Does the Label Have to Say Raw Milk? Canada's Unpasteurized Cheese Rules

On 2 October 2026, Quebec's Ministere de l'Agriculture, des Pecheries et de l'Alimentation (MAPAQ) warned the public not to eat a sheep's milk cheese called Nouveau Brebis, made and sold by Fromagerie des Grondines. The cheese was not found to be contaminated. It was pulled from sale because its label did not carry four words that Quebec law requires on cheese made from unpasteurized milk: fait de lait cru, made from raw milk.

That single omission turned a saleable product into a public warning aimed at pregnant people, young children, older adults and anyone with a weakened immune system. For cheesemakers, importers and retailers across Canada, it raises a question that many answer incorrectly: does a cheese label have to say the milk was not pasteurized? The honest answer is that it depends on where you sell, and the detail is easy to get wrong. This guide sets out the federal rules, the provincial rules, and the preventive controls that keep raw milk cheese both safe and on the shelf.

Executive summary

Canada regulates raw milk cheese on two separate tracks. Safety is federal and mandatory. The raw milk statement on the label is partly federal recommendation and partly provincial requirement.

• The federal Food and Drug Regulations require cheese to be made from pasteurized milk, or to be stored at 2 degrees Celsius or more for 60 days or more from the start of manufacturing. This is the most important rule, and it is mandatory everywhere in Canada.
• A statement that a cheese is made from raw or unpasteurized milk is recommended by Health Canada guidance at the federal level, but it is not a federal legal requirement.
• Quebec makes the raw milk statement mandatory. A missing fait de lait cru declaration is enough on its own to trigger a public warning and removal from sale, as the Grondines case shows.
• Raw milk cheese is linked to Listeria, E. coli, Salmonella and Staphylococcus aureus risk, so labelling and preventive controls exist to protect vulnerable groups, not just to inform buyers.
• Under the Safe Food for Canadians Regulations, your preventive control plan should treat the raw milk status as both a safety control and a label control, with verification that the statement appears correctly on every lot.

What happened with the Grondines cheese, and why it matters

What it is: a provincial food safety warning. MAPAQ advised vulnerable consumers not to eat the Nouveau Brebis cheese because the label did not state that it was made from raw milk. Why it matters: the product itself was saleable on its safety profile, yet a label gap alone was treated as a Class 1 risk. The lesson is that in Quebec the raw milk statement is not optional wording. It is a control, and leaving it off is a reportable failure.

The warning told vulnerable people to either discard the cheese or heat it to an internal temperature of 74 degrees Celsius before eating. That advice is the tell. Regulators treat raw milk cheese as a higher risk food for pregnant people, children under five, adults over sixty and anyone who is immunocompromised, because unpasteurized milk can carry pathogens that pasteurization would have killed. The label statement exists so that those buyers can make an informed choice. When it is missing, the informed choice is removed, and the regulator steps in.

The same producer had separately recalled other cheeses in 2026 for possible generic E. coli and Staphylococcus aureus. Those are contamination events, and they connect to different controls. We cover them in our articles on the Staphylococcus aureus cheese recall and your preventive control plan and on generic E. coli and your PCP. The raw milk labelling warning is a distinct issue. Do not confuse a labelling failure with a contamination finding, because the corrective actions are not the same.

Is a raw milk statement mandatory on a Canadian cheese label?

What to do: check the province of sale first. Federally, the statement made from raw milk or made from unpasteurized milk is a Health Canada recommendation, not a legal requirement. Several provinces, Quebec among them, make the statement mandatory in their own food regulations. So the same cheese can be federally compliant without the statement and still be non compliant for sale in Quebec. Sell nationally and you must meet the strictest applicable rule.

The Canadian Food Inspection Agency's industry guidance on dairy product labelling recommends, but does not require at the federal level, that manufacturers label products with the words made from raw or unpasteurized milk, and that the statement appear either on the principal display panel or in the list of ingredients. Health Canada frames this as helping consumers, especially vulnerable ones, make an informed decision. The word recommended is doing a lot of work here. A federal recommendation is good practice. A provincial requirement is law. Treat the recommendation as your national baseline, because it protects you in every market and it is what a prudent preventive control plan would specify anyway.

The table below shows where the federal and Quebec positions line up and where they diverge.

