There's a quiet argument running through the federal food-safety rules that has nothing to do with what's in the cheese and everything to do with what a small producer sold last year. The qualified-exemption threshold that lets the smallest creameries follow a lighter compliance path was written around a dollar figure, and dollar figures from a few years ago buy less than they used to. We've had enough members raise this in the last month that it's worth spelling out plainly, and worth doing before the calendar turns and everyone starts closing out this year's books.
The exemption exists so that a farmstead operation selling mostly direct to customers and local retailers doesn't have to build the same paper trail as a plant shipping pallets across three states. That's a reasonable distinction, and most members support keeping some version of it in place. The problem members are describing is that milk, packaging, and labor have all gotten more expensive since the threshold was set, so a creamery doing the same actual volume of cheese it made a few years ago can now show up on paper as if it's grown past the line — without a single additional wheel leaving the door.
What members are telling us
A handful of small producers have written in this fall describing the same thing from different angles: gross sales climbing on invoices that reflect price, not output, and a worry that the next renewal cycle will push them out of the exemption on paper alone. One member put it simply — the rule is supposed to track how much cheese you're making, and right now it's tracking how much a pound of cheese costs. We think that's a fair read, and it's the kind of specific, first-hand account that carries weight when a threshold gets revisited.
If this describes your operation, we want to hear from you directly, and we'd also encourage you to say so in your own words if a comment period opens on this question. A short account of your actual sales history — units, not just dollars — is more useful to a regulator than a general complaint that the number feels low. It also helps us build a record now, rather than scrambling to assemble one after a window opens and starts counting down.
Where this goes next
The Standards Committee is compiling these accounts now, ahead of any formal comment window, so that we have documented examples ready rather than starting from scratch when one opens. If you've been tracking your own numbers and are willing to share a redacted version — enough to show the trend, not enough to expose your books — email the committee. We'll fold it into what we bring to the agency, and we'll let you know if and when a public comment period opens so you can weigh in as well.
We'd also point out, gently, that this is exactly the kind of issue where a trade association earns its dues: no single small creamery has the time to track a threshold's history against a decade of milk and labor cost data, but collectively we can, and we can hand a regulator something more useful than one member's frustration.
None of this is a promise the threshold moves. It's a promise that if it doesn't, it won't be for lack of members putting real numbers in front of the people who set it. If you want to be added to the list of members we contact when this moves forward, the Standards Committee inbox is the place to start.
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.