A proposal has been open for public comment since midsummer to revoke roughly eighteen older labeling standards that cover a handful of cheese and dairy products — the kind of standard that spells out, in regulatory language, exactly what has to be true about a product before it can carry a given name. Most of our members have never had a reason to read one closely. That's usually a sign the standard was written for a category nobody makes much of anymore, not that it doesn't matter.
We've heard from a few members who checked the list and found it didn't touch anything they produce, and shrugged. We'd push back gently on the shrug. Once a standard is off the books, the name it used to define becomes fair game for a broader range of products, and depending on what your labeling and marketing already lean on, that can change what "matches expectations" means for the wheel next to yours on a shelf. It's worth five minutes to actually check the list rather than assume.
Why this is a "labeling standards" question and not a "somebody else's problem" question
Standards of identity work quietly in the background of a lot of member marketing. If your label says a cheese is a specific named style, part of what backs that claim up — in the eyes of a regulator, and often in the eyes of a careful customer — is that the name still means something specific under the rules. Removing an obsolete standard is not automatically bad; several on this list appear to cover products nobody has made commercially in years, and clearing dead language off the books is reasonable housekeeping. But "reasonable in general" and "fine for your specific label" are two different questions, and only one of them is answered by reading a summary.
The comment window on this proposal closes September 15. That's not far off, and it's exactly the kind of deadline that's easy to let slide past while you're dealing with a fall order sheet. Separately, and on a faster clock, a related front-of-package nutrition labeling proposal has its own comment history working through the same rulemaking system — different rule, same broader push toward changing what has to appear on a label and how.
What to do with two weeks left
If you haven't looked at the list of standards under review, that's the first step — not every member needs to comment, but every member should at least know whether their product category is on it. If it is, and you think the change would affect how your product is understood on a shelf, that's exactly the kind of specific, concrete input a comment period is built to collect. General objections don't move a rulemaking process much. A clear description of how a change would affect your actual label does.
Our advocacy team can help you find the specific docket and draft language if you've never filed a comment before — it's a shorter process than it sounds, and several members have gone through it with us in past cycles. Reach out before the window closes rather than after.
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.