Our advocacy team has been tracking a comment period touching interstate cheese shipment requirements, and so far the submissions skew heavily toward larger shippers and cold-chain logistics firms. Small and mid-sized producers are underrepresented, which matters because the rule as drafted would apply the same paperwork threshold to a two-person farmstead operation as it does to a regional distributor. We think that threshold needs a size-based carve-out, and we need more of you on the record saying so.
A member who ships direct to a handful of out-of-state retailers put it to us plainly on a call this week. "I can meet the standard," she told us. "I can't meet it and also run the make schedule if the paperwork triples." That is the exact distinction we are trying to get into the record — not opposition to shipment oversight, but a proportional bar for smaller operations. It echoes a pattern we have seen in other recent federal traceability proposals, where a rule written with the largest shippers in mind ends up costing a small creamery disproportionately more of its week.
What we are asking members to submit
If you ship product across state lines, even occasionally, we would like your comment in the docket before it closes. You do not need to be a policy expert. A short, specific account of what the current process actually requires of your operation — how many shipments a year, what documentation you already keep, what a tripled requirement would cost you in time — is more persuasive to a rulemaking body than a general objection. Our government affairs volunteers can help you find the right filing format if you have never submitted a comment before; reach out through the Membership & Outreach Committee and someone will walk you through it this week, before the window closes.
Where this sits alongside our other advocacy work
This comment period is separate from the ongoing conversation about raw-milk aging rules, though both fall under the same broader push: rules that scale to the size of the operation they govern, rather than a single standard written with the largest players in mind. Members who submitted testimony on the aging-rule question earlier this year already know the drill — the same plain, specific approach works here too. We will keep members posted as the docket moves, and we will flag the filing deadline again once it is set, so you are not scrambling in the last week.
Export demand has been strong enough this year that some members are also weighing whether to ship out of state for the first time, which is exactly the audience this comment period was written for and mostly hasn't heard from yet. If that describes you, this is doubly worth ten minutes of your week.
If paperwork compliance is already eating into your week regardless of how this rule lands, our Food Safety & HACCP coursework touches on documentation practices that can make a filing like this one faster next time. Not required reading for this comment period, but worth knowing about if recordkeeping is a recurring headache for your operation.
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.