© 2007 Her Majesty the Queen in Right of Canada 
(Canadian Food Inspection Agency), all rights reserved. Use without permission is prohibited. 2007 Revisions to FDR and DPR 
regarding  Cheese 
Framework for Inspection 
October 30, 2008 Dairy Stakeholder Meeting
Aussi disponible en français2
Purpose of Meeting
1.To provide background information regarding the 
implementation approach for the revised cheese 
compositional standards in the Food and Drug 
Regulations and Dairy Products Regulations . 
2.To build awareness of the formula to be used to 
assess compliance.3
Background
•Revisions to the Food and Drug Regulations (FDR) and the 
Dairy Products Regulations (DPR) harmonize and clarify the 
ingredients permitted for c heese making. The DPR also 
introduces cheese import licensing. The revisions come into 
effect December 14, 2008.
•The revisions require that c heese derive a minimum amount of 
its casein from fluid milks and ultr afiltered milks rather than from 
other milk products AND have a w hey protein to casein ratio 
that does not exceed that of milk. 
•The casein content derived from milks must meet or exceed the 
percentages of the total protein content of the cheese, dependent on the variety
•total protein refers to the value deter mined using internationally recognized 
official methods which meas ure total nitrogen (Kjeldhal)4Inspection Framework
•Compliance Objectives
•Industry must meet regulatory requirements and be able to 
demonstrate that products are in compliance 
•Assess compliance through review and verification of 
documentation
•Focus verification efforts based on priority and risk
•Scope
•Cheese - imported and domestic (produced by federally registered establishments)  
•Foods (imported and domestic) declaring cheese as an ingredient (e.g. lasagna, pizza)5FDR/DPR Cheese Compositional 
Standards’ Framework
No
monitoringCFIA
Monitoring
If concerns or
issues arise
Non-Compliance
No
n-Compliance
6Cheese Importers
•All cheese importers will require a CFIA cheese 
import licence as of December 14, 2008
•An “Application for a Cheese Import Licence” form completed and 
required documentation attached (recall program, cheese list, and 
if required, establishment plans, sanitation and pest control 
programs, water analysis, etc.)
•During regular monitoring of the Importer Verification 
activity which assesses Good Importing Practices 
(GIP), CFIA will assess compliance of imported cheese, including the revised compositional requirements.  Acceptable documentation includes:
•Cheese specification sheets indicating specific ingredients
•Supporting documentation7Federally Registered Dairy Establishments
•CFIA will perform a verification activity to assess compliance of 
cheese to the compositional standards based on the 
establishment’s current and available records:
•Same frequency as other consumer protection activities 
•Random selection of cheese variety and several vat records over a 
one month period
•Corresponding lab reports/ invoices related to milk payment for 
protein analysis results
•Supporting documentation (e.g. lab analysis) for protein 
declaration on Nutrition Facts Table
•Random sampling and analysis of cheese for total protein by CFIA8Imported and Domestic Prepared Foods
•Inspection approaches for imported and domestic 
prepared foods (non-registered) are different from the registered food commodities. 
•CFIA conducts priority based inspections and responds to complaints for the non-registered sector. 
•CFIA will respond to complaints related to foods that contain cheese to determine compliance to the regulations. 
•The regulated party will be expected to show appropriate 
documentation to demonstrate compliance9Enforcement Approach
•Instances of non-compliance could result in one or 
more of the following enforcement actions:
•Letters of Non-Compliance; 
•Seizure and Detention of Product; 
•Suspension/Cancellation of Registration;
•Suspension/Cancellation of Licence; or 
•Prosecution.
•Each instance will be asse ssed on a case-by-case 
basis and the action(s) taken will be proportionate to the gravity of the non-compliance.10Methods to Validate Compliance
1.CFIA will randomly assess whether the cheese whey protein to 
casein ratio requirement (Codex parameter) is met by reviewing 
vat records and performing analytical testing of the cheese, if required.
2.Casein derived from milks – must meet regulatory standards
•Although there is no analytical methodology related to casein origin in the 
final product, this requi rement can be assessed by applying the following 
formula:
% Casein derived from milks = 
Quantity of milks X Protein of milks X Casein number X Re tention coefficient
Protein content of cheese  X Quantity of cheese
% CDM = Qm x Pmx CN x RC
Pc x Qc11Data sources for formula
•Quantity of milks  - individual ingredient quantities: vat records
•Protein of milks - milk payment lab reports/invoices
•Casein number - for milks, use constant values
•Retention coefficient  - use constant value
•Protein content of cheese – plant and/or CFIA lab analysis
•Quantity of Cheese – total vat quantity: vat records12Constant Values
•Although milk composition can va ry depending on time of year, 
breed, and feed, the following cons tant values will be used to 
facilitate more standardized cheese formulations and to enable uniform implementation:
•Retention coefficient  - constant value: 0.96 (Van Slyke
equation for cheese yield)
•Casein number:
•for milk: constant value: 0.7761(AAFC research)
•for cream: (xx% BF): 0.776 x (P - 0.002 x %BF)/P 
considering 2mg MFGM protein is associated to each g fat. 
(MFGM = milk fat globule membrane)
•for UF milk: value is estimated from prot ein concentration (P):    
CN = (P - 0.15) x 0.813)/P.
1Couture, L. and Britten, M. 1997 Variation saisonnières des propriét és physico-chimiques du lait. Dossier 
recherche 1.2,Cellule de recherche en physico -chimie du lait, St-Hyacinthe (Qc.), 10pp.13Next Steps
•Distribution of Information Letter to regulated parties 
to explain the framework for inspection
•CFIA training of inspection staff to assess compliance14