The mandatory rule most people miss: the 60 day aging standard

What it is: the federal safety standard for cheese. Under the Food and Drug Regulations, cheese must be made from milk that has been pasteurized, or the cheese must be stored at a temperature of 2 degrees Celsius or more for a period of 60 days or more from the date the manufacturing process began. This is the real gatekeeper. The label statement tells people the cheese is raw. The 60 day rule is what makes a raw milk cheese legal to make and sell in the first place.

The Food and Drug Regulations set the cheese standard in section B.08.030. They also set microbial limits for the finished cheese and require the manufacturing date to be marked or recorded. The aging period is not a guideline you can shorten for a faster release. It is a defined control with a defined duration, and shortening it is a direct breach of the standard. Inspectors verify it through your batch records, so your dates have to be real and traceable, not reconstructed after the fact.

Those microbial limits matter for a practical reason. Generic E. coli and Staphylococcus aureus are indicators of hygiene and process control during cheesemaking. A raw milk cheese that exceeds them cannot be sold, aging period or not. This is why the 60 day rule is necessary but never sufficient. Aging reduces some pathogens over time, yet it does not fix poor sanitation, a sick animal, or a contaminated starter culture. Your preventive controls have to manage the whole chain, from the farm and the milk to the make procedure and the aging room.

Quebec's mandatory fait de lait cru rule

How it affects compliance: if you sell raw milk cheese in Quebec, the fait de lait cru statement is not optional. Under Quebec's provincial food rules administered by MAPAQ, cheese made from unpasteurized milk must carry the made from raw milk declaration. Omitting it is treated as a safety labelling failure, not a cosmetic one, because it removes the warning that vulnerable consumers depend on. That is exactly why the Grondines product was pulled.

Quebec has one of the most developed raw milk cheese sectors in Canada, so its enforcement is correspondingly strict. If you make raw milk cheese anywhere in Canada and ship into Quebec, or sell to a distributor who does, the Quebec requirement reaches you. The safe design is to put the raw milk statement on every raw milk cheese you make, in both official languages where bilingual labelling applies, regardless of the province of sale. That removes the risk of a lot built for one market ending up in another without the mandatory wording.

Why vulnerable populations drive the rule

Why it matters: raw milk can carry Listeria monocytogenes, Salmonella, pathogenic E. coli and Staphylococcus aureus. For most healthy adults the risk is low. For pregnant people, newborns, older adults and immunocompromised people it can be severe, and Listeria in particular can cause miscarriage, stillbirth and life threatening illness. The raw milk statement is a targeted safety message for those groups, which is why regulators treat its absence as a safety issue rather than a marketing slip.

This is also why a raw milk labelling failure escalates quickly. Once a regulator decides that a missing statement exposes vulnerable consumers, the response is a warning and a withdrawal, and your business is suddenly running a recall. If you have never pressure tested how fast you can reach your customers and account for product, our guide on how to run an SFCR mock recall is a good place to start, because a label driven recall moves on the same clock as a contamination recall.

Where raw milk belongs in your SFCR preventive control plan

What to do: treat raw milk status as two linked controls in your preventive control plan. First a safety control, covering pasteurization or verified 60 day aging, farm and milk controls, and finished product testing against the microbial limits. Second a labelling control, verifying that the made from raw milk statement is present, correct and in the right languages on every lot before release.

Most preventive control plans handle the safety side reasonably well and then leave labelling to a design proof that nobody checks again at release. That gap is how the raw milk statement goes missing. With CFIA expanding inspection coverage, as we discuss in our article on CFIA inspecting thousands of food facilities, a label verification step tied to lot release is cheap insurance. Our broader guidance on preventing label errors shows how to build that verification into a repeatable check rather than a one time design sign off.

There is a wider pattern here worth naming. Regulators are increasingly treating a label claim as a control that has to be verified, not a statement that can be assumed. We have seen the same logic applied to plant based and vegan claims as allergen controls and to no dairy claims on natural health products. The raw milk statement is part of the same shift. If your label says something that affects safety, you need evidence that it is true and a check that it is present.

Raw milk cheese compliance checklist

• Confirm each cheese is made from pasteurized milk, or is stored at 2 degrees Celsius or more for 60 days or more from the start of manufacturing.
• Record the date the manufacturing process began for every batch, and keep the aging records traceable to that date.
• Test finished cheese against the microbial limits, not more than 500 generic E. coli per gram and not more than 1,000 Staphylococcus aureus per gram.
• Include a made from raw milk or made from unpasteurized milk statement on every raw milk cheese, on the principal display panel or in the ingredient list.
• Apply the statement in both official languages where bilingual labelling applies, and confirm the Quebec fait de lait cru wording for product that may reach Quebec.
• Add a label verification step tied to lot release so the raw milk statement is checked on the actual printed label, not just the approved artwork.
• Map the raw milk status into your preventive control plan as both a safety control and a labelling control, with verification records for each.
• Keep a recall procedure ready that can act on a labelling failure as quickly as a contamination event.

