Does my sauce or salsa need a scheduled process?
If you add acid — vinegar, lemon, citric acid — to a low-acid food, and the finished product settles at an equilibrium pH of 4.6 or below with a water activity above 0.85, it is an acidified food. That means registering the establishment, having a qualified process authority establish a scheduled process, and filing that process with the FDA. There is no exemption for being small.
The definition is narrower than 'anything with vinegar'
An acidified food is a low-acid food that has had acid or acid foods added to it, ending at a finished equilibrium pH of 4.6 or below and a water activity greater than 0.85. All three parts matter.
Equilibrium pH is the pH after everything has settled and mixed, not the reading you take a minute after stirring in the vinegar. Water activity above 0.85 is what separates a salsa from something shelf-stable by dryness, like a spice blend.
Salsas, pickled vegetables, many hot sauces, marinated products and dressings routinely land inside this definition. A naturally acidic product that was always below 4.6 on its own is a different category, and so is anything genuinely low-moisture.
What being acidified actually requires
Three things, and they are separate from ordinary facility registration:
- Register the establishment as an acidified foods processor, which gives you an FCE number
- Have a scheduled process established by a qualified person with training and experience in acidified foods — the process authority
- File that scheduled process with the FDA for each food and each container size, which returns a submission identifier
There is no small-producer exemption
This is the part that surprises people, and it is worth being blunt about. Commercial processors of acidified foods are subject to these requirements regardless of size. A two-person operation making salsa in a rented kitchen is in the same regulatory category as a national brand.
The scale of the obligation differs — your scheduled process is simpler and your paperwork is thinner — but the obligation itself does not go away because the business is small.
What a process authority does, and what it costs you in time
A process authority is a qualified person, usually at a university food science extension or a private lab, who reviews your formulation and process and establishes the parameters that make it safe: the acid level, the timing, the fill temperature, the critical factors you then have to hold every batch.
Practically, you send them your formulation and process, they come back with a letter, and that letter is what you file and what an inspector asks to see. Budget weeks rather than days, and expect to be asked for pH readings on a real batch made the way you actually make it.
Why changing the recipe later is expensive
The scheduled process is tied to the formulation it was written for. Materially change the acid level, the ratio, the container or the process and the scheduled process may no longer cover you, which means going back to the process authority.
This is the practical argument for locking your formula before you scale, not after. It is cheaper to settle the recipe and then get it validated once.
Common questions
Check this yourself
This is general information for U.S. food businesses, not legal advice, and rules change. Check it against the sources below and against your own state's rules before you rely on it.