Packaged juice that hasn't been treated to kill pathogens has to carry FDA's warning statement, word for word: "WARNING: This product has not been pasteurized and, therefore, may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems." It applies to any juice, and any drink containing juice, unless the juice or the drink went through a process that achieves at least a 5-log reduction, a 100,000-fold cut, in the most resistant pathogen likely to be in it, for its whole shelf life. Pasteurization and high pressure processing (HPP) are the usual ways to get there. The warning goes on the information panel or the front, prominent and easy to see, with WARNING capitalized and in bold, inside a box of hairlines. Juice sold to another business to be processed or repacked doesn't need it on the label if the papers that go with it say it wasn't processed. In the example below, a cold-pressed juice bar labels its counter bottles, then drops the warning for the bottles it sends to grocers through an HPP co-packer.
The short version
- Unpasteurized packaged juice carries FDA's warning statement, word for word.
- Not needed if the juice or drink is processed for a 5-log reduction, such as by pasteurization or HPP.
- On the information panel or front, prominent and conspicuous.
- WARNING in capitals and bold, the statement set off in a hairline box.
- Juice going to another business to process or repack: disclose it in the paperwork instead.
- Selling to grocers makes you a juice processor, with a HACCP plan.
- TaroStack keeps each bottling as a batch with its lot and its HPP or pasteurization record. More below.
The warning, exactly
| Part | What the rule says |
|---|---|
| The words | WARNING: This product has not been pasteurized and, therefore, may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems. |
| Where | The information panel or the principal display panel, prominent and conspicuous |
| WARNING | Capitalized, in bold type |
| Box | Set off by hairlines |
| Who needs it | Juice, and drinks containing juice, not processed for a 5-log reduction |
The processor's side, with the 5-log step, is in juice HACCP plan, and the business side in how to start a juice business.
The rules
| Rule | Where |
|---|---|
| The warning | Required on juice and juice drinks not processed for a 5-log reduction in the pertinent microorganism (21 CFR 101.17(g)(2), (7)) |
| How it looks | Prominent on the information panel or front; WARNING capitalized and bold; in a hairline box (101.17(g)(4) to (6)) |
| Going to another business | Not on the label for juice to be processed or repacked elsewhere, if the paperwork discloses it wasn't processed (101.17(g)(3)) |
| Retail or processor | A retail establishment provides juice directly to consumers; selling to other businesses makes you a processor (21 CFR 120.3(l)) |
States and counties can add their own rules for juice sold at a counter. This is general information, not legal advice.
An example: counter bottles and grocery bottles
Sunset Cliffs Juice Co., a made-up cold-pressed juice bar in San Diego, California, presses juice in the morning and bottles 12 oz servings for its counter and grab-and-go cooler. It doesn't pasteurize or use HPP for those, so every counter bottle carries the warning in a hairline box on the back label, WARNING in bold. When a grocer asked for 2,000 bottles a month, the bar moved those bottles to a co-packer that cold-presses and runs HPP to a validated 5-log reduction:
| Bottle | Treated for 5-log? | Sold to | Warning on the label? |
|---|---|---|---|
| Counter green juice | No | Its own customers | Yes |
| Counter orange carrot ginger | No | Its own customers | Yes |
| Grocery green juice | Yes, HPP | A grocer | No |
| Bulk lemon juice for a café's lemonade | No | Another business, to make drinks | No, disclosed on the invoice |
The grocery bottles don't need the warning because the HPP step does the work, but selling to a grocer makes the bar a juice processor with a HACCP plan, which the co-packer's validation supports. The lemon juice for the café goes with "not pasteurized" on the invoice, so the café knows what it's using. What the co-packer charges is in juice co-packer.
Get the checker
Download the juice warning label checker. One sheet: list each juice or juice drink, whether it's processed for a 5-log reduction, whether it goes to retail customers in a labeled package, and whether it goes to another business to process or repack; whether it needs the warning on the label fills in, with the exact wording to copy. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The checker settles the label. Once the same juice goes out two ways, raw at the counter and HPP'd to a grocer, each bottle has to stay with the right label and the right lot, and the grocer's lots need their HPP records.
How TaroStack does it
TaroStack keeps each bottling as a batch, with its lot and its records.
Each bottling a batch. A morning's counter bottles and a co-packer's HPP run are separate batches, each with its own lot and best-before date.
Your own fields. Fields of your own on the batch record can hold the HPP cycle number, or "unpasteurized: warning label", so the record says which label went on.
Where it went. Each grocer's order records the lots it got, so one recall report shows every store that has a lot.
| The job | Clipboard | In TaroStack |
|---|---|---|
| Which bottles are raw and which are HPP | Two label rolls on one shelf | Separate batches and lots |
| A run's HPP record | The co-packer's email | A field on the batch record |
| Which grocers got a lot | Invoices | One recall report |
Batches, lots and recalls are on every plan, from $49 a month. 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.