To get a sauce onto grocery store shelves, you need four things: a plant that makes it legally, a label and barcode a retailer can scan and trust, the insurance and food safety audit a buyer asks for, and sales numbers that prove people buy it. For most shelf-stable sauces the legal part starts with one question: is your recipe an acidified food? If it is, FDA requires a scheduled process set by a qualified expert, a trained supervisor in the plant and an FDA filing before new product is packed.
Getting Sauce on Shelves at a Glance
- 4.6The pH line in FDA's rules: acidified foods must reach pH 4.6 or below and stay there21 CFR 114
- 60 daysOuter limit to file an acidified sauce's scheduled process after plant registration; it must be on file before any new product is packed21 CFR 108.25
- 9Major food allergens a U.S. label must declare, including sesame since January 1, 2023FDA
- $30One GS1 US barcode number (GTIN), one-time; a 10-item company prefix is $250 plus $50 a yearGS1 US
Key takeaways
- Chain retail means a commercial plant. Walmart, for one, says every product it sells must be made in a commercial food manufacturing or packing environment.
- Find out whether your sauce is an acid, acidified, low-acid or refrigerated food first. That one answer decides which FDA rules apply, from scheduled processes to retort canning.
- An acidified sauce needs a scheduled process set by a qualified person (often called a process authority), a supervisor trained at an FDA-approved school, FDA food facility (Form 3537) and canning establishment (Form 2541) registrations, and a process filing on Form 2541e.
- Grocery buyers want proof the plant passes a recognized food safety audit. Kroger and Target require GFSI certification for their own brands, and Walmart does too, allowing an alternative audit only by exception. For your own brand, expect an annual approved audit or a case-by-case request.
- Budget for the paperwork buyers check: a GS1 company prefix, a D-U-N-S number, product liability insurance and a label that meets 21 CFR 101.
Updated October 7, 2026. Checked against the eCFR (21 CFR parts 1, 101, 108, 113, 114 and 117), FDA's acidified food, labeling and allergen pages, GS1 US pricing, the published supplier requirements of Walmart, Kroger, Target and KeHE, and the GFSI and SQF program documents. This article is general information, not legal advice. State rules vary, so confirm current requirements with FDA, your state and your buyers.
What Are the Steps to Get a Sauce Into Grocery Stores?
Most sauce makers go through the same seven steps. The order matters: the type of food decides which rules apply, and the rules decide which plant can make it.
- 01Find out what kind of food your sauce isAcid, acidified, low-acid or refrigerated. A lab test and a process authority's review settle it. See the categories.
- 02Choose where it's madeA licensed shared kitchen you run yourself, or a co-packer that makes it for you. Compare the two.
- 03Get a scheduled processFor an acidified sauce, a qualified expert sets the pH, heat treatment and other critical factors. How it works.
- 04Register and fileThe plant registers with FDA, gets any state license and files the scheduled process for each product. The filings.
- 05Build a compliant label and get barcodesName, net quantity, ingredients, allergens, your name and address, Nutrition Facts (or an exemption) and a GS1 barcode. Label rules.
- 06Line up the business paperworkA legal entity, product liability insurance, a D-U-N-S number and the food safety audit a buyer asks for. What buyers ask for.
- 07Prove it sells, then pitchStart with local and independent stores, track units per store per week, then approach distributors and chain buyers. Getting placed.
Is Your Sauce an Acid, Acidified or Low-Acid Food?
