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The milk

Raw milk, and where it is allowed

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The federal rule is about interstate commerce, so the raw milk question is almost entirely a state one, and the states disagree with each other more here than on anything else in this library.

The range of state positions

Retail sale in shops, sale only at the farm where it was produced, herd-share or cow-share arrangements where the buyer owns part of the animal, sale permitted only for animal consumption, and prohibition of sale for human consumption altogether. All of those exist simultaneously in different states.

Which means nothing transfers

A maker in a neighboring state doing something openly is telling you about their state and nothing about yours. This is the single worst craft in the library for reasoning by analogy from what somebody else is doing.

The line is the state border, not the sale

Even where intrastate sale is permitted, moving the product across a state line puts it squarely inside the federal prohibition. That catches makers near a border, makers at a market that draws from two states, and anybody thinking about mail order.

It is a different safety conversation, not a lighter one

Where raw sale is permitted it usually comes with testing requirements, labeling requirements, herd health requirements and inspection, and those are frequently more demanding than what a pasteurizing operation faces. Permitted does not mean unregulated.

The cheese exception is real and narrow

Cheese made from unpasteurized milk is provided for separately, and the soft ripened cheese standard states the condition plainly: if the milk used is not pasteurized, the cheese is cured at not less than 35 degrees F for not less than 60 days. That is a specific carve-out with a specific number, not a general permission.

Be careful what you imply as well as what you say

Marketing that gestures at the virtues of unpasteurized milk while selling a pasteurized product, or that describes a herd-share in terms that look like a sale, attracts attention this craft does not need. Say plainly what the product is and how it was made.

References

21 CFR 1240.61, Mandatory pasteurization for all milk and milk products in final package form intended for direct human consumption, which prohibits delivering such a product into interstate commerce unless it has been pasteurized or is made from pasteurized dairy ingredients. law.cornell.edu
21 CFR 133.182, Soft ripened cheeses: “If the milk used is not pasteurized, the cheese so made is cured at a temperature of not less than 35 °F for not less than 60 days.” law.cornell.edu
Written from federal regulation and FDA guidance, not from a laboratory. Pasteurization of milk and milk products in final package form for interstate commerce is a federal requirement, and what your state permits inside its own borders is a separate question. Anything here is a starting point for a conversation with your state department of agriculture, not a determination that you comply.