A federal comment period on cheese labeling language is open through early next year, and the federation has been encouraging members to weigh in directly rather than leaving it to trade groups to speak for the whole industry. The docket in question is about how terms like "aged," "farmstead," and "small-batch" get defined for labeling purposes, and it matters more than the dry procedural language suggests, because a producer who's used a term informally for a decade can find themselves relabeling a whole product line if the final wording doesn't match how they've been using it.
Where the friction actually is
The gap between how members talk about their own cheese and how a regulator reads a label is real, and it's not always about anyone being wrong. A cheesemaker who says "farmstead" means milk from animals on the same property producing the cheese. A regulator drafting a definition has to account for operations that lease adjacent land, or that process milk from a herd split across two nearby parcels, and a definition written to be enforceable at scale doesn't always match the plain-language version a small producer has been using with customers for years.
Our Standards Committee has been compiling member examples of exactly this kind of mismatch — cases where a term in common use on a label doesn't cleanly fit a proposed regulatory category — because specific, concrete examples carry more weight in a comment than a general objection does. A regulator reading a docket full of "this hurts small producers" learns less than one reading "here is the exact wording of my label, here is why the proposed definition would require me to change it, and here is what that change would cost."
What we're asking members to do
If you use any of the terms under review on your own labels, we'd rather you tell the docket that directly than assume someone else already has. The comment period doesn't require a lawyer or a polished public statement — a short, specific account of how you currently label your product and what the proposed language would change about that is exactly the kind of input that shapes a final rule. We're not offering legal advice on how to comply with whatever the rule ends up saying; that's a conversation for a member's own counsel once the language is final. What we can help with is making sure the rule gets written with an accurate picture of how small producers actually use these terms in the first place.
Tom Reyes, who runs a small raw-milk operation and has submitted testimony on more of these dockets than most of us can count, put it simply on a recent committee call: the version of your process you'd explain to a regulator is usually not that different from the version you'd explain to a customer — it's just that only one of those conversations gets written down and kept.
If you want help drafting a comment or want to see examples other members have already submitted, reach out to the Standards Committee before the docket closes. A late comment on a rule that will define your label for years is still better than no comment at all, but an early one gives the committee time to help you sharpen it.
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.