Start here, because everything else depends on it. FDA sorts shelf-stable sauces by acidity (pH) and water activity, and each group has its own rules. The line matters because acidified foods carry a risk of botulism if they're processed wrong.[4] FDA doesn't class tomatoes and tomato products with a finished pH below 4.7 as low-acid foods, but that doesn't settle a tomato sauce with other ingredients: in a 2024 warning letter, FDA treated a marinara sauce as an acidified food.[2][5]
| Category | FDA definition | Typical sauces | Rules that apply |
|---|---|---|---|
| Acid food | A food with a natural pH of 4.6 or below.[1] | Condiment sauces and dressings made mainly from acid ingredients, with only small amounts of low-acid ingredients, whose pH stays close to the main acid ingredient's | Excluded from the acidified food rule (21 CFR 114). FDA's food plant rules (21 CFR 117) still apply. |
| Acidified food | A low-acid food with acid or acid foods added, a water activity above 0.85 and a finished pH of 4.6 or below.[1] | Many salsas, pepper sauces and other sauces built on low-acid ingredients such as peppers, onions or garlic, with vinegar or another acid added | 21 CFR 114 and 108.25: scheduled process, trained supervisor, plant registration and process filing. |
| Low-acid food | A finished pH above 4.6 and a water activity above 0.85.[2] | Cream, cheese and many vegetable sauces sold shelf-stable in jars, cans or pouches (meat sauces under USDA inspection follow FSIS rules instead) | 21 CFR 113: heat-processed to commercial sterility in a hermetically sealed container, usually in a retort. |
| Refrigerated food | Part 114 doesn't cover foods stored, distributed and sold under refrigeration.[1] | Fresh salsas, pestos and sauces sold in the chilled case | Not part 114. FDA's manufacturing rules (21 CFR 117) still apply, and unless the plant is a qualified facility, its food safety plan must control the hazards, including temperature.[3] |
Typical examples are illustrations, not determinations. A recipe's category depends on its ingredients, proportions and measured pH.[1][6]
The acid food exclusion is narrower than it looks. NC State's guide for sauce makers notes that naturally acid foods and certain dressings and sauces are exempt, but that a food mixing acid and low-acid ingredients generally falls under the acidified food rule. The exclusion only covers acid foods with small amounts of low-acid ingredients.[6] A tomato-based barbecue sauce, for example, might be an acid food or an acidified food depending on what else is in it, so don't classify it from the base ingredient alone.
FDA's own decision flow sends a few more products outside the acidified and low-acid canning rules: foods with a water activity of 0.85 or less, fermented foods with a finished pH of 4.6 or lower, and products made under USDA meat and poultry inspection. If you're unsure, FDA says you can ask it about a specific product.[10]
Can You Sell Sauce Under a Cottage Food Law?
Usually not for a grocery chain. Cottage food laws are state laws that let people make certain lower-risk foods at home, and each state draws the lines differently. FDA doesn't treat a private home as a facility for food facility registration, so your state is the main gatekeeper, though FDA's acidified food rules apply to any commercial processor.[17][18]
| State | Are sauces allowed? | Can you sell to stores? |
|---|---|---|
| Michigan | No. Sauces and condiments, including barbecue sauce, hot sauce, ketchup and mustard, are excluded, as are salsas and tomato sauces. The state notes that pickled and acidified foods pose a botulism risk. | No. Wholesale and consignment sales are prohibited, and products may be sold only within Michigan.[13] |
| Texas | Some. Since 2019, pickled and plant-based acidified canned goods have been allowed if the recipe comes from an approved source, is lab-tested or is approved by a process authority, or if every batch is pH-tested, and each label carries a batch number. Since September 1, 2025, most other foods are allowed too; meat products and low-acid canned goods are still excluded.[14] | Through registered cottage food vendors, who may sell to consumers in Texas at retail stores and other outlets.[15] |
| California | No. Only foods on the state's approved list qualify, and its only condiment category is vinegars and mustards. | Class B operations may also sell indirectly through restaurants and food markets, within 2026 sales limits of $177,756.[16] |
Checked October 7, 2026. Rules change; read your own state's current rules.
Even where a state allows home-made sauce, the products usually stay in-state, sales are capped, and big buyers expect commercial production. Use a cottage law to test recipes and gather early sales if your state allows it, and plan for a commercial plant before you pitch a chain.
Should You Use a Commercial Kitchen or a Co-Packer?
Home kitchens are out for chain retail. Walmart's supplier rules, for example, say every product it sells must be made in a commercial food manufacturing or packing environment.[27] That leaves two realistic options.
| Item | Commercial (shared) kitchen | Co-packer |
|---|---|---|
| What it is | A licensed shared-use kitchen you rent and produce in yourself | A contract manufacturer that makes your recipe in its own plant |
| Who runs production | You and your staff | The co-packer's staff, to your specification |
| Who holds the FDA registrations | Usually you, as the processor; confirm with the kitchen who holds the food facility registration | The co-packer's plant; ask to see its registration and the process filing for your product |
| Trained supervisor (acidified foods) | You or someone you employ must qualify | The co-packer's supervisor |
| Food safety certification | Not usually; you'd need your own audit if a buyer asks for one | Some hold SQF, BRCGS, FSSC 22000 or IFS; check the certificate covers sauces and is current |
| Minimums | Usually rent by the hour or shift | Minimum runs per batch, set by each co-packer |
| Your label | Your name and address as manufacturer | Your name and address with a qualifying phrase such as "Manufactured for" or "Distributed by"[19] |
A shared kitchen keeps you close to the product and costs little to start, but you take on every regulatory duty yourself. A co-packer brings an established plant, trained staff and often a certificate buyers already recognize, in exchange for minimum runs and less control.
