Q: Is a cream cheese-based frosting allowed, if I keep it cold?

Frosted cupcakes

A: Icings and frosting using eggs, milk, cream or cream cheese are not allowed because most are considered a potentially hazardous food. Only non potentially hazardous foods are allowed under the cottage foods exemption. However, you can use tested recipes from the Come and Bake book tested and deemed as a non potentially hazardous food.

If you create your own frosting recipe using these ingredients, have the product tested. If deemed a non-potentially hazardous food then it would be allowed. Keep the test results as documentation.