever used ultrafiltration to concentrate protein before culturing, this is the rulemaking that decides whether your process counts as compliant or as something that needs a different label.
It's a technical question with a very practical answer for members. A creamery that's built its whole production line around ultrafiltered milk needs the rule to land in a place that doesn't force a relabel or a reformulation overnight. A smaller maker who's never touched the technology mostly needs to know the standard won't shift under a cheese they're already selling under a name customers recognize.
This isn't a new fight, and it's worth knowing that going in. The federal government's own regulatory agenda, published earlier this year, lists this rulemaking as still open after a long history of proposals, guidance, and comment periods on exactly this question, and a final rule has been expected and then delayed more than once. That pattern is a reasonable sign that a well-documented comment from a working creamery carries more weight here than it might in a faster-moving rulemaking — the agency has shown it's willing to keep the window open when the input warrants it.
Why the Standards Committee is asking now
Our Standards Committee has been tracking this question for longer than the current comment window has been open, because it touches the same standard-of-identity language that governs what a member can legally call "cheddar," "mozzarella," or a dozen other names on a label. A comment period like this is exactly the moment member experience is most useful to the record — not general support or opposition, but specifics: what a rule change would actually require you to do differently on your production floor. We're not going to tell you what position to take. We are going to tell you that a rule written without input from small and mid-sized producers tends to assume a scale of operation that doesn't match most of our membership, and that's a gap only members can close. A large processor with a dedicated regulatory-affairs team is going to file a comment either way. A two-person creamery usually doesn't, and that's exactly the voice a comment period like this tends to be missing.
If you're not using ultrafiltered milk at all, this may feel like someone else's problem, and for most of your operation it is. But standard-of-identity language has a way of touching adjacent categories once it's rewritten — a change to how one cheese category is defined can shift how inspectors read a related category during a routine visit, even when nothing in your own process changed. That's part of why the committee wants a wide range of member input, not just comments from creameries that use the technology directly.
What to do before the window closes
If ultrafiltration is part of how you make a cheese that carries a standardized name, read the notice yourself rather than relying on someone else's summary — the specifics of your process are what matter here, not the general shape of the debate. Then send your comment through the regulator's own docket, and separately, let the Standards Committee know what you filed. We're keeping an informal tally of member positions so the committee can speak to patterns, not just individual voices, when this comes up in front of the federation's own policy conversations.
If you're not sure whether your process is affected, that's a fair question to bring to the committee directly rather than guess. A five-minute call now is cheaper than finding out after the rule is final that your make sheet needs to change.
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.