Who is a process authority, and how do I choose one?
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A process authority is a food scientist with training and experience in acidified foods who tests your sauce and writes the scheduled process FDA expects you to follow. Federal law sets the standard in one sentence (21 CFR 114.83) and does not license or list them, so you choose. Most small sauce makers use a university food science program in their own state, because in-state fees are lower and state regulators already know the letters. If your state has none, or your sauce is fermented, look for an authority that takes out-of-state work and says in writing that it will evaluate your kind of product. This page covers the qualifications, the main types of authority, and what to send.
The legal standard
There is no federal license, exam or registry for process authorities. The rule sets a standard of knowledge. Section 114.83 says the scheduled process "shall be established by a qualified person who has expert knowledge acquired through appropriate training and experience in the acidification and processing of acidified foods" [1]. The definition of a scheduled process in 114.3(e) refers to "a competent processing authority" [2].
State regulators phrase it the same way. Montana's acidified food overview calls the process authority "a person whose expert food safety knowledge has been acquired through both training and experience," who tests the food for pH and other factors, sets time, temperature and handling limits, and issues a written letter that the state needs before it will issue a food license [3]. Cornell's Food Venture Center describes itself as recognized as a processing authority by state and federal agencies [4].
What that means for you: an inspector can ask who set your process and on what basis. A letter from a recognized university program or an established food safety lab answers that question. A letter from a consultant with no acidified foods background may not. FDA's January 2026 warning letter to an Arkansas pickled egg maker opened with exactly this finding: "A scheduled process was not established by a qualified person" [5].
The kinds of process authority
| Type | Examples | Usual strengths | Watch for |
|---|---|---|---|
| Your state's university food science program | Cornell Food Venture Center (NY), NC State Food Business, Texas A&M Food Processing Entrepreneurs, WSU Food Processing Extension (WA, ID, MT), UGA Extension Food Science, Arkansas Food Innovation Center, CSU Spur Food Innovation Center (CO), Kansas Value Added Foods Lab | Lower in-state rates; state regulators know their letters; often also run training | Some serve residents only; some will not take fermented products |
| An out-of-state university program | Cornell and WSU both publish out-of-state rates [4][6] | Fills the gap if your state has no program | Higher fees; ask whether your state accepts the letter |
| Private food safety labs and consultants | Eurofins offers process authority opinion letters, thermal process recommendations and deviation reviews [7] | Complex products, challenge studies, deviation evaluation | Cost; confirm acidified foods experience |
The Minnesota Department of Agriculture points producers to the Association of Food and Drug Officials (AFDO) directory of food process authorities [8]. The process authority directory in this book lists providers with their current fees and turnaround.
Who serves whom, and who takes ferments
What each program's public page said as of October 2026:
| Program | Out-of-state work | Fermented products | What they require up front |
|---|---|---|---|
| Cornell Food Venture Center | Yes, at non-New York rates [4] | Not stated | One-time client registration, then a scheduled process request per product [4] |
| WSU Food Processing Extension | Yes, at out-of-state rates; in-state means WA, ID and MT [6] | "We do not provide process authority evaluations for any fermented products" [6] | One jar per recipe in the selling size, a recipe spreadsheet in weights and percentages, your label, and certified lab results (required since July 1, 2025) [6] |
| Texas A&M Food Processing Entrepreneurs | Not stated; approved labs listed are in Texas [9] | Not stated | One container per product, two more to an approved outside lab for a 30-day incubation, an intake form and a signed testing agreement [9] |
| UGA Extension Food Science | Georgia residents only on its process approval form [10] | Not stated | One sample packaged as it will be sold, the approval form, payment in advance [10] |
| CSU Spur Food Innovation Center | Not stated | Not stated | Formula in grams, ounces or pounds (volume measures not accepted), before and after cooking weights, any lab reports, container and step-by-step procedure [11] |
"Not stated" means the page did not say. Ask before you send samples.
