The federal food-safety regulator's new recordkeeping rule for traceable foods has been on the books since late 2022, and the compliance date — January 2026 — can feel far enough away to set aside. It isn't. Hard cheeses made from pasteurized milk are already carved out of the rule entirely, but most soft-ripened, washed-curd, and short-aged styles sit squarely inside it, and the exemption boundaries for smaller producers are still being worked out while that clock runs.
Our Membership & Outreach Committee has been fielding calls from members trying to figure out whether their own cheese lands inside or outside the recordkeeping requirement, and the honest answer this week is: it depends on details regulators haven't fully settled yet.
Why this is worth your attention now, not later
This is the window where advocacy actually moves something. Once a final line is drawn between which producers get relief and which don't, it's far harder to get reclassified than it is to make the case for where that line should sit while it's still being drawn. Full lot-level tracing across every batch — recording every ingredient lot against every outgoing case — is a different proposition for a two-person creamery than for an operation with a dedicated quality staff, and that's exactly the distinction we're pressing regulators to recognize before the requirement locks in.
Advocacy on a rule like this depends on members telling us what compliance would actually look like on their floor, not in the abstract. If you make a cheese anywhere near the traceability list, pull together a short, honest account of what full recordkeeping would cost you in hours and dollars: how many batches a month, how you currently track lot codes if at all, and what would break first under the requirement as written. Send it to the Membership & Outreach Committee and we'll fold it into the case members have been building since the rule was first finalized.
Advocacy actions like this only carry weight in volume and specificity. A dozen members describing the same real cost in different words is a stronger case than one polished statement, so don't hold back because you think someone else already said it better — and don't wait for a final exemption announcement to have your numbers ready.
What compliance actually asks of you
The rule's core requirement is a traceability lot code — a single identifier that follows a batch through every critical tracking event, from the day you receive milk or cultures to the day a wheel or wedge leaves your building. For a large operation with inventory software already in place, that's a configuration problem. For a farmstead creamery keeping records on a clipboard, it's closer to building a new system from nothing: assigning lot codes, logging them at each handoff, and being able to hand over that data within 24 hours if it's ever requested. The regulator's own small-entity compliance guide acknowledges this gap exists, which is exactly why the exemption conversation matters as much as the base rule.
Members who make a hard cheese from pasteurized milk can set this aside — that category sits outside the rule already. Everyone else, especially anyone working in the softer, shorter-aged styles that are more associated with foodborne illness risk, should assume they're covered until told otherwise, and should be building basic lot-tracking habits now rather than waiting to see where an exemption line eventually lands.
In the meantime, if you haven't already started keeping basic lot records, even informally, now is a reasonable moment to start regardless of how any small-producer exemption plays out. It's good practice on its own, and it puts you ahead of whatever the final requirement turns out to be when the 2026 deadline arrives.
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.