Cheese Composition Standards Verification
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1. Objective of Activity
To assess that cheese manufactured at federally registered dairy establishments meets the compositional requirements of the Dairy Products Regulations and the Food and Drug Regulations related to the content of casein derived from milk, partly skimmed milk, skimmed milk, ultrafiltered milk, ultrafiltered partly skimmed milk, ultra-filtered skimmed milk (fluid milks) and cream, collectively referred to as percentage casein derived from milks (% CDM).
This activity is conducted by Canadian Food Inspection Agency (CFIA) inspectors to assess compliance with the compositional requirements for cheese produced at registered dairy establishments in Canada. This activity is conducted in both traditionally inspected dairy establishments and in Hazard Analysis Critical Control Point (HACCP) recognized establishments making cheese. This activity does not apply to establishments that only cut, shred or repackage domestic cheese.
This verification activity applies to all (naming the variety) cheese including varieties not listed in the table referred to under Section 28(1) of the Dairy Products Regulations (refer to Appendix I), and to cheddar cheese. It does not apply to whey, cream, cottage, processed, or cold-pack cheeses. There is a separate regulatory requirement for cheddar cheese labelled as aged cheddar cheese which requires it to be made solely from fluid milks and cream. This will be assessed, along with the requirement that the whey to casein ratio of the cheese shall not exceed that of milk, during an Ingredient Verification task. Feta cheese is exempt from the compositional casein requirements.
This verification is not required at establishments that manufacture cheese using only fluid milks, and cream (i.e. no powders, milk protein concentrate, whey protein concentrate, etc.). Compositional requirements of these cheeses will be verified during an Ingredient Verification as per Dairy Ingredient Verification. If ingredient verification determines that ingredients other than fluid milks or cream have been used, a Cheese Composition Standard Verification must be conducted.
Verification of compositional requirements for imported cheese will be conducted as part of the Dairy Importing Activities.
3. Required Equipment/References
- Dairy Products Regulations (DPR) s.6 and s.28
- Food and Drug Regulations (FDR) s.B.08.001 and B.08.033-034
- Dairy Inspection Report (CFIA/ACIA 950) (intended for internal use)
- Establishment File (previous verification compliance reports)
- Cheese Composition Verification Report
- Requirement for Casein Content Derived from Fluid Milks (Appendix I)
- Canadian Cheese Production Volumes (Appendix II)
- Cheese Composition Verification Worksheet (Appendix III)
- Conversion Factors (Appendix IV)
- Milk Class Definitions (Appendix V)
- Sample Letters (Appendix VI and VII)
4. Inspection Procedures at Registered Dairy Establishments
This activity should be performed in conjunction with one or more other product inspection activity(ies) such as Ingredient, Label or Nutrition Facts Table Verifications. When possible, if a sample has been scheduled for collection from a facility under the D116 sample plan, a Cheese Composition Standard Verification should be performed and the D116 sample taken from the cheese formulation selected for verification. Plan D116 has been expanded to include protein analysis as well as the percentage of moisture and milk fat of cheese.
Unlike an in-depth inspection, no advance notice should be given prior to a Cheese Composition Standard Verification. Verifications should be scheduled so that they are conducted throughout the year. More than one composition verification can be done in a single visit.
Prior to the verification activity, review the plant profile to determine which cheese varieties are made in the establishment and, if known, the number of formulas used per variety. Compositional requirements differ for full fat and light versions of cheese varieties. Light versions are considered to be a separate variety. See Appendix I for a list of cheese varieties grouped by % CDM.
The number of verifications will vary based on the type and number of cheese varieties produced in an establishment and the plant's compliance history. Refer to the dairy operational workplan for the frequency of inspection.
During each verification, a sample is taken and submitted under plan D116 for fat, moisture and protein analysis.
4.2 Selection of Cheese Formulation
To provide the most effective verification of cheese composition, the following factors should be considered when determining which cheese formulation should be selected
- the cheese is produced for sale in Canada (cheese destined for export is not subject to Canadian compositional standards)
- formulations that use milk products other than fluid milks and cream (compliance for formulations using only fluid milks will be verified during an ingredient verification). It does not necessarily include a cheese formulation when the other milk ingredients are only used in small amounts in the starter media
- varieties with several formulations using different amounts of milk products (formulations using higher proportions of milk products are likely to be closer to the regulatory limit)
- the quantities of each variety produced (variety selected should be representative of the plant's production). See Appendix II for a listing of the major cheese varieties by Canadian production quantities
- if the plant produces cheese from the different categories of minimum amount of % CDM (i.e. 95% CDM, 83% CDM etc.), a cheese from each category produced should be evaluated over a one year period
- where possible, select a cheese formulation with a lot that is available in the establishment for sampling
4.3 Review of Records (batch/vat records, lab analysis records and milk invoices)
Review previous batch/vat records over a one month period for the cheese formulation selected for verification. Select a month of records, preferably from a month prior to the inspection, for which the milk invoice has been received by the plant. From that month, randomly select three batch records of the same variety of cheese from different dates. When a lot is available in the establishment, the records for that particular lot should be one of the three records selected. If three batches using the same formulation have not been produced within a one month period, this timeframe can be lengthened so as to include a sufficient number of records from which three batches can randomly be chosen. For establishments that manufacture cheese through a continuous process, and for which individual vats cannot be easily separated, an entire production run must be considered as one lot or batch.
