A kombucha HACCP plan comes down to two measurements on every batch. pH: kombucha is safe because the ferment turns acidic fast, so the primary fermentation is a critical control point with a pH limit before flavoring, set by your process authority or state program. And alcohol: under federal law, kombucha at 0.5% alcohol by volume or more at any time, during production, at bottling, or after bottling on a shop shelf, is an alcohol beverage under TTB's rules. Live kombucha keeps fermenting, and TTB says refrigeration alone isn't an adequate safeguard, so the plan measures alcohol on each batch and uses a method that keeps it from rising. Below 0.5%, kombucha is a food: a registered brewery follows FDA's preventive controls rule, or files an attestation if it's small. In the example below, a Portland brewer's kombucha comes down to those two critical control points. Below are the rules, the hazard analysis, the plan, a week of records, and a free worksheet.
The short version
- Kombucha at 0.5% alcohol by volume or more at any time, including after bottling, is an alcohol beverage under TTB.
- Below 0.5% at every point, it's a food under FDA, with state and local rules on top.
- Refrigeration alone isn't an adequate safeguard against alcohol rising, according to TTB.
- The ferment's pH is the food safety control: a limit before flavoring, set by your process authority or state.
- Alcohol is measured on each batch, and retained bottles are tested at the end of the shelf life.
- A registered brewery follows the preventive controls rule; one under $1,000,000 in food sales attests instead.
- TaroStack keeps each batch's pH and alcohol readings on its batch record. More below.
The rules
| Rule | What it says |
|---|---|
| Alcohol | 0.5% alcohol by volume or more at any time during production, when bottled, or after bottling: an alcohol beverage, subject to TTB |
| After bottling | Kombucha bottled under 0.5% that rises to 0.5% or more from fermentation in the bottle is covered by TTB's rules |
| Food | Kombucha never at 0.5% or more follows FDA's regulations and state and local rules |
| Food safety plan | A registered facility follows 21 CFR part 117, unless it's a qualified facility, which files attestations |
| pH | Your process authority or state program sets the limit the ferment must reach |
TTB's rules are on its kombucha page; the attestations for a small facility are in 21 CFR 117.201. How pH is measured and recorded is in pH testing for acidified foods. This is general information, not legal advice.
An example: the hazard analysis
Brightwater Ferments, the made-up fermented food and drink maker in Portland, Oregon, I use in these examples, brews kombucha for bottles, kegs and growler refills:
| Step | Hazard | Reasonably likely? | Control | CCP? |
|---|---|---|---|---|
| Receiving tea, sugar, juice, bottles | Pathogens in juice; glass | No | Pasteurized juice, supplier guarantee; bottles inspected | No |
| Brewing the tea | None surviving the boil | No | Boiling water | No |
| Adding starter and SCOBY | Pathogens if acid is slow | Yes | Starter at the plan's ratio | No |
| Primary fermentation | Pathogens if the pH doesn't drop; mold | Yes | pH at or below the limit before flavoring | CCP 1 |
| Flavoring with juice | No allergens in this recipe | No | Label check | No |
| Bottling | Alcohol rising past 0.5% in the bottle; glass | Yes | Alcohol measured, with a method that keeps it down | CCP 2 |
| Cold storage and shipping | Alcohol rise if warm | No | Controlled at CCP 2 | No |
What the kombucha earns is in kombucha business plan.
The plan
| CCP | Critical limit | Monitoring | Corrective action | Verification |
|---|---|---|---|---|
| CCP 1 Primary fermentation pH | At or below the plan's limit before flavoring (example: 4.2) | Calibrated pH meter, a sample from each vessel | Hold; extend fermentation and retest; discard if it doesn't reach the limit | Meter calibrated each day of use; records reviewed weekly |
| CCP 2 Alcohol | Below 0.5% ABV at bottling, by a method validated to keep it there through the shelf life | Lab or validated method on each batch; retained bottles at the end of the shelf life | Hold; don't release above the limit; find the cause | Retained bottles tested; records reviewed |
The pH limit is an example; yours comes from your process authority or state program. How a monitoring record is kept is in HACCP record keeping form example.
A week of records
| Date | Batch | CCP | Reading | Limit | OK? | Action |
|---|---|---|---|---|---|---|
| Oct 5 | KB-1005 | Fermentation pH | 3.4 | 4.2 or below | Yes | |
| Oct 5 | KB-1005 | Alcohol | 0.31% | Below 0.5% | Yes | |
| Oct 8 | KB-1008 | Fermentation pH | 4.4 | 4.2 or below | No | Cold room slowed the ferment; held two more days |
| Oct 10 | KB-1008 | Fermentation pH | 3.6 | 4.2 or below | Yes | Released to flavoring |
Get the worksheet
Download the kombucha HACCP plan worksheet. Four sheets: the hazard analysis, the HACCP plan with a place to sign, a monitoring log that checks each reading against its limits, and a read-me. It's a worksheet to organize your own plan, not a plan to copy. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
Each batch has a pH reading, an alcohol result, and retained bottles to test weeks later, and kegs and growlers go to different customers from the bottles. When TTB or a buyer asks about one batch, the answer has to be on record.
How TaroStack does it
TaroStack keeps each batch's pH and alcohol readings on its batch record.
Readings on the batch. Fields of your own on the batch record hold the pH, the alcohol result and the retained bottle's end-of-shelf-life test, and printable batch-record forms carry a sign-off.
Held until tested. A batch can be held, kept out of what can be sold, until its alcohol result is in.
Where it went. Each café's keg and each shop's case records the lots it got, so one recall report shows every customer a batch reached.
| The job | Clipboard | In TaroStack |
|---|---|---|
| A batch's pH and alcohol | A log sheet | Fields on the batch record |
| A batch waiting for its result | A note on the tank | A hold until released |
| Which cafés got a batch | Invoices | One recall report |
Lots, batches and orders 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.