Selling it

What you may legally call it

Updated October 2026

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Names with legal definitions Juice Water Fermented, and the alcohol question References

Several of the words this category most wants to use are defined terms, and using them loosely is a labeling problem rather than a marketing one.

Names with legal definitions

Unlike minerals or candles, beverages sit inside food labeling law, where the statement of identity must be the common or usual name and several common names carry standards.

Juice

The word implies the product is juice. A drink containing a small proportion of juice is not a juice, and where a beverage purports to contain juice the percentage is generally required to be declared.

"Juice drink", "juice cocktail" and "beverage" exist precisely because the unqualified word does not fit a diluted product.

Which also matters upstream: calling a product juice invites the juice HACCP question, and the answer to that question depends on whether there is juice in it rather than on what it is called.

Water

Bottled water has its own standard of identity and quality under 21 CFR 165.110, with defined terms, spring, mineral, purified and so on, each meaning something specific.

A flavored product may or may not be inside that regime depending on what it is and how it is presented, and it is worth establishing which before designing a label around the word.

Fermented, and the alcohol question

"Kombucha", "kefir" and "fermented" are not standards of identity in the same way, and they carry a different risk: they tell the buyer, and a regulator, that there is a live fermentation in the bottle.

Which is honest and is also an invitation to ask what the alcohol content is.

And there is a harder line beyond it: describing a non-alcoholic product in terms borrowed from alcohol, "brewed", "hard", "session", can imply a category it is not in, while a product at or above 0.5 percent must carry the ABLA health warning and be labeled as what it is.

References

US Food and Drug Administration. Food Labeling Guide, including the nutrition labeling and serving size rules that apply to beverages. fda.gov

21 CFR 165.110, Bottled water, which sets standards of identity and quality for water sold as a beverage and is a separate regime from other drinks. ecfr.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

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

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.