The chosen batch records should contain the following information:
- the date of production
- the vat number
- the type of cheese
- the formulation name/number or reference
- the quantity of milk, partly skimmed milk, skim milk and their ultra-filtered counterparts and cream used in the vat/batch
- for each milk/cream used, the fat and protein content (if not available on the batch record, this information is to be provided by the company from plant lab testing results or Milk Marketing Board invoices)
- the final weight of cheese produced and, if available, its total protein content
- % fat and % moisture of the cheese produced
4.4 Collection of Data
While at the establishment, use the Cheese Composition Verification Worksheet (Appendix III), to gather the necessary information supplied by the company. Copies of records or documents used to fill out the information should be attached to the worksheet. Fill in all mandatory fields, A through F. For establishments using a continuous process it may difficult to compile all the data required at the plant. In these cases it may be necessary to complete the worksheet back at the office. Refer to the explanations for each field below.
Column A: List all milk, partly skimmed milk, skimmed milk and their ultrafiltered (UF) counterparts and cream used in column A of the worksheet. The last row of this column is kept for UF milk only due to programmed calculations in the Excel spreadsheet. UF milk, as defined in the DPR, means, milk, partly skimmed milk or skim milk that has been subjected to a process in which it is passed over one or more semi-permeable membranes to partially remove water, lactose, minerals and water-soluble vitamins without altering the whey protein to casein ratio and that results in a liquid product. The UF milk must meet this definition in order to be considered as part of the casein derived from milks.
Column B: Enter the quantity (in hl) for each ingredient in column A. To convert from litres, kg, or lbs, see conversion factors in Appendix IV.
Column C: Enter the fat concentration in kg/hl or % for each ingredient in column A. The fat concentration should be taken from the company's inline analysis. If not available, lab tested values can be used. Values calculated from the Milk Marketing Board monthly invoices may be used if no other values are available. The values must represent each individual milk, not the final blend in the vat. (To convert inline analysis or lab tested values from kg/kg to kg/hl see Appendix IV).
Column D: Enter the protein concentration for each ingredient in column A. The protein concentration should be taken from the company's inline analysis. If not available, lab tested values can be used. Values calculated from the Milk Marketing Board monthly invoices may be used if other values are not available. For cream, see Table 1 below for protein values based on fat levels. The values must represent each individual milk, not the final blend in the vat. To convert lab tested values from kg/kg to kg/hl see Appendix IV.
|% MF||Protein (kg/hl or % milk)|
|0.5 – Skim-milk||3.5|
For Columns C and D: All plant analyses or lab tested values used should be cross-checked with the Milk Marketing Board monthly invoices for gross variations. When using values from the monthly invoice, the plant should indicate which class (3a, 3b or 5a) of milk was used in the formulation being assessed. Refer to Appendix V for milk class definitions).
If the fat and protein concentrations are not listed on the Milk Marketing Board invoice in kg/hl, the following formula, which incorporates the weight (kg) of fat/protein and the total volume (hl) for the class of milk used, should be applied;
kg of fat or protein in class x milk divided by hl of class x milk = kg/hl fat or protein in class x milk
Box E: Record the total weight (kg) of cheese produced for that vat/batch of cheese and must also include the weight (kg) of any wastage (as provided by the plant), i.e. cheese fines or any additional curds that may get discarded.
Note: For continuous processes, where information is available on a single vat basis as well as the total production, both the individual and cumulative data should be collected. This will allow for more information to be gathered on how the plant controls its process. The calculations will be based on the cumulative data so the total volume of inputs to all vats should be used in column B. The total weight of cheese produced from all vats is entered in Box E.
Box F: Record the total protein content (%) in the finished cheese. The total protein content of the cheese is taken from the results of the CFIA laboratory analysis. The box will be left blank until the lab analysis results are received.
Repeat this process 2 more times until the 3 vat/batch records selected have been reviewed and the data for each entered into the Cheese Composition Verification Worksheet. (Appendix III). For continuous processes, repeat this process until 3 different days/runs have been assessed. All vats from a single day/run are combined to equal one set of values.
