We are all familiar with the requirement to wait after eating meat before consuming dairy foods. However, what about the opposite case? Must one wait after eating dairy foods before partaking of meat? How must one conduct himself when transitioning from dairy to meat? What about after eating hard cheese?

General Requirements
The Gemara in Chullin (105a) quotes Rav Chisda, who states that one need not wait at all after eating cheese before consuming meat. However, if one consumes cheese and the plans to then eat bosor behemah or bosor chaya - animal meat, rather than fowl – one must ascertain that his hands are clean, and he must cleanse and rinse his mouth. (Gemara ibid. 104b and 105a). The sugya there elaborates on what constitutes proper kinuach and hadocho.

The Shulchan Oruch (Yoreh Deah 89:2) quotes the Gemara, stipulating that one may eat cheese immediately prior to meat, so long as he inspects his hands for any cheese residue before consuming the meat, and that – if one cannot ascertain the hands’ cleanliness – he must wash them prior to the meat dish. “One must cleanse his mouth (”kinuach“ -“cleanse” ) and rinse it (”hadocho“ – “rinse” ); kinuach is to chew bread and thereby clean his mouth very well. And one may perform kinuach with anything that he wishes, except for flour, dates and vegetables, since they adhere to the gums and do not cleanse well. And then one must rinse his mouth with water or wine. This is only for bosor behemah or chaya, but for fowl, there is no need for any cleaning or washing of hands.”

The above procedures, taken directly from the Gemara, seem pretty simple. However, the Nosei Kelim on Shulchan Oruch add a few noteworthy caveats.

The Shach (s.k. 9) quotes the Rif that one should always wash his hands after cheese before meat and not rely on visual inspection, as one cannot really tell if his hands are truly free of shamnunis – greasy residue – by merely looking at them, and the Shach quotes the Itturei Zohov who says that this is the minhag. In practice, one should conduct himself according to this position and always be sure to wash his hands after eating dairy foods before then eating meat.

The Be’er Hetev (s.k. 5) notes that the Pri Chodosh holds that one need not wash his hands before meat if he ate cheese with a fork, as the hands do not become soiled thereby due to lack of any direct contact with the cheese; it appears that the Be’er Hetev paskens this way l’halacha, and the Oruch Ha-Shulchan (89:8) holds like the Pri Chodosh as well. This is the accepted halacha. (Nevertheless, one must be very careful in determining if he really meets this criterion upon each dairy meal eaten with proper utensils. All too often does food eaten with utensils somehow end up on one’s hands! This almost inevitably happens in the course of eating, serving or cleaning up… )

Although the Shulchan Oruch states that one must first perform kinuach and then do hadocho, the Shach (s.k. 13) and Be’er Hetev (s.k. 7) contend that the order does not matter. The Shach quotes the Beis Yosef himself on the Tur (s.k. 11) that one may do kinuach and hadocho in whichever order he prefers. The halacha is as the Shach explains, and one may do kinuach and hadocho in the order of preference or convenience.

Although the Gemara and Shulchan Oruch state that kinuach is done with food, may a person fulfill the requirement of kinuach by brushing his teeth instead? This issue is not widely discussed by poskim, although the issue is debatable and should be referred to one’s individual rov. (There is a view that brushing teeth does not constitute kinuach, as a toothbrush does not rub against the insides of the mouth to cleanse it as does food; others argue that tooth brushing is fully effective.)

Is There a Waiting Period?
Once one has finished eating dairy food and has performed kinuach and hadocho and has cleansed his hands, can he eat meat right away? The Gemara does not stipulate any waiting period. In fact, the Shulchan Oruch (YD 89:2 – above) states that one may eat meat “miyad” – “immediately” – and the Rif, Rambam and Tur also do not record any requirement for a waiting period. However, the Zohar in Parshas Mishpotim (155a) indicates that one must bentch and wait an hour before being permitted to consume meat. Many conduct themselves as such and wait half an hour or an hour in light of the Zohar’s position, although the bottom-line halacha is not to require any such waiting period.

