A TCS food, time/temperature control for safety food, is one that has to be kept hot or cold to stop bacteria growing or making toxins. The FDA Food Code, which states adopt for restaurants, retail and often cottage food, lists them in two ways. By group: raw or cooked animal foods (meat, eggs, dairy, fish); cooked plant foods; and raw seed sprouts, cut melons, cut leafy greens, cut tomatoes and garlic in oil. And by measurement: two tables of pH and water activity that decide whether a food is non-TCS, or needs a product assessment. Bread, most cookies and fruit pies come out non-TCS; custard pies, cream cheese frostings and focaccia with fresh tomatoes don't. In the example below, a home baker sorts six products. Below is the list, the tables, the example, and a free checker.
The short version
- TCS foods need time and temperature control to keep them safe.
- Listed groups: raw or cooked animal foods; cooked plant foods; raw seed sprouts; cut melons; cut leafy greens; cut tomatoes; garlic in oil.
- pH and water activity can make a food non-TCS: Table A for foods cooked and then packaged, Table B for the rest.
- A food in a "product assessment required" cell is TCS unless an assessment shows otherwise.
- Not TCS: unopened commercially sterile cans, and shell eggs that are pasteurized or air-cooled hard-boiled.
- Cottage food laws generally allow only non-TCS foods from a home kitchen.
- TaroStack keeps each batch's pH and water activity on its batch record. More below.
The listed groups
| Group | Examples |
|---|---|
| Animal food, raw or heat-treated | Meat, poultry, fish, eggs, milk, cream cheese, custard, cheesecake |
| Plant food, heat-treated | Cooked rice, beans, potatoes, cooked vegetables |
| Raw seed sprouts | Alfalfa, bean sprouts |
| Cut melons | Cut watermelon, cantaloupe |
| Cut leafy greens | Cut lettuce, spinach, kale |
| Cut tomatoes | Cut or chopped tomatoes, unless modified so they can't support growth |
| Garlic in oil | Fresh garlic in oil, unless modified so it can't support growth |
All of these come from the Food Code's definition (FDA Food Code 2026), which also lets pH and water activity take a food out of the list: a cooked plant food or even an animal food can be non-TCS if its numbers fall in a non-TCS cell. This is general information, not legal advice; your state may use a different edition.
The tables
Table A, for foods heat-treated to destroy vegetative cells and then packaged:
| Water activity | pH 4.6 or less | pH above 4.6 to 5.6 | pH above 5.6 |
|---|---|---|---|
| 0.92 or less | Non-TCS | Non-TCS | Non-TCS |
| Above 0.92 to 0.95 | Non-TCS | Non-TCS | Product assessment |
| Above 0.95 | Non-TCS | Product assessment | Product assessment |
Table B, for foods not heat-treated, or heat-treated but not packaged:
| Water activity | pH below 4.2 | pH 4.2 to 4.6 | pH above 4.6 to 5.0 | pH above 5.0 |
|---|---|---|---|---|
| Below 0.88 | Non-TCS | Non-TCS | Non-TCS | Non-TCS |
| 0.88 to 0.90 | Non-TCS | Non-TCS | Non-TCS | Product assessment |
| Above 0.90 to 0.92 | Non-TCS | Non-TCS | Product assessment | Product assessment |
| Above 0.92 | Non-TCS | Product assessment | Product assessment | Product assessment |
An example: a home baker's six products
Prairie Hearth Bread, a made-up home micro bakery in Fargo, North Dakota, I use in these examples, sells under its state's cottage food law and checks what it can make at home:
| Product | Listed group? | pH | Water activity | Table | What it is |
|---|---|---|---|---|---|
| Sourdough loaf, baked and bagged | Cooked plant food | 4.2 | 0.95 | A | Non-TCS |
| Apple pie, baked and boxed | Cooked plant food | 3.6 | 0.96 | A | Non-TCS |
| Focaccia with fresh cut tomatoes | Cut tomatoes | TCS | |||
| Pumpkin pie (eggs and milk) | Cooked animal food | TCS | |||
| Garlic-herb dipping oil with fresh garlic | Garlic in oil | TCS | |||
| Cinnamon rolls with cream cheese frosting | 5.8 | 0.91 | B | Product assessment, so TCS unless shown otherwise |
The sourdough and apple pie are cooked plant foods, but their pH and water activity put them in non-TCS cells, so they can be made at home. The focaccia's fresh tomatoes, the pumpkin pie's custard and the garlic oil are TCS by their groups. The cinnamon rolls land in a product assessment cell; Prairie Hearth switched to a powdered sugar glaze rather than pay for an assessment. How cottage food businesses start is in how to start a cottage food business, Hawaiʻi's version of the rule in Hawaii cottage food law, and the records a home kitchen keeps in cottage food record keeping.
Get the checker
Download the TCS food checker. One sheet: one line for each product, with the listed group it belongs to, whether it's heat-treated and then packaged, and its pH and water activity if measured, where the table that applies, what the table says and what the product is fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
A pH and water activity reading describes one batch. The next batch with a little more butter, or baked a few minutes less, can read differently, and a home baker selling non-TCS food has to be able to show the recipe and the readings haven't drifted into a TCS cell.
How TaroStack does it
TaroStack keeps each batch's pH and water activity on its batch record.
Readings on the batch record. Fields of your own on the batch record, numbers and initials, hold the pH and water activity readings for the batches you test, and printable batch-record forms carry them for the kitchen.
Recipes by version. Recipes are versioned, so the cinnamon roll with a glaze is a new version, and each batch records which version it was made from.
Dates and lots. Each batch gets a lot with its production and best-before dates, so a loaf's date is on the record, and each order records the lots each customer got.
| The job | Notebook | In TaroStack |
|---|---|---|
| pH and water activity | A notebook | Fields on the batch record |
| The recipe that was tested | Remembered | A recipe version on a date |
| A batch's date | Written on the bag | The batch's lot and dates |
Batches, batch records with fields of your own, versioned recipes and lots 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.