What to check before you sign with a co-packer
- A current certificate you can verify. Look the plant up yourself: SQF's certified site directory and the FSSC 22000 public register are open to anyone, and the BRCGS Directory needs a free account.[20][21][22] Certificates expire, so check the status yourself rather than relying on a PDF; see the dangers of falsified food safety certificates.
- A scope that covers your product. In SQF Edition 9, food sector category 18 (preserved foods) names sauces, dressings and marinades, and category 15 covers low-acid sauces sterilized in sealed containers. No category names acidified foods, so check that the certificate's scope lists your type of product.[23]
- FDA registrations and a process filing for your sauce. For an acidified sauce, the plant's canning establishment registration and a scheduled process filed for your product and container size.[18][24]
- A current FDA food facility registration. 2026 is a renewal year, and FDA will treat registrations not renewed by December 31, 2026 as expired.[25]
- A supervisor trained at an approved school. Required for acidified food production.[26]
- Allergen, traceability and recall programs. Ask how the plant keeps allergens out of products that don't declare them, and how it would trace and recall a lot.
- A written agreement and agreed specifications. SQF requires certified sites to document finished product specifications approved by the site and its customer, covering limits, composition to meet label claims, labeling and storage.[23]
If you want your own look at a co-packer, you can commission a second-party supplier audit, which checks the plant against your own criteria. Kiwa ASI conducts supplier audits for food brands and retailers.[28]
What Is a Scheduled Process, and Who Sets It?
A scheduled process is the written set of conditions a plant must follow to make an acidified food safe, such as the maximum finished pH, the heat treatment and the other critical factors. FDA requires it to be established by a qualified person with expert knowledge of acidifying and processing acidified foods.[29][4] Part 114 calls this expert a "qualified person" and a "competent processing authority"; industry, state programs and FDA's own inspectors shorten that to "process authority," and the result usually comes as a letter.[1][8][9]
- What it controls. The plant must reach a finished equilibrium pH of 4.6 or lower within the time the scheduled process sets and keep it there in every finished container.[30]
- Who supervises. Production must run under a supervisor who completed a course in pH control and the critical factors of acidification at a school approved by the FDA Commissioner, commonly called Better Process Control School.[26][8]
- How pH is checked. The plant must test pH often and record the results. If the finished pH is above 4.0, it must be measured with a pH meter (a potentiometric method); at 4.0 or below, any suitable method may be used.[30]
- What happens when it goes wrong. If a batch misses the scheduled process or its finished pH is above 4.6, the plant must fully reprocess it, process it as a low-acid food, or set it aside for evaluation by a competent processing authority. Product that isn't shown to be safe must be reprocessed or destroyed, and if affected product has already shipped, the processor must promptly report it to FDA.[31][18]
- Codes, records and recalls. Every container needs a permanent code visible to the naked eye. The plant keeps processing, production and initial-distribution records for three years, and keeps written recall plans on file.[30][32][18]
University food programs and private labs provide the review. Cornell Food Venture Center, for example, says state and federal agencies recognize it as a processing authority. On October 7, 2026, it listed a scheduled process at $190 per product for businesses outside New York ($95 inside New York), plus a one-time client registration fee of $60 ($30), with a 4 to 6 week turnaround. It asks for a submission form and a 4 to 6 ounce sample, plus your co-packer's details if you use one.[7] NC State Extension offers product testing and an FDA-recognized acidified foods manufacturing school.[4]
FDA's compliance program for these foods lists failing to have a product evaluated by a process authority, and failing to file scheduled processes, as inspection findings.[9]
Which FDA Registrations and Filings Does a Sauce Need?
