FSC 8910/8940

METRIC

A-A-20154C

September 29, 2021

SUPERSEDING

A-A-20154B

December 3, 2012

COMMERCIAL ITEM DESCRIPTION

COTTAGE CHEESE

The U.S. Department of Agriculture (USDA) has authorized

the use of this Commercial Item Description (CID).

1. SCOPE. This CID covers cottage cheese, packed in commercially acceptable containers, 

suitable for use by Federal, State, local governments, and other interested parties. Please note: 

This document does not guarantee purchase of this item by USDA.1

2. PURCHASER NOTES.

2.1 Purchasers must specify the following:

• Group(s), style(s), type(s), flavor(s), packaging size(s), and agricultural practice(s) of cottage 

cheese desired (Sec. 3).

• When compliance with analytical requirements must be verified (Sec. 7.2).

• Manufacturer’s/distributor’s certification (Sec. 10.2) or USDA certification (Sec. 10.3).

2.2 Purchasers may specify the following:

• Manufacturer’s quality assurance and plant survey (Sec. 10.1).

• Packaging requirements other than commercial (Sec. 11).

3. CLASSIFICATION. The cottage cheese must conform to the following list which must be 

specified in the solicitation, contract, or purchase order.

1 USDA purchase specifications are available at: https://www.ams.usda.gov/selling-food/product-specs.
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Groups, styles, types, flavors, packaging sizes, and agricultural practices of cottage cheese.

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Group I - Curd set by bacteria culture

Group II - Curd set by direct acidification

Style A - Small curd3

Style B - Large curd3

Type 1 - Dry curd cottage cheese

Type 2 - Fat free cottage cheese

Type 3 - Low fat cottage cheese

Type 4 - Cottage cheese

Type 5 - No salt added low fat cottage cheese

Flavor a - Unflavored

Flavor b - With added nuts, fruits, chives, olives, peppers, or pimientos

Flavor c - Other (as specified by the purchaser)

Packaging size (1) - 142 grams (g) (5 ounces (oz))

Packaging size (2) - 150 g (5.3 oz)

Packaging size (3) - 397 g (14 oz)

Packaging size (4) - 454 g (16 oz)

Packaging size (5) - 634 g (22 oz)

Packaging size (6) - 680 g (24 oz)

Packaging size (7) - Other (as specified by purchaser)

Agricultural practice (a) - Conventional

Agricultural practice (b) - Organic

4. MANUFACTURER’S/DISTRIBUTOR’S NOTES. Manufacturer’s/distributor’s 

products must meet the requirements of the:

• Processing guidelines (Sec. 5).

• Salient characteristics (Sec. 6).

• Analytical requirements: as specified by the purchaser (Sec. 7).

• Manufacturer’s/distributor’s product assurance (Sec. 8).

• Regulatory requirements (Sec. 9).

2 Not all options are available from every manufacturer. Check with the manufacturer/distributor for availability. 

3 USDA Specifications for Cottage Cheese and Dry Curd Cottage Cheese available at https://www.ams.usda.gov/grades-standards/dairy-productquality-specifications. 
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• Quality assurance provisions: as specified by the purchaser (Sec. 10).

• Packaging requirements other than commercial: as specified by the purchaser (Sec. 11).

5. PROCESSING GUIDELINES.

5.1 Processing. The cottage cheese must be processed in accordance with Current Good 

Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food

(21 Code of Federal Regulations (CFR) Part 117). The manufacturing plants must be eligible for 

Section I listing in the most recent version of the publication Dairy Plants Surveyed and 

Approved for USDA Grading Service.

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5.2 Food defense. The cottage cheese must be processed and transported in accordance with

Mitigation Strategies to Protect Food Against Intentional Adulteration (21 CFR Part 121). This 

document identifies the kinds of preventive measures food manufacturers, processors, or 

handlers may take to minimize the risk that food under their control will be subject to tampering 

or other malicious, criminal, or terrorist actions. The implementation of enhanced food defense

preventive measures provides for the security of a plant’s production processes and includes the 

storage and transportation of pre-production raw materials, other ingredients, and postproduction finished product. 

5.3 Organic ingredients. When organic cottage cheese is specified in the solicitation, contract, 

or purchase order, the cottage cheese must be produced, handled, and labeled in accordance with 

the USDA organic regulations by an operation that is certified organic in accordance with the 

requirements of the National Organic Program (7 CFR Part 205). A Certificate of Organic 

Production or Handling must be provided to verify that the product was processed and handled in 

accordance with the USDA organic regulations.

