FDA Food Traceability Rule · soft, semi-soft and fresh soft cheeses on the FTL · hard cheeses excluded · compliance 20 July 2028.
The Food Traceability List splits the cheese case in half: soft ripened, semi-soft, and fresh soft unripened cheeses (think brie, blue, queso fresco, mozzarella) are covered; hard cheeses like cheddar and parmesan are not. If any covered cheese crosses your plant, the CTE/KDE recordkeeping applies to those lines — and mixed-line plants need records that know the difference.
Soft ripened, semi-soft and fresh soft unripened cheeses are FTL; hard cheeses are not. Multi-product plants need item-level covered/not-covered logic in their records.
Milk into cheese is a transformation: new traceability lot codes assigned at the make, linked to inputs — the record starts in the make room, not the warehouse.
Aging rooms, brine tanks and cutting rooms are hostile to paperwork. Capture must work with wet hands and gloves or it will not happen.
As with all FTL foods: an electronic sortable spreadsheet of relevant CTEs/KDEs to FDA within 24 hours of request.
Compliance lands 20 July 2028 with the FDA's extension. Retail buyers of private-label cheese are already pushing FTL-grade data requirements into co-packers ahead of the date.
Classify every SKU covered or not, in writing. This single document scopes your whole program and your buyer conversations.
The make sheet becomes the birth record: traceability lot code assigned at the vat, carried through aging, cutting and packing.
Pick a wheel at random and produce its chain — milk receipt to ship-to — inside 24 hours. Fix what breaks.
Aeroz carries the traceability lot code on chip-read carriers at wheel, case or pallet level, writing each CTE as an EPCIS 2.0 event on a tap — make, age, cut, pack, ship. Records assemble themselves in environments where clipboards die, and the FDA's 24-hour request becomes an export.
Cheeses other than hard cheese: soft ripened (brie, camembert), semi-soft (blue, havarti, monterey jack), and fresh soft unripened (mozzarella, queso fresco, cream cheese types). Hard cheeses such as cheddar and parmesan are excluded.
Fluid milk is not on the FTL — but milk as an input to a covered cheese enters your transformation records as the ingredient behind the new traceability lot.
The FDA extended the compliance date to 20 July 2028. Large retail and foodservice buyers are imposing equivalent requirements earlier through contracts.
Months of aging separate the make from the sale, and wheels get cut into many sellable units. Lot identity must survive that timeline and that division — which is why physical carriers beat paper logs.
A fixed-fee Aeroz audit maps your products against fsma 204 for cheese requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.