Compliance cannot be determined until the data collected is transferred to the Excel Cheese Composition Verification Report.
Discuss the collection of the data with the plant representative and have the representative sign the worksheet. Record the activity on the CFIA/ACIA 950 form. In the event that the worksheet cannot be completed at the establishment because of the amount of calculations that may be required, the plant representative should sign the CFIA/ACIA 950 form.
5. Completing the Cheese Composition Verification Report
Transpose the data collected from the worksheet (Appendix III) and any CFIA lab test results to the identical fields on the Excel Cheese Composition Verification Report. In column A, always enter any UF milk data in the last line, due to programmed calculations. The report will determine the % casein in the cheese derived from the ingredients in column A (% CDM), for each vat/batch assessed and the overall average of the three.
5.1 Satisfactory Inspections
The cheese verification is considered satisfactory when the average % CDM value of the three vats/batches meets or exceeds the % CDM requirement for the cheese variety assessed. When the cheese is assessed as satisfactory, place a check-mark in the satisfactory box, on the Cheese Composition Verification Report. If any individual vat/batch is below the % CDM, make note of this on the CFIA/ACIA 950 form, and inform the company. Print and sign the Cheese Composition Verification Report. Keep copies of the reports in the establishment file and inform the company of the satisfactory result by phone, email or fax or during the next visit. A copy of the Report can be sent to the company if requested.
5.2 Non Satisfactory Inspections
The cheese is considered non satisfactory if the overall average of the three lots/vats is under the minimum required % CDM. When the cheese is below its required % CDM level, place a check mark in the non-satisfactory box on the Cheese Composition Verification Report.
Actions taken should coincide with the degree of non-satisfactory, as follows:
- If the non-satisfactory result is ≤ 1% of the minimum % CDM (e.g. for a cheese with a minimum % CDM of 63% a result of 62% < 63%), notify the company in writing of the results and perform a follow-up verification within 3 months on the same variety/recipe of cheese.
See Appendix VII.
- If the non-satisfactory result is > 1% less than the minimum % CDM (e.g. < 62% for a cheese with a minimum % CDM of 63%), notify the company in writing of the results and request an action plan. The corrective action plan should be received by the CFIA office within 3 weeks of the date of the letter and should include a change to the formulation within a specific timeframe. See Appendix VI. Perform a follow up visit to verify that the corrective action was taken on the non-satisfactory formulation and that it was effective.
When a corrective action plan is requested, it should address the formulation that was found to be non satisfactory along with any other formulations that may be affected.
At a follow-up visit, verify that corrective action was taken on the non satisfactory cheese variety. The formulation(s) for the non-satisfactory cheese(s) should be reviewed for changes. If no corrective action has been taken, detain any cheese from that formulation. Perform another verification on that formulation using only the vat/batch records from the detained lots. Collect directed samples for protein analysis by CFIA from the detained lots. In this case the verification will be based on the individual lot rather than the average of three lots. Copies of all documents and/or records used to gather the information should be kept and attached to the inspection report.
If the detained cheese is found to be non-satisfactory, the plant will have to bring it into compliance before it can be released and the formulation will need to be corrected.
Where an inspector identifies significant non-compliance, for example where there are continued or subsequent incidents of non-compliance, and the person or company does not correct the product, the inspector should complete an Inspector's Non-Compliance Report (INCR). The appropriate Program Specialist should be informed. If necessary, a Management Review Team will review the case and recommend possible enforcement actions to be taken based on the degree of harm, history and intent posed by non-compliance.
When complete, the verification should be entered into Management Resources and Results Structure (MRRS) under task 13a15.
Appendix I - Cheese Varieties by Minimum Percentage of Casein Derived from Fluid Milks
Cheese Variety: Pizza Mozzarella, Part Skim Pizza Mozzarella
- Minimum Percentage of Casein Content Derived from Fluid Milks: 63%
Cheese Variety: Asiago, Baby Edam, Baby Gouda, Blue, Butter, Bra, Brie, Caciocavallo, Camembert, Danbo, Edam, Elbo, Emmental, Esrom, Fontina, Fynbo, Gouda, Gournay, Gruyère, Havarti, Kasseri, Limburger, Maribo, Montasio, Muenster, Neufchâtel, Parmesan, Provolone, Romano, St-Jorge, Saint-Paulin, Samsoë, Tilsiter, Tybo
- Minimum Percentage of Casein Content Derived from Fluid Milks: 95%
Cheese Variety: Cheddar, Brick, Canadian Style Brick and Munster, Colby, Farmer's, Jack, Monterey (Monterey Jack), Mozzarella (Scamorza), Part Skim Mozzarella (Part Skim Scamorza), Part Skim Pizza, Skim Milk, and any other variety of cheese not referred to in this table
- Minimum Percentage of Casein Content Derived from Fluid Milks: 83%
Cheese Variety: Aged Cheddar Cheese
- No minimum casein content, but made solely with "fluid milks", cream– in any combination
Cheese Variety: Light versions
- For cheeses in the 95% category, the minimum is 90%. For cheeses in the 83% category, the minimum is 78%.