Hard Cheese
The Remo (89:2) adds that the minhag is to wait after eating hard cheese before partaking of meat, just as one waits after meat before dairy. The Maharshal (quoted by the Shach s.k. 17) disputes this approach and dismisses it as “minus” – heresy – as the Gemara specifically states that there is no need to wait at all after consuming cheese. The Gra (s.k. 11) writes that the Zohar in Parshas Mishpotim also endorses the position of the Remo, and the Gra takes issue with the Maharshal’s contention that the Remo contradicts the Gemara’s statement that one may eat meat after cheese, explaining that the practice to refrain from hard cheese before meat is a chumra (stringency) akin to other personal chumros practiced by the Amoraim and recorded in the sugya in Chullin.

Thus, from the words of the Remo, Shach and Gra, as well as the elaboration on the Remo by the Taz and Be’er Hetev, it is quite clear that one should conduct himself strictly and not eat meat after hard cheese. (The Mechaber omits this issue, seemingly holding that one may indeed eat meat right after hard cheese. Sefardim should consult their individual morei horo’oh [halachic authorities] as to how to conduct themselves.)

What Is The Waiting Period After Hard Cheese?
After eating meat, there is a machlokes as to how long one must wait before consuming dairy products. The Mechaber and Remo (YD 89:1) are of the opinion that the waiting period is six hours, although the Remo references various other prevalent opinions and customs, such as waiting for one hour or three hours. (German Jews traditionally wait three hours, while Dutch Jews wait only one hour.)

The various opinions and resultant minhogim revolve around Mar Ukva’s statement in the Gemara (Chullin 105a) that upon eating meat, he would wait “until the next meal” to partake of cheese. The question is how long the break period “until the next meal” endures? It may be short or long, depending upon how one defines the day’s meals; this is the issue upon which the machlokes hinges.

The poskim are clear that the waiting period after consuming hard cheese is identical to the waiting period after eating meat, before one wishes to partake of dairy foods. (See Taz 89:4, Aruch Ha-Shulchan 89:11, Chochmas Odom 40:13.) Thus, one should follow his personal custom regarding waiting after meat for the purpose of waiting after hard cheese.

A most critical question, however, is what constitutes hard cheese (for the purpose of waiting) according the Remo. Is all cheese which we refer to as “hard” included in this category? The answer is a clear “no”.

The poskim explain that cheese is considered to be hard for the purpose for waiting if it is six months old or if it is developed to the extent that it has holes (such as Swiss cheese – see Oruch Ha-Shulchan ibid.).

Many kashrus organizations take the position that the six-month period is not to be applied literally in determining whether or not a given cheese is “hard”. Rather, these agencies interpret the six-month period as a general indicator of cheese with unique “aged” qualities, holding that the six-month figure is not absolute. These kashrus agencies look to the cheese’s texture and only require waiting periods for cheese which is hard enough so that it shreds or grates when cut.

Along the same lines, if a cheese is specifically marketed by its manufacturer as “aged”, some kashrus organizations advocate a waiting period (even though the cheese will not necessarily shred or grate when cut), as the company which specifies that its cheese as aged is notifying consumers that the product has the distinct, long-lasting flavor associated with purposefully-aged cheese; it is precisely the long-lasting flavor quality of meat which engenders its waiting period according to many poskim, and – so, too in the case of aged cheese – its long-lasting flavor creates an obligation to wait after consuming it before eating meat, as the taste of the cheese lingers for quite a while. (See Oruch Ha-Shulchan ibid.)

Other kashrus agencies take a totally different approach. They hold that if cheese is six months old, it requires a waiting period, regardless of the cheese’s taste or texture. In fact, these agencies assure (by use of production-date codes) that the consumer is knowledgeable of the date of manufacture of any cheese it certifies so that the consumer can easily determine when the product has become six months old.

