Note on source materials
- The header metadata supplied with this request includes an inconsistent title (“Congratulating the Honorable Bill Callegari and Ann Callegari on their 65th wedding anniversary”) and classification as a resolution. The full bill text provided is instead a substantive statute bill that would amend the Federal Food, Drug, and Cosmetic Act to define “natural cheese.” This summary addresses the substantive bill text (introduced Feb 14, 2025), commonly called the “Codifying Useful Regulatory Definitions Act” or “CURD Act.”
Overview
- Short title: Codifying Useful Regulatory Definitions Act (CURD Act).
- Purpose: Add a statutory definition of the term “natural cheese” to the Federal Food, Drug, and Cosmetic Act (FD&C Act), require labeling consistency, and clarify national uniformity for use of the term.
- Bill number/status: H.R. 1394 — introduced Feb 14, 2025; referred to House Energy & Commerce; rules suspended and adopted May 29, 2025; reported enrolled May 29, 2025.
Key provisions
1. New statutory definition (adds section 201(ss) to FD&C Act, 21 U.S.C. 321):
- Defines “natural cheese” as a ripened or unripened soft, semi‑soft, or hard cheese (may be coated) produced either:
- By coagulating milk proteins (milk, skimmed milk, partially skimmed milk, cream, whey cream, buttermilk, or combinations) via rennet or other coagulating agents and partially draining whey — emphasizing concentration of casein/protein; or
- By processing techniques that coagulate milk protein to yield end‑products with similar physical, chemical, and organoleptic characteristics to the product above.
- Permits addition of “safe and suitable non‑milk derived ingredients” of the type allowed under applicable standards of identity.
- Allows compliance alternatively with standards of identity under 21 C.F.R. part 133 (other than certain excluded standards).
Explicit exclusions (products that are not “natural cheese”):
- Pasteurized process cheeses and related categories (specific 21 C.F.R. sections cited: e.g., 133.169–133.171, 133.173–133.174, 133.175–133.176–133.178, 133.179–133.180, 133.167–133.168).
- Cold pack cheeses (133.123–133.125), grated American cheese food (133.147), comparable products, and any other products the FDA Secretary designates as “process cheese.”
Definition of “milk”:
- Incorporates the meaning in 21 C.F.R. 133.3 and explicitly includes lacteal secretions from animals other than cows.
Labeling amendment (adds FD&C Act section 403(z), 21 U.S.C. 343):
- Prohibits labeling or labeling claims that describe a product as “natural cheese” unless it meets the new statutory definition.
- Clarifies that the bill does not prohibit the use of “natural,” “all‑natural,” or similar claims when consistent with FDA regulations, guidance, or policy.
National uniformity:
- Amends section 403A(a)(2) to include the new labeling subsection (403(z)), reinforcing federal preemption / national uniformity for this labeling claim.
Who would be affected
- Cheese producers and processors (dairy industry), especially manufacturers of specialty cheeses and processed cheese products.
- Food manufacturers and private‑label brands that use “natural cheese” as a descriptor.
- Retailers and foodservice operations that label or market cheese products.
- State regulators and consumers: national uniformity may limit state‑level divergent labeling requirements; consumers could see clearer distinctions between “natural cheese” and process cheeses.
Procedural / timeline notes
- Introduced in House: Feb 14, 2025 (Rep. Bryan Steil primary sponsor, with multiple cosponsors including Jim Costa, Mark Pocan, Glenn Grothman, among others).
- Referred to House Energy & Commerce: Feb 14, 2025.
- Filed: May 26, 2025; Rules suspended, adopted, and reported enrolled: May 29, 2025.
- Companion bill: S. 184.
Potential implications
- Provides a federal, statutory baseline definition intended to reduce labeling ambiguity and potential consumer confusion.
- May prompt regulatory adjustments (FDA guidance or administrative actions) and compliance costs for producers who must modify formulations, labeling, or marketing practices to meet the statutory definition.
- Strengthens federal uniformity over state standards or disparate claims related to “natural cheese.”