Labeling

A cheese label is a dense little legal document, and once you can read one the supermarket becomes a much more interesting place. Most of what is printed there is printed because something requires it, and the wording is chosen with more care than it looks.

I am not a lawyer and none of this is legal advice.

What has to be on it

For a packaged food sold in the United States, the recurring pieces are:

• The statement of identity — what the thing is. If a standard of identity exists and you meet it, this is that name. If it does not, it is a common or usual name, or an appropriately descriptive term.
• Net quantity of contents.
• Ingredient list, in descending order of predominance by weight.
• Allergen declaration — milk is one of the major allergens, so a cheese says so.
• Name and place of business of the manufacturer, packer or distributor.
• Nutrition labelling, subject to the small-business and other exemptions.

⚠ And for raw-milk cheese riding the 60-day exception, the cheese must be clearly labelled as unpasteurised. The permission and the disclosure travel together.

State law adds to this. Michigan cottage food products, for example, carry a mandatory statement saying the product was made in a home kitchen that is not inspected — but as the Michigan page explains, that scheme does not reach cheese anyway.

⭐ The words that are doing legal work

This is the part worth actually learning, because these phrases look like marketing and are not.

“Pasteurized process cheese” / “cheese food” / “cheese spread.” A descending ladder, each rung a separate standard, each holding less cheese and more water than the one above. When a label works its way down that ladder it is not being coy — it is being precise, and the precision is legally required.

“Pasteurized process American cheese.” As covered on the standards page, this is a defined mixture of cheddar, washed curd, colby or granular cheese. The word “American” there is a naming permission, not a provenance.

“Made with real cheese.” Not a standard-of-identity term. It tells you the product is not one, because if it were, it would say so.

⭐ “Natural cheese.” The one people find most surprising. It is an industry contrast term used to distinguish ordinary cheese from process cheese — it is not a regulated claim about how the animal was raised, what it ate, or whether anything was added. A “natural cheese” can contain annatto, calcium chloride, lipase and preservatives.

“Aged 60 days.” Occasionally printed as a virtue. It is a legal minimum being restated as a feature.

🔴 The place-name problem, on the label

Here is where labelling and protected names collide, and where the same package can be honest in one country and misleading in another.

In the United States, “Parmesan” and “reggiano” are the names of a federal standard of identity (21 CFR 133.165), and “gruyere” likewise (§133.149) — held generic by the Fourth Circuit in 2023. Printing either on an American-made cheese that meets the composition is not a false statement; it is the regulation’s own vocabulary.

In the EU, the same words on the same package would be an infringement of a protected designation.

⚠ So a label is not simply true or false — it is true relative to a jurisdiction. I find this the hardest single idea in cheese law to hold on to, because every instinct says a name either describes the thing or it does not. But genericness is a finding of fact about consumers in one country, and consumers differ, so the same ink means different things on different shelves.

⭐ Which is the honest answer to the argument you will see in every comment section — “American Parmesan is a fake” against “Europe is trying to own ordinary words.” Both sides are describing their own jurisdiction accurately. The disagreement is real, it is commercial, and it will not be settled by anyone being shown a dictionary.

What I would put on a label if I sold

Assuming the Michigan plant question were solved, the labelling instinct I have arrived at is boring and I think correct: name the cheese myself.

An invented name carries no compositional obligation, so it cannot fail a standard of identity, and it does not borrow a place I have never been. Then say what it actually is underneath — milk, animal, raw or pasteurised, rough age, what the rind is — because that is the information a buyer can use, and none of it requires a legal term.

The great American cheeses of the last thirty years are overwhelmingly sold under invented names, and I used to read that as marketing. It is at least as much a legal strategy, and a sound one.

Sources

• FDA food labelling requirements: statement of identity, net quantity, ingredient list, allergen declaration, manufacturer address, nutrition labelling.
• 21 CFR Part 133, especially §133.169 (pasteurized process cheese) and the related process cheese food / spread standards; §133.149 (gruyere); §133.165 (parmesan and reggiano).
• Raw-milk cheese labelling as unpasteurised, under the 21 CFR 1240.61 / Part 133 architecture.
• Interprofession du Gruyère v. U.S. Dairy Export Council, 61 F.4th 407 (4th Cir. 2023).