๐Ÿต Pennsylvania ยท Beverage Rules

Beverages in Pennsylvania

Pennsylvania is one of the few states that allows home food sellers to produce and sell craft beverages โ€” including kombucha, cold-pressed juice, shrubs, and specialty lemonade. Here's what's allowed, what's restricted, and where the line is.

โœ… Pennsylvania allows bottled beverages from home kitchens โ€” a significant advantage over most states, which prohibit non-alcoholic craft beverage production entirely under cottage food programs. Kombucha, cold brew, juices, shrubs, drinking vinegars, and specialty lemonade are all approvable under the Limited Food Establishment program, provided they pass required lab testing before your application is submitted.

โš ๏ธ Lab testing is required for all bottled beverages before your LFE application is submitted. Unlike baked goods or dry spice blends, beverages must be tested at an accredited lab to verify pH, water activity, and safety before PDA will approve your registration. Budget time and cost for this step โ€” it cannot be skipped.

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Kombucha
Restricted
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Specialty Lemonade
Restricted
๐Ÿซ™
Shrubs & Drinking Vinegars
Restricted
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Cold-Pressed Juice
Restricted
โ˜•
Cold Brew Coffee
Restricted
๐Ÿซš
Switchel & Tonics
Restricted
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Bottled Herbal Tea
Restricted
๐Ÿบ
Beer, Wine & Spirits
Prohibited

Beverage Rules in Detail

Every craft beverage category has its own set of requirements under Pennsylvania's LFE program. Read the conditions carefully โ€” lab testing timing, alcohol thresholds, and pasteurization rules all vary.

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Kombucha
Fermented tea beverage โ€” non-alcoholic threshold required
Restricted

Kombucha is allowed under Pennsylvania's LFE program โ€” a significant distinction from most states, which prohibit fermented beverages from home kitchens entirely. The critical requirement is keeping alcohol content below 0.5% ABV (alcohol by volume) at all times. Above that threshold, kombucha is legally classified as an alcoholic beverage and requires a separate liquor license, which cannot be obtained for a home kitchen.

The fermentation process makes alcohol content variable and difficult to control, especially in warm weather or when a batch continues fermenting after bottling. This is the primary compliance risk for kombucha producers. Testing each batch โ€” and managing fermentation time, temperature, and sugar levels carefully โ€” is essential to staying below 0.5% ABV consistently.

Requirements to sell kombucha in Pennsylvania
  • Lab testing required before LFE application submission โ€” pH and safety testing
  • Alcohol content must stay below 0.5% ABV โ€” test batches regularly [VERIFY required testing frequency with PDA]
  • Document your SCOBY source, brewing process, sugar content, and fermentation timeline
  • Batch pH monitoring required โ€” log production date, batch number, pH reading
  • Proper sealing and labeling required on all bottles
  • Contact PDA at RA-FoodSafety@pa.gov to confirm current kombucha-specific requirements before applying
Kombucha Alcohol Content โ€” Where the Lines Are
0.5% ABV 3.5% ABV
LFE Allowed Zone
<0.5% ABV
Gray Area
0.5โ€“3.5%
Requires Liquor License
>0.5% ABV
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Juices & Cold-Pressed Drinks
Fresh and processed fruit and vegetable juices
Restricted

Pennsylvania allows bottled juices and cold-pressed drinks under the LFE program, but these products carry specific safety requirements rooted in federal FDA rules. Fresh, unpasteurized juices have been associated with foodborne illness outbreaks from pathogens like E. coli and Salmonella โ€” particularly in apple cider and cold-pressed vegetable blends. Pennsylvania follows federal FDA guidance on juice safety.