Appendix II - Canadian Cheese Production Volumes
- Information on the production volumes of major varieties of Canadian cheese can be found on the Canadian Dairy Information Centre's site.
Source: Statistics Canada
Calculations done by AAFC-AID, Dairy Section
Appendix III – Cheese Composition Verification Worksheet
Appendix IV – Conversion Factors
Appendix IV – Conversion FactorsFootnote 1
The formula for calculating density to be used in converting a weight of milk or cream to volume is as follows:
- Density = 1 divided by (Skim content / Skim Density) + (BF (butterfat) test / BF Density)
In order to use the formula properly the following conventions must be followed:
- Skim content = (1 – Butterfat test). For example the Skim content of 35% cream is 1 - .35 = .65
- Skim Density = 1.0355 kg/L Footnote 2
- Butterfat Density = 0.95260 kg/L
- The density of 35% cream is:
- 1 / ((.65 / 1.0355 kg/L Footnote 2) + (0.35 / .9526 kg/L))
- = 1 / (.627716 L/kg + .36742 L/kg)
- = 1 / .99514 L/kg
- = 1.00488 kg/L
In order to determine the volume of cream in at this butterfat content it is necessary to divide the weight of the cream by the density.
- 15,333 kg of cream at 35%
- = 15,333 kg / 1.00488 kg/L x 0.01 hl/L
- = 152.38 hl
Pounds (lbs) To Kilograms (kg)
- 1 lb = 0.454 kg
- 1 kg = 2.2 lbs
Appendix V - Milk Marketing Board Class Definitions
Definition for Class 3(a): All cheeses other than those identified in class 3(b), all types of cheese curds other than stirred curd.
Definition for Class 3(b): All types of cheddar cheese, stirred curd, cream cheese, creamy cheese bases (cheese mixes), cheddar and cheddar-type cheeses sold fresh.
Definition: Cheddar type cheese: a cheese of descriptive nomenclature will be recognized as a cheddar type cheese for the purposes of classification if it is a semi-soft, unripened, unwashed curd cheese, with a minimum milk fat content of 25% and maximum moisture of 45%.
Definition for Class 5(a)Footnote 3: Cheese used as ingredients for further processing for the domestic and export markets.
Appendix VI – Sample Letter for Unsatisfactory Results
Subject: Unsatisfactory Results – Cheese Composition Verification
On (Date), a cheese composition verification of (formula/recipe) was performed by CFIA inspection staff at your facility. The results of this verification indicate that the product does not comply with the compositional standards for cheese.
This is contrary to the standards set out in the section 28 (or section 3.(3) for Cheddar) of the Dairy Products Regulations and section B.08.033 (or B.08.034 for Cheddar) of the Food and Drug Regulations which require the casein content that is derived from milk, ultrafiltered milk, partly skimmed milk, ultrafiltered partly skimmed milk, skim milk, ultrafiltered skim milk or cream rather than from other milk products for (Naming the Variety Cheese) be at least (X%) of the total protein content of the cheese.
Please forward your written and signed action plan to this office no later than, (Date – 3 weeks from date on letter).
This letter is also to advise you that your corrective actions will be verified during a follow-up visit. Future instances of non-compliance may also result in further enforcement action.
If you have any questions, please contact the undersigned at (Phone Number).
cc: Supervisor, Operations Officer, Area Program Network Specialist
Appendix VII – Sample Letter for Notification of Verification Findings
Subject: Cheese Composition Verification
On (Date), a cheese composition verification of (formula/recipe) was performed by CFIA inspection staff at your facility. The results of this verification indicate that the product does not comply with the compositional standards for cheese however it is within 1% of the minimum % CDM and as such the CFIA will not be taking immediate action on this product.
This letter is also to advise you that the CFIA may complete another cheese composition verification on the same variety/recipe of cheese as the original cheese composition verification within 3 months.
Please be reminded that the standards are set out in the section 28 (or section 3.(3) for Cheddar) of the Dairy Products Regulations and section B.08.033 (or B.08.034 for Cheddar) of the Food and Drug Regulations which require the casein content that is derived from milk, ultrafiltered milk, partly skimmed milk, ultrafiltered partly skimmed milk, skim milk, ultrafiltered skim milk or cream rather than from other milk products for (Naming the Variety Cheese) be at least (X%) of the total protein content of the cheese.
If you have any questions, please contact the undersigned at (Phone Number).
cc: Supervisor, Operations Officer, Area Program Network Specialist
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