AskHACCP: Licensing & Compliance for Cheese Counters and Salumeria Programs

Cheese counters and salumeria programs can distinguish specialty retailers, but they operate in a highly regulated space. Licensing structures vary by state, but the framework below applies nationwide and highlights where federal oversight begins. Understanding where your activities fall is critical for compliance.

1. Oversight Map: Who Regulates What

• State agriculture or health. Licenses for retail food and many small processing activities are issued at the state level.

• USDA FSIS. Federal inspection for meat and poultry is required when you move beyond retail, sell wholesale, or enter interstate commerce. Retail exemptions exist but have limits and recordkeeping requirements.

• FDA and state dairy divisions. FDA sets national standards and the model Food Code for retail. State dairy programs license dairy plants and enforce milk and cheese safety. Raw and pasteurized milk cheeses have different requirements.

2. Retail Food License: What It Usually Covers

A standard retail food license generally allows:

• Cutting, slicing, wrap and label of food for sale to consumers inside your licensed store.

• Handling prepackaged, ready-to-eat meats and cheeses for retail sale.

A retail license does not typically cover:

• Wholesale or distribution to other businesses.

• Copacking or white label production for other brands.

• Off-site production.

When in doubt, confirm with your state agency before launching wholesale or copack lines.

3. When Retail Becomes Processing

These activities usually trigger a separate processing or dairy plant license and a higher compliance bar:

• Cheese. Cutting whole wheels for rewrap, aging on site, or making cheese.

• Meat. Curing, fermenting, drying, smoking, grinding, forming, or recipe development beyond simple slicing.

• Copacking. Making or packaging under someone else’s brand.

Processing licensure brings scheduled inspections, written programs, and more rigorous documentation.

4. Cheese Program Details

• Prepackaged cheese only. A retail license is often sufficient.

• Cut to order or rewrap. Many states treat this as dairy processing and require a plant license. Confirm locally.

• Aging or production. Requires a state dairy plant license.

• Raw milk cheeses. Federal policy recognizes a 60-day aging minimum for certain raw milk cheeses. States may impose additional controls. Always verify your product category and your state’s requirements.

5. Salumeria and Meat Program Details

• Retail slicing of sealed, labeled, ready-to-eat meats. Generally allowed under retail.

• Curing, fermenting, drying, smoking, grinding, and forming. Treated as processing.

• Wholesale or interstate shipment. Requires USDA FSIS inspection. Retail exemptions exist, but they have strict volume and sales channel limits and require records that demonstrate compliance with these limits.

• Listeria control at retail. Follow current retail guidance to prevent cross-contamination when opening and slicing ready-to-eat meats and cheeses.

6. Reduced Oxygen Packaging (ROP) at Retail and in Processing

ROP methods include vacuum sealing, MAP, cook chill, and sous vide. These extend shelf life but increase risk for Clostridium botulinum and Listeria monocytogenes.

At retail under the Food Code

• Requires a written ROP HACCP plan that covers labeling, refrigeration, shelf life, training, and recordkeeping.

• In most jurisdictions, you also obtain a variance and prior approval before packaging time and temperature control for safety foods under ROP.

• A common control is a maximum refrigerated shelf life of 30 days unless the product is frozen or supported by validated barriers to pathogen growth.

State-licensed food processing

• States that license processors generally require submission and approval of an ROP HACCP plan.

• Label approval is often required before sale.

• State dairy programs may restrict or prohibit ROP of certain fresh cheeses due to safety risks.
  

USDA FSIS establishments for meat and poultry

• All FSIS establishments operate under HACCP. For ROP products, the HACCP plan explicitly addresses hazards such as C. botulinum and Listeria.

• Establishments provide scientific validation for shelf life assignments and critical limits.

• There is no variance process at FSIS. ROP is handled within the hazard analysis and the validated HACCP plan.

7. Common Grey Areas

• Shared kitchens and commissaries. Often requires layered licensing. Clarify ownership, location, and sales channels.

• White label and copack programs. Usually considered processing.

• Dual operations. Retail and wholesale typically require both retail and processing licensure, and for meat and poultry wholesale, this usually means FSIS inspection.

8. Startup Tips

• Define your model early: retail, processing, wholesale, or a combination.

• Contact regulators first to confirm license types and plan review needs.

• Map product flow and zoning so retail and processing do not commingle.

• Build written programs: HACCP, sanitation, allergen controls, ROP plan, and labeling files.

• Train staff and set logs for temperatures, ROP dates, sanitation, and corrective actions.

• Keep sales and production records, especially if you operate under the retail exemption for meat and poultry.

Quick Decision Table

If you plan to…	Likely license or inspection path
Sell prepackaged cheese and sealed RTE meats at the counter.	Retail food license
Cut wheels to order, rewrap cheese, or age cheese on site.	Dairy plant or state processing license
Cure, ferment, smoke, dry, grind, or form meats.	State processing license; FSIS required if wholesale or interstate
Vacuum seal RTE cheese or meat at retail.	Retail license plus ROP HACCP plan and, in most states, a variance
Copack or produce under another brand.	State processing or dairy plant license; FSIS for meat and poultry if wholesale
Sell meat or poultry wholesale or across state lines.	USDA FSIS inspection; retail exemption limits and records apply only within caps

Adding cheese and salumeria can set your business apart. Build compliance in from day one, and you protect customers, your investment, and your ability to grow.

Have a specific question about your setup, licensing path, or ROP? The AskHACCP Hotline is a complimentary (free) and confidential service. We will walk through your product list, intended sales channels, and your state’s requirements, then help you outline your next steps: schedule a call, AskHACCP Hotline Service.