Raw Milk Cheese Warning Label Petition: Parmigiano Reggiano And Roquefort Cannot Be Pasteurised

Most of the coverage reads this as a food safety story. I read it as a trade one. A draft FDA petition would put a warning label on every raw milk cheese sold in America. Imported cheese is included. The US took in 251.3 million pounds of cheese in the first seven months of 2026. Italy and France sent 87.8 million pounds of it. The most famous cheeses from both are raw milk by their own rules.

What the petition asks for

Bill Marler, a food safety lawyer at Marler Clark, published a draft petition on 27 September. He is asking for comments before he files it with the FDA. The draft would amend 21 CFR 101.17. Every raw milk cheese would carry a warning in bold capitals. Shops cutting cheese at the counter would need a placard where it is sold. The rule would cover American and imported cheese alike. Cheese made from heat treated milk would be exempt.

The outbreak behind it

The trigger is named. An E. coli O26:H11 outbreak was linked to Graziers raw milk cheese from Sierra Nevada Cheese Company. Thirteen people fell ill across nine states. Eight went to hospital. Three young children suffered kidney failure. Most of those affected were five or younger. The same plant had a Listeria recall in 2025.

The 1987 rule the petition targets

American law has allowed raw milk cheese across state lines since 1987. The cheese must age for at least 60 days at 35 degrees Fahrenheit or more. No label is asked for. Marler counts four outbreaks in 31 months. All of that cheese met the 60-day rule. He also cites the FDA's own 2015 risk work. It put the listeriosis risk from raw milk soft cheese at 50 to 160 times the heat treated level.

Where the label would land

Imports are the part of this market nobody is counting. US cheese imports ran to 251.3 million pounds in the seven months to July, worth 1.03 billion dollars. July alone brought in 37.8 million pounds, up 17% on a year earlier. Italy led the seven months with 53.8 million pounds, up 24%. France followed with 34.0 million pounds, up 11%. Those two origins are 35% of the import pool. Both are growing.

The rest of the pool is moving the other way. The Netherlands sent 19.1 million pounds, down 11%. Spain sent 18.0 million pounds, down 4%. Nicaragua fell 18% and Greece slipped 3%. Europe still leads the trade, and the growth inside it sits with Italy and France.

Why the PDO rulebook blocks the cheap answer

A label rule usually has a cheap answer. Heat the milk and the warning goes away. That answer is closed for the biggest imported names. The Parmigiano Reggiano rulebook calls for raw, partly skimmed milk. It bars any heat treatment of the milk at all. Minimum ageing runs to twelve months. The Roquefort rules, approved in November 2025, allow raw whole sheep's milk only. Warming is permitted to reach renneting temperature and no further. A maker who heats the milk loses the name.

What this means for the market

This is a market access question dressed as a label. The import lane it touches is defined, named and growing. Buyers of speciality cheese should know their raw milk share by line and by origin. European sellers should know what a warning does to shelf placement in American shops. The ink is the cheap part. The work sits in listings, own label specs and foodservice contracts that have to be reopened. An entrant pricing a US speciality launch should test two things. First, which of its lines are raw milk. Second, whether a warning changes the buyer's answer.

This also raises a wider question. How much of each country's cheese trade sits in types that cannot be heat treated? That is one of the areas we are tracking across cheese markets in our 2026 cheese research. The database splits production, imports, exports and consumption into 39 cheese types across 48 countries, in tonnes. Waitlist members get a free sample country chapter.