Four months until the small-producer deadline

The compliance date most of our larger members already cleared back in January doesn't apply to everyone the same way. Operations selling between twenty-five and two hundred fifty thousand dollars a year in gross food sales — a category that catches more small and mid-size creameries than the name suggests — have until the end of January 2020 to come into line with the federal preventive-controls rule. That's four months out, and we're hearing from enough members who thought "qualified exempt" meant "exempt, full stop" that it's worth walking through the difference now rather than in December.

"Qualified exempt" is not the same as excused. A very small business under this threshold still has to keep records showing it qualifies, still has to meet basic labeling requirements naming the business responsible for the food, and can still lose the exemption if a regulator determines it poses a public-health risk that outweighs the exemption's purpose. What it doesn't require is the full written food-safety plan that larger operations have spent the last two years building out. That distinction — lighter paperwork, not no paperwork — is where several members told us they'd been operating on an outdated assumption.

Where the confusion comes from

The rule's thresholds were set based on total food sales, not cheese sales specifically, which trips people up. If your creamery also runs a small farm stand or sells eggs and honey alongside your cheese, all of that revenue counts toward the threshold that determines which bucket you're in — not just the wheels you're selling wholesale. One member on our Membership & Outreach Committee's fall call put it plainly: "I'd been telling people at markets for two years that we were too small to worry about this. Turns out I was counting the wrong number."

We've asked the Food Safety Committee to put together a short worksheet members can use to check their own total food sales against the thresholds, rather than relying on secondhand summaries like this one — we'll share it through the member portal once it's ready. In the meantime, our Food Safety & HACCP Certificate course covers what qualified-exempt recordkeeping actually needs to look like, and it's a lighter lift than the full preventive-controls track built for larger operations.

What to do before January

If you haven't pulled your last three years of total food sales and checked which bucket you fall into, that's the first step — not researching the rule itself. Once you know your bucket, the paperwork requirement is a lot more specific and a lot less alarming than the rule's reputation suggests. Four months is enough time to get this right if you start now; it isn't enough time if you start in December.

There's also a practical reason not to wait: qualifying as exempt isn't automatic just because your sales fall under the threshold. You have to be able to produce the records showing it, on request, and a regulator asking for three years of sales documentation in January is a much worse conversation than pulling the same numbers today with no deadline pressure attached. Members who've already been through an inspection under the larger-operation rules tell us the paperwork itself was never the hard part — it was scrambling to reconstruct records after the fact that cost them time.

We know "keep better records" is not a thrilling piece of advocacy content, and we'd rather push for a simpler threshold test than tell members to just try harder at bookkeeping. That's part of why the worksheet from the Food Safety Committee matters to us beyond this one deadline — a clear, shared standard for what counts as "total food sales" reduces the number of members who find out the hard way that a farm stand or an egg counter changed their bucket. Until that worksheet is out, the safest move is the boring one: pull the number now, write down which bucket it puts you in, and revisit it if your product mix changes before January.

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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.