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What does European law say about raw-milk cheeses?


Let's start with some history.

Europe began issuing general conduct regulations in the 1990s, with the aim of allowing the survival of raw-milk cheese production and at the same time guaranteeing consumer safety.

There are two schools of thought within the European Union. Northern countries tend to focus more on industrial production using pasteurized milk and intensive farming, while around the Mediterranean, a large variety of traditional cheeses are still produced. France, which has an important history of PDO raw-milk cheeses, plays a crucial role in the debate. Some scientific documents on potential risks relating to raw milk - in particular that on staphylococcal enterotoxin published in 2003 by the European Union and the documents on Listeria monocytogenes published in 1997 by the Ecole Nationale Vétérinaire of Maisons Alfort and in 2000 by the French Food Safety Agency - support the choice to preserve artisan cheeses as long as an efficient self-checking program plan is in place.

The first European directive dates from 1992 (92/46/EEC) and has been followed by a number of regulations (852/2004, 853/2004, 2073/2005, 2074/2005). The production of raw-milk cheeses was allowed, as long as certain minimum requirements were met.

Each European Union member state must follow these minimum regulations, but they can also establish stricter measures. As a result, an individual country can decide to ban the sale of raw-milk cheeses.

Here is an outline of the basic requirements established by the EU for producing raw-milk cheeses.

Raw material


- The milk must come from animals that have no symptoms of infectious diseases that can be transmitted to humans through milk (in particular it must come from farms officially free from brucellosis and tuberculosis), that are healthy and that have not been given unauthorized substances or products, and minimum suspension times must have been respected.


- The bacterial count allowed for raw cow's milk is a maximum of 100,000 bacteria per ml (measured at 30°C).


- The bacterial count allowed for raw milk from other animals is a maximum of 500,000 bacteria per ml (measured at 30°C).
In the case of cow's milk, the somatic cell count is also measured, and the maximum allowed is 400,000 cells per ml.
If these minimum requirements are not respected, producers have three months to identify and resolve the problem.
After this period, depending on the country, the producers either cannot continue to sell or process the milk, or they can use it only for specific products (or to make pasteurized cheeses or raw-milk cheeses aged for at least 60 days). 


- If the milk is not processed within two hours of milking, it must immediately be stored in a clean place and chilled to a temperature below 8°C (in case of daily milking) or below 6°C (when milking is not carried out daily).

 

 

Processing facilities


The facilities must be clean, undergo regular maintenance and be kept in good conditions. The design, construction and location of the facilities must allow proper maintenance, cleaning and/or disinfection, avoiding or reducing to the minimum any air-borne contamination and ensuring a work space that allows all operations to be carried out in hygienic conditions. A sufficient number of toilets must be available, connected to a suitable disposal system, which must not discharge directly to where food is being processed, and a sufficient number of sinks, properly located and signposted for handwashing. 


Floors, walls, ceilings, doors and windows must be kept in good condition, be easy to clean and, if necessary, to disinfect. This requires the use of resistant, non-absorbent, washable and non-toxic materials. 


All the surfaces, including equipment surfaces, in the area where food is processed and particularly those that come into contact with food must be kept in good condition and be easy to clean and, if necessary, to disinfect.

 

Therefore they must be made from smooth, washable, corrosion-resistant and non-toxic materials.

 

 

Exceptions


Member states can grant exceptions regarding processing facilities and materials to businesses that produce traditional cheeses (PDO, IGT, PAT - Prodotti Agroalimentari Tradizionali, traditional food products).


If the environment contributes to the development of the cheese's characteristics, the facilities can have walls, ceilings and doors not made from smooth, impermeable, non-absorbent, corrosion-resistant materials and natural geological walls, ceilings and floors. 


The same applies to the materials used for the tools and equipment for the preparation and packaging of the cheeses.

 

 

Recognition and registration

 

Businesses that produce, process, transport, store and sell products of animal origin must be either registered or recognized.

 

Registration allows sales at a local level. Recognition replaces the old EEC stamp and allows sales to other retailers, abroad, etc., without geographical limitations.

 

The procedures for obtaining registration are slightly simpler.

Recognition involves more frequent inspections by the health authorities.

 

 

Microbiological characteristics of raw-milk cheese

 

Moving on from milk to cheese, it is necessary to guarantee the following through regular analyses:
- the absence of Listeria monocytogenes
- the absence of Salmonella
- the absence of staphylococcal enterotoxins
- the control of the presence of bacteria indicating poor hygiene (Escherichia coli and coagulase-negative staphylococci)

 

 

Labels

 

The label (packaging, document, placard, label, ring or band) that accompanies products made from raw milk must clearly indicate "made with raw milk."

 

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