Kombucha Co-Packer: Alcohol Rules, Minimums and Quotes

A kombucha co-packer either brews your kombucha to your recipe in its own tanks, or takes the kombucha you've brewed and fills it into cans or bottles. Either way, the question it will ask first is how you keep the alcohol under 0.5%, because kombucha that reaches 0.5% alcohol by volume at any point, including after bottling, is an alcohol beverage under federal rules. After that come tank time, refrigeration and minimums. In the example below, a kombucha brewer selling 3,000 bottles a month pays $1.72 a bottle brewing and bottling it itself, $2.22 with a co-packer that brews for it, and $1.32 when it brews and a co-packer cans, with four months of cans to keep cold. Below is the alcohol line, what the co-packer needs, three ways to split the work, and a free calculator.

The short version

• At 0.5% alcohol by volume or more at any time, kombucha falls under TTB's alcohol rules; below it, FDA's.
• That includes alcohol that rises in the bottle after it leaves the co-packer.
• Fruit juice added to kombucha brings FDA's juice HACCP rule.
• Some co-packers brew; more only fill. Brewing ties up their tanks for days, and costs more.
• Test every batch for alcohol, and agree who tests what, when.
• Plan the cold chain: kombucha is often kept refrigerated to stop it fermenting further.
• TaroStack keeps track of what's at your co-packer, by lot and date, with the alcohol test on each batch. More below.

The alcohol line

TTB's rule is simple to state: if kombucha's alcohol content is 0.5% or more by volume at any time during production, when bottled, or at any time after bottling, it's an alcohol beverage subject to TTB regulations; if it never reaches 0.5%, FDA's rules apply instead, along with state and local requirements (TTB). The "after bottling" part is the one that catches small brands: kombucha that leaves the co-packer at 0.3% and keeps fermenting in a warm truck can be over the line by the time it's on a shelf. So the plan for staying under it, whether that's refrigeration, filtration, a recipe that limits the yeast's sugar, or something else, is the first thing a co-packer wants to see. Kombucha with fruit juice added also brings FDA's juice HACCP rule, which applies to juice used as an ingredient in beverages (21 CFR 120.1). This is general information, not legal advice. How a kombucha business is set up from the start is in kombucha business plan.

What a kombucha co-packer will ask you for

• The recipe and process: tea, sugar, culture, fermentation time and temperature, flavoring, and when it's stopped.
• Your alcohol control: how you keep it under 0.5% through its shelf life, and the testing behind that.
• Specs: pH, Brix, alcohol, carbonation, and the flavor to match.
• The cold chain: refrigerated storage and refrigerated trucks, if the kombucha needs them.
• Packaging, labels, a forecast and a deposit.

What a spec sheet holds is in product specification sheet.

Three ways to split the work

Brightwater Ferments, a made-up kombucha, kimchi and sauerkraut maker in Portland, Oregon, I use in these examples, sells about 3,000 sixteen-ounce units of kombucha a month:

The co-packer that brews charges 70 cents a bottle, because a batch sits in its tanks for one to two weeks before it's ready, tank time it could sell to someone else. In the third column, Brightwater brews the base itself, its own labor counted in the 51 cents, and sends it in totes to a canning co-packer, which fills 16-ounce cans for 25 cents. That's the cheapest a unit, and it's twelve thousand cans, four months of sales, to keep cold and sell before their date, with every one of them needing to stay under 0.5% the whole time. How quotes like these fit a brand's size is in co-packer vs commercial kitchen.

Testing

Agree in writing who tests alcohol, by what method, on which samples and when: at the end of fermentation, at filling, and on retained cans later in their shelf life. Keep the results with the lot, so a question from a store or a regulator about a can leads to its test. What to settle with any co-packer is in what is a co-packer.

Get the calculator

Download the kombucha co-packer quote calculator. One column for each quote and one for doing it yourself: type the run you'd order, the minimum, the loss, the setup, the fee or your labor, ingredients, packaging, 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 unit 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

Base brewed in your tanks, totes on a truck, cans at the co-packer, pallets in your cooler and kegs at cafés, each lot with its own date and alcohol tests. A spreadsheet can't keep the test results with the lot, say which lot is closest to its date, or show which cafés got the cans you're asked about.

How TaroStack does it

TaroStack keeps track of what's at your co-packer, by lot and date, with the alcohol test on each batch.

Tests on the batch. A batch record form carries your own fields, such as the alcohol reading at the end of fermentation and at filling, the pH and the Brix, with limits and a sign-off, on the batch they belong to. A lot that fails can be held, kept out of what can be sold, until it's sorted out.

The co-packer as a site. The co-packer's premises can be a site, so the base in totes is a transfer, shown in transit, and the canned lots there are counted as yours. More than one site is on Standard at $99 a month.

Lots with dates. Each run gets a lot and a best-by date, so orders pick the earliest dates first and an alert warns before a lot nears its date. A recall report shows which customers got each lot. How shelf life is set is in shelf life testing methods.

Batch records, holds, sites, transfers and lots are on Standard at $99 a month for more than one site. 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.

Questions people also ask

Is kombucha regulated by TTB or FDA?

By TTB if it reaches 0.5% alcohol by volume or more at any time, including after bottling; by FDA if it never does. State and local rules apply either way.

Do kombucha co-packers brew the kombucha?

Some brew to your recipe in their tanks; many only fill kombucha you've brewed. In the example, brewing costs 70 cents a bottle and canning only 25 cents.

What is the minimum order for a kombucha co-packer?

In the example, 2,400 bottles at a co-packer that brews and 12,000 cans at a canning co-packer.

Does kombucha need to be refrigerated?

Kombucha is often kept cold to stop further fermentation, which can raise the alcohol after bottling. Your process and testing decide what yours needs.