A federal food-safety compliance date is coming up in January, and it's the topic our advocacy volunteers have fielded more calls about this month than any other, including the interstate shipment questions we wrote about back in August. The rule phases in requirements for smaller operations that were previously exempt or given extra time, and the thresholds are based on average annual sales — which means whether it applies to your creamery depends on a number a lot of small producers haven't calculated recently.
We're not going to tell you whether the exemption applies to your operation specifically; that's a determination that depends on your actual sales figures and product mix, and it's not something a blog post can safely answer for you. What we can do is explain why this keeps coming up and what the federation is doing about it.
Why the threshold matters more than the rule itself
Most food-safety rules get discussed in terms of what they require — testing, documentation, water quality standards. For small producers, though, the more consequential number is usually the sales threshold that determines which tier of the rule applies to them at all. A creamery that grew this year, even modestly, may have crossed a line that changes its compliance timeline without anyone at the business realizing it happened. Growth is usually treated as unambiguously good news; in this specific case, it's also a reason to recheck a number you might not have looked at since last year's tax filing.
Members who work with a food-safety consultant or a co-op compliance program have an easier time here, since recalculating a threshold is often already part of that relationship. Members running solo or with a very small team are the ones we hear from most, because the paperwork that determines the threshold — trailing sales averages — isn't something most people track for its own sake.
What the federation is doing
Our Food Safety Committee has spent the last several weeks compiling member questions into a single comment document, which we plan to submit during the relevant public comment window. The goal isn't to argue against food-safety standards — nobody on the committee believes that's a fight worth having — but to flag specific places where the compliance timeline creates a harder cliff for small operations than the rule's authors may have intended, particularly for creameries that cross the sales threshold mid-cycle.
If you have a concrete example of how this threshold has affected your planning — not a hypothetical, an actual number and an actual decision it changed — we want to hear it before the comment document closes. Specific examples carry more weight in testimony than general concern does, and they're the reason our advocacy work has had traction on similar questions before.
If you haven't recalculated your trailing sales average against the new thresholds, that's the concrete task worth doing before the end of the month, not before January. Reach out to the Food Safety Committee if you want help interpreting where you land, and consider our Allergen Management or food-safety coursework if the threshold change means new documentation is now required for your operation. None of this is legal advice — for a determination specific to your business, talk to a food-safety consultant or an attorney who knows your numbers.
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.