Several, and most belong to the plant that makes the sauce. Under FDA's general manufacturing rules, any food that relies mainly on pH to stop harmful microbes, such as an acidified sauce, must also be monitored and kept at pH 4.6 or below.[40]
| Filing | Who needs it | When |
|---|---|---|
| Food facility registration (Form 3537) | Plants that make, pack or hold food. Farms, retail food establishments, restaurants and private homes are exempt.[33][17] | Before the plant starts. Renew every even-numbered year between October 1 and December 31: registrations not renewed by December 31, 2026 expire. No fee.[34][25] |
| Food canning establishment registration (Form 2541) | Commercial processors of acidified and low-acid canned foods. Each plant gets an FCE number.[18][35] | No later than 10 days after the plant first processes these foods. In practice, register first: each process filing is tied to the plant's FCE number and must be on file before new product is packed.[18][35] |
| Process filing (Form 2541e for acidified foods) | The processor, for each acidified food in each container size. Each filing gets an SID number.[18][35] | Within 60 days after registration, and before packing any new product. Filing isn't FDA approval. (Low-acid canned sauces file under 21 CFR 108.35 on Form 2541d, 2541f or 2541g instead.)[18][36] |
| Preventive controls (21 CFR 117) | Registered facilities need a written food safety plan with a hazard analysis and preventive controls, prepared or overseen by a preventive controls qualified individual (PCQI), who can qualify through FDA-recognized training or job experience. Part 117 has no exemption for acidified foods. A very small business, averaging under $1,372,952 a year over 2023 to 2025 in human food sales plus the value of food held without sale, counting affiliates (FDA's current inflation-adjusted cut-off), is a qualified facility with modified requirements.[3][37][38] | Qualified facilities file an attestation (Form 3942a) before starting and again every two years in the same October to December window.[39][25] |
| State license or approval | Your state will likely also license or inspect the plant, usually through its agriculture or health department. In Oregon, for example, the facility must be inspected and approved before it makes acidified foods.[8][4] | Before production starts; check your state. |
If a co-packer makes your sauce, the canning registration, process filings and food safety plan are its job. FDA says distributors and brokers don't register as canning establishments or file processes, but they must make sure the processors they represent do.[41] Ask your co-packer for its FCE number and the SID of the filing for your product. If you hold inventory in your own warehouse, you may still need your own food facility registration and state license.[34]
What Must a Sauce Label and Barcode Show?
FDA doesn't pre-approve food labels, so getting it right is on you and your label designer.[45] A packaged sauce needs these elements:
| Label element | What the rule requires |
|---|---|
| Statement of identity | On the front (principal display) panel, in bold type: the standardized name if one exists (catsup and mayonnaise have one), otherwise the common or usual name.[43] |
| Net quantity | In the bottom 30% of the front panel, in both metric and U.S. units. Viscous sauces are declared by weight; thin liquids by fluid measure.[44][45] |
| Ingredient list | Every ingredient by its common or usual name, in descending order of predominance by weight, with limited exceptions such as "spices" and ingredients at 2% or less.[46] |
| Allergens | Any of the nine major allergens, declared in the ingredient list (for example "whey (milk)") or in a "Contains" statement next to it.[47] |
| Name and place of business | The manufacturer, packer or distributor, with street address, city, state and ZIP. If a co-packer makes it, qualify your name, for example "Manufactured for."[19] |
| Nutrition Facts | Required unless an exemption applies.[48] |
| Container code (acidified foods) | A permanent code on every container, visible to the naked eye, that ties it to the batch. Plan where it goes before you print.[30] |
Allergens deserve extra care in sauces. In FDA's review of 2009 to 2014 reports, dressings, including sauces and gravies, were among the five food types most often involved in allergen recalls.[47] ASI Training and Consulting, LLC, which operates separately from the certification body and has no effect on audit outcomes, offers allergen management training on these controls.[50]
Barcodes: get them from GS1
GS1 US says most retailers and marketplaces require GS1 barcodes, and its numbers identify your company as the brand owner.[51][52] A single GS1 US GTIN costs $30 once, with no renewal fee. A company prefix for up to 10 items costs $250 plus $50 a year, and one for 100 items costs $750 plus $150 a year.[52] Plan for the prefix if you're aiming at a big chain: Walmart requires a GS1 Company Prefix on its supplier application documents.[53]
What Do Grocery Buyers Ask Sauce Suppliers For?
