Beverages in Washington, D.C.

All fruit and vegetable juices — fresh-pressed, cold-pressed, blended, or concentrated — are explicitly prohibited under DC's cottage food regulations. This includes fresh-squeezed lemonade, specialty lemonade, orange juice, apple juice, green juices, and any beverage whose primary ingredient is fruit or vegetable juice.

The FDA requires that unpasteurized juice sold to consumers carry a specific warning statement: "WARNING: This product has not been pasteurized and, therefore, may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems." Juice sold without this warning must be pasteurized under a HACCP plan filed with the FDA. Neither pathway is available under DC's cottage food framework.

Kombucha is not on DC's approved cottage food product list. This is a product that sits at the intersection of several regulatory concerns — and none of them resolve cleanly under cottage food rules.

Alcohol content: Kombucha is produced through live fermentation of sweetened tea by a SCOBY (symbiotic culture of bacteria and yeast). This fermentation naturally produces alcohol as a byproduct. Commercially sold kombucha is typically held below 0.5% ABV to qualify as a non-alcoholic beverage. Home fermentation makes precise alcohol control extremely difficult — batches can easily exceed 0.5% ABV, crossing into territory regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB) as an alcoholic beverage requiring a brewer's permit.

pH variability: Kombucha's pH must be consistently at or below 4.0 to be considered safe. Home production cannot reliably guarantee this without lab testing of every batch.

If you want to sell kombucha commercially, you need a licensed beverage manufacturing facility, a DC business license, and potentially a TTB permit if your product exceeds 0.5% ABV. See the Special Categories page for more on this path.

Cold brew coffee concentrate and ready-to-drink bottled coffee are TCS (Temperature Control for Safety) foods. Cold brew is produced by steeping coffee grounds in cold water for 12–24 hours, resulting in a beverage with water activity well above the 0.85 threshold that defines shelf-stable foods. Without refrigeration, cold brew can support bacterial growth — specifically, there is documented risk of Clostridium botulinum in cold brew concentrate stored without refrigeration or in sealed low-oxygen containers.

Cold brew is one of the fastest-growing craft beverage categories in the country, and DC has a vibrant coffee culture. But producing and selling cold brew legally requires a licensed beverage manufacturing facility with proper refrigeration, HACCP planning, and a DC food establishment license. Roasted coffee beans, however, are a completely different matter — see below.

Shrubs — also called drinking vinegars or switchels — are concentrated acidic syrups made from fruit, sugar, and vinegar, typically diluted with water or sparkling water before serving. Despite their artisan appeal, shrubs in bottled beverage form fall under the regulatory category of acidified foods.

Acidified foods must be produced in a facility registered with the FDA under 21 CFR Part 108 and must follow scheduled processes established and reviewed by a "Process Authority" — a food scientist qualified to certify that the product's acidification process consistently achieves a safe pH. This is a commercial food manufacturing requirement that is not compatible with home kitchen production under cottage food law.

Note: Plain vinegar (white, apple cider, balsamic, wine, or infused vinegars) sold as a condiment — not a diluted beverage — is allowed under DC's cottage food regulations. See the allowed category below.

Loose leaf tea, packaged tea bags, and dry herbal tea blends are fully permitted under DC's cottage food regulations. These are dry goods — they contain no free moisture that would support microbial growth and require no refrigeration. A seller can blend, package, and sell custom tea mixtures, herbal infusions, chai blends, and tisanes without any special beverage license.

The key distinction is the form: you are selling dry leaves and botanicals, not a brewed liquid beverage. Properly dried and packaged tea products have indefinite shelf stability and present no food safety risk that cottage food regulations are designed to address. Label your product with the full ingredient list, net weight, and your DC cottage food business ID number — and you're ready to sell.

Roasted coffee beans — whole bean or ground — are permitted under DC's cottage food regulations as a shelf-stable dry good. Coffee is shelf-stable once roasted: low moisture content prevents microbial growth, and properly packaged roasted coffee can be stored at room temperature for months. If you roast your own beans or source and package specialty blends, this is a viable cottage food product.

The distinction between coffee beans and cold brew is absolute: selling roasted beans is allowed; selling brewed liquid coffee in any bottled or cold form is not. You can sell a bag of your signature roast alongside a jar of your jam at a farmers market — that's a winning combination for DC's coffee-obsessed buyer community.

Sweet syrups (simple syrups, flavored syrups, honey syrups) and vinegars (plain or infused) are permitted as condiments under DC's cottage food regulations. These are listed on DC Health's approved product list. The key is that they are sold as shelf-stable condiments — not diluted into beverages for immediate consumption.

Syrups: Sugar-based simple syrups have high sugar content that acts as a natural preservative, keeping water activity low. Lavender simple syrup, vanilla syrup, flavored coffee syrups — all permitted as packaged shelf-stable products. Note that syrups containing fresh fruit purées or requiring refrigeration would be TCS and are not permitted.

Vinegars: Plain vinegars (apple cider, white, balsamic, wine vinegars) and infused vinegars (herb-infused, fruit-infused) are allowed as shelf-stable condiments. The natural acidity of vinegar (pH typically 2.5–3.5) makes these products inherently shelf-stable. Shrubs packaged and marketed as beverages to be diluted are a different category — prohibited as acidified beverages.