Most members never think about a "standard of identity" until it affects what they can legally put on a label, and this fall is a good time to start. The federal food-safety regulator has proposed dropping a batch of labeling standards for cheese and other dairy products that it now considers outdated, on the theory that some decades-old rules no longer serve the purpose they were written for. A public comment period on the proposal closed in mid-September, but the broader rulemaking is still open, and it's worth understanding before the next round of comment windows opens.
Standards of identity sound bureaucratic because they are, but they're also the reason a label can say "cheddar" without a paragraph of qualifiers. Each standard sets out what a product has to contain, and in what proportion, before it can legally use a given name. Regulators loosening or removing some of them is being framed as a cleanup of rules nobody enforces anymore, and for a handful of the affected categories, that's a fair description. For others, our Standards Committee has flagged real ambiguity about what a small creamery would be allowed to call a product once the underlying rule disappears.
Why the federation is watching this closely
A standard of identity cuts both ways for a small producer. It can feel like a straitjacket when you're making something slightly outside the traditional profile and can't use the name customers would recognize. It can also be the only thing stopping a large-volume producer from using a traditional name on a product that bears little resemblance to it, which matters most to members who've built a reputation on doing the traditional version properly. Removing a standard doesn't just deregulate the innovative small maker; it also opens the door to broader use of a name by producers with no connection to the original method.
Our Standards Committee has been reviewing the proposal category by category rather than treating it as one decision, because the categories genuinely differ. Some of the standards under review cover product types with almost no current commercial use, where removal changes little for anyone. A few others cover categories where members have told us the traditional definition is actively part of how they market a product, and where a loosened standard could make that marketing claim harder to defend if a lower-quality version enters the category under the same name.
What we're asking members to do
If you make, age, or sell a product whose name is governed by one of the standards under review, tell us before the next comment window rather than after. A single production account — what your standard currently requires, what you'd do differently if it changed, whether a looser rule would help or hurt how you sell the product — is more useful to the committee than a general opinion on regulatory reform in either direction. We've had members change our position on individual categories in past rulemakings because their firsthand account contradicted an assumption the committee had been working from.
We'll keep members updated as the rulemaking moves and will flag the next comment period as soon as a date is set. In the meantime, if labeling language on your own packaging or website leans on a name that might be affected, this is a reasonable week to check your understanding of the current standard against what's actually proposed — not to change anything yet, but so you're not caught flat if the rule does move.
Members with a specific product affected should reach out to the Standards Committee directly; general questions about how standards of identity work are also welcome and often help us understand what to explain more clearly to the whole membership.
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.