Proof that the plant passes a recognized food safety audit, plus insurance and identifiers. Requirements often differ for private brand (the store's own label) and national brand (your label) products. Here is what some of the largest buyers publish:
| Buyer | Food safety audit | Insurance and IDs |
|---|---|---|
| Walmart (national brand) | An annual, approved food safety audit for every site that makes the product; GFSI certification encouraged. FDA, USDA, state or local inspections, ServSafe and audits done for other retailers aren't accepted.[27] | General liability $1M per occurrence / $2M aggregate; product liability $2M per occurrence / $4M aggregate for most foods (Category I(F)). Suppliers with no more than $1M a year in revenue (GMV) may be exempt from the product limits if they meet the lowest category. GS1 Company Prefix and D-U-N-S number.[54][53] |
| Walmart (private brand) | GFSI-recognized certification or, by exception, a Walmart alternative audit standard.[55] | As above |
| Kroger | Our Brands (private label): GFSI certification for each manufacturing plant. New vendors: HACCP or GFSI documents may be required depending on the product.[56][57] | General liability $3M per occurrence for product vendors; D-U-N-S number.[57] |
| Target | Owned brands: GFSI certification, required since 2009.[58] | Not stated on the page |
| KeHE (distributor) | An annual third-party audit of each facility by an accredited audit company KeHE approves.[59] | Commercial general liability of at least $2M per occurrence and in the aggregate.[59] |
Requirements change. Read each buyer's current supplier pages and your contract before you rely on them.
What GFSI certification is
The Global Food Safety Initiative (GFSI) doesn't certify anyone. It recognizes certification programs that meet its benchmarking requirements, and sites get a GFSI-recognized certificate by passing a third-party audit by an accredited certification body against one of those programs.[60] GFSI's current list includes the SQF Food Safety Code Edition 9, BRCGS Food Safety Issue 9, FSSC 22000 Version 6 and IFS Food version 8.[61] Newer editions are on the way: SQF says Edition 10 audits won't begin before January 2, 2027, and FSSC 22000 Version 7 was released on May 1, 2026, with Version 6 audits allowed until April 30, 2027.[62][63] For how the programs differ, see IFS vs. FSSC 22000 vs. BRCGS.
If a co-packer makes your sauce, buyers look at that plant's certificate, so you usually don't need your own. If you make it yourself, the plant is yours and so is the audit. For a closer look at one large retailer, see our guide to Walmart food supplier requirements.
How Do You Prove Your Sauce Will Sell?
Buyers add products that will sell, and your best evidence is your own sales history. Start where you can get on a shelf without a big program: farmers' markets, online, and local independent grocers. A new item takes shelf space from another product, so track your sales velocity, the units sold per store per week, and bring it to every buyer meeting.
- Distributors. Many retailers, especially independents and natural and specialty stores, buy new brands through distributors, and distributors have their own requirements. KeHE, for example, offers new, small suppliers (under $500,000) in their first year an opt-in 2% flat-rate program covering distribution fees such as new-item introduction allowances and setup fees, subject to approval.[64]
- Slotting allowances. The FTC defines these as one-time payments a supplier makes to a retailer for initial shelf placement or warehouse access. In its 2003 study of five product categories, including shelf-stable salad dressing, average allowances for all five combined ran from $2,313 to $21,768 per item, per retailer, per metro area, from a small sample. Retailers in the study said allowances help cover the cost and risk of new items, citing a failure rate of about 70%. The figures are old, so ask each buyer what applies today.[65]
- Sell sheet. One page with the product photo, case pack, wholesale price and lead times, and the plant's food safety certificate or audit result. Buyers commonly ask for the certificate and your certificate of insurance, so have both ready.
What Does It Cost, and How Long Does It Take?
