The two lines

HACCP, or the retail exemption

Updated October 2026

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The exemption that most small makers rely on What the exemption covers One case to a cafe ends it What HACCP actually requires References

The most consequential sentence in this property for a small producer, and the one that changes without anybody noticing.

The exemption that most small makers rely on

A retail establishment that makes and sells juice directly to consumers, and does not sell or distribute juice to other businesses, is exempt from the juice HACCP regulation.

Which is what makes a farm stand, a market stall and a juice bar possible.

The exemption is from the HACCP rule. It is not an exemption from the warning statement on untreated juice, which still applies.

What the exemption covers

Selling your own juice, from your own premises or stall, to the person who will drink it.

It does not cover distribution, and the test is whether juice goes to another business rather than how much of it does.

One case to a cafe ends it

This is the part to carry away.

A processor that sells juice both to other businesses and directly to consumers must use HACCP.

So the day you supply a single case to a café, a farm shop, a hotel or a restaurant, you are a juice processor with a HACCP obligation covering what you make, including the part you still sell at the market.

It is a common and entirely accidental transition. Somebody asks whether you can supply them, the answer feels like growth, and the regulatory position changed with the order.

What HACCP actually requires

A hazard analysis for the product and process.

Critical control points, with critical limits, which for juice means the validated 5-log step.

Monitoring procedures, corrective actions, verification, and records.

Training: HACCP plan development requires somebody who has completed appropriate training.

It is a real system rather than a document, and standing it up takes weeks rather than an afternoon, which is why the answer to the café is "give me a month", not "yes".

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.