We've fielded more questions about interstate shipment of unpasteurized-milk cheese in the past month than in most of the past year combined, and the short answer hasn't moved: the federal rule requiring at least 60 days of aging at a controlled temperature before an unpasteurized-milk cheese can cross state lines is still in effect, unchanged, and it is not currently under active revision at the federal level. The longer answer is why members keep asking anyway, and that part is worth explaining.
Part of it is simply attention. A federally funded study released earlier this year found that the 60-day aging window on its own does not reliably inactivate certain livestock viruses that can end up in raw milk, though the same research suggested that heat treatment or a low enough finished pH does the job. That finding got real trade-press coverage, and members selling any unpasteurized-milk product — even one that's well past the 60-day mark and squarely compliant — have been getting questions from buyers and, in a few cases, from their own distributors wanting reassurance. That's a reasonable thing for a buyer to ask about, and it's worth having a clear, one-page answer ready rather than explaining the rule from scratch every time it comes up.
What the rule actually requires, plainly
If a cheese is made from unpasteurized milk and it's going to move across a state line, it has to be aged no less than 60 days at a temperature of not less than 35 degrees Fahrenheit. That's the federal floor. States can and do layer additional requirements on top of it for cheese sold only within their own borders, so a raw-milk cheese that never leaves your home state may be governed by a different, sometimes stricter, standard than the interstate rule. If you sell both in-state and across state lines, you need to know which standard applies to which batch, and that's a recordkeeping question as much as a production one.
This is also where the aging log matters more than most members treat it. A dated, temperature-logged record of when a batch entered the cave and when it left is what demonstrates compliance if a distributor or an inspector asks — not the recipe, not the milk source, the log. If your current record is a chalk mark on a shelf, that's a gap worth closing before it's tested by a real question. A few members told us this month they've started keeping a duplicate digital copy of the log specifically because a buyer asked to see one on short notice and a paper binder in a back office wasn't a fast enough answer.
What we're advocating for, and what we're not
Federation members have historically split on whether the 60-day threshold should move at all, and we're not taking a position on changing the number itself in this post. The pathogen-inactivation research is a live scientific question, not a settled one, and members on both sides of the raw-milk debate should expect more findings before any rule changes. What we have been pushing for, through coalition meetings and comment letters over the past several years, is clearer federal guidance on how the rule interacts with state-level aging and labeling requirements, so a member selling in three states isn't reverse-engineering three different standards from scratch. That's a narrower ask, and it's the one with the most traction right now.
We're also asking, separately, for more advance notice before any new federal sampling assignment targets aged raw-milk cheese specifically, since a member who finds out about a testing program only after inspectors are already at the door has lost the chance to review their own records first.
If you make anything from unpasteurized milk and ship it across state lines, now is a reasonable moment to double-check your aging documentation against the 60-day standard rather than waiting for a buyer to ask first. The advocacy team can walk you through what a compliant log looks like, and if you want a voice in the guidance conversation, the next coalition meeting is open to any member with a stake in the outcome.
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.