A member wrote to us last week with a question we hadn't gotten before this year: is a hand-cut, unwrapped wedge that goes into a curbside pickup bag "labeled for retail sale," and if it isn't, what does she need to put on it instead? It's a small question with a real answer, and it's the kind of thing this spring has generated a lot of, as members who used to sell almost entirely across a counter figure out packaging and labeling for channels they never planned to use.
The short background: a federal food-safety regulator issued temporary guidance this spring giving food makers more flexibility on package labeling during the public-health emergency, mainly aimed at ingredient substitutions and formulation changes when a usual supplier was unavailable. It also touched on labeling for products moving through channels — like bulk sale to a restaurant, or a to-go container — that weren't originally built with a retail label in mind. That guidance is temporary and narrower than the rumor mill has made it sound, and our Standards Committee has fielded more than one call from a member who'd heard "labeling requirements are relaxed" and wanted to know exactly how far that goes.
What's actually flexible, and what isn't
The flexibility is real but specific. It mostly covers minor formulation substitutions made necessary by supply disruption, and some packaging formats used for food moving to a restaurant or reseller rather than directly to a consumer. It does not touch the basics: a product sold directly to a household still needs a statement of identity, an ingredient list, the name and address of who made it, an accurate net quantity, and allergen information. If you're direct-selling raw-milk cheese, your aging disclosure requirements haven't moved at all. The instinct to simplify labeling because "everything's different this year" is understandable, but it's the wrong instinct — this is exactly the kind of shortcut that turns into a bigger problem once things settle down and a regulator starts reviewing what went out the door during the emergency period.
Where members are running into real gaps isn't the legal minimum, it's practical: a wedge that used to leave the shop pre-labeled by a packaging vendor now needs a workable label printed in-house, fast, for a format nobody designed for. The Membership & Outreach Committee has been collecting examples of what members have improvised — adhesive labels sized for a deli tub, a half-sheet insert dropped into a paper bag — and will post a short guide of workable formats for members setting up direct sale or curbside pickup for the first time.
What we're asking for
Beyond the immediate guidance, we've been in touch with members about a longer-standing labeling issue that this year has made more visible: how "farmstead," "aged," and similar terms get defined and enforced differently depending on which channel a product moves through. It's not a new fight, but a summer of unfamiliar direct-sale formats has put more members in a position of labeling a product for a channel where the rules were written with a different kind of seller in mind. We'll keep members posted as that conversation develops, and if you've hit a labeling question specific to a new sales channel this year, the Membership & Outreach Committee wants to hear about it — those examples are what shape the guidance we end up asking for.
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.