How to Sell Raw Juice Through Other Retailers

Raw Juice Laws and Regulations

It's very important to understand that the US has official FDA guidelines regarding the distribution and sales of raw juice. By "raw" we specifically mean juice that hasn't been put through a process like HPP or heat pasteurization to extend the shelf life.

Basically, under FDA guidelines, it's only approved to sell raw juice direct to the end customer. It's not ok to sell it to another retailer that will resell it. So we're not allowed to sell raw juice wholesale to grocery markets, cafes, gyms, or other businesses that will resell it.

If you would like to read more in depth about the regulations, I recommend giving these articles a read:

• The Truth About HPP
• The Raw on Raw Juice
• Official FDA Guidance

But what about raw juice I see for sale in grocery stores?

If you see brands of "raw" juice for sale at grocery stores in the US, one of the following is true:

1. It's made in-house at the grocery store, or
2. It's not actually raw. Many HPP juice brands label the juice as raw. They are legally allowed to do this because there's no official definition (AKA standard of identity) for the term "raw" under the FDA. Even though it's legal, it's very misleading to customers who don't realize the juice was made over a month ago in many cases. In my opinion, they do this intentionally to confuse the customer. Read more about this in the link above to the HPP article.

How to Sell Raw Juice Through Other Retailers

What you're allowed to do is going to be based a lot on how your local health department interprets the FDA guidance. We recommend reaching out to your health department early and establishing communication so there are no surprises. Here are the various ways we've seen various health departments allow the distribution of raw juice:

• Some regions will actually allow reselling raw juice through retailers. Usually they will require that your business have a HACCP certified manager on staff, and also have an approved HACCP plan. Read more about HACCP plans below.
• Most regions will allow selling your juice at other retailers, as long as your business is collecting the money (see more below).
• Most regions will allow selling your juice in smart coolers that you place in other businesses (see more below).
• Some regions are very strict and will only allow selling the juice direct to customers at the place the juice is produced. It really just depends on their interpretation.

Collecting Payment at Other Businesses

Theoretically if you stock juice at another location (like a yoga studio for example), and the customer makes a purchase through a POS system that is tied directly to your business, you are still selling direct to the consumer. The important piece here is the money is going directly to your business, and not the 3rd party where the juice is stocked.

To be extra safe, you can also send a staff member to be there to sell the juice. This also adds the benefit of having a more educated staff member that can talk knowledgeably about the juice and answer customers questions about your products.

Using Smart Coolers (Vending Machines)

One growing trend has been utilizing branded refrigerators that handle all the sales using RFID chips and smart technology, in order to charge the customer for products they remove from the refrigerator. The most popular brand of these smart coolers is Byte Technologies brand.

Placing these coolers in strategic locations allows you to place your juice (and other grab and go items) in high traffic areas, without the need to have your staff there making sales.

As products are sold, you can view the data remotely to help keep track of sales and inventory at each location.

The costs for this business model include purchasing the smart coolers up front, then ongoing monthly fees for the service.

It's important to note that using technology like this can also come with challenges when there are technical issues. When a cooler stops working correctly, it may be down for days or weeks before it can be repaired, as reported by some customers. Using a "dumber" technology like just stocking a yoga studio with a regular POS system will help prevent these outages.

You can read about other businesses using Byte Technologies vending machines in the Goodnature Commercial Juicing Facebook group.

Managing Safety and Using a HACCP Plan

HACCP may be required whenever there is a special process, in this case the special process is referred to ROP (Reduced oxygen Packaging) and, and will likely be required with any transportation of a bottled raw juice.

HACCP stands for Hazard Analysis Critical Control Points. Basically, it's an analysis of how and where in the process the juice could become contaminated, and how your staff will ensure it hasn't been contaminated at those various steps in the process.

The reason the FDA is so strict about raw juice is because it can present safety issues. For example, if the juice is made in an environment contaminated by something like E. Coli or Listeria, the juice may become very dangerous to consume since it hasn't undergone a process to reduce the bacteria.

HACCP helps ensure that the necessary steps are taken to reduce the risk as much as possible. Not only is it often required, but even when it's not it can help protect your business in case of an outbreak that is tracked back to your business. Often times, if there is an outbreak, but you can prove that you were taking the necessary steps with an approved HACCP plan, your business will not be liable for the outbreak. So even when it's not required, we always recommend creating an approved HACCP plan.

If you need help creating a custom HACCP plan, you can request a free consultation with our expert juice business consultant, Chef Ari Sexner.