Regulations Governing Cheese (aka Alphabet Soup!)

Question 1

Who regulates cheese in the US?

Answer 1

FDA

Question 2

Where are cheese and cheese-related products covered in the code of federal regulations?

Answer 2

Title 21, Part 133

Question 3

How do the acronyms CBP and CFR relate to one another in relation to cheese industry regulation?

Answer 3

CBP stands for Customs and Border Patrol. Their body of governing law is the CFR, which stands for Code of Federal Regulations in implementing the GTIN/GS1 program, and dairy tariff rate quotas.

Question 4

What is the FDA’s program regarding cheese production?

Answer 4

Their body of law is the CGMP (current good manufacturing processes), and the program is FSPCA or the Food Safety Preventive Controls Alliance.

Question 5

What is the FSPCA program of the FDA and what does it do?

Answer 5

The Food Safety Preventive Controls Alliance (FSPCA) is a broad-based public private alliance consisting of industry, academic and government stakeholders whose mission is to develop curricula, and training and outreach programs to support compliance with the prevention-oriented standards of the Food Safety Modernization Act (FSMA).

Question 6

What is the CFR?

Answer 6

The Code of Federal Regulations (CFR) annual edition is the codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government.

Question 7

What does FSVP stand for, what agency regulates it and what is their program?

Answer 7

Foreign Supplier Verification Programs (FSVP). Regulated by the USDA , which operates the PDO (Protected Designation of Origin) program in the US. Note: as of this date, there are no PDO cheeses in the United States. (2023)

Question 8

What does GTIN stand for? Where is it found on a product item?

Answer 8

Global Trade Item Number, it is the CBP assigned number located underneath the UPC barcode on a particular product.

Question 9

What does FMSA stand for? What agency regulates it per the cheese industry?

Answer 9

Food Safety Modernization Act, regulated by the FDA.

Question 10

What does CGMP or GMP stand for?

Answer 10

Current Good Manufacturing Practices or Good Manufacturing Practices, the FDA regulations for producing safe food. CGMP is a national standard representing a minimum sanitary standard for producing safe food.

Question 11

What does SSOP stand for?

Answer 11

Safety Standard Operating Procedure.
This is the FDA’s body of regulations for retail retail food service. It is the minimum standard for selling safe food.

Question 12

What is the main difference between CGMPs and SSOPs?

Answer 12

CGMP code covers production facilities; SSOP code covers operations with public exposure risk (retail).

Question 13

What are the big-picture regulating bodies for food safety?

Answer 13

Customs, FDA, and USDA

Question 14

What is the primary function of CBP, Customs and Border Patrol?

Answer 14

Collection of tariffs, any business can import cheese. Only those with Dairy Important Licenses may fall within the lower tariff, which determines threshold for amount of duty paid.

Question 15

The FDA’s prime mission is…

Answer 15

Food safety for the nation. They set the minimum standard.

Question 16

AQI stands for…

Answer 16

Agricultural Quarantine Inspection, which falls to the USDA.

Question 17

If a cheese has been flagged for an issue, where can you find the details?

Answer 17

The FDA’s Alert List online.
There are three categories:
12-03 all clear
12-07 stop, detain and inspect
12-10 mfg is on the “hot list”, product found compromised

Question 18

Nutritional labeling is under the jurisdiction of which government body?

Answer 18

FDA

Question 19

HTS is…

Answer 19

Harmonized Tariff Schedule, www.hts/usitc.gov

Question 20

HACCP is…

Answer 20

Hazard Analysis Critical Control Point. A plan for keeping food safe, and tracking it.

Question 21

GTIN stands for

Answer 21

Global Trade Identification Number

Question 22

The USDA’s primary concern is…

Answer 22

The prevention of infestations and pests entering the country, and setting the tariff schedules for licenced importers of Cheese.

Question 23

What two changes to importing (food) cheese were made by the FDA post 9-11?

Answer 23

All domestic food facilities must register, and written notice must be given, called “Prior notice “

Question 24

True or False? - a Dairy Import License is not a requirement for importing cheese.

Answer 24

True, it is a license, applied for annually and issued by the USDA, that allows access to a lower tariff, with certain caps. Although not required, it allows license holders lower tariffs.

Question 25

What agency manages The Dairy Licensing Program, and what is its function?

Answer 25

The USDA administers tariff schedules on certain cheeses that have multiple possible rates of duty and issues licenses allowing to importers to obtain lower tariff rates.

Question 26

What is the function of the WCO, the World Customs Organization?

Answer 26

The World Customs Organization, affiliated with the WTO, provides a forum for trade disputes internationally.

Question 27

True or false? - Code dates, such as “sell by” or “use by” used by mfg are applied for food quality not safety reasons.

Answer 27

True

Question 28

NBFDS stands for….? What is it?

Answer 28

National Bioengineered Food Disclosure Standard. As of January 1st, 2022, the enforcement changed from “absence to that of Disclosure” with regard to food labeling.

Question 29

What common hormone, used with dairy cows is bio-engineered?

Answer 29

rBST

Question 30

What is FP, or FPC?

Answer 30

A genetically-engineered coagulant, commonly known as caimacin, used in cheese making.

Question 31

What is the FSVP?

Answer 31

FSVP stands for Foreign Supplier Verification Program. It is a regulation within the Food Safety Modernization Act (FSMA), a program of the FDA, in which the importer is responsible for verifying that a foreign supplier meets U.S. food safety standards.

Question 32

MAV stands for what in relative to distribution of cheese?

Answer 32

Moisture Allowable Variation, a reasonable amount is 3%.

Question 33

What is the PMO?

Answer 33

It is the Pasteurized Milk Ordinance. Federal law makes it illegal to sell raw fluid milk in the U.S. for human consumption.

Question 34

What are the three tiers of geographical indications?

Answer 34

PDO, PGI, and TSG. PDO (Protected Denomination of Origin) being the highest or most specific in its restrictions.

Question 35

Describe a PGI cheese. Can you name a few?

Answer 35

Protected Geographical Indication or PGI is a designation, just below PDO, and covers agricultural products and food closely linked to the geographical area for at one of the stage of production. Some well-known PGI cheeses include: Gruyere, Havarti, Brillat-Savarin, Raclette, and Valdeon.

Question 36

What does TSG on a food product label indicate?

Answer 36

The TSG ( Traditional Specialty Guaranteed) emblem is two tiers below PDO ( just below PGI), and highlights traditional character of a food product either in composition or means of production. It is the lease restrictive.

Question 37

What GMO changes were implemented as of January 1, 2020?

Answer 37

The National Bioengineered Food Disclosure Act changed its standard from one of “absence” to that of “disclosure”. In other words, if a food is genetically modified, it must declare so on the packaging.

Question 38

Instead of the EU’s PDO, PGI, and TSG quality nomenclature system, what does the USA have?

Answer 38

Standards of Identity (SOI), maintained by the FDA. More than 70 SOI are described in the CFR (Code of Federal Regulations). Whew, that’s a lot of acronyms!