Licenses, and which one you actually need

Producers routinely complete one of these and believe they have done all of them. They are separate, issued by different bodies, for different reasons.

Four separate things

A business entity and a sales tax registration. Ordinary business formation, nothing to do with food.

Federal food facility registration. Identifies who you are and where you manufacture.

A process filing for each acidified product. Describes what you make and how it is made safe.

A state or local food processing license and inspection. The authority that actually visits.

The federal layer

Facility registration and, for acidified foods, the process filing and operator training. The training requirement is specific: someone supervising production must hold a Better Process Control School certificate or equivalent.

These are the ones with no local variation and no discretion, and they are the ones a retailer's compliance team asks about by name.

The state layer

This is where the variation lives. Some states license the facility, some the operator, some both. Cottage food programs exist in most states and generally exclude acidified foods. Inspection frequency and fees vary widely.

Because it varies, treat any general description as a prompt to ask your own state rather than as an answer. Your state department of agriculture is the right first call and the conversation is usually short and helpful.

Getting it in the right order

Recipe finalized first, because a process authority evaluates a fixed formulation and a change means re-evaluation. Then process authority. Then the filings. Then the kitchen and the state license, which depend on where you will actually produce.

Doing it in the other order is the common expensive mistake: producers secure a kitchen and print labels, then discover the process authority needs six weeks and the recipe needs adjusting.

References