← All posts Advocacy

The sampling program behind the 60-day rule

A federal sampling assignment on 60-day aged raw-milk cheese has been running since the start of the year. Here's what it covers, and what it doesn't change yet.

If you make or sell raw-milk cheese across state lines, you're already operating under a rule most of the membership can recite from memory: aged a minimum of 60 days at a specified temperature, clearly labeled as unpasteurized, or it doesn't ship interstate. That rule has been in place for decades and isn't changing this week. What has changed is that a federal sampling assignment on 60-day aged raw-milk cheese has been quietly running since the start of this year, and enough members have asked us about it that it's worth walking through plainly.

The short version: regulators have been collecting samples of aged raw-milk cheese as part of a broader look at whether the 60-day aging window does what it was designed to do against certain pathogens under current dairy conditions. This isn't a new rule, a proposed rule, or an emergency order — it's a data-gathering exercise, and as of this writing it hasn't produced a rule change. We're not going to speculate about what the sampling results mean for food safety, because that's not our lane, and any member telling you they know how this comes out is guessing same as we are.

What this means for your business today

Nothing in your labeling or your aging protocol needs to change based on this alone. If you already ship 60-day aged raw-milk cheese across state lines, the rule you're following is the same rule it was in May. What we'd actually recommend: if a sampling assignment ever reaches your creamery directly, treat it as routine regulatory contact, document what's asked of you and what's collected, and loop in whoever handles your regulatory correspondence — your co-op field rep, your state department of agriculture contact, or legal counsel if you have it, not a federation staffer. We can tell you what a rule says. We can't tell you what to do if an inspector shows up, and we'd be doing you a disservice if we pretended otherwise.

Where the federation can be useful is upstream of that. Our Food Safety Committee tracks proposed changes to interstate shipment rules and aging requirements as they move through the federal process, and when there's an actual comment period open — not just a sampling assignment, an actual proposed rule — we let members know with enough lead time to weigh in if they want to. Several members submitted comments during last year's aging-rule discussion, and that kind of direct testimony from people actually making the cheese in question tends to carry more weight in these processes than a trade association's general position does.

If you want to stay ahead of this

The most useful thing any raw-milk cheesemaker can do right now is make sure your own aging and labeling records are complete and current — not because anything is about to happen, but because good records are the thing that turns a routine regulatory contact into a five-minute conversation instead of a long one. If you want a second set of eyes on your documentation, that's a fair question for the Food Safety Committee, and it's also core material in our Food Safety & HACCP Certificate coursework if you'd rather work through it as a structured course than a one-off review.

We'll keep watching this and will say something more specific the moment there's an actual proposal on the table. Until then, this is a "know what's happening" post, not a "do something differently" post, and we'd rather tell you that plainly than manufacture urgency where none exists yet.


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.

raw-milkinterstate-shipmentfood-safetyadvocacy

More from the blog

All Advocacy posts →