Differing Traditions

Rav Ovadia Yosef (Teshuvot Yabia, Omer 6, Yoreh Deah 7 and Yalkut Yosef, Yoreh Deah 89:46) permits Sephardic Jews to eat meat after dairy, if they wash and clean their mouths and hands. Rav Mordechai Lebhar (Magen Avot, Yoreh Deah 89:2) writes that this is a well-accepted custom among Sephardic Jews. However, Ashkenazic Jews customarily wait six hours after eating “hard cheese” (Rama Yoreh Deah 89:2 and Mishna Berura 494:16). Surprisingly, the Ben Ish Chai (Shelach 2:15) records that some Sephardic Jews have adopted this custom, or a modified version of it. What are the basis of these practices?

The Lenient View

The lenient view is well supported by the Gemara, Rambam and Shulchan Aruch. The Gemara (Chullin 105a) states that one may eat meat after dairy. Chullin 104b says that meat may be eaten freely after milk. The Rambam (Hilchot Maachalot Asurot 9:26) and Shulchan Aruch (Yoreh Deah 89:2) codify these Talmudic teachings without reservation. Rav Ovadia continues this straightforward pattern by permitting meat after dairy, after cleaning and rinsing.

The Strict View

That would seem to conclude the discussion. However, the Beit Yosef (Orach Chayim 173 s.v. Katuv) presents two surprising additions. The first is the Zohar (Parshat Mishpatim) which forbids meat after milk.

Typically, when the Zohar conflicts with the Gemara, we follow the Gemara. However, a second factor enters the equation. The Beit Yosef quotes an incident which occurred with the Maharam of Rothenburg, who discovered cheese remaining in his mouth while eating meat. As a result, the Maharam resolved never to eat meat after cheese for the remainder of his life.

Since the Shulchan Aruch does not cite either the Zohar or the Maharam of Rothenburg, Rav Ovadia Yosef rules leniently. However, the Rama records the compromise customarily adopted by Ashkenazim, which is to wait six hours after eating “hard cheese.”

Defining Hard Cheese

The term “hard cheese” is open to interpretation. The Shach (Yoreh Deah 89:15) and the Taz (Yoreh Deah 89:4) say that hard cheese means “six months have passed.” The Taz adds that Swiss cheese is also hard cheese, even if six months have not passed. To what do these six months refer?

Rav Shmuel Wosner (Teshuvot Shevet Halevi 2:35) includes refrigeration time in the six months. However, Rav Wosner notes the difficulty of tracking the time elapsed from cheese production to consumption. Due to this doubt, he requires a six-hour wait even after common cheeses, such as the “Israeli yellow cheese.” Rav Yosef Shalom Eliashiv (cited in Ashrei Haish, volume 3 Moadim, page 442) adopts a similar approach. He requires a six-hour wait, even after eating pizza cheese.

However, one wonders why one should be strict in case of doubt about a custom. We rule strictly in case of doubt only for a Torah law — not a rabbinic law — and certainly not a custom. In addition, cheese experts report that it does not age or change its texture or taste when refrigerated. Hence, the OU adopts Rav Yosef Dov Soloveitchik’s understanding that six months refers to cheese’s aging process. Only cheese that has aged for six months acquires a pungent taste. Cheese with a sharp taste lingers in the mouth; therefore, Ashkenazim customarily wait six hours before eating meat. The Taz’s addition of Swiss cheese shows that six months is not a “hard” definition. Rather, any cheese with an exceptionally strong taste is categorized as “hard cheese.”

The OU’s dairy expert, Rav Avraham Gordimer, lists dozens of cheeses and notes which are considered “hard” (either aged six months or exceptionally pungent) by OU Kosher’s senior poskim (https://oukosher.org/blog/consumer-kosher/aged-cheese-list/). Generally speaking, only higher-end cheeses fit the OU poskim’s definition of “hard cheese.” Interestingly, according to OU Kosher, regular Swiss cheese does not require a six-hour wait. Only the special, made in Switzerland, “Emmental cheese,” is sufficiently intense to require the six-hour separation.

Melted and Grated Cheese

For most, the most common encounter with “hard cheese” is melted or grated parmesan cheese (aged 10 to 24 months). However, the Yad Yehuda’s commentary to Yoreh Deah writes that melted cheese loses its status as hard cheese.

However, some poskim limit Yad Yehuda’s leniency to cheese dissolved into the food, but not when it is on its surface (such as pizza cheese). The more lenient view seems more compelling, if the melted cheese does not retain its pungent taste. The Taz’s addition of Swiss cheese to the hard cheese list shows that the six-month rule is not hard and fast. If it is not pungent, there is no need to wait six hours — even if the cheese was aged for more than six months.

The same applies to grated parmesan cheese. Rav Ari Marcus (in “Halacha 24/7/12,” page 379) requires a six-hour wait after eating grated parmesan sprinkled on a salad — but this is not compelling. Typical grated cheese does not retain a very potent taste like the gourmet cheeses on the OU list and, therefore, does not require a six-hour wait.

Packaged Cheese That Has Acquired a Potent Taste

The OU Kosher includes it on its website. However, it has come to our attention that some non-aged cheeses, if left to age in their packaging, may acquire a meshichas ta’am — a very potent taste — which is one of the factors that requires a person to wait after certain cheeses. (V. Taz. s.k. 4 and other poskim on Shulchan Aruch Yoreh 89:2.) Should a person notice that an otherwise non-aged cheese which has aged after production presents a very potent taste — or that it has acquired a brittle texture similar to that of aged cheeses — he should treat such cheese the same as regular, aged cheese and wait the full period, before consuming meat.

Since it is a matter of custom, one may be lenient if in doubt, if the cheese has acquired a potent taste.

Conclusion

Rav Ovadia Yosef’s lenient approach represents the most straightforward approach that flows directly from the Gemara, Rambam and Shulchan Aruch. Ashkenazim, though, added a strict custom of waiting six hours after hard cheese, atypically, based on two extra-Talmudic sources. However, since the wait for hard cheese stems from a custom, Ashkenazic Jews may adopt lenient interpretations and applications regarding hard cheese. Thus, a six-hour delay applies only to the cheeses appearing on the OU list. Melted or grated hard cheese, typically, loses its status as hard cheese, and a six-hour wait is unnecessary.

Rabbi Haim Jachter is the spiritual leader of Congregation Shaarei Orah, the Sephardic Congregation of Teaneck. He also serves as a rebbe at Torah Academy of Bergen County and a dayan on the Beth Din of Elizabeth.