If you make or sell anything built on unpasteurized milk, this has been a busy year for the rulebook, and not in a way that makes your life simpler. Three states rewrote their raw-milk statutes in 2025 alone, and the federation's Food Safety Committee has spent a good part of the summer just keeping the reference sheet current.
Arkansas removed its old monthly volume cap and widened the definition of what counts as a raw-milk product, so a small goat dairy that used to sell only raw milk can now sell raw-milk cheese, kefir and colostrum under the same license. Utah's new licensing framework took effect in the spring and opened retail sales of raw dairy products, not just farm-gate sales, to licensed producers. North Dakota went a different direction: its update extends raw-milk provisions to a wider list of products, but it also spells out, more clearly than before, that none of it may cross the state line, sold or given away.
None of that touches the one rule that hasn't moved in decades: milk sold across state lines still has to be pasteurized under federal law. A producer can be fully compliant at home and still be barred from shipping the same cheese to a member three states over. That gap between what's legal to make and what's legal to ship is exactly where our members keep getting stuck, and it's the reason "interstate cheese shipment" and "raw-milk aging rules" stay near the top of our advocacy tracker year after year.
What we're hearing from members
A farmstead member in the upper Midwest told us this summer that she now keeps two separate labeling templates for the same aged raw-milk wheel: one for the farm store, and one for anything destined for a mail-order box, because the second one has to clear a pasteurization question she can answer honestly only by not shipping it raw at all. That's not a hypothetical; it's a Tuesday.
We hear a version of this from members in licensed and unlicensed states alike: the patchwork isn't just a legal problem, it's an operations problem. Every new state law is good news for someone and a new compliance line for someone else, and right now there's no single map that shows all three changes side by side in plain language. A member who ships to a mail-order list spread across a dozen states has to track a dozen different answers to the same question, and the answer can change from one legislative session to the next with very little warning to a small operation that doesn't have a compliance office watching state bill trackers.
That's compounded by the fact that "raw milk product" doesn't mean the same thing from state to state either. Arkansas's new definition is broad enough to cover a wheel of aged raw-milk cheddar sitting on a shelf for a year; North Dakota's update covers a similar list of products but only for sale inside its own borders, direct to an end consumer, never through a wholesaler or retailer. Two members making functionally the same product can be operating under entirely different rules depending on which side of a state line their cave sits on.
Where the federation stands
We're not asking anyone to change what raw-milk aging rules should say. We're asking for a plainer, more current summary of what's actually in force, state by state, so a member can check one thing before printing a label instead of five. Members have signed on to letters making that case before, and the Food Safety Committee is preparing another round of comments this fall built around the same three questions: what's legal at home, what's legal to ship, and what changed this year that a small producer might not have heard about yet.
The committee is also compiling a short list of states where 2025's changes are still working their way through implementing regulations, since a law taking effect on paper and a rule a state agriculture office is actually ready to enforce are sometimes months apart. Members operating in those states have told us they'd rather wait for clear guidance than assume the broadest possible reading of a new statute and find out later they guessed wrong.
If your operation touches raw milk or raw-milk aged product and you want to add your name to the next round, or just want the current state-by-state summary before your next label run, reach out to the Food Safety Committee through the member portal. We'll keep the sheet current as the rest of 2025 plays out.
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.