These kashrus agencies are aware that the date of manufacture is especially relevant for cheese with a long shelf-life. Many varieties of cheese (e.g. Muenster, Provolone, some types of Cheddar) are not aged by their manufacturers for significant periods of time, if at all. However, these cheeses may become six months old or more by the time they arrive on the consumer’s table, as they are well-preserved and are able to remain fresh for extended durations. These agencies advise that one wait before eating meat after consuming such unintentionally-aged cheese, whereas other major kashrus agencies do not endorse a waiting period in such cases (footnote 1).

“Ripening”
Consultations with dairy and cheese experts have revealed that cheese indeed continues to “ripen” (develop) even after it is packaged, but the extent and quality of such ripening depend on a variety of conditions, including the type of cheese, storage temperature and moisture level, as well as method of packaging.

Those who are machmir to wait after all cheese which is six months old, even if the cheese reaches the six-month period incidentally while sitting on a supermarket shelf, point to the ongoing ripening process even after packaging. Those who do not require waiting after such cheese hold that the rate of ripening after packaging is insignificant, as – if ripening after packaging would affect the cheese in any serious way, noticeably transforming the texture or taste – the manufacturer would not be able to sell stable and predicable product, for the ability of the cheese to ripen so as to materially change it would be present once the cheese leaves the factory. Although it is true that one can retain many non-aged cheeses well past their expiration dates and thereby cultivate a truly ripened, highly-enhanced product, this latter position points to the fact that cheese eaten within its expiration date is expected by the manufacturer to retain its qualities and characteristics as at the time of sale, when the cheese was surely not aged.

FDA regulations (CFR 21:133) provide aging periods for numerous types of cheese. In order for a company to legally label its cheese as being of a specific variety, it is required that the product be aged for a mandatory period; otherwise, the cheese does not meet the legal specifications of the variety. Among the listings: Cheddar, Edam, Emmentaler, Gouda, Provolone and Swiss cheese must be aged for at least 60 days; Romano and Sap Sago cheese must aged for at least five months; Asiago medium cheese and “hard grating cheeses” (all types) must be aged for at least six months; Parmesan and Reggiano cheese must be aged for at least ten months; hard Asiago cheese must be aged for at least a year…

Hard Melted Cheese
What is the din if hard cheese is melted? There is a well-known approach of the Yad Yehuda (YYK 89:30), who asserts that melted cheese is not subject to the Remo’s chumra. Some apply this ruling to all melted cheese (e.g. Parmesan cheese melted onto pizza), while others contend that the Yad Yehuda’s position only pertains to cheese melted into food (e.g. lasagna), whereas hard cheese melted onto food and cheese which is not part of a food at all remains subject to the Remo’s waiting period. Others apply the Yad Yehuda’s position to all cheese which has been melted, even if it has become re-hardened by the point of consumption.

Furthermore, not all poskim concur with the Yad Yehuda’s leniency. It is thus clearly necessary to consult one’s posek as to how to deal with the matter. The above was intended to merely lay out some basic approaches as to how to conduct oneself after consuming dairy before eating meat. As with any halachic topic, one should speak with his personal rov for guidance.

Footnote 1: The two approaches as to how to define hard cheese for the purpose of waiting seem to hinge on an apparent machlokes (dispute) between the Shach and Taz. At face value, the Taz (89:4) presents the six-month period as a flat rule (“The shiur for ‘gevinoh koshoh’ [hard cheese] that the Remo wrote about is that which is six months old…” ), whereas the Shach (s.k. 15) writes that, “On average, if it is six months old, it is considered to be hard…”
Upon a careful reading of the words of the Taz and Shach, one can detect that they seem to differ in their views. Whereas the Taz gives six months as the shiur of time to render cheese hard, the Shach presents this period as a mere estimation. That is to say, the Taz seems to hold that the six-month period is what classifies cheese as “hard”, and one must follow this time period as the factor in determining the din (unless the cheese has holes, as the Taz writes), but the Shach holds that the shiur is not one of time per se but one of texture.
In fact, both the views of the Shach and Taz can be culled from examining the slightly divergent expressions in Darchei Moshe on Tur YD 89 s.k. 2.)