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Homemade Drinks

Beverages in Arkansas

The Food Freedom Act covers more than just food — homemade drink products that don't require refrigeration are also eligible. Here's the full breakdown by category, including alcohol thresholds and bottling requirements.

What's Covered

Beverage Categories Under the Food Freedom Act

The Arkansas Food Freedom Act (Ark. Code § 20-57-504) allows the sale of homemade "food or drink products" that are non-TCS — meaning they don't require time or temperature control for safety. For beverages, this means shelf-stable drinks that won't support bacterial growth at room temperature. Acidified and fermented beverages can qualify, but they must meet specific pH requirements and record-keeping standards.

Here's how each beverage category breaks down:

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Kombucha
Restricted

Kombucha is a fermented tea that naturally produces small amounts of alcohol during fermentation. It can be sold under the Food Freedom Act, but you must manage two critical thresholds: pH and alcohol content.

pH requirement: Final product must achieve pH 4.6 or below. Kombucha typically ferments to pH 2.5–3.5, so most recipes naturally meet this threshold. Test every batch.
Alcohol threshold: If your kombucha exceeds 0.5% ABV, it is legally classified as an alcoholic beverage and triggers federal TTB (Alcohol and Tobacco Tax and Trade Bureau) regulation and state alcohol licensing. Keep fermentation time controlled and test ABV regularly.
Record-keeping: Maintain batch records with recipe, batch number, production date, pH results, and testing method. Label each bottle with a unique batch number.
Shelf stability: Kombucha must be shelf-stable (non-TCS) to qualify. If your product requires refrigeration to prevent continued fermentation or maintain safety, it may not qualify under the Food Freedom Act.
Cold Brew Coffee & Tea Concentrates
Restricted

Cold brew coffee and tea present a classification challenge. While the dry ingredients (roasted coffee beans, tea leaves) are clearly non-TCS, the brewed liquid product may require temperature control depending on its composition and pH.

Black coffee/tea concentrates: High acidity (low pH) and no added dairy or sweeteners may qualify as non-TCS. pH testing is essential — coffee typically ranges 4.85–5.10 pH, which is above the 4.6 threshold for acidified foods.
With dairy or sweeteners: Adding milk, cream, sugar, or flavoring syrups likely makes the product TCS and disqualifies it from the Food Freedom Act.
Recommendation: Contact your local ADH health unit to confirm whether your specific cold brew recipe qualifies as non-TCS before selling.
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Acidified Beverages — Shrubs, Switchels & Drinking Vinegars
Restricted

Vinegar-based drinking products — shrubs (fruit-vinegar syrups), switchels, and flavored drinking vinegars — are natural fits for the Food Freedom Act because their high acidity makes them inherently shelf-stable.

pH requirement: Must test at or below pH 4.6. Most vinegar-based drinks easily meet this — apple cider vinegar alone is typically pH 2.5–3.0.
Record-keeping: Same acidified food requirements apply — batch number on label, production records with pH test results for each batch.

These products are growing in popularity at farmers markets and in specialty retail. Their naturally low pH and long shelf life make them excellent candidates for the Food Freedom Act pathway.

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Lemonade, Fruit Drinks & Specialty Waters
Restricted

Beverages made with fresh fruit juice, water, and sweeteners occupy a tricky middle ground. Their eligibility depends entirely on whether the finished product is TCS or non-TCS.

Fresh-squeezed juice: Unpasteurized fresh juice is generally considered TCS because it supports microbial growth. It likely does not qualify under the Food Freedom Act without acidification or pasteurization.
Acidified lemonade or fruit drinks: If the product is acidified to pH 4.6 or below and is shelf-stable without refrigeration, it may qualify. Test each batch and maintain records.
Flavored waters with herbs or fruit: Water infused with cut fruit is likely TCS. Dry herb-infused products may be non-TCS. Verify with your local health unit.
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Honey-Based & Syrup-Based Drinks
Open

Pure honey, maple syrup, and sorghum syrup are explicitly covered by the Food Freedom Act. Drink products or syrups made from these base ingredients — with only non-TCS flavorings added — are allowed for sale.

Honey-based syrups, flavored sorghum, and maple-based drink concentrates that remain shelf-stable at room temperature are strong candidates. However, if you add water, dairy, or other TCS ingredients to create a ready-to-drink beverage, the product may become TCS. Keep the base ingredient shelf-stable and let the customer add water or milk at home.

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Fresh Juice (Unpasteurized)
Prohibited under Food Freedom Act

Unpasteurized fresh fruit and vegetable juices are generally classified as TCS foods because they provide an ideal environment for microbial growth. Fresh juice requires refrigeration and poses significant food safety risks without pasteurization or high-pressure processing.

Not covered by the Food Freedom Act. To sell fresh juice, you would need an ADH-permitted facility and likely FDA juice HACCP compliance.
Alternative: Consider making shelf-stable, acidified fruit drink concentrates or shrubs instead — these can qualify under the Food Freedom Act with proper pH management.

Alcohol — A Separate Regulatory World

The Food Freedom Act Does Not Cover Alcoholic Beverages

Producing and selling alcoholic beverages — including beer, wine, spirits, hard cider, mead, and hard kombucha above 0.5% ABV — requires entirely separate licensing at the federal, state, and often local level. This is true regardless of the Food Freedom Act.

At the federal level, the Alcohol and Tobacco Tax and Trade Bureau (TTB) regulates all alcoholic beverage production. You need a federal Brewer's Notice (beer), Winery Permit (wine/mead/cider), or Distilled Spirits Permit (spirits) before producing any alcoholic beverage for sale.

At the state level, the Arkansas Alcoholic Beverage Control Division (ABC) issues manufacturer permits for breweries, wineries, and distilleries. Fees, zoning requirements, and production limits vary by permit type.

The 0.5% ABV Threshold

The critical number for home beverage sellers is 0.5% ABV (alcohol by volume). Any beverage that stays below this threshold is not legally classified as alcoholic and can be sold under the Food Freedom Act (assuming it meets all other non-TCS requirements). This matters most for kombucha and naturally fermented beverages where small amounts of alcohol are a natural byproduct of fermentation.

If your fermented beverage creeps above 0.5% ABV — even unintentionally — it becomes a regulated alcoholic beverage. Techniques to manage this include shortening fermentation time, controlling temperature, pasteurizing to halt fermentation, and testing each batch with a hydrometer or alcohol testing kit.

Do not guess on alcohol content. Fermentation is variable — a batch that tested at 0.4% ABV one week might reach 0.8% the next week if conditions change. Invest in reliable ABV testing equipment and test every batch before sale. The legal and financial consequences of unknowingly selling an unregulated alcoholic beverage are serious.

Packaging

Bottling and Packaging Requirements

The Food Freedom Act doesn't prescribe specific packaging standards for beverages, but practical food safety and labeling compliance require thoughtful packaging choices. Here's a checklist for home beverage producers:

Sourcing bottles: Food-grade glass bottles with swing-top or screw-cap closures are available from restaurant supply stores, online homebrew retailers, and wholesale packaging suppliers. Buying in bulk (cases of 24–48) significantly reduces per-unit cost. Many Arkansas homebrew supply shops carry appropriate options.

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