The warning statement on untreated juice
Updated
The obligation that applies even to the smallest producer, and the one most often missing from a market stall.
It survives the exemption
A retail establishment selling juice directly to consumers is exempt from the HACCP rule, and it is not exempt from the warning statement.
Packaged fruit and vegetable juice that has not been processed to prevent, reduce or eliminate pathogenic microorganisms must carry the warning.
So the two obligations come apart, and the one that survives is the one on the bottle.
What it is for
It tells the buyer that the juice has not been treated, and it names who is most at risk: children, the elderly, and people with weakened immune systems.
Which is a real communication rather than a formality. Untreated juice has caused serious outbreaks, and the people it hurts most are the ones least able to judge the risk from a label that does not say.
Where it goes
On the packaged product, legible, where a purchaser will see it.
Which raises the question of what "packaged" means for a cup poured at a stall, and the answer there is generally different from a bottle sold to take away. Where a product is bottled and handed over, it is packaged.
If in doubt, carry it. A warning present where it was not strictly required has cost nothing; the reverse is not true.
When it is not needed
When the juice has been processed to achieve the 5-log reduction, which is the whole point of doing so.
That is the trade: treat the juice and lose the raw position but gain the shelf and the wholesale channel, or stay untreated and carry the warning and the direct-only restriction.
Both are legitimate businesses. What is not legitimate is untreated juice with no warning, which is the common state of a first-year producer who has read about HACCP exemptions and stopped there.