Arizona cottage food label requirements

What Arizona does require is registration. You have to be on the Arizona Department of Health Services cottage food registry before you sell anything, and you have to hold a current food handler certificate. Both are covered below. Arizona also did something in 2024 that almost no other state has done: it opened cottage food up to perishable, refrigerated products.

The label Arizona actually requires

Under A.R.S. § 36-932 and the ADHS rule at R9-8-101.02(C), every packaged cottage food product needs:

1. The name and registration number of the cottage food preparer. Your ADHS registration number goes on the package. This is the one element people forget, and it's the first thing an inspector or market manager looks for.
2. A list of all the ingredients in the product. Descending order by weight, with sub-ingredients. If your chocolate chips contain soy lecithin, that has to show up.
3. The date the product was prepared. Every unit. Not a best-by date — the production date.
4. Both required statements, word for word. They're below.

If the food was prepared at a licensed facility serving people with developmental disabilities, the label has to say so as well.

Two things Arizona does not require on the label: net weight and a separate allergen declaration. The allergen statement below is what the state asks for. That's a weaker standard than federal law, which covers nine allergens — milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame, the last added by the FASTER Act on January 1, 2023 — and names tree nuts, fish, and shellfish by species. Add a "Contains" statement and a net weight anyway. You'll need both the day you leave cottage food, and a customer with a peanut allergy is not comforted by "may come in contact."

The exact statement wording

Statement one, the one that matters most:

This product was produced in a home kitchen that may come in contact with common food allergens and pet allergens and is not subject to public health inspection.

Statement two, required by the ADHS rule:

To obtain additional information about cottage foods or to report a foodborne illness, go to azdhs.gov/Cottagefood

Neither A.R.S. § 36-932 nor R9-8-101.02 sets a minimum type size. The rule requires the label be legible and printed or handwritten in clear type, affixed to the package, and that the packaging carry a tamper-evident seal — the label itself can serve as that seal.

Do not shorten statement one. An older, shorter version without the pet-allergen clause is still circulating on template sites and in guides written before the 2024 rewrite. It no longer matches the statute or the rule. Note also that the published rule prints "FOOD" in capitals, because FOOD is a defined term in Arizona's food code and the drafters capitalize defined terms throughout. ADHS's own program materials print the statement in ordinary sentence case, and that's what you should put on a label.

Where a Nutrition Facts panel becomes required

No US state requires a full Nutrition Facts panel on cottage food products. You need one when:

1. You make a nutrient content claim — "high protein," "low sugar," "keto," "sugar free." Any of these obligates the panel that substantiates it.
2. You make a health claim — connecting your food to a disease or health condition.
3. You outgrow your state's cottage food cap and move to a commercial kitchen. At that point you are a regular food manufacturer and the cottage exemption is gone.
4. You sell wholesale or into retail. Cottage exemptions are almost universally direct-to-consumer only.
5. You sell on Amazon or another marketplace that requires a panel. Amazon's requirement is contractual, not legal, and it does not care what your state says.

Arizona breaks the pattern on triggers three and four. There is no cap to cross, so three never fires on its own. And four is legal here: § 36-932 lets a third-party vendor — a retail shop or grocery store — sell your shelf-stable products, provided the store keeps them in a separate section with signage identifying them as homemade and not subject to licensing or inspection. Legal isn't the same as easy. Retail buyers routinely require a panel as a condition of stocking you, and that contractual demand, not Arizona law, is what usually forces the purchase. Triggers one and five are the other two that actually bite.

Trigger one catches more people than the other four combined, and it catches them somewhere they don't expect. Under 21 CFR 101.9(j)(18), the exemption is void if the claim appears in advertising — not just on the package. Calling your granola "high protein" in an Instagram caption is enough to require the panel on the bag.

What you can and can't make in Arizona

Arizona uses an exclusion model. Anything that isn't carved out of the definition of "cottage food product" in A.R.S. § 36-931 is allowed. That definition now covers both categories of food: products that are not potentially hazardous, and products that are potentially hazardous or require time and temperature control for safety.

That second half is the part to pay attention to. House Bill 2042, Laws 2024, ch. 18 — signed March 29, 2024, effective September 14, 2024 — expanded Arizona's cottage food program to perishable foods. Refrigerated cakes, cheesecakes, custard fillings, dairy-containing items, prepared foods that need to be held cold: all in scope, subject to strict handling rules. Very few states allow this. If you're reading a guide that tells you Arizona is baked-goods-and-confections only, it predates the rewrite.

Excluded from the definition:

If your product is on that list, cottage food law is not your path in Arizona. A jerky maker, a smoked-fish producer, or a raw-milk dairy needs a licensed commercial or shared-use kitchen, and for meat and poultry likely a state or federal grant of inspection. Once you're operating out of a licensed facility you're a food manufacturer under federal law, which means full labeling including a Nutrition Facts panel unless you qualify for the small business exemption below.

