Beverages
Juices, ciders, kombucha and soft drinks are TCS or regulated: plan for a licensed path.
Licensed Facility Required5 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
| Item | Rule | Regulator |
|---|---|---|
| Juice | HACCP; warning label if unpasteurized | FDA 21 CFR 120 |
| Wholesale beverage | Manufacturing permit and GMPs | DPH 105 CMR 500 |
| Bottle bill | 5 cent deposit on soda, beer, malt | MA Bottle Bill |
| Alcohol | State and federal licenses; kombucha over 0.5% ABV is alcohol | ABCC; TTB |
| Labeling | Identity, ingredients, net contents | FDA |
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