5.4 Pasteurization. The dairy ingredients used in the manufacture of cottage cheese and the 

final product must be subjected to such temperatures and holding periods in approved systems as 

will assure proper pasteurization or ultra-pasteurization of the product. The heat treatment by 

either process must be sufficient to ensure public health safety and to assure adequate keeping 

quality yet retaining the most desirable flavor and body characteristics of the finished product in 

accordance with the requirements of Good Laboratory Practice for Nonclinical Laboratory 

Studies (21 CFR Part 58).

5.5 Storage temperature. Once the cottage cheese is packaged, the cottage cheese must be 

maintained at a temperature of 7.2°C (45°F) or lower.

5.6 Shelf life. Once the cottage cheese is packaged, the cottage cheese must have a remaining 

shelf life of at least 60 days.

4 The Dairy Plants Surveyed and Approved for USDA Grading Service is available at: https://apps.ams.usda.gov/dairy/ApprovedPlantList/. 
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5.7. Keeping quality requirements. Keeping quality samples taken from the packaging line 

must be held at 45°F for 10 days for assessment. At the end of the 10-day period the samples 

must possess a satisfactory flavor and appearance, and must be free from bitter, sour, fruity, or 

other objectionable tastes and odors. The surface must not be discolored, translucent, slimy or 

show any other objectionable condition in accordance with the requirements (7 CFR §58.530).

6. SALIENT CHARACTERISTICS.

6.1 Definitions. 

6.1.1. Direct acidification. The production of cottage cheese, without the use of bacterial 

starter cultures, through the use of approved food grade acids. This product must be labeled 

according to the requirements of the Food and Drug Administration (FDA), 21 CFR §133.128 or 

§133.129, as appropriate (7 CFR §58.505(c)).

6.1.2. Dry curd cottage cheese. Cottage cheese dry curd is the soft uncured cheese with less 

than 0.5 percent milkfat. It contains not more than 80 percent moisture (21 CFR §131.129(a)).

6.1.3. Cottage cheese. Cottage cheese is the soft uncured cheese prepared by mixing cottage 

cheese dry curd with a creaming mixture prepared from safe and suitable ingredients including 

but not limited to, milk or substances derived from milk. The milkfat content is not less than 4 

percent by weight of the finished food, within limits of good manufacturing practice. The 

finished food contains not more than 80 percent moisture. (21 CFR §133.128(a)).

6.1.4. Fat free. Less than 0.5 g of total fat per reference amount customarily consumed 

(RACC)

5 (21 CFR §101.62(b)(1)(i)).

6.1.5. Low fat. The food has a RACC greater than 30 g or greater than 2 tablespoons and 

contains 3 g or less of fat per RACC5 (21 CFR §101.62(b)(2)(i)(A)).

6.1.6. No salt added. Food contains no added salt and must meet the conditions of use and 

must declare “This is Not a Sodium Free Food” as required if the food is not “Sodium Free” in 

accordance with 21 CFR §101.61(c)(2).

6.2 Labeling. All ingredients must be declared by their common or usual name in descending 

order of predominance by weight (21 CFR §101.4) unless exempted by 21 CFR §101.100.

5 The RACC for cottage cheese is 110 grams (Table 2 of 21 CFR §101.12(b)). 
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6.3 Ingredients.

6.3.1 Raw ingredients. Dairy ingredients used in the manufacture of cottage cheese must 

originate from a plant that has been approved by the Dairy Grading and Standards Division

(DGSD), Dairy Program (DP), Agricultural Marketing Service (AMS), USDA.

6.3.2 Additional and optional processing ingredients. When used, all additional ingredients 

must meet the standards specified in the Food Chemicals Codex (FCC) or, in the absence of FCC 

specification at a minimum, meet the specifications for quality set by the U.S. Pharmacopeia 

(USP)-National Formulary. The additional ingredients must be approved food additives 

(21 CFR Part 170) or meet Generally Recognized as Safe (GRAS) requirements (21 CFR Parts 

182 and 184) for those uses by FDA.

6.4 Finished product.

6.4.1 Flavor and aroma. The cottage cheese must possess a pleasing and desirable flavor to 

fresh milk, or cream (if creamed) and may possess the delicate flavor and aroma of a good lactic 

starter if used. The cottage cheese may possess to a slight degree feed (such as alfalfa, clover, 

silage, or similar feeds or grasses), acid, flat, or salty flavor but must be free from bitter, chalky, 

utensil, fruity, fermented, yeasty, or other objectionable flavors and odors. Flavor b cottage 

cheese must possess a clean characteristic flavor of the added nuts, fruits, chives, olives, peppers, 

or pimientos as specified by the purchaser. The flavor of the added ingredients used must be 

natural and represent the intended flavor and intensity desired in the finished product. 