Shelf-stable juices that have been pasteurized or treated with an alternative pathogen reduction step (such as high-pressure processing) are the safest path under the LFE program. Unpasteurized juices sold directly to consumers require a specific warning label. Selling unpasteurized juice to any institution (restaurant, cafรฉ, retail store) is prohibited under federal FDA rules without pasteurization. [VERIFY current PDA requirements for juice processing at the home kitchen level]

Requirements to sell juice in Pennsylvania
  • Lab testing required before LFE application
  • If unpasteurized and sold direct-to-consumer: FDA-mandated warning label required ("WARNING: This product has not been pasteurized...")
  • If selling to retail or restaurants: pasteurization or equivalent pathogen reduction required
  • Document your production process, equipment, and packaging method
  • pH testing and batch logging required for acidified juice blends
  • Strongly recommended: contact PDA before producing to confirm your specific juice type and process are approvable
๐Ÿซ™
Shrubs & Drinking Vinegars
Vinegar-based fruit syrups, cocktail mixers, non-alcoholic
Restricted

Shrubs โ€” concentrated vinegar-based fruit syrups typically mixed with water or sparkling water โ€” are one of the most straightforward beverage categories for LFE producers in Pennsylvania. Because vinegar is the primary preservative and acidifier, properly made shrubs naturally achieve a low pH (usually well below 4.6) that makes them safely shelf-stable.

The key requirements are consistent with other acidified foods: lab testing before your application, documented formulas and procedures, and pH batch monitoring during production. The high acidity that makes shrubs safe is also what makes them shelf-stable โ€” a natural fit for the LFE program.

Requirements to sell shrubs in Pennsylvania
  • Lab testing required before application โ€” pH verification
  • Document recipes with precise vinegar ratios and fruit ratios
  • Batch pH monitoring required โ€” log production date, batch, pH reading
  • Label must include all required elements including ingredients and allergens
  • Shelf-stable storage and bottling required โ€” no refrigeration dependency
โ˜•
Cold Brew Coffee & Tea Concentrates
Bottled cold-steeped coffee and tea โ€” shelf-stable considerations
Restricted

Cold brew coffee and cold-steeped tea concentrates are possible products under Pennsylvania's LFE program, but they require careful attention to pH and water activity to confirm shelf stability. Unflavored cold brew coffee has a slightly acidic pH (typically 5.0โ€“6.0) โ€” above the 4.6 threshold โ€” meaning it is technically a low-acid beverage and may not be approvable as-is under the LFE framework without either refrigeration (making it TCS) or an alternative preservation method.

Acidified cold brew โ€” where the pH is brought below 4.6 through the addition of citric acid, phosphoric acid, or a similar acidulant โ€” may qualify as an acidified food under the LFE program with proper lab testing and documentation. This is a path used by some small-batch producers. Plain cold brew sold as a refrigerated TCS product is not approvable under a standard home kitchen LFE. [VERIFY specific cold brew requirements with PDA before investing in production equipment]

Cold brew path to LFE eligibility
  • Acidify product to bring final pH below 4.6 โ€” lab-verified before application
  • Document acidification process, ingredient ratios, and water source
  • Batch pH monitoring and logging required
  • Proper sealing (hermetic seal) required โ€” no open-pour style containers
  • Contact PDA before production to confirm your specific process is approvable
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Specialty Lemonade, Switchel & Craft Tonics
Artisan non-alcoholic fruit and herb beverages
Restricted

Specialty lemonades, switchel (an old-fashioned vinegar-ginger drink with deep Pennsylvania Dutch roots), and craft herbal tonics are natural fits for Pennsylvania's artisan food culture and the LFE program. These are typically high-acid products โ€” lemon juice, apple cider vinegar, and citrus are natural acidifiers โ€” that can achieve pH levels well below 4.6 when properly formulated.

As bottled beverages, they require lab testing before your application, pH documentation, and proper labeling. Carbonated versions follow the same rules with additional attention to bottle pressure and sealing integrity. These products pair well with the state's farmers market culture and the growing consumer interest in shrubs and switchel as mixer alternatives.

Requirements for lemonade, switchel, and tonics
  • Lab testing required โ€” pH and safety verification before application
  • Final pH must be verified to be below 4.6 for shelf stability
  • Carbonated versions: proper pressure-rated bottles required; document carbonation process
  • Batch pH monitoring and log required during production
  • Full label compliance required โ€” ingredients, allergens, net quantity, business name and address
๐Ÿซ–
Bottled Herbal Tea & Infusions
Pre-brewed, shelf-stable tea and herbal drink blends
Restricted

Shelf-stable bottled herbal teas and infusions โ€” products that are brewed, sealed, and shelf-stable without refrigeration โ€” are approvable under Pennsylvania's LFE program with lab testing. Note that plain dry tea leaves, loose leaf herbal blends, and tea mix packets are considered dry goods and are Open with no lab testing required. The bottled/brewed product is what requires the additional documentation.