How to choose
- Start in your state. Call your state agriculture or health department and ask which process authorities it accepts. Some states, like Georgia, route you to a specific program as part of licensing [10].
- Match the product. If your sauce is fermented, oil-based or not heat treated, confirm the authority evaluates that kind of product. WSU, for example, also excludes products that have not been thermally processed and those with high oil content [6].
- Ask what you get. You want a letter that classifies the product, lists every critical factor with a number and is dated and signed. What a scheduled process is shows what belongs in it.
- Ask about support afterward. Deviations and recipe changes go back to the authority that set the process. Eurofins, for example, reviews processing and batching records and test results after a deviation [7]. A program that answers the phone matters more than a small price difference.
- Ask about changes and versions. Cornell prices amendments and versions separately from new processes and recommends reevaluating scheduled processes every three years [4].
What to have ready before you call
Process authorities ask for the same core information. Gather it before you make contact and the review goes faster.
- The formula by weight. Every ingredient in grams or ounces for one batch, not cups or "a pinch." Georgia's form says it plainly: "not 'pinch'!" [10]. From recipe to product shows how to convert a kitchen recipe.
- Batch weights before and after cooking, if the sauce is cooked [11].
- pH readings: the mixed ingredients before acid goes in, the acid itself and the finished sauce [10].
- The procedure, step by step, detailed enough for a stranger to reproduce, with temperatures and times [11].
- Container and closure: material, size and cap type [10][11].
- How you will sell it: shelf stable or refrigerated, retail or wholesale [11].
- Your label draft, which WSU asks for [6].
- Product samples, packed in the container you will sell, in the number each program asks for.
Getting the letter itself
Once you have picked an authority, the review runs through intake, samples, testing and a letter. Getting your scheduled process covers those steps, the 2026 fee range and how long each part takes.
References
- U.S. Food and Drug Administration, 21 CFR Part 114, Acidified Foods, eCFR, up to date as of October 20, 2026. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-114
- Legal Information Institute, Cornell Law School, 21 CFR 114.3 Definitions, accessed October 2026. https://www.law.cornell.edu/cfr/text/21/114.3
- Montana Department of Public Health and Human Services, Acidified Food Overview, revised December 11, 2014. https://www.dphhs.mt.gov/assets/publichealth/FCS/Wholesale/AcidifiedOverview.pdf
- Cornell Food Venture Center, CFVC Services and Fees, accessed October 2026. https://cals.cornell.edu/cornell-agritech/partners-institutes/cornell-food-venture-center/cfvc-services-fees
- U.S. Food and Drug Administration, Warning Letter to Christopher Dale Butler, CMS 720334, January 9, 2026. https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/christopher-dale-butler-720334-01092026
- Washington State University Food Processing Extension, Product Evaluation, accessed October 2026. https://foodprocessing.wsu.edu/extension/product-eval/
- Eurofins, Process Authority: FAQ and Answers, May 8, 2025, updated May 6, 2026. https://www.eurofins.com/en-us/food-feed-testing/resource-library/process-authority-faq-and-answers/
- Minnesota Department of Agriculture, Acidified Foods, modified July 30, 2025. https://www.mda.state.mn.us/acidified-foods
- Texas A&M AgriLife Extension, Food Processing Entrepreneurs: Submitting Samples, accessed October 2026. https://aggie-horticulture.tamu.edu/food-technology/food-processing-entrepreneurs/getting-started/submitting-samples/
- Mohan, A., Step-by-Step Guidelines for Processing, Manufacturing, and Regulatory Approval of Acidified Foods in Georgia, UGA Extension Bulletin B 1455, November 2015. https://secure.caes.uga.edu/extension/publications/files/pdf/B%201455_1.PDF
- CSU Spur Food Innovation Center, Colorado State University, Process Authority Letter Request Form, 2025. https://agsci.colostate.edu/wp-content/uploads/2025/07/Process-Authority-Letter-Request-Form.pdf