6.4.2 Color. The finished cottage cheese must have an attractive natural creamy white color.

6.4.3 Texture. When creamed, the cottage cheese must be uniformly mixed with the creaming 

mixture which is properly absorbed into or adhering onto the curd so as to prevent excessive 

drainage. The added condiments to Flavor b cottage cheese must be distributed uniformly 

throughout the product. The cottage cheese body and texture must be smooth and velvety and 

must not be mealy, grainy, crumbly, pasty, sticky, mushy, weak, watery, rubbery, over firm or 

slimy. 

6.5 Foreign material. All condiments added to the cottage cheese that have Defect Action 

Levels must not exceed those tolerances specified in 21 CFR §117.110. All other ingredients 

must be clean, sound, wholesome, and free from foreign material, such as, but not limited to, 

extraneous plant material, dirt, plastic, insects, insect pieces or rodent or insect infestation. 
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7. ANALYTICAL REQUIREMENTS.

7.1 Analytical and microbiological requirements. Unless otherwise specified in the 

solicitation, contract or purchase order, the following analytical and microbiological 

requirements for the cottage cheese must conform to those in Table I:

TABLE I. Analytical and microbial requirements

Test Group Type Requirement

Fat6 I, II 1, 2 Less than 0.5 percent

Fat6 I, II 3, 5 0.5 - 3.0 percent

Fat6 I, II 4 4.0 - 5.0 percent

Moisture6 I, II 1, 2, 3, 4, 5 76 - 80 percent

Salt6 I, II 1, 2, 3, 4 0.8 - 1.2 percent

pH I, II 1, 2, 3, 4, 5 Less than 5.2

Phosphatase I, II 1, 2, 3, 4, 5 Not to exceed 4 micrograms of phenol 

equivalent per g of cheese

Coliform I, II 1, 2, 3, 4, 5 Not to exceed10 Colony Forming Units 

(CFU) per g or Most Probable Number 

(MPN) per g

Psychrotrophic I, II 1, 2, 3, 4, 5 Not to exceed 100 CFU per g

Enterobacteriaceae I, II 1, 2, 3, 4, 5 Not to exceed 10 CFU per g

Yeast and Mold I, II 1, 2, 3, 4, 5 Not to exceed10 CFU per g or MPN 

per g

6 Milkfat by weight of finished food.
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Standard Plate Count I 1, 2, 3, 4, 5 Not to exceed 25,000 CFU per g or 

MPN per g

Standard Plate Count II 1, 2, 3, 4, 5 Not to exceed 10 CFU per g or MPN 

per g

7.2 Analytical verification. Purchaser must specify manufacturer’s/distributor’s certification 

(Sec. 10.2) or USDA certification (Sec. 10.3).

7.3 USDA verification procedures. When USDA certification (Sec. 10.3) is specified in the 

solicitation, contract, or purchase order, analytical testing must be performed as follows.

7.3.1 Product verification sampling. When USDA verification of analytical requirements is 

specified in the solicitation, contract, or purchase order, analytical testing must be performed on 

subsamples of packages randomly selected from the lot. The number of subsamples must be 

based on USDA inspection service sampling procedures and plans. The contents of each will be 

used to create a composite sample that will be used in the analytical testing. 

7.3.2 Analytical testing and reporting. When specified in the solicitation, contract, or 

purchase order, the analyses must be made in accordance with the following methods from the 

Association of Official Analytical Collaboration (AOAC) International Official Methods of 

Analysis (OMA) or as specified in Table II. 

TABLE II. Analytical testing methods

Test Method Reported as

Fat AOAC 933.05 Nearest 0.1 percent

Moisture AOAC 926.08 Nearest 0.1 percent

Salt AOAC 935.43, 975.20, 983.14 Nearest 0.1 percent

pH AOAC 943.02; 945.27; 981.12 Nearest 0.01 value

Phosphatase AOAC 946.03 Nearest whole number

Coliform AOAC 992.30, 966.24, 991.14, 

2000.15

Nearest 10 CFU or MPN per g
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Psychrotrophic Standard Methods for the 

Examination of Dairy Products

(SMEDP) Chapter (Ch) 8, Tests 

for groups of Microorganisms, 

Psychrotropic Bacteria (Class O). 

SMEDP, 17th edition, 2004, pp 

227-229.