The primary challenge with bottled teas is pH โ€” plain brewed tea has a pH of approximately 7.0 (neutral), well above the 4.6 threshold. To be shelf-stable without refrigeration, bottled tea must be either acidified (adding citric acid or lemon juice to bring pH below 4.6) or, more practically, sold in concentrated syrup form or as a dry product.

For bottled shelf-stable tea
  • Acidify the product OR confirm it qualifies as shelf-stable through lab testing
  • Lab testing required before application โ€” pH and water activity testing
  • Alternatively: sell as a dry loose-leaf or mix product (Open, no lab testing needed)
  • Document production process and ingredient sourcing
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Alcoholic Beverages โ€” Beer, Wine & Spirits
Requires separate state liquor licensing โ€” not covered under LFE
Prohibited Under LFE

Home production of beer, wine, mead, hard cider, and distilled spirits for commercial sale is not permitted under Pennsylvania's Limited Food Establishment program. These products are regulated by the Pennsylvania Liquor Control Board (PLCB), not the Department of Agriculture, and require entirely separate licensing โ€” including brewery, winery, or distillery permits.

Personal/home brewing of beer and wine for non-commercial household use is federally permitted in limited quantities and is not the subject of LFE oversight. But the moment you sell any alcoholic beverage, even at a farmers market, you need PLCB licensing. This is a firm regulatory boundary that cannot be navigated through the LFE framework.

For sellers interested in alcohol production
  • Contact the Pennsylvania Liquor Control Board: lcb.pa.gov
  • Review PLCB licensing categories: Limited Winery, Limited Distillery, Brewery
  • Licensing requires a dedicated production facility โ€” home kitchens do not qualify for PLCB licensing
  • Hard kombucha (above 0.5% ABV) also requires PLCB licensing, not LFE registration

Bottling & Packaging Requirements

Proper bottling is not just about aesthetics โ€” it is part of your food safety documentation and a requirement of your LFE registration. Pennsylvania's PDA evaluates your packaging method during your initial inspection and may review it as part of your ongoing compliance. Here's what matters most.

Beverage Type Container Type Hermetic Seal Required Lab Testing Required pH Log Required
Kombucha (still) Glass or food-grade PET plastic Yes Yes โ€” before application Yes โ€” every batch
Kombucha (carbonated) Pressure-rated glass or PET only Yes โ€” pressure-rated Yes โ€” before application Yes โ€” every batch + ABV monitoring
Cold-pressed juice Food-grade glass or PET Yes Yes โ€” before application If acidified: Yes
Shrubs & drinking vinegars Glass preferred; food-grade plastic acceptable Yes Yes โ€” before application Yes โ€” every batch
Specialty lemonade / switchel Food-grade glass or PET Yes Yes โ€” before application Yes โ€” every batch
Bottled herbal tea (acidified) Food-grade glass or PET Yes Yes โ€” before application Yes โ€” every batch
Dry tea / herbal blend (loose) Any food-safe sealed packaging Not required Not required Not required

๐Ÿ“‹ Hermetic seal defined: A hermetic (airtight) seal means the container is fully sealed to prevent any air, moisture, or contamination from entering. For beverages, this typically means a proper bottle cap (crown cap, screw cap, or swing-top stopper) that cannot be opened without visible evidence of tampering. This is reviewed during your PDA inspection and must be part of your plan review documentation.

โ„น๏ธ Carbonated beverages โ€” safety note: If you're producing carbonated kombucha, sparkling lemonade, or any effervescent beverage, use only pressure-rated bottles designed for carbonated liquids. Standard glass bottles and mason jars are not rated for carbonation pressure and can shatter โ€” a food safety and liability risk. This requirement is part of PDA's review of your packaging method.

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