Where you can sell

The split runs along the perishability line. A shelf-stable product can be sold by you, by an agent, or by a third-party vendor, and delivered by any of them or by a third-party carrier — but the sale and the delivery both have to happen in Arizona. A product containing dairy, meat, or poultry must be sold by you to the consumer and delivered by you in person — no delivery apps, no carriers, no store shelves.

Anything requiring time and temperature control comes with three hard limits under § 36-932 and R9-8-101.02: it can be transported once, for no more than two hours, and it has to be held at safe temperature the whole way. That effectively caps a perishable cottage food business at whatever you can drive to in two hours.

Arizona cottage food may not cross state lines. Sell and deliver inside Arizona only.

Where that rule lives matters, because it changes what you're reading when you check the law yourself. The statutes are silent: neither § 36-931 nor § 36-932 sets a geographic limit, and if you read only the A.R.S. sections you will conclude there isn't one. The restriction is in the ADHS rule. A.A.C. R9-8-101.02(D)(1) says the registered cottage food preparer "shall only offer cottage FOODS for sale and delivery in Arizona." That language took effect February 4, 2025, in a final expedited rulemaking published at 31 A.A.R. 666, and it appears identically in the Secretary of State's published A.A.C. Title 9 Chapter 8, in the rule PDF ADHS posts on its own program page, and in Cornell LII's rendering. An agency rule adopted under a statutory grant binds you the same way the statute does.

The federal layer sits on top of that and points the same direction. A cottage food exemption is a state exemption from state registration, and a product crossing a state line is in interstate commerce, where FDA's authority sits. So if you want to ship out of state, cottage food is not the route — you need a licensed facility and full federal labeling.

The cap, the registration, and the training

Registration is an online application: contact details, your home kitchen address, the foods you intend to make, a signed attestation that you'll follow the program's safety requirements, and a copy of a current food handler training certificate from an ANSI-accredited program. ADHS will not process an application without the certificate. The department states applications take four to six weeks, though most applicants hear back within two.

Three ongoing obligations people miss. You must renew every three years under A.R.S. § 36-136(I)(13). You must report any change to your registration information within 30 days. And you must keep your food handler certification active — letting it lapse means you may not prepare cottage foods for commercial purposes, registration or not. ADHS can suspend or revoke a registration for noncompliance, for a verified food safety complaint, or for obstructing an investigation. When you sell somewhere other than your own home, carry the registration certificate and display it.

ADHS runs the registry statewide, including in Maricopa and Pima counties. County environmental health departments field questions but do not register cottage food preparers.

When you outgrow cottage food

There is no cap in Arizona, so the exemption ends for other reasons. Any of these does it:

• You want to make jerky, sell fish, or bottle raw milk.
• You want to produce somewhere other than your home kitchen.
• You want a perishable product on a store shelf, or delivered more than two hours away.
• You want to say "high protein" on the bag.
• You want to sell a product that another company will use as an ingredient.
• A grocery buyer says yes and their compliance team asks for a panel.

Whichever comes first, the day after it happens you are a food manufacturer, and food manufacturers label under 21 CFR 101.9. Your label needs a Nutrition Facts panel with a serving size pulled from the RACC table in 21 CFR 101.12 — not a serving size you picked — and a discrete unit holding 200% to 300% of the RACC needs a dual-column panel.

You might still be exempt, even out of a commercial kitchen

21 CFR 101.9(j)(18) exempts small businesses from the Nutrition Facts requirement if you have fewer than 100 full-time equivalent employees and sell fewer than 100,000 units in the US in a 12-month period. You have to file an annual notice with FDA to claim it. FDA is blunt about the follow-up: "FDA DOES NOT NOTIFY FIRMS WHEN IT IS TIME TO FILE A NOTICE." That's on you.

There's a smaller carve-out under the same section: if you're not an importer, have fewer than 10 full-time equivalent employees, and sell fewer than 10,000 units a year, you don't have to file anything at all.

And the exemption is void — filed or not — for any product carrying a nutrient content claim, a health claim, or other nutrition information, whether that appears on the label, in labeling, or in advertising. See FDA's food labeling guide for the full text.

If you've hit one of the triggers and need the panel itself, Nutrillius builds an FDA-compliant Nutrition Facts panel from your recipe in about a minute — $39 one time, no subscription. Compare that to $1,609–$1,724 for a single lab-analyzed sample at Medallion Labs, or $195 and a two-to-four week wait through a university extension lab.

Verify this yourself

Arizona rewrote this program in 2024 and ADHS updated the labeling rule after that, so both the food list and the required statement have moved recently. Check before you print:

• ADHS — Cottage Food Program
• A.A.C. R9-8-101.02, Cottage Food, full rule text
• A.R.S. § 36-932 — Labeling; food handler certification; sale and delivery requirements
• HB 2042, 56th Legislature, 2nd Regular Session (2024)

Last reviewed August 4, 2026. If you're reading this much later, confirm the statement wording and the excluded-foods list before you rely on either.