Nearest whole number

Enterobacteriaceae AOAC 2003.01 or Pour Plate by 

Violet Red Bile Glucose (VRBG)

Nearest 10 CFU per g

Yeast and mold AOAC 995.21, 997.02

Bacteriological Analytical 

Manual (BAM) Ch 187

Nearest 10 CFU or MPN per g

Standard Plate Count AOAC 986.32, 988.18, 990.12, 

2019.02 or BAM Ch 37

Nearest 10 CFU or MPN per g

8. MANUFACTURER’S/DISTRIBUTOR’S PRODUCT ASSURANCE. The manufacturer/ 

distributor must certify that the cottage cheese provided meets the salient characteristics of this 

CID, conform to their own specifications, standards, and quality assurance practices, and be the 

same cottage cheese offered for sale in the commercial market. The purchaser reserves the right 

to require proof of conformance.

9. REGULATORY REQUIREMENTS. The delivered cottage cheese must comply with all 

applicable Federal, State, and local mandatory requirements and regulations relating to the 

preparation, packaging, labeling, storage, distribution, and sale of the cottage cheese in the 

commercial marketplace. Delivered cottage cheese must comply with all applicable provisions 

of the Federal Food, Drug, and Cosmetic (FD&C) Act, the Fair Packaging and Labeling Act, 

Food Allergen Labeling and Consumer Protection Act (FALCPA), and regulations promulgated 

thereunder. The allergen statement must be provided in a format which complies with FALCPA 

for any product which contains wheat, fish, milk, soy, tree nuts, eggs, peanuts, and Crustacean 

shellfish or those in effect on the date of the solicitation, contract, or purchase order. When the 

cottage cheese is used for the Child Nutrition Programs, the cottage cheese must comply with all 

applicable provisions of the Child Nutrition (CN) Program. When a CN label is specified, the 

label must be approved in its final format by the AMS.

7 8th Edition, FDA Bacteriological Analytical Manual (BAM) or the FDA BAM Online is available at: https://www.fda.gov/food/laboratorymethods-food/bacteriological-analytical-manual-bam. 
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10. QUALITY ASSURANCE PROVISIONS. Purchaser must specify 10.2 or 10.3.

10.1 Manufacturer’s quality assurance and plant survey. When required in the solicitation, 

contract, or purchase order, the manufacturer must be required to have their facilities inspected 

by USDA, AMS, DP, DGSD, and be eligible for listing in Section I of the AMS publication 

Dairy Plants Surveyed and Approved for USDA Grading Service. An AMS DP plant survey 

verifies that at the time of the survey, the manufacturer produces products in a clean sanitary 

environment in accordance with Current Good Manufacturing Practice, Hazard Analysis, and 

Risk-Based Preventive Controls for Human Food (21 CFR Part 117) and the requirements 

contained in 7 CFR Part 58 Grading and Inspection, General Specifications for Approved Plants 

and Standards for Grades of Dairy Products.

10.2 Manufacturer’s/distributor’s certification. When required in the solicitation, contract, 

or purchase order, the manufacturer/distributor must certify that the cottage cheese delivered

meets or exceeds the requirements of this CID. The manufacturer/distributor must certify via a 

Certificate of Conformance or other adequate documentation (as specified by the purchaser) that 

the cottage cheese meets analytical requirements specified in Sec.7 of this CID.

10.3 USDA certification. When required in the solicitation, contract, or purchase order that 

product quality and acceptability or both be determined, the DGSD, DP, AMS, USDA, must be 

the certifying program. DGSD inspectors must certify the quality and acceptability of the 

cottage cheese in accordance with DGSD procedure which include: selecting random samples of 

the cottage evaluating the samples for conformance with the salient characteristics of this CID 

and other contractual requirements, and documenting the findings on official DGSD certificates.

In addition, when required in the solicitation, contract, or purchase order, DGSD inspectors will 

examine the cottage cheese for conformance to the Standards for Condition of Food Containers 

(7 CFR Part 42) in effect on the date of the solicitation. To qualify for this option the plant must 

be listed in Dairy Plants Surveyed and Approved for USDA Grading Service (See Sec. 10.1).

11. PACKAGING. Preservation, packaging, packing, labeling, and case marking must be 

commercial unless otherwise specified in the solicitation, contract, or purchase order.

12. USDA INSPECTION NOTES. When Sec. 10.3 is specified in the solicitation, contract, 

or purchase order, USDA certification must include evaluation of the quality and condition 

of samples of cottage cheese and compliance with requirements in the following areas:

• Processing guidelines (Sec. 5).

