Beverages

Juices, ciders, kombucha and soft drinks are TCS or regulated: plan for a licensed path.

Licensed Facility Required
5 centsDeposit, bottle bill
Part 120Juice HACCP
0.5%Alcohol line (ABV)
ABCCAlcohol license

What is covered and what needs a different path

What this guide covers

  • Dry drink mixes sold packaged (cottage path)
  • Bottled juice from a licensed, HACCP-covered kitchen
  • Retail-only fresh juice sold direct to consumers
  • Soft drinks from a licensed wholesale facility

Needs a different path

  • Bottled drinks made in a home kitchen
  • Alcoholic beverages without ABCC and TTB permits
  • Unpasteurized juice sold wholesale without a 5-log process
  • Health-cure claims on labels

Three compliance steps

A

Choose the path

Dry mix: residential kitchen. Anything liquid and shelf-stable: DPH wholesale food manufacturing permit under 105 CMR 500.

B

Meet federal rules

Juice processors follow 21 CFR 120 (HACCP; retail-only sellers are exempt but unpasteurized juice needs the warning label).

C

Check deposits and alcohol

Carbonated drinks, beer and malt carry the 5 cent deposit; any alcohol needs ABCC and TTB approval.

Quick reference

ItemRuleRegulator
JuiceHACCP; warning label if unpasteurizedFDA 21 CFR 120
Wholesale beverageManufacturing permit and GMPsDPH 105 CMR 500
Bottle bill5 cent deposit on soda, beer, maltMA Bottle Bill
AlcoholState and federal licenses; kombucha over 0.5% ABV is alcoholABCC; TTB
LabelingIdentity, ingredients, net contentsFDA

Frequently asked questions

Is kombucha a cottage food?No. It is a liquid fermented product and must come from a licensed facility.
Does the bottle deposit cover water or juice?The Massachusetts deposit law covers carbonated drinks, beer and malt; confirm if you add carbonation.
Can I sell fresh juice at a market?Only with the retail food permit from the local Board of Health.

Printable checklist

  • Path chosen: dry mix, retail or wholesale
  • Juice HACCP status confirmed
  • Warning label if unpasteurized
  • Deposit status confirmed
  • ABV tested under 0.5% or licensed
  • Ingredient label complete
  • Local market permit in hand