FDA Finalizes Cottage Cheese Exemption
March 3, 2026
After nearly a decade of back-and-forth, FDA announced Feb. 19 that Grade “A” cottage cheese is getting an exemption from FDA’s Food Traceability Rule.
This exemption from the added traceability requirements tied to foods on the Food Traceability List will reduce the record-keeping burden on Grade “A” cottage cheese manufacturers who are already meeting the highest standards set by the Grade “A” Pasteurized Milk Ordinance and regulated by the National Conference on Interstate Milk Shipments.
NMPF supported the passage of the Food Safety Modernization Act in 2011 and agrees that food traceability measures and adequate record keeping are important to food safety. However, since Congress passed FSMA, NMPF has disagreed with the FDA’s approach to determining the list of “high-risk foods” as defined in Section 204 of the law.
Despite NMPF’s many objections, FDA passed a final rule in November 2022 in which all cheeses other than hard cheeses are considered high-risk foods. FDA’s risk-ranking model under this rule places “pasteurized cheese, other than hard” as the highest risk level of all foods in the marketplace — even above cheese made from raw milk. The final rule set a compliance date of January 20, 2026, for all manufacturers to meet the rule requirements, but efforts by NMPF and other industry organizations led FDA to extend the compliance date for the rule by 30 months to July 20, 2028. This extension creates more opportunities for NMPF to push for changes. The Grade “A” cottage cheese exemption from the Food Traceability List announced this month was one change for which NMPF, in conjunction with the International Dairy Foods Association, pushed very hard. The Food Traceability List originally included cottage cheese because it falls into the category of “Cheese (made from pasteurized milk), fresh soft or soft unripened.”
FDA ultimately agreed with the case NMPF made in September 2024 comments that the oversight already in place from the PMO and its built-in safeguards make extra traceability steps unnecessary. This common-sense outcome reduces burden while keeping strong food safety protections.
