Since the federal food-traceability recordkeeping requirements took effect at the start of this year, we've fielded a steady stream of member calls asking the same question: does the small-producer exemption hold, or is it about to shrink? We don't have a firm answer yet, but we can tell you what we're watching and why it matters to your operation specifically.
The exemption, as written, carves out producers below a certain annual revenue threshold from the full lot-tracking and recordkeeping burden that applies to larger operations. For a lot of our farmstead and small-batch members, that threshold is the difference between a manageable spreadsheet and a system that needs dedicated software and, often, a dedicated person to run it. The regulator has been holding stakeholder engagement sessions this spring to gather input before deciding whether the threshold needs adjusting, and small producer advocacy groups — ours among them — have been submitting comment on where that line should sit.
What we're asking for
Our position, filed through the Membership & Outreach Committee's advocacy channel this spring, is straightforward: the exemption threshold should track inflation and shouldn't be revisited downward without a phase-in period long enough for a small creamery to actually build the recordkeeping capacity the rule would require. We've heard from members who could absorb a tighter threshold with eighteen months' notice and from members who couldn't absorb it with any notice at all, because the capital for a traceability system this year is going into a roof repair or a new vat instead.
If you haven't weighed in yet, the comment window is still technically open, and a short, specific letter from someone who actually runs a small creamery carries more weight with a regulator than a form letter from an association — which is why we ask members to write their own, even when we provide a template to start from. The Advocacy page has that template if you want a starting point rather than a blank page.
What this doesn't affect — yet
To be clear about what we don't know: nothing has been finalized, and members currently under the exemption threshold don't need to change anything about their recordkeeping today. If the threshold moves, there will be a public comment period and, based on how the rule was implemented the first time, likely a compliance date set well into the future rather than an immediate cutover. We'll flag it here the moment there's an actual proposed change to react to, rather than asking members to prepare for a hypothetical.
In the meantime, if you're currently just above the exemption line and already doing full recordkeeping, our Food Safety Committee has been collecting practical templates from members who've been through it — worth a look even if your own status doesn't change, since a wider threshold could still shift again in a future cycle.
We'll keep members posted as the stakeholder sessions wrap up this summer. If you want your creamery's specific situation on record before that happens, now is the window.
It's tempting to tune this out if you're well clear of the threshold in either direction — comfortably exempt, or already well past it with a system in place. But the exemption line does more than decide who fills out which forms. It shapes how many small producers stay small on purpose, because staying under a revenue ceiling is sometimes the difference between running a recordkeeping system yourself and hiring someone to run it for you. A threshold that doesn't move with inflation quietly pushes members toward growth decisions they might not otherwise make, just to absorb a compliance cost that arrives regardless of size.
That's part of why we've asked members across a range of operation sizes to weigh in, not just the ones closest to the line today. A regulator hearing from a two-hundred-cow dairy and a twelve-cow farmstead operation, both explaining what the threshold means for their specific books, makes a stronger case than either voice alone. If your operation has a story about how this rule — or the version of it that might come next — actually lands on your calendar and your budget, that's the letter worth sending this month.
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.