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Arkansas Food Freedom Act

What You Can Sell in Arkansas

The Food Freedom Act allows a wide range of non-temperature-controlled foods and drinks. Here's the complete breakdown of what's open, what has conditions, and what requires a separate license.

Product Status

Arkansas Food Product Guide

Under the Food Freedom Act (Ark. Code § 20-57-504), you can sell any homemade food or drink product that does not require time or temperature control for safety — known as a "Non-TCS" product. Products fall into three categories:

Open
Allowed — No conditions
Breads & Rolls
All types including sourdough, bagels, tortillas, sweet breads
Cookies, Brownies & Bars
All shelf-stable varieties
Cakes & Cupcakes
No cream/custard fillings; buttercream & fondant fine
Pies (Fruit & Nut)
No cream, custard, or cheesecake pies
Muffins, Scones & Pastries
Doughnuts, pizzelles, cake pops, macarons
Candy & Confections
Fudge, brittles, pralines, toffee, truffles, chocolate
Jams, Jellies & Preserves
Made with real sugar and high-acid fruits
Fruit Butters
Made with real sugar (no sugar substitutes)
Chocolate-Covered Fruit
Fruit and berries must be uncut
Honey
Plain or flavored with non-TCS flavorings
Maple Syrup & Sorghum
With only non-TCS flavorings
Granola & Trail Mix
Including roasted nuts and dry snack mixes
Popcorn
All shelf-stable flavors and coatings
Dry Herbs & Spice Blends
Seasonings, tea blends, roasted coffee beans
Whole Uncut Fruits & Vegetables
Fresh, unprocessed — no cutting or slicing
Cotton Candy
Shelf-stable, no refrigeration needed
Pet Treats
Must meet same labeling requirements
Restricted
Allowed with conditions
Pickled Vegetables
Must achieve final equilibrium pH of 4.6 or below. Requires state-approved recipe, process authority verification, or batch pH testing with records.
Salsas & Hot Sauces
pH must be 4.6 or below. Same testing and record-keeping requirements as pickles.
Acidified Sauces & Condiments
Must meet pH 4.6 threshold. Unique batch number required on label. Maintain production records.
Fermented Beverages (Kombucha)
Must be non-TCS with pH requirements met. Alcohol content above 0.5% ABV triggers separate licensing.
Acidified Beverages
Must meet pH 4.6 threshold and be shelf-stable without refrigeration.
Confections with Alcohol
Allowed if the finished product is shelf-stable and non-TCS. Alcohol used as flavoring only.
Wedding Cakes & Custom Cakes
Allowed if fillings and frostings are non-TCS (no cream cheese, custard, or whipped cream fillings).
Eggs (Farmers Market)
Not under Food Freedom Act. Producers with fewer than 200 hens may sell ungraded eggs at farmers markets — must keep at 45°F or below. Separate provisions apply.
Prohibited
Not allowed under Food Freedom Act
Meat (All Types)
Requires USDA or state-inspected facility. See Special Categories.
Poultry
Requires USDA inspection and commercial processing.
Seafood
Requires ADH-permitted and inspected facility.
Dairy Products
Milk, cheese, cream, butter as standalone products. Dairy as an ingredient in baked goods is fine.
Cream & Custard Pies
Cheesecakes, cream pies, custard fillings — all TCS.
Cut Leafy Greens
TCS food — requires commercial kitchen and ADH permit.
Cut Tomatoes & Melons
Sliced or cut produce is classified as TCS.
Garlic-in-Oil Mixtures
Botulism risk — requires commercial processing.
Raw Seed Sprouts
Requires process authority verification and ADH-permitted facility.
Sugar-Free Jams & Baked Goods
Products made with sugar substitutes (e.g., Splenda) are considered potentially hazardous.
Home-Canned Low-Acid Foods
Canned vegetables not properly acidified to pH 4.6 — botulism risk.
Wild Game
Requires USDA or state inspection depending on species.
Why These Categories?

Understanding the Rules

The Food Freedom Act's core organizing principle is simple: if a food doesn't need refrigeration to remain safe, you can make and sell it from your home kitchen. The technical term is "non-time/temperature control for safety" (Non-TCS) — foods that won't grow harmful bacteria at room temperature.

Most baked goods, candies, jams, honey, dried goods, and properly acidified products fall cleanly into this category. The "restricted" column includes foods that can be non-TCS, but only if they meet specific pH requirements (4.6 or below) and you maintain proper testing records. This is because improperly acidified foods — particularly pickles, salsas, and fermented products — can harbor deadly botulism bacteria if the acid level isn't high enough.

The "prohibited" column includes TCS foods — meat, dairy, seafood, cut produce, and other items that require refrigeration. These aren't banned outright in Arkansas. You can absolutely sell them — you just need an Arkansas Department of Health permit and a commercial kitchen that passes ADH inspection. The Special Categories page covers these alternative licensing paths.

Important: The Arkansas Department of Health can still investigate any homemade food product for adulteration or misbranding — even products covered by the Food Freedom Act. The ADH can request product samples for testing at any time. Always use safe, tested recipes and keep thorough records.

Acidified Foods — Extra Requirements

If you sell pickles, hot sauce, salsa, fermented beverages, or any acidified food product, the Food Freedom Act requires you to take additional steps beyond basic labeling. Your product must achieve a final equilibrium pH of 4.6 or below, verified through one of three methods: using a state-approved or tested recipe, working with a process authority to validate your recipe, or conducting batch-by-batch pH testing with a calibrated meter. You must also add a unique batch number to each label and maintain records that include the recipe used, batch number, production date, pH test results, and testing method. The University of Arkansas Extension and the National Center for Home Food Preservation both offer tested recipes and guidance.

A Note on Sugar Substitutes

Products made with sugar substitutes like Splenda, stevia, or other artificial sweeteners may seem similar to their sugar-based counterparts, but Arkansas considers them potentially hazardous. Sugar plays a critical food-safety role in jams, jellies, fruit butters, and many baked goods — it reduces water activity and inhibits bacterial growth. When sugar is replaced, that safety factor is removed, and the product may become a TCS food. If you want to sell sugar-free versions, contact the Arkansas Department of Health to learn what steps are needed.

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