Arizona's 2024 cottage food expansion opened the door to a wider range of food products — including certain beverages. Here's what's allowed, what's in a gray area, and what requires a separate license entirely.
Before the 2024 expansion, Arizona's cottage food program explicitly excluded beverages. The original pre-2024 list of prohibited items included "beverages" as a category. With the passage of HB 2042 on March 29, 2024, the law was significantly broadened to allow foods that are potentially hazardous or require time/temperature control — and the blanket beverage exclusion was removed from the new statute (A.R.S. §§ 36-931–933).
However, the Arizona Department of Health Services is still developing detailed rules consistent with the new law. This means the beverage landscape is evolving, and some categories remain in a gray area until ADHS finalizes its rulemaking. Here's what we know for each major beverage type.
Rules are still developing. ADHS was directed by HB 2042 to adopt rules consistent with the new statute. Some beverage categories may be further clarified or restricted once final rules are published. We recommend contacting ADHS directly at CottageFood@azdhs.gov or (602) 364-3118 before investing in beverage production.
Roasted coffee beans — whole or ground — are explicitly listed as an approved cottage food product in Arizona. These are shelf-stable and can be sold through all standard channels including online, at farmers markets, and in retail stores.
Dry tea blends and herbal tea mixes are shelf-stable products that fall comfortably within Arizona's cottage food program. Standard labeling and registration requirements apply. Sell them packaged for the customer to brew at home.
Cold brew coffee is a ready-to-drink TCS beverage that requires refrigeration. Under the 2024 expansion, TCS foods are now broadly permitted. Cold brew could potentially qualify as a cottage food product, but because beverages were historically excluded and ADHS is still finalizing its rules, sellers should confirm eligibility with ADHS before starting production.
Fresh-squeezed lemonade, agua fresca, and similar fruit-based beverages are TCS products requiring temperature control. With the 2024 expansion removing the blanket beverage exclusion, these may be permissible under the cottage food program. However, ADHS has not yet published specific guidance on ready-to-drink beverages. Contact ADHS before selling.
Fresh-pressed fruit and vegetable juices are TCS products. Unpasteurized juice may also trigger federal FDA requirements — the FDA's Juice HACCP regulation (21 CFR Part 120) applies to juice processors, though there are exemptions for direct-to-consumer retail sales. Sellers interested in juice should verify both state cottage food eligibility with ADHS and any applicable federal rules.
Shrubs (fruit-vinegar syrups) and drinking vinegars are typically shelf-stable due to their high acidity. As concentrates or syrups, they would likely fall within the cottage food program alongside other shelf-stable syrups and vinegars. However, if sold as a ready-to-drink diluted beverage, they may be classified differently. Confirm with ADHS for your specific product.
Kombucha sits in a unique gray area in Arizona. As a fermented tea, it naturally produces trace amounts of alcohol during fermentation. Arizona's cottage food program explicitly prohibits alcoholic beverages and foods containing alcohol intended to intoxicate. Kombucha that stays below 0.5% ABV is generally classified as non-alcoholic at the federal level — but whether ADHS considers it compliant under the cottage food program has not been specifically addressed.
If your kombucha consistently stays below the 0.5% ABV threshold, it may be possible to sell under the cottage food program — but this is not confirmed. If it exceeds 0.5% ABV, it would be classified as an alcoholic beverage and require a separate license. We strongly recommend contacting ADHS before producing kombucha for sale.
Alcoholic beverages and foods containing alcohol intended to intoxicate are explicitly prohibited under Arizona's cottage food program (A.R.S. § 36-931). This includes beer, wine, spirits, hard cider, hard seltzer, and any food product containing alcohol as an intoxicant.
If you want to produce and sell alcoholic beverages in Arizona, you need entirely separate licensing — a brewery, winery, distillery, or farm winery license issued by the Arizona Department of Liquor Licenses and Control. These operate under a completely different regulatory framework from cottage food.
See the Special Categories page for details on alcohol licensing paths.
If you sell beverages under Arizona's cottage food program, the same general packaging and labeling rules apply as for any other cottage food product. Here are the key requirements to keep in mind:
Beverages are one of the fastest-growing categories in the cottage food space nationally, and Arizona's broad 2024 expansion positions sellers well — but the regulatory picture is still filling in. Here's our practical guidance:
Roasted coffee beans and dried tea blends are clearly approved and shelf-stable. If you want to enter the beverage space with minimal regulatory uncertainty, these are the safest starting points. They don't require temperature control, can be sold through all channels, and carry straightforward labeling requirements.
For ready-to-drink beverages (cold brew, lemonade, juice, kombucha), contact ADHS before purchasing equipment or ingredients in bulk. A quick email to CottageFood@azdhs.gov with a description of your product and intended sales channels can save you time and money. ADHS staff are responsive and accustomed to these questions.
Syrups, shrub concentrates, and drink mixes that are shelf-stable may have a clearer regulatory path than ready-to-drink beverages. A shelf-stable product with the right pH and water activity (below 0.85 Aw and below 4.36 pH) avoids TCS handling requirements entirely and can be sold through all channels including retail stores and online shipping.
Full labeling details for beverages and all other cottage food products are covered on the Label Requirements page, including the exact Arizona disclaimer text you must include.
Enter your beverage type and ingredients to see what rules and conditions apply under Arizona's cottage food program.
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