• Salient characteristics (Sec. 6).

• Analytical requirements when specified in the solicitation, contract, or purchase order

(Sec.7). When USDA analytical testing is specified, SCI Division inspection personnel must 
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select samples and submit them to the USDA, AMS, Science and Technology Program 

(S&TP) laboratory for analysis.

• Packaging requirements (Sec. 11).

13. REFERENCE NOTES.

13.1 USDA services.

13.1.1 USDA plant surveys and certification. For USDA plant surveys and certification 

contact: Grading and Standards Division, DP, AMS, USDA, Room 2968 South Building, 

STOP 0225, 1400 Independence Avenue, SW, Washington, DC 20250-0225, telephone 

(202) 720-3171, via E-mail: DairyNFO@usda.gov or on the internet at:

www.ams.usda.gov/services/auditing/dairy-plant-survey-program.

13.1.2 Analytical testing and technical information. For USDA technical information on 

analytical testing, contact the Laboratory Approval and Testing Division, S&TP, AMS, 

USDA, STOP 0272, 1400 Independence Avenue, SW, Washington, DC 20250-0272, 

telephone (202) 690-4089 or via E-mail: LATD@usda.gov. Samples for specified USDA 

analytical testing should be sent to the USDA, AMS, S&TP laboratory for analysis at: USDA, 

AMS, S&T, National Science Laboratory, 801 Summit Crossing Place, Suite B, Gastonia, 

NC 28054.

13.2 Sources of documents.

13.2.1 Sources of information for nongovernmental documents are as follows:

Copies of the AOAC International OMA may be obtained from: AOAC International, 2275 

Research Boulevard, Suite 300, Rockville, MD 20850-3250, telephone (301) 924-7077. 

Internet address: http://www.aoac.org for nonmembers and http://www.eoma.aoac.org for 

members and AOAC OMA subscribers.

Copies of the Food Chemicals Codex and U.S. Pharmacopeia may be purchased from: United 

States Pharmacopeia Convention, 12601 Twinbrook Parkway, Rockville, MD 20877, 

telephone (800) 227-8772 or (301) 881-0666, fax (301) 816-8148 or on the Internet at: 

http://www.usp.org.

Copies of the Standard Methods for the Examination of Dairy Products may be purchased from: 

American Public Health Association, 800 I Street, NW, Washington, DC 20001, telephone 

(202) 777-2742 or on the Internet at: http://apha.org.
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13.2.2 Sources of information for governmental documents are as follows:

Applicable provisions of the Standards for Condition of Food Containers are contained in 7 CFR 

Part 42, the National Organic Program are contained in 7 CFR Part 205, the Fair Packaging and 

Labeling Act are contained in 16 CFR Parts 500 to 503, and the Federal Food, Drug, and 

Cosmetic Act are contained in 21 CFR Parts 1 to 199. These documents may be purchased from: 

Superintendent of Documents, New Orders, P.O. Box 979050, St. Louis, MO 63197-9000. 

Credit card (Visa, MasterCard, Discover/NOVUS, and American Express) purchases may 

be made by calling the Superintendent of Documents at (866) 512-1800, (202) 512-1800. 

These documents may also be obtained free of charge on the Internet at: 

http://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR.

Copies of the FDA Bacteriological Analytical Manual (BAM) are available online from: FDA, 

Center of Food Safety and Applied Nutrition (CFSAN) on the Internet at: 

https://www.fda.gov/food/laboratory-methods-food/bacteriological-analytical-manual-bam. 

Copies of this CID and the Standards for Condition of Food Containers (7 CFR Part 42) are 

available from: Director, SCI Division, SCP, AMS, USDA, Room 1536 South Building, 

STOP 0240, 1400 Independence Avenue, SW, Washington, DC 20250-0240, via E-mail: 

CIDS@usda.gov or on the Internet at: http://www.ams.usda.gov/grades-standards/cids

and https://www.gpo.gov/fdsys/pkg/CFR-2019-title7-vol2/pdf/CFR-2019-title7-vol2-

part42.pdf.

CIVIL AGENCY COORDINATING ACTIVITY:

DOJ - BOP

HHS - FDA

USDA - SCP

VA - OSS

PREPARING ACTIVITY:

USDA - SCP

Non-Discrimination Policy: In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations 

and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited 

from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, 

disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation

for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and 

complaint filing deadlines vary by program or incident. 

Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American 

Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA 

through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. 

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at How to 

File a Program Discrimination Complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the 
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information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to 

USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, 

Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov. 

USDA is an equal opportunity provider, employer, and lender.