The short answer
Most shelf-stable pickles, chutneys, relishes and vegetable pastes sold in jars are acidified foods in FDA’s eyes: low-acid vegetables or fruits brought to a pH of 4.6 or below by adding vinegar, lemon juice or another acid. That means, on top of normal food facility registration, the processor needs an FCE registration and an SID process filing for each product before shipping. Without them, shipments can be detained under Import Alert 99-37.
Naturally fermented products (like traditional sauerkraut or brine-fermented pickles) and refrigerated products (like fresh kimchi kept cold) are excluded from the acidified food rule — but they still need registration, safe processing and correct labels.
Is my product an acidified food?
| Product | Usually | Why |
|---|---|---|
| Mango, lime or mixed vegetable pickle in oil and vinegar, shelf-stable | Acidified food | Low-acid ingredients brought to pH 4.6 or below with acid |
| Tomato or tamarind chutney, shelf-stable | Depends on test results | Some fruit chutneys are naturally acid foods; added low-acid vegetables or onion can make them acidified |
| Pickled peppers, jalapeños, garlic in vinegar | Acidified food | Low-acid vegetables with acid added |
| Naturally fermented sauerkraut or brine pickles | Excluded from part 114 | Fermented foods are excluded from the acidified food definition |
| Kimchi sold refrigerated | Excluded from part 114 | Foods stored, distributed and sold refrigerated are excluded |
What an acidified food processor needs
- 1FDA food facility registrationWith a U.S. Agent, renewed every even-numbered year.
- 2FCE registration (Form FDA 2541)Registers the plant as an acidified food processor.
- 3SID process filing (Form FDA 2541e)One filing for each product, recipe style, container size and type, set by a qualified process authority.
- 4Trained supervisorOperations supervised by someone who completed an FDA-recognized course (Better Process Control School).
- 5RecordspH measurements and process records for every batch.
FDA has issued warning letters to foreign acidified food makers — including an acidified food facility in India — over acidified food processing problems. Import Alert 99-37 (published October 29, 2026) lists firms whose low-acid or acidified products can be detained because no scheduled process was filed.
Label points
- Name: an accurate common name — “mango pickle in mustard oil”, “mixed vegetable relish”.
- Ingredients: every ingredient, including oils, spices and any color; check colors are permitted in the U.S.
- Allergens: mustard is not a U.S. major allergen, but sesame, fish (in some fermented pastes), shellfish and wheat are.
- Sulfites of 10 ppm or more must be declared.
- Nutrition Facts in U.S. format, and net quantity in U.S. and metric units.
- Storage instructions such as “Refrigerate after opening” where needed.
Example: a pickle maker in India and a kimchi maker in South Korea
An Indian company making shelf-stable lime pickle in jars measures a finished pH of 3.8. Its product is an acidified food: it needs FDA facility registration, FCE registration, an SID filed on Form 2541e by a process authority and a trained supervisor before the first shipment. A Korean kimchi maker that ships and sells only under refrigeration is excluded from the acidified food rule, but still needs FDA registration, cold-chain control and a correct label declaring fish or shellfish ingredients.
FCE registration $550. SID process filing $350 per product. FDA food facility registration with U.S. Agent from $300.
Frequently asked questions
Do Indian pickles need FCE and SID?
Usually yes, if they are shelf-stable and made from low-acid ingredients brought to pH 4.6 or below with acid. The processor needs FCE registration and an SID filing for each product before shipping.
Is kimchi an acidified food?
Fermented foods and foods kept refrigerated are excluded from FDA’s acidified food rule. Refrigerated, fermented kimchi is generally outside part 114, but other FDA rules still apply.
What is Import Alert 99-37?
It allows FDA to detain low-acid canned and acidified foods without examination when the firm has not filed a scheduled process.
Does oil-based pickle count as acidified?
It depends on the finished equilibrium pH and water activity of the product, not on the oil. Most shelf-stable vegetable pickles with added acid are acidified foods.
Sources
- FDA — Acidified & Low-Acid Canned Foods guidance and regulatory information
- FDA — Import Alert 99-37 (published October 29, 2026)
- FDA — Warning letter to an acidified food facility in India (October 8, 2019)
Requirements checked on November 11, 2026. This article is general information, not legal advice.