There's no single price for getting a sauce to market. These are the line items, with published figures where they exist:
| Item | What we could confirm |
|---|---|
| FDA registrations and process filings | No FDA fee to register a food facility or renew it, and no fee to file an acidified food process.[25][8] |
| Scheduled process review | Varies by provider. Cornell Food Venture Center listed $190 per product for non-New York businesses ($95 in New York) plus a one-time $60 ($30) registration fee, 4 to 6 weeks, on October 7, 2026.[7] |
| GS1 barcodes | $30 per single GTIN, or $250 plus $50 a year for a 10-item company prefix.[52] |
| Nutrition Facts exemption notice | FDA lists no fee. File every year if you qualify (the smallest firms don't need to); FDA doesn't send reminders, and online notices go through FDA Industry Systems as of October 5, 2026.[49] |
| Insurance | Buyers set minimum limits, for example Walmart's $2M per occurrence product liability for most foods, with an exemption for suppliers with no more than $1M in revenue. Premiums depend on your insurer.[54] |
| Co-packer runs | Quoted by each co-packer: minimum batch, ingredients, packaging and per-unit fees. |
| Food safety certification | Paid by the certified plant; if a co-packer is certified, the cost is part of what it charges you. Buyers hold the supplier responsible, so if a buyer wants an audit your co-packer doesn't have, or runs its own facility audit, expect to pay for it.[27][56] |
| Slotting and distributor fees | Set by each retailer and distributor; see the FTC and KeHE examples above.[65][64] |
Timing has the same problem. The fixed steps are short: a few weeks for a process review, and FDA's registration and filing deadlines run in days, not months. Proving sales velocity and getting on a buyer's calendar take longer, and they vary by category and region. For planning ideas, see how to budget for food safety.
Where Does Kiwa ASI Fit In?
Kiwa ASI audits and certifies the plants that make sauces. Training is offered separately by ASI Training and Consulting, LLC (see below). Kiwa ASI doesn't set scheduled processes, act as a process authority, run Better Process Control School or test products.
- SQF certification. ASI Food Safety, LLC is licensed by SQFI and accredited by ANAB to ISO/IEC 17065 to deliver SQF certification audits, including the Food Manufacturing code, whose food sector category 18 includes sauces, dressings and marinades.[66][23]
- BRCGS and FSSC 22000. Kiwa ASI delivers BRCGS audits in the U.S. as a listed office of Kiwa Agri Food (UKAS) and Kiwa España (ENAC), and FSSC 22000 certificates are issued by a Kiwa group certification body licensed by Foundation FSSC.[67][68]
- A non-GFSI GMP audit. When a buyer or brand owner asks for a third-party food safety audit but not GFSI certification, Kiwa ASI's cGMP Food Processing standard is one option; confirm the buyer accepts it before you book. It's Kiwa ASI's own audit standard and isn't GFSI-benchmarked or accredited.[69]
- Supplier audits for brand owners. Second-party audits of your co-packer against your own criteria.[28]
- Training. HACCP (International HACCP Alliance accredited), PCQI and allergen management courses come from ASI Training and Consulting, LLC, which operates separately from the certification body; using it has no effect on audit outcomes.[70][71][50][66]
Frequently Asked Questions
Do I need a process authority letter to sell my sauce?
If your sauce is an acidified food, yes in practice. FDA requires a scheduled process established by a qualified person with expert knowledge of acidified foods, filed with FDA on Form 2541e before the product is packed. That expert is usually called a process authority, and the process usually comes as a letter. Acid foods and refrigerated sauces aren't covered by the acidified food rule, but a written classification from a process authority is your record of why, and FDA lets acid-food makers file a process voluntarily.
Is hot sauce or barbecue sauce an acidified food?
It depends on the recipe. A sauce built on low-acid ingredients such as peppers or onions with vinegar added is usually acidified, unless it's sold refrigerated or is a fermented sauce with a finished pH of 4.6 or lower. A condiment sauce made mainly from acid ingredients, with only small amounts of low-acid food and a pH close to its main acid ingredient, is excluded as an acid food. Plain tomato products below pH 4.7 aren't low-acid foods, but a tomato sauce with onions, garlic or other low-acid ingredients can still be acidified; FDA treated a marinara sauce that way in 2024. A pH test and a process authority's review settle it.
Can I sell homemade sauce in grocery stores under a cottage food law?
Rarely. Cottage food laws are set by each state. Michigan bans sauces and wholesale, California's approved list has no sauces or salsas, and Texas allows some acidified foods and sales through registered vendors in Texas. In the three states we checked, sales stay in-state or are capped, and chains expect commercial production.
Do I need my own GFSI certification if a co-packer makes my sauce?
