Overview of Cheese Regulation
21 content in the final product. Similarly, Canadian Food and Drug Regulations define the
properties of a number of types of cheeses CRC, c870. U.S. regulations have a standard for soft-ripened cheeses not otherwise standardized that specifies the production process and final
milk fat content 21 CFR 133.182. Canadian regulations are not as specific regarding the production processes for cheeses and soft-ripened cheeses in particular, but do define a soft-
ripened cheese such as Camembert as having less than 56 moisture and more than 22 milk fat and soft-ripened cheese such as Brie as having less than 54 moisture and more than 23
milk fat B.08.033.
Both U.S. and Canadian regulations also contain provisions related to cheese safety. These include regulatory definitions of the times and temperatures needed for milk pasteurization. U.S.
regulations define “pasteurized” to mean that milk has been heated in properly designed and operating equipment to one of several temperatures for defined times Table 5 as well as other
time-temperature combinations that have been “demonstrated to be equivalent thereto in microbial destruction” 21 CFR 133.3d. In addition, for soft-ripened cheeses in the U.S.,
“[m]ilk shall be deemed to have been pasteurized if it has been held at a temperature of not less than 143°F for a period of not less than 30 minutes, or for a time and at a temperature equivalent
thereto in phosphatase destruction” 21 CFR 133.182c2.
Table 5: Time temperature combinations for milk pasteurization as defined in 21 CFR 133.3d. Temperature
Time
145°F 30 min.
161°F 15 s.
191°F 1 s.
204°F 0.05 s.
212°F 0.01 s.
Canadian cheese regulations define pasteurization conditions as “being held at a temperature of not less than 61.6°C for a period of not less than 30 minutes” or “for a time and a temperature
that is equivalent thereto in phosphatase destruction” B.08.030 61.6°C = 142.9°F. The U.S. definition of soft-ripened cheese also states that “[i]f the milk used is not pasteurized, the cheese
so made is cured at a temperature of not less than 35°F for not less than 60 days” 21 CFR 133.182a. In Canada, Regulation B08.043 of the Food and Drugs Act and Regulations requires
that any cheese made from milk from an unpasteurized source be stored and B.08.030 defines
22 “stored” as to have been kept or held at a temperature of 2°C 36°F or more for a period of 60
days or more from the date of the beginning of the manufacturing process .
In both the U.S. and Canada, cheese that is produced and distributed purely intrastate or intraprovince is still subject to regulation at the state or provincial level. In the U.S., there are
significant state-to-state differences in the regulations governing the sale of raw milk. In Canada, as of September 2009, the province of Québec allows the manufacture and sale of soft and semi-
soft cheeses made from raw milk that have not been aged for 60 days if the manufacturer meets requirements prescribed in the provincial regulation respecting food.