The federal aging requirement for raw-milk cheese — the rule requiring at least 60 days before a raw-milk wheel can be sold — is back under active review, and our Food Safety Committee wants members to understand what's actually being asked before they sign anything. This isn't a new rule. It's a question about whether the old one still does what it was written to do, and the research behind it has moved a long way since the number was first set.
The short version: 60 days of aging was set decades ago as a rough proxy for pathogen die-off, and the regulator reviewing it has said plainly that the research since then is mixed. Some pathogens decline steadily over that window. Others, under certain moisture and salt conditions, decline much more slowly, and low pH may matter more than the calendar does. A recent study looking specifically at avian flu in raw-milk cheese found that aging alone did not reliably inactivate the pathogen, while a lower pH measurably helped — which is exactly the kind of chemistry-over-calendar finding that's driving this review. None of that is new to anyone who has spent a season watching a cave, checking pH before release rather than counting days on a calendar. It's new that federal reviewers are saying it out loud in a formal proceeding.
What the federation is asking for
We are not asking members to take a position on whether 60 days is the right number — reasonable cheesemakers disagree, and this isn't a debate we're going to settle on a blog post. What we're asking is narrower: if the standard changes, it should change based on a wheel's actual chemistry — pH, moisture, salt — rather than a single date that applies the same way to a washed-rind and a hard grating cheese. Those are different foods with different risk profiles, and a one-size aging clock has never quite fit both. A rule built around measurable endpoints would also give members a clearer path to demonstrate compliance on their own terms, instead of waiting out a fixed number of days regardless of what the wheel is actually doing.
If your operation makes anything raw-milk and aged, this is worth ten minutes of your week. The comment period isn't open indefinitely, and general public comment volume tends to favor whichever side organizes first. A single line from a working cheesemaker — what you actually measure before you release a wheel, and why — carries more weight in this kind of proceeding than most of us expect. We've had members tell us after the fact that they wished they'd written something, usually after reading a rule change they had no hand in shaping.
Where to send it
The Food Safety Committee has a short template members can adapt on the advocacy page, along with a summary of what's changed since the last time this rule was reviewed. If you've never submitted a comment before, that's the easiest place to start — it walks through where the language actually goes and what regulators tend to skim versus read in full. Keep it specific: a description of your own aging and testing practice does more work than a general statement of support or opposition. If you make raw-milk cheese and have opinions about what 60 days does or doesn't tell you, we'd rather you write them down for the record than tell us about them at the next committee call.
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.