Pasteurization is the law, not a choice
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What the rule says
The section is titled mandatory pasteurization for all milk and milk products in final package form intended for direct human consumption, and it prohibits delivering such a product into interstate commerce, or selling it, unless it has been pasteurized or is made from pasteurized dairy ingredients. Certain cheeses are provided for separately.
How this differs from everywhere else here
An acidified sauce needs a process established for it by a process authority. A nut butter needs a kill step you validate. A syrup needs a number you hit and record. All three leave the maker responsible for establishing what is sufficient. Here that question is closed, and what remains is proving you did it.
Which makes the record the deliverable
Time and temperature for every batch, from instrumentation that can be checked, retained. The process is not in dispute; whether this batch went through it is the only question anybody can ask, and the answer is a record or it is nothing.
It reaches ingredients as well as products
Made from pasteurized dairy ingredients is part of the rule, which means a cultured product, a spread or a dessert built on dairy inherits the requirement through its ingredients. Buying in a dairy component does not move the question outside your product.
The equipment follows from this
A pasteurizer that holds temperature reliably and records that it did is not an optional upgrade; it is the thing that makes the product legal. That is why the capital cost in this property is front-loaded in a way it is not elsewhere.
Calibrate the instruments that produce the record
The record is only as good as the device that wrote it, and an uncalibrated recorder produces paperwork rather than evidence. Scheduled calibration, documented, is part of the control rather than maintenance.