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  1 
Implementation Approach for Revised Cheese Compositional Standards  
 
Dairy and Food Industry Stakeholders,  
The purpose of this notice is to advise you of  the implementation approach that the Canadian 
Food Inspection Agency (CFIA) will use to assess the compliance of cheese, as per the amendments to the Food and Drug Regulations  (FDR) and the Dairy Products Regulations 
(DPR), which come into effect on December 14, 2008.  The amendments can be accessed at http://canadagazette.gc.ca/partII/2007/20071226/pdf/g2-14126.pdf
. 
 
Scope  
 All cheese is included in these Regulations, except for those with separate compositional standards – cream cheese, whey cheese, cottage  cheese.  The casein content requirement 
does not apply to Feta cheese.  Cheese used as an ingredient in any other food, must meet the 
compositional standard for cheese.  CFIA will assess compliance with the revised FDR and 
DPR requirements of domestic cheese produced in federally registered establishments and 
imported cheese.    Compliance Objectives
 
 
• The food industry is responsible for meeting regulatory requirements and demonstrating 
that products are in compliance. 
• CFIA will assess compliance through review and verification of documentation. 
• CFIA will focus verification efforts based on priority and risk. 
 
Cheese Importers  
 The CFIA will assess the compliance of imported cheese from licensed cheese importers as part of the Importer Verification activity (distributed July 2008 for December implementation, to assess the importer’s controls to meet various regulatory requirements).  Acceptable documentation that importers could provide incl udes specification sheets for each cheese and if 
necessary, supporting documentation (i.e. attestations based on the compliance formula) that 
the cheese meets the revised regulatory requirements.  Federally Registered Establishments producing Cheese
 
 
The CFIA will perform a verification activity to monitor and assess the compliance of 
domestically produced cheese based on the est ablishment’s current and available vat and 
laboratory records.  For each inspection, the inspector will randomly select a cheese variety and several of its vat records over a one month period.  Corresponding laboratory reports/invoices for protein levels in milk (used for milk pay ment purposes) and supporting documentation or 
analyses for cheese protein values will be inserted into the formula (indicated below) to validate 
compliance.  CFIA will periodically sample and analyze the cheese variety selected to confirm its total protein value.  Imported and Domestic Prepared Foods
 
 
The food industry is required to meet regulatory requirements and be able to demonstrate 
compliance.  CFIA will respond to complaints related to foods that contain cheese and review and verify appropriate documentation to assess the compliance of the cheese used as an ingredient in other food.   Aussi disponible en français 
   
  2 
Methods to Validate Compliance   
 1. The CFIA will randomly assess whether the chees e whey protein to casein ratio requirement 
is met by reviewing vat records and performing analytical testing of the cheese, if required. 
 
2. The Regulations state that specific cheese varieties must have a casein content that is derived from milk
1 or from ultrafiltered milk1, partly skimmed milk1, ultrafiltered partly skimmed 
milk1, skim milk1, ultrafiltered skim milk1or cream1, rather than from other milk products, that 
meets at least the stated percentage of the total protein content2 of the cheese.  
2 Total Protein: total nitrogen x 6.38 (Kjeldahl method – recognized method included in CODEX 
STAN 234-1999 for protein analysis in cheese) 
 This can be expressed as the following formula:  
% Casein derived from milks = 
 
Quantity of milks
1 X Protein of milks X Casein number3 X Retention coefficient4 
  Protein content of cheese2 X Quantity of cheese 
 
% CDM = Qm x Pm x CN x RC  
Pc x Qc 
 
Although milk composition can vary depending on time of year, breed and feed, to facilitate more standardized cheese formulations and to enable uniform implementation, the following constant values will be used: 
  
• 3Casein number: 
 • for milk use constant value: 0.776,   
(derived from research performed by AAFC, averaging specific milk values over a 48 week period) 
• for cream ( xx% BF): 0.776 x (P - .002 x BF)/P  
(considering 2mg MFGM protein is associated to each g fat. (MFGM = milk fat globule membrane)) 
• for UF milk: CN = (P - 0.15) x 0.813)/P. 
(value is estimated from protein concentration (P))                           
 
• 
4Retention coefficient - use constant value: 0.96  
(constant value from the Van Slyke equation representing the amount of casein retained in cheese)   
 The CFIA will use this formula during inspections at federally registered cheese establishments 
and cheese importers are to provide it to foreign suppliers to enable attestations of imported 
cheese varieties.    Enforcement Approach
 
 The CFIA has the flexibility to select the appropriate enforcement response based on the gravity 
of the non-compliance, considering factors such as the potential or actual harm, the compliance 
history of the regulated party and the intent. There are a range of activities that the CFIA may utilize that provide for a graduated enforcement approach and results in a compliance and enforcement continuum - promoting compliance, assessing compliance and responding to non-compliance.