Raw juices allowed in wholesale kombucha?

Hello all, I have been doing research on the regulations surrounding adding raw juice to beverages that only contain, say, up to 20% juice. Examples would be kombucha with juice added, carbonated water with juice added to it, alcoholic beverages with juice added, etc.

We want to wholesale infused beverages that contain only 20% of our juice bar’s raw juices.

I have reached out to a few kombucha companies, included the largest raw kombucha company, GT Dave. They informed me that they do indeed use 100% raw juices and sell it wholesale. No processing for log-5 reduction. The raw juice is added to the kombucha that is first fermented with other raw juices. My understanding is that the raw juice wholesale regulations apply to juices added in any percentage in beverages. So raw juice to flavor carbonated water would require processing through pasteurization, HPP, UV…

Any thoughts or insights surrounding how it is that kombucha seems to be excerpt from the raw juice laws? My guesses included the fact that it continues to ferment somewhat after the juice is added. The first round of juice is added and fermented with the scoby. The GT label indicates that the second round of raw juice is not considered part of the initial kombucha culture that also uses raw juices. My other guess is that the low alcohol percentage plays a role.

Thanks for any feedback,


I think this comes down to the fact that kombucha is considered its own sort of thing - for a while it was actually classified as beer because of the alcohol content. The KBI (kombucha brewers association) lobbied the government to get this changed.

The questions of legally what is kombucha is what you would refer to as a “standard of identity” - and is something that’s currently being debated in the kombucha world: https://www.foodnavigator-usa.com/Article/2019/08/27/KBI-enlists-consultant-to-review-proposed-kombucha-standard-of-identity#

Many companies are indeed pasteurizing kombucha now - however I do believe GT’s keeps it raw. Dave himself is pretty passionate about living foods.

If you plan on adding water to raw juice it will 100% be classified as juice and must go through the 5 log kill step to sell wholesale.

The Juice Makers Association is working towards getting the raw juice regulations changed - if this is something you’re passionate about and would like to help please join us: https://juiceassociation.org

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Thanks for the insight Charlie. I’ve found it very difficult to get definitive answers from research or the state cdc or agricultural department. Maine is interesting because the state legislature passed a law that allows Apple cider to be wholesaled raw. It’s ironic because this all started with apple juice from Odwalla.

I’m curious if you know if the rules are different for alcoholic beverages with raw juice added? A local distillery has expressed interest in partnering with us to make raw juice cocktails with around 5%-7% alcohol content (raw juices, carbonated water, vodka, etc.)

I will check out the Juice Makers Association.



I’m not sure about raw juice in alcohol - I would imagine if the drink is classified as alcohol there are different regulations.

All that being said - it may be necessary to pasteurize the drink for safety and shelf life stability even if it’s not specified in the regulations.

Interesting topic because we’ve had customers that have made kombucha with our raw juices. I was thinking that since it’s used more to flavor the kombucha that is fermented; the raw juice just ferments with it?
We just started looking into making 1/2 kegs to feature on tap, but we’re only in our early stages of designing a separate kitchen for kombucha and fermented foods. The raw juice issue, I hope will not be an issue.
More research is needed obviously.


Yes that’s true, it’s a 2nd fermentation step.

Regarding the 2nd kitchen - it shouldn’t be an issue as long as it’s owned by the same entity. En example of this is Juice Press in NYC - they make all of their juice in one location and sell it through like 30 stores throughout the city. Since they are all owned by the same entity so it’s technically still selling direct to consumer.

All that being said, it depends on your local health department!

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