Getting started

Which regime you are in

Updated October 2026

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Juice Acidified food Live ferment Dietary supplement Which means the first page is a sorting exercise The juice question is the sharpest And it decides your business model Settle it before you buy a bottle References

Twelve leaves and at least four bodies of law. The first job is working out which one you are under.

Juice

If it contains juice, the juice HACCP regulation is in play, and the number at the centre of it is a 5 log reduction in the pertinent microorganism. Cold pressed juice, lemonade, agua fresca and a mixer containing juice are all candidates.

Acidified food

A shelf stable tonic, switchel or syrup-based drink that keeps because of its acidity rather than refrigeration is in acidified food territory, with scheduled processes and filings. The hot sauce, syrups and pickles properties cover that in detail.

Live ferment

Kombucha carries its own questions: continuing fermentation in a sealed bottle produces pressure, and it can produce alcohol above the threshold that would make it an alcoholic beverage.

Dietary supplement

A 60 mL energy shot can be labeled as a beverage with Nutrition Facts or as a dietary supplement with Supplement Facts. They are different regimes, the choice is yours and it is made once.

Which means the first page is a sorting exercise

Not an evasion. Most beverage businesses are in two of these at once, and the failure mode is assuming the one you learned about covers the whole range.

The juice question is the sharpest

Because it has only two outcomes. Achieve the 5-log reduction and prove it, or print a warning whose words you do not choose. Nothing in between exists.

And it decides your business model

Treated juice has a longer shelf life, can be distributed more widely, and needs equipment. Untreated juice is fresher, is sold locally and quickly, and carries a warning that some buyers will read and some retailers will decline.

Settle it before you buy a bottle

The treatment route changes the fill temperature, which changes the container material. That is the practical reason this question comes first rather than the regulatory one.

References

21 CFR 120.24, process controls for juice. A processor must use "control measures that will consistently produce, at a minimum, a 5 log (i.e., 10 5) reduction" in the pertinent microorganism, effective "for a period at least as long as the shelf life of the product when stored under normal and moderate abuse conditions", with the requirements met and "final product packaging within a single production facility operating under current good manufacturing practices". law.cornell.edu

21 CFR 101.17(g), the warning statement for untreated juice, required verbatim: "WARNING: This product has not been pasteurized and, therefore, may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems." Exempt where the product achieves the 5-log reduction or meets equivalent HACCP process controls, and for juice sent for further manufacturing at another facility with documentation disclosing the lack of processing. law.cornell.edu

The Davis Pack Supply catalog, measured 18 October 2026. The beverages shelf is 558 rows: 305 containers and 253 closures, 246 PET and 59 glass, from 30 to 976 mL with a median of 118. No HDPE and no PP. The closures include 159 continuous thread, 27 spouted, 19 flip top and 18 lug and twist, and no crown finish anywhere on the shelf.

Written from 21 CFR 120.24 and 101.17(g), and from the catalog as it stood on 18 October 2026. Whether a given product is a juice, an acidified food, a dietary supplement or an alcoholic beverage decides which regime applies, and that determination is specific to a formula and a label.