What a BBQ sauce label must show
| Label part | Where it goes | BBQ sauce detail |
|---|---|---|
| Product name | Front | "Barbecue sauce" or "BBQ sauce", with your style in front of it: "Carolina vinegar BBQ sauce" |
| Net quantity | Front, bottom 30% | Thick sauce by weight (NET WT), a thin sauce that pours like water in fl oz. Always with the metric amount |
| Nutrition Facts | Front or information panel | Per 2 tablespoons, the reference amount for barbecue sauce |
| Ingredient list | Front or information panel | Heaviest first, with the ingredients of ketchup, mustard or Worcestershire in parentheses |
| Allergens | Next to the ingredients | A Contains line, or the allergen named in the list itself |
| Name and address | Front or information panel | City, state and ZIP. "Distributed by" or "Manufactured for" if a co-packer makes it |
| Lot code | On the bottle or label | Required for shelf-stable acidified sauces (see below) |
Is your BBQ sauce an acidified food?
FDA defines an acidified food as a low-acid food with acid or acid foods added, a water activity above 0.85 and a finished equilibrium pH of 4.6 or below. Onions, garlic and peppers are low-acid. Vinegar is the acid. So the question is not the name on the bottle but what is in it and where it ends up on the pH meter.
| What the sauce is | What the rule says |
|---|---|
| Low-acid ingredients like onions or peppers brought to pH 4.6 or below with vinegar, sold from a shelf | Acidified food: 21 CFR 114 and 108.25 apply |
| An acid condiment sauce with only small amounts of low-acid ingredients, and a final pH close to that of its main acid ingredient | Excluded from Part 114 |
| Tomatoes and tomato products with a pH below 4.7 | Not classed as low-acid foods |
| Stored, shipped and sold under refrigeration | Excluded from Part 114 |
| Processed under continuous USDA meat or poultry inspection | FDA's acidified food registration rule does not apply |
Many BBQ sauces sit between the first two rows: a tomato and vinegar base with onion, garlic or chiles stirred in. Which side yours lands on depends on the recipe and the finished pH. A process authority can test it and set your scheduled process, the written process FDA expects for a shelf-stable acidified food.
What a shelf-stable acidified BBQ sauce adds
- Register your plant with FDA on Form FDA 2541 within 10 days of first making acidified foods
- File the process on Form FDA 2541e for each sauce in each container size, within 60 days of registering and before you pack a new product. A 12 oz bottle and a gallon jug of the same sauce are two filings
- Reach a finished pH of 4.6 or below and make the sauce exactly as the scheduled process says
- Work under the supervision of someone who completed an FDA-approved course in acidification and pH control
- Keep processing, pH and distribution records for 3 years
- Mark every bottle with a lot code
The lot code is the one part of these rules shoppers can see. It must be permanently visible and tell you, in code, the plant, the product, and the year, day and period it was packed. If you cannot emboss or ink the bottle, you may perforate or mark the label, as long as the label is stuck on securely. Change the period part often enough to trace a lot: every 4 to 5 hours, at each shift change, or per batch within one shift.
Example: Carolina vinegar BBQ sauce, 16 fl oz
A thin vinegar mop sauce pours like water, so it is a liquid and its net quantity goes in fluid ounces: 16 FL OZ (473 mL). The serving is 2 tablespoons, the reference amount for barbecue sauce, declared in milliliters because the sauce is a liquid: 2 Tbsp (30mL).
Ingredients: Apple cider vinegar, ketchup (tomato concentrate, distilled vinegar, high fructose corn syrup, corn syrup, salt, spice, onion powder, natural flavoring), brown sugar, salt, red pepper, black pepper.
- No Contains line: none of the 9 major allergens is in this recipe. Mustard is not on the US list either, so a mustard-based sauce needs no Contains line for it
- Ketchup keeps its own ingredients in parentheses, which is how the corn syrup shows up on your label
- Sodium is the big number: 410 mg, 18% of the Daily Value per 2 tbsp
- Brown sugar and the corn syrups in the ketchup count as added sugars: 2g
Naming your sauce: honey, bourbon, hickory
- Put a flavor on the front, like "Honey" or "Bourbon", and it becomes the characterizing flavor. It must stand next to the product name in letters at least half as tall
- Real honey in the bottle? "Honey BBQ sauce" works. If there is too little honey to carry the taste and a natural honey flavor does the work, the name becomes "honey flavored BBQ sauce", optionally "natural honey flavored"
- An artificial flavor that imitates the named flavor adds "artificial" or "artificially flavored" to it
- Artificial smoke flavor has its own rule: the label may not suggest the sauce was smoked
When a BBQ sauce maker can skip Nutrition Facts
| Exemption | Who qualifies | The catch |
|---|---|---|
| Small retailer | You sell straight to consumers, with sales to consumers of $500,000 or less a year, or food sales to consumers of $50,000 or less | No nutrition claims or nutrition information anywhere |
| Low volume | Fewer than 100 full-time equivalent employees and fewer than 100,000 units of that sauce sold in the US in 12 months | File a notice with FDA, unless you have fewer than 10 employees, sell fewer than 10,000 units and do not import |
| Tiny package | Sample or gift-set bottles with less than 12 square inches of total label surface | Print an address or phone number where buyers can get the nutrition information |
FDA counts units per product, not per bottle size: the same sauce under the same brand and name, made the same way, adds up across every size you sell. And skipping Nutrition Facts is all these exemptions do. Name, net quantity, ingredients, allergens and address stay on the bottle, and so do the acidified food rules.