A juice bar can press juice and sell it to the people standing at its counter. The moment it sells bottles to a grocer or café, it stops being a retail establishment under FDA's juice HACCP rule, 21 CFR part 120, and the juice needs a HACCP plan with a process that achieves a 5-log reduction, a 100,000-fold cut, in the most resistant pathogen likely in it, applied to the juice itself and packed in the same facility. Raw cold-pressed juice from a counter press doesn't do that; high pressure processing (HPP) after bottling, or pasteurization, does. That's what a juice co-packer brings: the press, the HPP vessel or pasteurizer, the validated process and the HACCP plan. The catch is shelf life: HPP juice keeps weeks in the cold, not months, so the run you order is capped by how fast it sells, not by the minimum you'd like. In the example below, a San Diego juice bar wanting to sell about 2,000 bottles a month to grocers pays $4.20 a bottle at a cold-press and HPP co-packer; a larger plant's $3.47 comes with a run five months long. Below are the rule, what juice co-packers do, three quotes, and a free calculator.
The short version
- Selling juice only to people at your counter is retail; selling bottles to grocers isn't.
- Juice sold to other businesses needs a juice HACCP plan.
- The process must achieve a 5-log reduction in the pertinent pathogen, applied to the juice.
- Final packaging happens in the same facility as the 5-log step.
- Raw cold-pressed juice doesn't meet it; HPP or pasteurization can.
- HPP juice keeps weeks, so shelf life caps the run size.
- TaroStack keeps each run's lot and date, and earliest dates out first. More below.
The rule
| Rule | 21 CFR part 120 |
|---|---|
| Covered | Any juice sold as juice or used as a beverage ingredient, shipped across state lines or not (120.1) |
| Retail exempt | An operation that provides juice directly to consumers; one that also sells to other businesses isn't retail (120.3) |
| 5-log | Control measures that consistently produce at least a 5-log reduction in the pertinent microorganism, for the shelf life (120.24) |
| Applied to the juice | Treatments applied directly to the juice, except citrus surface treatments (120.24) |
| One facility | The 5-log step and final packaging in a single facility under good manufacturing practices (120.24) |
| Shelf-stable exemption | A single thermal process to shelf stability, documented in the hazard analysis (120.24) |
How the plan is written is in juice HACCP plan, and starting out in how to start a juice business. This is general information, not legal advice.
What juice co-packers do
They wash and press your recipe, bottle it, and run the sealed bottles through an HPP vessel, or pasteurize, then code, label and chill. Many buy the produce at their own volume price; a specialty fruit you may have to supply. The co-packer holds the validated process and the HACCP plan for what it makes. What a co-packer is in general is in what is a co-packer, and drinks more widely in beverage co-packers.
Three quotes compared
Sunset Cliffs Juice Co., a made-up juice bar in San Diego, California, I use in these examples, presses 12 oz juices at its counter and wants to sell about 2,000 bottles a month to grocers:
| Press at the bar | Cold-press and HPP co-packer | Larger HPP juice plant | |
|---|---|---|---|
| Can go to grocers? | No: no 5-log step | Yes | Yes |
| Run you'd order | 300 | 2,000 | 10,000 |
| Minimum run | none | 1,500 | 10,000 |
| Good bottles, after the loss | 288 | 1,940 | 9,800 |
| Setup | $0 | $300 | $600 |
| Fee, or your own labor, a bottle | $0.90 | $0.95 | $0.55 |
| Produce, a bottle | $2.40 | $2.30 | $2.10 |
| Bottle and label | $0.55 | $0.55 | $0.48 |
| Freight a run, refrigerated | $0 | $250 | $600 |
| Run cost | $1,155 | $8,150 | $32,500 |
| Months to sell the run | 0.1 | 1.0 | 4.9 |
| Cold storage while it sells | $0 | $0 | $1,470 |
| Cost a good bottle | $4.01 | $4.20 | $3.47 |
The counter's $4.01 is for comparison only: those bottles can't go to a grocer. The HPP co-packer's $4.20 is what the grocery business really costs, and a month's run sells inside the juice's weeks of shelf life. The larger plant's $3.47 looks better until the run: nearly five months of juice that keeps weeks. It becomes the right quote when sales reach the plant's minimum every few weeks.
What to settle before the first run
- The recipe by weight, and who buys the produce.
- The validated process: HPP pressure and time, or pasteurization, and the shelf life it supports.
- Bottle, fill volume and declared net contents.
- Lot code and use-by date on every bottle.
- Cold chain from the plant to the grocer.
What a spec sheet holds is in product specification sheet.
Get the calculator
Download the juice co-packer quote calculator. One column for each quote and one for pressing it yourself: type the run you'd order, the minimum, the loss, the setup, the fee or your labor, the produce, the bottle and label, freight and storage, and the run's cost, the months it takes to sell at your sales a month, the storage while it sells, the cost of each good bottle and the cash out before it sells fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
Juice that keeps weeks, grocers who want two weeks of life left on delivery, and runs arriving every month: a spreadsheet doesn't know which bottles are oldest or which grocer got which run.
How TaroStack does it
TaroStack keeps each run's lot and date, and earliest dates out first.
Runs with dates. Each run from the co-packer is received as a lot with its use-by date, and the co-packer's cooler can be a site of its own; more than one site is on Standard at $99 a month.
Earliest first, with each grocer's rule. Orders pick the earliest dates first, and a grocer can carry its own minimum days left, so short-dated bottles don't go to the store that refuses them.
Where it went. Each grocer's order records the lots it got, so one recall report shows every store a run reached.
| The job | Spreadsheet | In TaroStack |
|---|---|---|
| Which bottles are oldest | A guess | Earliest dates first |
| A grocer's minimum days left | Remembered | The customer's own rule |
| Which stores got a run | Invoices | One recall report |
Lots, expiry and sales orders are on every plan, from $49 a month; more than one site is on Standard at $99. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.