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Selling it

Selling wholesale, and what it does to your exemption

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The growth step that, in this property, changes what you legally are.

The order that changes your regime

The juice HACCP retail exemption applies to a retail establishment that sells directly to consumers and does not sell or distribute juice to other businesses.

A processor selling both to businesses and to consumers must use HACCP.

So the first wholesale order for a juice-containing product is not a commercial milestone, it is a regulatory transition, and the obligation covers everything you make, including what you still sell at the market.

Which is why the honest answer to a café asking whether you can supply them is "give me a month", not "yes".

What a buyer asks for

A line sheet, case quantities, a minimum, a barcode.

Liability insurance.

And increasingly, documentation: your HACCP plan or your exemption basis, your shelf life data, and for a live product your alcohol testing. Larger buyers ask in writing, and a compliance team is the one that actually reads it.

Consistency, because the reorder sits on a shelf next to the last one.

The cold chain becomes their problem too

A refrigerated product sold wholesale depends on a chain you no longer control: their van, their back door, their stockroom, their cabinet.

Which means either choosing accounts that can hold it, or stabilizing the product so it does not need them.

That choice usually forces itself at exactly this point, and it is better made deliberately than after a batch has been left out.

Making the margin work

Wholesale is conventionally about half of retail, and a beverage has thin unit economics to start with because of freight and packaging.

Set direct price so wholesale clears, and cost the delivery honestly, because a refrigerated local delivery round is a real expense that a dry-goods maker does not have.

References

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
US Food and Drug Administration. Juice HACCP Hazards and Controls Guidance. How the 5-log requirement is met, validated and monitored. fda.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.