PolicyBrief
S. 184
119th CongressJan 22nd 2025
Codifying Useful Regulatory Definitions Act
IN COMMITTEE

The CURD Act establishes a formal federal definition and standardized labeling requirements for "natural cheese" to ensure transparency and distinguish it from processed cheese products.

Ron Johnson
R

Ron Johnson

Senator

WI

LEGISLATION

New CURD Act Sets National Standard for 'Natural Cheese' Labels Starting in 2024

Ever stood in the dairy aisle wondering why some cheddar feels like real food while that yellow block next to it feels like a science experiment? The Codifying Useful Regulatory Definitions (CURD) Act is stepping in to clear the air. This bill officially amends the Federal Food, Drug, and Cosmetic Act to create a legal definition for "natural cheese," finally drawing a hard line between traditional dairy products and the "process cheese" that often sits right beside them on the shelf. By setting a federal standard, the bill ensures that when you see "natural cheese" on a label, it refers to a product made through traditional coagulation or modern techniques that yield the same physical and chemical results (Section 3). For a busy parent trying to buy real ingredients for school lunches, this means less time squinting at fine print and more confidence that the label actually matches the contents.

The Shred on Standards

To qualify as "natural cheese" under this new rule, a product must be a ripened or unripened soft, semi-soft, or hard cheese. It has to be made by coagulating milk proteins—whether from cows, goats, or other animals—and draining the whey so the protein count is higher than the original milk (Section 3). The bill specifically kicks several products out of the "natural" club, including pasteurized process cheeses, cheese spreads, and "cold pack" cheeses. Think of it this way: if you’re a small deli owner, you’ll now have a clear legal distinction between the premium blocks you slice for sandwiches and the shelf-stable spreads that are now explicitly excluded from the "natural" category.

One Label to Rule Them All

One of the biggest shifts here is the move toward national uniformity. The CURD Act prevents states from coming up with their own quirky definitions for "natural cheese," meaning a cheesemaker in Wisconsin doesn't have to worry about different labeling laws when shipping to California (Section 3). This streamlines the process for producers and keeps costs from spiking due to redundant packaging requirements. However, there is a bit of a loophole to watch: while the phrase "natural cheese" is now strictly regulated, companies can still use terms like "all-natural" or "natural" based on broader, existing FDA guidance. It’s a subtle distinction, but it means you might still see some marketing fluff on products that don't quite meet the strict "natural cheese" technical standard.

Who Wins and Who Adjusts

The clear winners here are traditional dairy farmers and artisanal producers who have been competing against cheaper, processed alternatives that use similar-sounding names. On the flip side, companies currently using "natural cheese" branding for products that fall into the "process" category—like certain snack packs or pre-melted dips—will have to overhaul their packaging to stay compliant. While the bill relies on the Secretary of Health and Human Services to handle future "comparable products," the immediate impact is a much-needed reality check for the dairy case, ensuring that the "natural" label actually stands for something specific rather than just being a vibe.