# Bottling and packaging requirements for spice blends



## brandeeno (Nov 14, 2016)

Hello,

I have been an avid cook for some 15 years. I have always been making my own spice blends to use as meat rubs and for various cooking uses. Recently, I decided to give it a go at selling my products.  I purchased over a hundred bottles, lids, seals, made labels, and created new repeatable formulas for my blends. Each blend contains about 10 different dry spices (cumin, various chilies powders, turmeric, mustard, nutmeg, etc...) . I purchased about 30 pounds of spices and did the blending in my home kitchen.

I put this all together and sold two different blends at a private event, where I was given a table to sell to 200 people attending a party. I sold about 70 bottles. This helped me prove my packaging looked good and spices smelled good. Now I will await any feedback on the product once people get to cook with it. 

I hope to now sell at some farmers markets and other places where I can buy a table and prove the viability of my product. I plan to cook with the spice on site and give out samples this time (the prior event was just smelling it). The next goal after that will be getting the product onto shelves are various food stores. 

Down to my question: I am confused on requirements to make/blend the spices and packing requirements. I am having trouble parsing through the pages of FDA documents.  Which brings me to some questions.

1. Am I required to make the spice blend in a certified kitchen?

2. What about bottling? Is that ok that I am doing that in my kitchen?

3. Do I need a nutritional label considering these are spices?

4. Do I need to state my ingredients? again, considering these are spices.  I often see professionally produced products list some spices then say "and other spices".

5. Do I need to list out the weight?

All feedback and help is appreciated, but I would like to note.... that I believe these answers differ to me versus other food products because 1) I am doing this in small batches and 2) they are spices, which falls under special category since its not "food".  If I am wrong, let me know. I am all ears. 

I will certainly do my own due diligence, but looking forward to your help and guidance on the above.

Thanks!


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## someday (Aug 15, 2003)

I think a lot depends on where you live. Some places require you to make things in an inspected facility, some don't. You should be able to find that info pretty easily. You didn't say where you live so I don't know. 

You should get your business registered and licensed. Sometimes you need 2 licenses. I don't know if you need a resale license either but you should check. Some states have "homesteading" laws, which I'm not sure if this qualifies but you should check. 

I have no idea if you need nutrition or ingredient information. It is probably exempt but I really have no idea. That info has to be pretty easy to google though. 

You should consider allergen labeling, so if it has things like nuts, peanuts, gluten, etc. you should probably say that. Again, I'm not sure if you need to have ingredients listed. 

I would list the weight so that people know how much they are buying.


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## jimyra (Jun 23, 2015)

I would think doing this in a home kitchen is a bad idea and probably illegal. The way most do this is to work with a private label company. They manufacture and package the product to your specification. This is the first on a bing search. http://www.privatelabelfoods.com/ Find one to fit your needs.


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## millionsknives (Apr 25, 2014)

I don't think dry spices fall under 'potentially hazardous foods' category, but you should check with your local health department to be safe.

IMO it is a 'low-risk food' that would fall under cottage law (which not all municipalities have).  Again, check your local health department.


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## brandeeno (Nov 14, 2016)

There seems to be small business exemptions at the FDA level, for not having to follow the labeling requirements (nutrition, ingredients, etc...). 

I am in north NJ. I found some homesteading rules listed out, but they don't pertain to spice mixes.

I am very confused on the difference between federal regulations vs state.


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## jimyra (Jun 23, 2015)

What do you do when your spice grinder chips and a splinter of metal gets in your spice mix?  You get sued for millions and have no insurance.


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## brandeeno (Nov 14, 2016)

Thanks for pointing that out Jimyra, but not clear how that relates to my questions. I can think of dozens of issues arising from the product I sell that could negatively impact my customers... and if i were to focus on all things, I don't think I would ever be able to get a business going. I am looking for some help on what I am legally responsible for at the bare minimum, in order to help get my business up and running. 

If and when I am so lucky to be selling more than a few hundred bottles of product, I will step up my game to go further than the bare minimum, have insurance, and avoid grinder chips


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## jimyra (Jun 23, 2015)

Providing a safe properly produced product for human consumption is minimum required. I have provided a link for the requirements in Alabama. I do not know about your state. http://www.aces.edu/pubs/docs/F/FCS-2058/FCS-2058-low.pdf We are not lawyers here so if I were you maybe you should consult one to find out your minimum legal requirements.


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## flipflopgirl (Jun 27, 2012)

brandeeno said:


> I am looking for some help on what I am legally responsible for at the bare minimum.


Some spices (esp those imported from places not so concerned with food safety) can be iffy (see a bug? spray with DDT of course) is that mold (nah...you worry to much mimi)....

Talk to an attorney who is familiar with the FDA regs.

Someone you can count on to have your back if (God forbid) something untoward occurs and you get sued.

Don't know where you are located but here is the FDA site http://www.fda.gov/default.htm .

Good place to start when you are bottling a product with many ingredients.

Lots of links leading to answers for the things you don't know you need to know.

Same for your state and county and city....

Take your time...do your due diligence and plug into your biz plan.

Cottage laws are great tools to get your baby off the ground, tweak where needed and hopefully capture the American Dream.

mimi


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## cronker (Mar 3, 2016)

Good luck with your new project!
I have a friend who has been very successful in the game, and her cottage industry is now highly regarded.
As others have mentioned, you need to look into your state laws for a start, but also look at federal law later on if you wish to expand.


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## jay lancaster (Aug 26, 2016)

State law is what's important to you.  Federal regulations come in to play typically if/when you decide to cross state lines.  Consult your local health department...they are there to help, not hinder.


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## flipflopgirl (Jun 27, 2012)

Unless you will be importing, mixing and repackaging for domestic resale http://www.fda.gov/downloads/food/internationalinteragencycoordination/ucm344753.pdf .

mimi


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