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What you have to register, and with whom

Updated October 2026

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Four possible registrations Always If there is juice in it If it ferments past the line References

More registration questions than any other property here, and which apply depends on the two thresholds.

Four possible registrations

FDA food facility registration. A state or local food establishment license. A juice HACCP obligation. And TTB brewer qualification.

The first two apply broadly; the second two depend on what is in the bottle and what it does in it.

Always

FDA food facility registration, for a facility manufacturing food for consumption in the United States, renewed biennially. A retail establishment is treated differently, which is worth confirming for your own operation.

A state or local food establishment license, with inspection and frequently a plan review.

Business registration and sales tax, as anywhere.

And preventive controls obligations under the FDA food safety framework, which for a beverage facility is a real requirement rather than a formality.

If there is juice in it

The juice HACCP question. A retail establishment selling only direct to consumers is exempt from the rule and still carries the warning statement on untreated juice.

Anything else is a processor: a HACCP plan, a validated 5-log step, monitoring, records, and trained personnel.

Note that this is an obligation rather than a registration. Nobody issues you a HACCP license; you are expected to have the system and to be able to show it.

If it ferments past the line

TTB, and it is a different order of magnitude.

Premises qualified under the Internal Revenue Code, brewer qualification under 27 CFR part 25, a formula filed before production, excise tax, and the ABLA health warning on the container.

Plus state alcohol licensing on top, which is separate and frequently harder.

Which is why the measurement on warm retained samples is not an optional quality check. It is what tells you which of these lists you are on.

References

US Food and Drug Administration. Food Facility Registration and the preventive controls requirements for human food. fda.gov

21 CFR Part 120, Hazard Analysis and Critical Control Point (HACCP) Systems for juice. Covered processors must achieve a 5-log reduction in the pertinent pathogen. ecfr.gov

US Food and Drug Administration. Exemptions from the Warning Label Requirement for Juice. A retail establishment selling juice directly to consumers and not distributing to other businesses is exempt from the HACCP rule, and untreated juice must still carry the warning statement. fda.gov

Alcohol and Tobacco Tax and Trade Bureau. General TTB Requirements for Kombucha. Production on premises qualified under the Internal Revenue Code, compliance with labeling, formula and tax requirements, and the health warning statement required by the Alcoholic Beverage Labeling Act of 1988. ttb.gov

Alcohol and Tobacco Tax and Trade Bureau. Requirements for Kombucha Classified as Beer. Fermented beverages at or above 0.5 percent ABV are classified as beer for tax purposes; a brewer must qualify under 27 CFR part 25 and file a formula before production. ttb.gov

Written from the federal regulation and agency guidance named on each page, not from a laboratory. Whether a particular product meets a pathogen reduction requirement, and what its alcohol content actually is, are measurements about your product, and this is not those measurements.