FSMA 204 for cheese makers: which cheeses are covered and what to record

Most cheese is covered by FSMA 204. FDA’s Food Traceability List includes soft and semi-soft cheeses, and any cheese made from unpasteurized milk that is not a hard cheese. Hard cheeses such as cheddar, romano and parmesan are not on the list, and neither are cheeses that are frozen, shelf stable at ambient temperature, or aseptically processed and packaged.

This guide shows how to sort your own cheeses, what a cheesemaker keeps, and what a seller or restaurant keeps.

Which cheeses are on the Food Traceability List?

The FDA list has three cheese entries. The examples below are FDA’s own, and FDA says they are “not limited to” these.

FDA entry	Examples FDA gives
Cheese (made from pasteurized milk), fresh soft or soft unripened	cottage, chevre, cream cheese, mascarpone, ricotta, queso blanco, queso fresco, queso de crema, queso de puna
Cheese (made from pasteurized milk), soft ripened or semi-soft	brie, camembert, feta, mozzarella, taleggio, blue, brick, fontina, monterey jack, muenster
Cheese (made from unpasteurized milk), other than hard cheese	all cheeses made with unpasteurized milk, other than hard cheeses

FDA’s rule FAQs (item TFTL.13) put it in one line: all cheeses other than hard cheeses are on the list. The list page also carries a footnote that Interstate Milk Shippers (IMS) listed Grade “A” cottage cheese is exempt from the requirements of the rule.

Which cheeses are not covered?

Three groups fall outside the cheese entries:

• Hard cheeses. FDA gives cheddar, romano and parmesan as examples. The FAQ also names colby and caciocavallo siciliano as excluded. If your cheese is close to the line, ask FDA or a food safety professional before you decide it is hard cheese.
• Frozen or previously frozen cheese. FAQ item TFTL.7 says frozen cheese on a frozen pizza is not on the list, and item TFTL.24 says previously frozen cheeses are not on the list.
• Shelf-stable and aseptically packaged cheese. The list excludes cheeses that are shelf stable at ambient temperature or aseptically processed and packaged.

Being off the list does not remove every duty. It means the traceability records in 21 CFR Part 1, Subpart S do not apply to that product.

What does a cheesemaker keep?

A cheesemaker “transforms” food: milk and other ingredients go in, and a new product comes out. Under 21 CFR 1.1350, you keep these records for each new traceability lot, linked to the inputs:

1. For any listed food you used as an input: its traceability lot code, product description, and the quantity and unit of measure used from each lot
2. The new traceability lot code
3. The location description for where you made the cheese (the traceability lot code source)
4. The date transformation was completed
5. The product description
6. The quantity and unit of measure
7. The reference document type and number for the transformation event

Milk is not on the list, so you generally do not need receiving records for it. The FAQ (item TFTL.22) says that in general no records are required for the milk or other ingredients for cheese. It adds a catch: “Some cheeses might include an ingredient that is on the FTL, such as a fresh herb.” In that case you need receiving records for the herb and must link it to the cheese lot. Our guide on transformation records goes through this step.

What do you keep when you ship cheese?

When you ship a listed cheese, 21 CFR 1.1340 asks for these records per traceability lot:

• The traceability lot code, product description, and quantity and unit of measure
• The location of the immediate subsequent recipient (other than a transporter) and the place you shipped from
• The date you shipped
• The location of the lot code source, or a lot code source reference
• The reference document type and number

You must give the recipient everything above except the reference document type and number. That can be on paper or electronic. In practice, that means your invoice or packing slip has to carry the lot code. Our traceability lot code guide covers how to assign one.

What do buyers and restaurants keep?

If you buy and resell cheese, you keep receiving records under 21 CFR 1.1345. FDA’s FAQ (item TRFE.8) says a restaurant receiving certain fresh vegetables and soft cheeses on the list must keep receiving records. Small retailers and restaurants may be exempt. 21 CFR 1.1305, paragraph (i), covers retail food establishments and restaurants below an average annual sales threshold, and paragraph (j) covers some that buy directly from a farm. Each exemption has conditions, so read the text. Our restaurant and retail guide covers the buyer side.

Can a kill step change the answer?

Sometimes. FAQ item TFTL.13 says applying a kill step to a listed cheese can qualify it for a partial exemption. Under 21 CFR 1.1305(d)(3), the exemption applies only if you keep records: the receiving information that 21 CFR 1.1345 requires for the cheese you apply the kill step to (unless a written agreement under paragraph (d)(6) covers it), and a record of your application of the kill step. Do not assume your process counts. Ask FDA or a food safety professional whether it meets the definition.

When do these rules apply?

Check FDA’s rule page, which FDA marked current as of October 8, 2026. It says FDA proposed to extend the compliance date by 30 months to July 20, 2028, and that Congress directed FDA not to enforce the rule before that date. The original date was January 20, 2026. Retail buyers may ask for lot data earlier, as our retailer guide explains.

Where Lotcrumb fits

Lotcrumb is being built to read the make sheets, invoices and bills of lading a creamery already has, link cheese lots to their inputs, and produce a sortable spreadsheet on request. Join the waitlist for early access.

This guide is general information, not legal or regulatory advice. Whether a cheese is covered or exempt depends on how it is made and sold, so confirm it with FDA or a food safety professional.