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?

ProductUsuallyWhy
Mango, lime or mixed vegetable pickle in oil and vinegar, shelf-stableAcidified foodLow-acid ingredients brought to pH 4.6 or below with acid
Tomato or tamarind chutney, shelf-stableDepends on test resultsSome fruit chutneys are naturally acid foods; added low-acid vegetables or onion can make them acidified
Pickled peppers, jalapeños, garlic in vinegarAcidified foodLow-acid vegetables with acid added
Naturally fermented sauerkraut or brine picklesExcluded from part 114Fermented foods are excluded from the acidified food definition
Kimchi sold refrigeratedExcluded from part 114Foods stored, distributed and sold refrigerated are excluded
⚠️ Oil-based pickles are often misunderstood. Oil does not make a product safe — what matters is the finished equilibrium pH of the vegetable pieces and the water activity. Test your product and ask a process authority. For the full rules, see acidified vs low-acid canned foods.

What an acidified food processor needs

  1. 1FDA food facility registrationWith a U.S. Agent, renewed every even-numbered year.
  2. 2FCE registration (Form FDA 2541)Registers the plant as an acidified food processor.
  3. 3SID process filing (Form FDA 2541e)One filing for each product, recipe style, container size and type, set by a qualified process authority.
  4. 4Trained supervisorOperations supervised by someone who completed an FDA-recognized course (Better Process Control School).
  5. 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

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.

Pickles, chutneys or sauces for the US?

FCE registration $550. SID process filing $350 per product. FDA food facility registration with U.S. Agent from $300.

FCE & SID registration →

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

Requirements checked on November 11, 2026. This article is general information, not legal advice.