United States: the 60-day rule for raw milk cheese

What the rule says

The base rule is 21 CFR 1240.61: no milk or milk product intended for direct human consumption may move in US commerce unless it is pasteurized, except where a regulation provides an alternative procedure — which is exactly what Part 133 does for the curing of certain cheese varieties.

The alternative procedure is always the same: if the milk is not pasteurized, the cheese must be cured for at least 60 days at a temperature no lower than 35 °F (1.7 °C). The wording appears in the standard for each family — 21 CFR 133.150 for hard cheeses, which covers Bitto and Valtellina Casera, and 21 CFR 133.182 for semisoft cheeses, such as Taleggio. This is not a recommendation, and it is independent of how good the product is. It is a condition of admissibility.

For an Italian exporter the point that matters is that the rule draws no distinction between domestic and imported product. A raw milk cheese with 45 days of aging can be entirely compliant in Europe and still not enter the United States.

Why we raise this first rather than later

Offering a US importer an item that cannot clear customs is not a commercial hiccup. It costs both sides time and money, and it surfaces at the worst point in the chain. We would rather the selection arrives already filtered.

The same applies to this site. We do not present items to the US market unless we know they are admissible.

Three questions to ask of every item

1. What milk is it made from? Raw, thermized or pasteurized. Thermized is not pasteurized: for the purposes of the US rule it should be treated as unpasteurized unless the actual heat treatment has been verified.
2. How many days of aging does it have when it leaves our plant? Not the minimum in the production specification — the actual days of that batch.
3. How many days pass before customs clearance? What counts is aging completed, and the count does not stop during refrigerated transport — but planning to land right on the 60-day line is an avoidable risk.

Where our range stands

For every item you are interested in we state, in writing, what milk it is made from and how many days of aging it has when it leaves our plant. That goes in the technical data sheet we send after first contact, tied to the batch: a regulatory compliance table is either exact and current to the lot, or it is worse than useless.

What stays with the importer

Some obligations cannot be handed to a foreign supplier. The Foreign Supplier Verification Program is the US importer’s obligation, not ours. We have to supply the documentation you need in order to discharge it, but the verification and the responsibility remain yours. The same goes for the label intended for the US market.

Once the table is complete we will publish it here and attach it to the technical data sheet we send after first contact.