What is a process authority, and does your jam business need one?

A process authority is a food scientist qualified to decide how a product must be made and sealed to be safe on the shelf, and to put that decision in writing as a scheduled process. Federal law requires one for acidified foods, and this book treats pepper jelly and other jellies made with vegetables or herbs as acidified for sale. A standard fruit jam does not need one under federal rules, yet state inspectors, copackers and buyers often ask for a process review anyway, especially for hot-fill-hold, low-sugar spreads or anything unusual. This page explains what a process authority does, when you need one, how to find one, and what comes after the letter.

What the process authority actually decides

The Michigan Department of Agriculture and Rural Development describes a process authority as "a qualified expert with experience and specialized training in areas of food preservation." Its first job is classification: reviewing your written recipe and finished product to decide whether it is a low-acid food, an acidified food, or a naturally acid food, and recommending changes [1]. For an acidified product it then sets a scheduled process, the written set of conditions (formula, maximum pH, heat treatment, fill temperature, hold time, container and closure) that every batch must meet. The acidified foods rule requires that process to be "established by a qualified person who has expert knowledge acquired through appropriate training and experience in the acidification and processing of acidified foods" [2].

A process letter is specific. It names the product, the formula, the jar size and the process. Change the jar, the pepper, the fill temperature or the closure, and you should expect to go back for a revised letter.

Product by product: when one is required

Two sources sit in tension here. The text of 114.3(b) excludes jellies without qualification, while Penn State and Michigan treat jellies built on low-acid ingredients as acidified. No written FDA answer on pepper jelly was found for this page; confirm with FDA at LACF@FDA.HHS.GOV. Following the more cautious reading costs a review fee; following the other one wrong could mean selling an unfiled acidified food. The safety side of that decision lives on pepper jelly.

Why states and buyers ask for jam reviews

Even where federal law is silent, a licensing agency may want evidence your product is shelf stable before it approves it, and copackers often will not run a formula without a letter. Virginia Cooperative Extension tells jam makers that pH and water activity tests can be done "through a process authority, food scientist, or food-testing laboratory," and that if testing shows the product is acidified, "you must go through a process authority" [6]. Ask your state agency early which documents it will want with your license application.

Finding one and what it costs

Michigan's agency points makers to the Food Processing Authorities directory kept by the Association of Food and Drug Officials (AFDO) [1]. Most small makers end up with a university food science program, because their fees are published and modest. Review fees run about $75 to $300 per product across 2026 university fee pages [7][8][9][15]. Four examples, as listed on the providers' pages in October 2026:

Fees change, so check the provider's page before you send samples. Budget for lab tests on top of the review where the provider requires them.

What to send

Prepare these before you contact anyone. A clean submission is faster and cheaper.

1. The formula by weight, with every ingredient named as you buy it (fresh jalapeños, 5 percent distilled vinegar, a named pectin).
2. Your method step by step, including batch size, cook time, the temperature at which you fill, and how you seal (water bath time, or hot fill and invert).
3. The jar size and the lid or cap type.
4. Finished product readings if you have them: pH from a calibrated meter, and soluble solids from a refractometer.
5. Product samples, if the provider asks for them.

After the letter: training and FDA filing for acidified products

For a fruit jam, the letter goes in your product file and to whoever asked for it. For an acidified product such as pepper jelly, two more federal steps follow.

Better Process Control School

The acidified foods rule requires that operations be "under the operating supervisions of a person who has attended a school approved by the Commissioner" (the regulation's own wording) and been certified [10]. That school is Better Process Control School (BPCS), and Michigan's agency lists it as the course to complete [1]. Course formats and prices as of October 2026:

Registering and filing with FDA

Under 21 CFR 108.25, a commercial processor of acidified foods registers the plant on Form FDA 2541 "not later than 10 days after first so engaging," then files the process on Form FDA 2541e within 60 days of registration and before packing any new product, for each product in each container size [13]. This is separate from food facility registration, which is covered on FDA registration and food safety rules. FDA's acidified foods page lists the forms and the contact address [14].

Two federal questions have no written FDA answer that this book could find: whether a seller who sells acidified products only at farmers markets must file Forms 2541 and 2541e, and whose filing covers a copacked product. Do not rely on anyone's claim either way. Ask FDA at LACF@FDA.HHS.GOV and keep the reply.

The process most jam makers ask about next

The question that sends many fruit jam makers to a process authority is whether a licensed kitchen can fill hot, invert the jar and skip the water bath. What that method is, the numbers it runs on and who has to approve it are on hot-fill-hold and commercial filling.

References

1. Michigan Department of Agriculture and Rural Development, *Low Acid Foods and Acidified Foods*, accessed October 2026. https://www.michigan.gov/mdard/food-dairy/wholesale-industry-resources/wholesale-manufactured-foods-new-business-guide/food-operations-with-special-requirements/low-acid-foods-and-acidified-foods
2. eCFR, 21 CFR Part 114, Acidified Foods (section 114.83), up to date as of October 20, 2026. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-114
3. Legal Information Institute, Cornell Law School, 21 CFR 114.3, Definitions, accessed October 2026. https://www.law.cornell.edu/cfr/text/21/114.3
4. Penn State Extension, LaBorde, *Food for Profit: Commercial Production of Jams, Jellies and Fruit Butters*, updated May 24, 2024. https://extension.psu.edu/food-for-profit-commercial-production-of-jams-jellies-and-fruit-butters
5. Kansas State University Research and Extension, Getty and Gaikwad, *Hot-Fill-Hold Process for Acid and Acidified Foods* (MF3671), September 2024. https://bookstore.ksre.ksu.edu/download/hot-fill-hold-process-for-acid-and-acidified-foods_MF3671
6. Virginia Cooperative Extension, Eifert, Boyer, Wells, Saunders and Yang, *What do I need to know to sell jams, preserves, jellies, and fruit butters at the farmers market?* (FST-301P), June 2, 2020. https://www.pubs.ext.vt.edu/content/pubs_ext_vt_edu/en/FST/FST-301/FST-301.html
7. Washington State University Food Processing Extension, *Product Evaluation*, accessed October 2026. https://foodprocessing.wsu.edu/extension/product-eval/
8. 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
9. 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/
10. Legal Information Institute, Cornell Law School, 21 CFR 114.10, Personnel, accessed October 2026. https://www.law.cornell.edu/cfr/text/21/114.10
11. Seafood Products Association, *Better Process Control School for Acidified Foods*, April 20 to 22, 2026 session, page updated January 30, 2025. https://www.spa-food.org/Events/EventRegistration/2
12. NC State Extension Food Business, *Acidified Foods Manufacturing School*, updated August 12, 2026. https://foodbusiness.ces.ncsu.edu/acidified-foods-manufacturing-school
13. eCFR, 21 CFR 108.25, Acidified foods, up to date as of October 20, 2026. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-108/subpart-B/section-108.25
14. US Food and Drug Administration, *Establishment Registration and Process Filing for Acidified and Low-Acid Canned Foods (LACF)*, content current May 29, 2025. https://www.fda.gov/food/registration-food-facilities-and-other-submissions/establishment-registration-process-filing-acidified-and-low-acid-canned-foods-lacf
15. Kansas State University Research and Extension, Getty and Gaikwad, *Working with a Process Authority* (MF3731), March 2026. https://bookstore.ksre.ksu.edu/download/working-with-a-process-authority_MF3731