Members ask us fairly often whether we know when the federal food-safety regulator is going to act on the traceability recordkeeping proposal that's been under review since it was first published in the fall of 2020. Short answer: not yet, and we don't have a date to give you. Longer answer: the comment period closed over a year ago, the rule covers a defined list of higher-risk foods, and soft and semi-soft cheeses are widely expected to land on that list when something does get finalized. Waiting for a final rule before you touch your recordkeeping is the wrong move either way.
What the proposal actually asks for
Set aside the politics of when it lands. The substance of the proposal is about being able to answer one question fast: where did this batch come from, and where did it go. That means tracking specific points in your process — receiving milk, transforming it into curd, packing finished wheels, shipping them out — with enough detail that a batch can be traced back and forward if something goes wrong. For a lot of our members this isn't a new practice, it's a more formal version of a log they're already keeping in a notebook by the vat, made more rigorous.
The gap we see most often isn't that members lack the information. It's that the information lives in three different places — a paper make sheet, a shipping spreadsheet, a supplier invoice folder — and nobody could pull them together fast enough if a regulator or a buyer asked for it this afternoon. That's the part worth fixing now, rule or no rule, because it's also the part that matters most in an actual recall, which doesn't wait for a convenient week.
The proposal organizes recordkeeping around a handful of points in your process rather than asking for a record of everything, all the time. Receiving milk from a supplier is one such point. Transforming it — turning milk into curd, curd into a wheel — is another. Creating a new lot by combining batches is a third, and shipping a finished product out the door is a fourth. At each of these points, the expectation is a record with enough detail to answer "where did this come from and where is it going" without a phone call to three different people. For a member running a one-room creamery, that list is manageable precisely because it maps onto steps you're already performing by hand — the work isn't inventing new steps to track, it's making sure the records from each step end up somewhere that can be searched in minutes rather than reconstructed from memory.
What to do this spring
If your Food Safety & HACCP Certificate is coming up for renewal, this is a natural moment to fold a traceability review into that work — the credential already covers hazard analysis and recall readiness, and a clean recordkeeping system is most of what a recall exercise asks you to prove. If Listeria is a real concern in your environment, the next cohort of Listeria Control in Small Creameries opens April 28 and spends real time on environmental monitoring logs that double as traceability records.
We'll keep watching this one and will tell members directly the day anything moves. In the meantime, the Food Safety Committee is collecting member questions about what a final rule would mean for a creamery your size — send yours in, and we'll fold the common ones into a member call once there's something concrete to react to.
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.