HACCP without 5-log reduction

Hello everyone!
I know HACCP plans have been discussed on here. I found this statement on the FDA website

  • Retail establishments or businesses that make and sell juice directly to consumers and do not sell or distribute juice to other businesses are exempt from the juice HACCP regulation, but must comply with FDA’s food labeling regulation in 21 CFR 101.17(g) that requires a warning statement on packaged fruit and vegetable juice products that have not been processed to prevent, reduce, or eliminate pathogenic microorganisms that may be present, and with any applicable state regulations.


My current business, I am working out of a commercial kitchen, and simply juicing the produce then bottling it for consumers. Is this stating that if you put a warning label on each juice you are exempt from doing a HACCP plan?
Additionally if that isn’t the case, when do you know if you need to also produce a 5 log reduction? Is that only for pasteurized, heat treated, or HPP treated juices?
Thanks everyone!

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A HACCP plan is required along with the warning label if the product HAS NOT gone through a HPP / 5 LOG reduction.

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@shelbystratton Hello, you always want to make sure you are corresponding with the appropriate agency as well. Typically FDA is for large Distribution/Wholesale across the states, for everyone else they will most commonly go through their county health department or department of agriculture.
This is important because FDA is mostly referring to those types of business models, whereas the health dept or dept of agriculture will use the FDA guidelines but will go much more in-depth and specific for retail and local operations.
The rule typically is that HACCP is required when you are moving or transporting the bottled juice from the facility it was produced, I say typically because in many cases its interpreted differently or might vary from county to county.
I always recommend, get in contact with this local department, go over you process you are planning and they will provide the requirements needed, HACCP doesn’t always mean it needs to be HPP or pasteurized. Fell free to send me an email if you need any help or more information.
Good luck. Aris@goodnature.com


You actually need one in any juice factory, even if it’s being pasteurized. The pasteurization just becomes one of the steps in the HACCP plan. You do not always need one when selling direct to consumers, it depends on how the local health department interprets the guidance. At least this has been my understanding for a while.

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