No analogy is perfect. In this case, there are questions that legitimately have no definitive answer (like what is "large scale"), so it is more like the cheese

No analogy is perfect. In this case, there are questions that legitimately have no definitive answer (like what is "large scale"), so it is more like the cheese maker genuinely doesn't know whether their milk would be audited as raw-milk or not, and even if they consult with a lawyer they still don't have confidence that they would know.