Common mistakes

• Assuming the raw milk statement is optional everywhere. It is recommended federally but mandatory in Quebec, and a missing statement alone caused a public warning in October 2026.
• Treating the 60 day aging rule as flexible. The 60 day period runs from the start of manufacturing and is verified against your records. Releasing early breaches the federal standard.
• Believing aging makes any raw milk cheese safe. Aging does not override the microbial limits or compensate for poor sanitation or a contaminated starter.
• Checking the artwork, not the label. A statement approved in design can still be dropped in a print run or on a relabelled lot. Verify the physical label at release.
• Building one label for a single province. Product moves. A label that omits the raw milk statement can end up in a market that requires it.

Frequently asked questions

Does Canadian law require cheese labels to say the milk is unpasteurized?

At the federal level it is recommended, not required. Health Canada guidance, reflected in CFIA industry material, advises including a made from raw or unpasteurized milk statement, but it is not a federal legal obligation. Some provinces, including Quebec, make the statement mandatory in their own food regulations, so the answer depends on where the cheese is sold.

What is the 60 day rule for raw milk cheese in Canada?

Under the Food and Drug Regulations, cheese must be made from pasteurized milk, or it must be stored at a temperature of 2 degrees Celsius or more for a period of 60 days or more from the date the manufacturing process began. The aging period is the alternative to pasteurization and is mandatory nationwide.

Why was the Grondines Nouveau Brebis cheese recalled?

MAPAQ issued a public warning on 2 October 2026 because the label did not carry the required fait de lait cru, made from raw milk, statement. It was a labelling failure rather than a reported contamination event, and vulnerable consumers were advised to discard the cheese or heat it to 74 degrees Celsius.

Who is most at risk from raw milk cheese?

Pregnant people, children under five, adults over sixty and anyone with a weakened immune system face the highest risk, because unpasteurized milk can carry Listeria, Salmonella and pathogenic E. coli. The raw milk statement is a targeted warning so those groups can make an informed choice.

Does the raw milk statement have to be in French and English?

Where bilingual labelling rules apply, mandatory information must appear in both official languages. For product sold in Quebec the fait de lait cru wording is expected, and the safe approach is to carry the statement bilingually by default so a single labelling run stays compliant across markets.

How should a preventive control plan handle raw milk labelling?

Treat it as a verified control, not an assumption. Include a step that confirms the raw milk statement is present and correct on the physical label of each lot before release, alongside the safety controls for aging or pasteurization and microbial testing. Keep verification records so you can demonstrate the check to an inspector.

How MFLRC can help

MFLRC helps cheesemakers, dairy processors, importers and retailers keep raw milk products both safe and saleable. Our food and beverage regulatory team builds and reviews preventive control plans under the Safe Food for Canadians Regulations, while our label and claims compliance service checks that mandatory statements, including the raw milk declaration, are present, correct and multilingual before product ships.

If you want to pressure test your readiness before an inspector or a recall does, our mock audit and inspection readiness service runs the scenario end to end, and our food safety compliance support maps the gaps between what your plan says and what your records actually prove. The goal is simple: no product pulled from a shelf over a line of text that should have been there.

Need to confirm your raw milk labelling and preventive controls hold up? Talk to MFLRC for practical, Canada specific guidance.

Conclusion

Raw milk cheese sits at the intersection of two kinds of rule. The federal safety standard, pasteurize or age for 60 days and stay within the microbial limits, is mandatory everywhere and is what inspectors verify first. The raw milk statement is recommended federally and required in provinces such as Quebec, and its absence alone can trigger a public warning. The safe, simple design is to meet the strictest version of both, every time: age or pasteurize with real records, test the finished cheese, and label it as made from raw milk by default. Build that into your preventive control plan as a verified step, and a missing phrase stops being the thing that empties your shelves.

Sources and references

• Food and Drug Regulations (C.R.C., c. 870), cheese standard B.08.030 (Justice Canada)
• Canadian Food Inspection Agency, labelling requirements for dairy products
• Recalls and Safety Alerts, Fromagerie des Grondines cheeses (Government of Canada)
• Health Canada, food safety for vulnerable populations