Who inspects you

Two layers, and they answer different questions

The federal layer says what the product must be to carry its name. The state layer licenses the space, inspects it and decides whether you may sell what you make and where. A clear answer from one does not settle the other, and the gap is where somebody finds out late that a product they may legally make is one they may not sell at the venue they planned on.

The maple states have a third layer

Where there is an industry there are usually detailed state rules: density above the federal floor, grade naming, container marking, sometimes licensing and inspection specific to maple. Vermont’s 66.9 Brix minimum is the clearest example of a state number sitting above the federal one.

Describe the product fully

What it is, how it is made, the density you finish at, the container, and where it will be sold. Say explicitly whether it is hot packed and whether it is shelf stable or refrigerated, because those change the answer and they are the details makers leave out.

Record who told you what

Name, date, what you described and what they said. Guidance gets restated and staff change, and pointing at a specific conversation is a different position from remembering that somebody said it was fine.

Ask before the equipment, not after

The space question is the one that decides whether the plan works at all, and it is the cheapest to ask early. An evaporator bought for a building that turns out not to be licensable is the most expensive version of this mistake, and it is entirely avoidable with one conversation in the quiet part of the year.

References