Usually not. Buyers look at the certificate of the plant that makes the product, so a certified co-packer's certificate covers that plant. If you make the sauce in your own plant, the audit is yours.
Does FDA approve sauce recipes or labels?
No. FDA doesn't pre-approve food labels, and filing a scheduled process with FDA doesn't mean FDA approved it. FDA also doesn't issue registration certificates or recognize ones sold by private businesses.
Who files with FDA when a co-packer makes my sauce?
The co-packer, as the processor. Its plant holds the food facility and canning establishment registrations and files the scheduled process for your product. FDA says distributors and brokers don't file but must make sure the processors they represent do, so ask for the FCE number and the SID of your product's filing.
Do I need a Nutrition Facts label on a small-batch sauce?
Not always. FDA's low-volume exemption covers products from businesses with fewer than 100 full-time equivalent employees selling fewer than 100,000 units of the product a year in the U.S., with an annual notice to FDA. Businesses with fewer than 10 full-time equivalent employees selling fewer than 10,000 units, that don't import, don't file a notice. Any nutrition claim cancels the exemption.
How much does a UPC barcode cost for a sauce?
From GS1 US, a single GTIN costs $30 once, with no renewal fee. A company prefix for up to 10 items costs $250 plus $50 a year. Walmart requires suppliers to have a GS1 Company Prefix.
What insurance do grocery stores require from sauce suppliers?
It varies by buyer. Walmart asks for general liability of $1 million per occurrence and $2 million aggregate, and product liability of $2 million per occurrence and $4 million aggregate for most foods, with a possible exemption for suppliers with no more than $1 million in revenue. Kroger asks product vendors for $3 million in general liability per occurrence, and KeHE for at least $2 million in commercial general liability.
What is Better Process Control School, and who needs it?
It's the common name for the FDA-approved training that 21 CFR 114.10 requires. Acidified food production must run under a supervisor who attended a school approved by the FDA Commissioner and completed its course on pH control and critical factors. Several universities run the course. If a co-packer makes your sauce, its supervisor needs the training, not you.
Making sauce for your brand or someone else's?
ASI Food Safety, LLC certifies sauce plants and co-packers to SQF, Kiwa ASI delivers BRCGS and FSSC 22000 audits for Kiwa group certification bodies, and it certifies sites to its own cGMP Food Processing standard. Tell us about your site and the certificate your buyers ask for.
Questions? Email US.Info@kiwa-asi.com or call 1 (800) 477-0778.
Keep reading
- BlogWalmart Food Supplier RequirementsWhat Walmart asks of private brand, national brand and produce suppliers.
- BlogSQF Certification GuideHow SQF certification works, from scope to audit day.
- BlogFalsified Food Safety CertificatesWhy you should verify a supplier's certificate yourself.
- PageSQF CertificationSQF audits from ASI Food Safety, LLC, an SQFI-licensed certification body.
- PageSupplier AuditsSecond-party audits of your suppliers and co-packers against your criteria.
- TrainingAllergen Management TrainingFrom ASI Training and Consulting, LLC, which operates separately from the certification body and has no effect on audit outcomes.
Sources
- 21 CFR 114.3, definitions (acidified foods). eCFR, accessed October 7, 2026. ecfr.gov
- 21 CFR 113.3, definitions (thermally processed low-acid foods packaged in hermetically sealed containers). eCFR, accessed October 7, 2026. ecfr.gov
- 21 CFR part 117, current good manufacturing practice, hazard analysis, and risk-based preventive controls for human food (subparts A to C, including the exemptions in 117.5). eCFR, accessed October 7, 2026. ecfr.gov
- NC State Extension. Resources and Steps for Acidified Food Processors, accessed October 7, 2026. ncsu.edu
- FDA. Warning letter to F1 Foods, Inc. dba Flavor First Foods, Inc., MARCS-CMS 668515, March 14, 2024. fda.gov
- Rushing, J. Formulating Acidified Dressings and Sauces (FSE 99-21). NC State Extension. ncsu.edu (PDF)
- Cornell Food Venture Center. Services and fees, and Frequently Asked Questions, accessed October 7, 2026. cornell.edu cornell.edu
- Oregon Department of Agriculture, Food Safety Program. The Step by Step Guide to the Licensed Processing of Acidified Foods (revised February 18, 2025). oregon.gov (PDF)
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