Two numbers, two agencies

Almost every other property in this estate turns on one determination. This one turns on two numbers, set by two different agencies, and a drink can be inside both at once.

Five logs and half a percent

Five logs is FDA. A juice processor must achieve a 5-log reduction in the pertinent pathogen under the juice HACCP rule, 21 CFR Part 120. A hundred-thousand-fold reduction.

Half a percent is TTB. A fermented beverage at 0.5 percent alcohol by volume or more is an alcohol beverage, taxed and regulated as beer.

The first is about what you must destroy. The second is about what you must not create.

Why both are measurements

Neither is a claim you make or a category you choose. Both are quantities in the product, established by measurement and validated by a process.

Which means neither can be reasoned into. A juice is or is not 5-log treated; a kombucha is or is not above 0.5 percent. Whatever the label says.

And both are the kind of number a regulator can check on a bottle bought from a shelf.

Which one applies to you

Juice, or a beverage containing juice: the five-log question, and the answer depends on whether you are a processor or a retail establishment.

Anything fermented, including kombucha, water kefir and jun: the half-percent question.

A fermented drink containing juice: both.

Tea, coffee, syrups, flavored water and carbonated soft drinks without juice: neither of these two, though the ordinary food requirements still apply.

What they have in common

Both are held by a process rather than by a recipe, so both need validation, monitoring and records.

And both can be crossed after the product leaves you. Untreated juice that was fine at dispatch can be a problem after a warm delivery; a kombucha at 0.4 percent can ferment to 0.5 on a shelf.

That second point is what makes this property unusual: the container is not holding a finished product, it is hosting a reaction, and the cold chain is part of compliance rather than part of quality.

References