Earlier this year the federal food-safety regulator proposed striking a list of standards of identity for dairy products it considers outdated — rules that fix, in regulatory language, exactly what a product has to contain and how it has to be made before it can carry a given name. Most of the list is unglamorous: low-sodium cheddar, acidified sour cream, a couple of cheese types few members make anymore. But a comment window on the proposal has been extended, and it's still open, which means members who make anything on that list still have a chance to say something before the record closes.
We've heard from members on both sides of this one, and both sides have a point worth taking seriously.
Why "outdated" cuts two ways
The case for repeal is straightforward: a standard of identity written decades ago can lock a recipe in place long after the market and the science have moved past it, and a maker who wants to adjust a formulation for cost or shelf life sometimes finds the standard is the thing stopping them, not food safety. Members who've felt boxed in by an old standard are, understandably, glad to see it go.
The case for caution is just as real. A standard of identity is also a floor — it's what stops a labeling shortcut from quietly changing what's actually inside the wheel a customer is buying on the strength of a name they trust. Remove the standard and you remove the guardrail along with the rigidity. A member who spent years building a reputation around what a name like theirs is supposed to mean doesn't necessarily want that meaning left to the market to sort out.
Neither position is wrong, and the federation isn't taking one for you. What we can do is make sure the mechanics of commenting aren't the obstacle. If you make one of the affected products and haven't checked whether the current rule text actually matches how you already work, that's worth ten minutes before you write anything — some members have found the standard already permits more than they assumed.
There's a related docket tangled up in the same conversation, and members sometimes confuse the two. A separate proposal would let makers use ultra-filtered milk in standardized cheeses without triggering a different labeling category. That one has its own comment history and its own reopened window, and it's worth reading the actual text of whichever docket applies to you rather than relying on secondhand summaries, ours included. The two proposals move on different timelines and could land differently.
We heard from a small-batch cheddar maker this week who assumed none of this applied to her because she doesn't make anything as obscure as the rarer cheese types on the repeal list. It turned out one of the standards up for removal touches a labeling detail on reduced-sodium cheddar specifically, which she does produce a version of for a regional grocery account. That's the kind of gap between "this sounds technical and remote" and "this is actually about my label" that we'd rather members close before the comment window shuts than after a new rule takes effect and surprises them.
What to do this week
The Standards Committee has been tracking this docket since it opened and can point you to the specific standard text for your product category, along with a short template for writing testimony that describes what the change would actually mean for a working creamery rather than restating the proposal back at the regulator. A comment that says "here is what this changes for a wheel I make every week" reads very differently to a rulemaking record than one that just says "support" or "oppose."
If you're not sure whether your product is on the list, or you want a second read before you submit anything, a note through the member portal reaches the committee directly. The window won't stay open indefinitely, and a rule this specific rarely gets revisited once it's settled. Whichever side of this you land on, a specific comment tied to your own product and your own label does more for the record than a general statement of support or opposition ever will.
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.