I am not a cottage operator today. I run a CFIA-licensed (Canadian Food Inspection Agency) mushroom production facility in Brantford, Ontario. But in 2020 I started exactly where most readers of this page are: at my kitchen counter, packing orders into padded mailers, printing labels on a home printer, and trying to figure out what records I actually needed to keep. I built the Free tier of HACCPlan because that is the tool I would have used on day one. No card, no trial countdown, no upgrade prompts — free forever for cottage-scale operations. Here is what it does and when you outgrow it.
01What you are
What "cottage food operator" actually means in 2026.
A cottage food operator is a person who makes food at home and sells it directly to the public under a special carve-out in state law. The carve-out exists because regulators decided that small, low-risk home production (jam, cookies, granola, dry mixes) does not need to clear the same bar as a commercial bakery. In the United States, every state has a cottage food law, but they are not the same law. The cap on annual sales can be $25,000 or $250,000 or unlimited depending on which side of the state line your kitchen sits.
A few terms I will use throughout this article, defined plainly:
- TCS — Time/temperature Control for Safety food. Items that have to be held cold or hot because pathogens grow in the middle temperature range. Cream cheese frosting, refrigerated salsa, custard fillings. Most states still ban TCS foods under cottage law. Nine now allow some.
- HACCP — Hazard Analysis and Critical Control Points. The structured food-safety plan a commercial facility has to write. Cottage operators almost never need a full HACCP plan.
- FDA — Food and Drug Administration (U.S. federal food regulator). FDA mostly does not regulate cottage operators directly. Your state department of agriculture or health does.
- CFIA — Canadian Food Inspection Agency. The federal regulator north of the border. Canadian home-based food operators run under provincial rules, not CFIA, until they scale.
80–180K
Active U.S. cottage food operators by the Institute for Justice's "Baking Bad" survey (2023) plus state registry counts. Likely higher once you include unregistered side hustles.
9 states
Now permit TCS foods in home kitchens — California, Iowa, Montana, North Dakota, Oklahoma, Utah, Wyoming, Texas, Tennessee. Cream cheese frostings, refrigerated casseroles, savory items.
Sept 2025
Texas SB 541 raised the cottage cap from $50,000 to $150,000 (inflation-adjusted going forward). Michigan went $25K to $50K in March 2026. Florida sits at $250,000.
The 2026 reality: the cottage food category is the largest and most permissive it has ever been. More operators are scaling further before they trip the wire that forces a commercial kitchen. Higher revenue ceilings, more product variety, and more recordkeeping pressure on people who never set out to run a "compliance" function in their business.
02The four trends
Four state-law changes you should know about.
I am not going to walk you through all 50 state laws on this page. The state-by-state lookup belongs in a tool, not an article (and we have one — link below). But there are four shifts since 2024 that matter no matter where you live, because they signal where the rules are heading.
- 01
The caps keep going up
Texas SB 541 (September 1, 2025) raised the annual sales cap from $50,000 to $150,000 and indexed it to inflation. Michigan HB 4122 (March 24, 2026) doubled the cap from $25,000 to $50,000. California's Class B cottage permits sit around $172,000 (CPI-adjusted). Pennsylvania, Maine, Wyoming, and Georgia (post-July 2025) have no cap at all. At least eight states now permit cottage sales high enough to support a part-time-to-full-time income.
- 02
TCS foods opening up in home kitchens
Nine states allow at least some Time/Temperature Control for Safety foods — refrigerated frostings, savory items, certain meat-free prepared meals. California, Iowa, Montana, North Dakota, Oklahoma, Utah, Wyoming, Texas, Tennessee. This is the single biggest product-range change of the past five years. If your state allows TCS items, you have new responsibilities (temperature logs, dated batches) that did not exist for the dry-cookie-only era.
- 03
Interstate shipping is still mostly off the table
Three exceptions only, as of 2026: Pennsylvania's Limited Food Establishment permit, Wyoming's Food Freedom Act, and North Dakota SB 2386 (effective March 21, 2025 — interstate shipping explicitly permitted). Every other state: shipping across a state line voids your cottage exemption. The instant you put a cookie box on a truck to a neighboring state, you become a commercial food business subject to FDA rules, not state cottage rules.
- 04
California's two-track program
California has both the traditional CFO (Cottage Food Operation, Class A/B) and the newer MEHKO (Microenterprise Home Kitchen Operation, created by AB 626). MEHKO allows prepared meals served from a home kitchen, including TCS items, with a roughly $100,000 cap — but each county has to opt in. Los Angeles County opted in late 2024 and issued more than 100 MEHKO permits by May 2025. If you are in California and want to sell meals (not just shelf-stable items), MEHKO is the path; CFO is for baked goods, jam, granola, and the like.
The underlying message: your state changed in the past 24 months even if you did not notice. Cap, allowed foods, label wording — at least one of those probably moved. Worth a five-minute check before your next farmers market season.
03Your obligations
What your state actually requires of you (even at cottage scale).
Cottage operators are exempt from a lot. You are not exempt from everything. The four areas every state asks about in some form:
Labels
#1 miss
The single most-missed compliance item. Every state requires labels on cottage-produced food, and the wording is not negotiable. A typical required label has: your name and address (some states now allow a state-issued ID for label privacy — Texas SB 541, Georgia post-July 2025), the product name, ingredients in descending weight, an allergen statement, the net weight, and a state-mandated disclosure statement like "THIS PRODUCT WAS PRODUCED IN A PRIVATE RESIDENCE THAT IS NOT SUBJECT TO GOVERNMENTAL LICENSING OR INSPECTION" (Texas) or "This product was produced in a home kitchen not inspected by a health department that may also process common food allergens" (Illinois). The disclosure wording is state-specific and an inspector will compare your label to the statute character-for-character.
Allergens
Big 9 + FASTER
Sesame became allergen number 9 on January 1, 2023 under the FASTER Act (Food Allergy Safety, Treatment, Education, and Research Act). The Big 9 are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame. Your label has to declare any of those that appear in the recipe, either as "Contains: wheat, eggs, milk" after the ingredient list, or bolded inline within the ingredients. Cottage operators are not exempt from FASTER. The fine for an undeclared allergen on a state-required label is the same whether you sell ten cookies a month or ten thousand.
Sales records
Cap proof + IRS
Every transaction. Two reasons: your state needs to verify you are under the cap if questioned, and the IRS wants Schedule C income reported. Etsy, PayPal, Stripe, and Square issue 1099-K forms starting at $600 in gross sales (the threshold dropped in 2026), which surfaces a lot of previously-quiet cottage income. Some states ask for more — Texas requires purchaser contact information for recall purposes; Florida wants sales records available on demand. The IRS wants three years minimum.
Batch records
State-specific
Not every state requires batch records, but most states that allow acidified, fermented, pickled, or TCS products do. Texas asks for a 12-month batch history for pickled, fermented, and acidified foods. Pennsylvania's Limited Food Establishment requires batch logs plus pH (acidity) records plus lab testing on acidified items. Mississippi wants pH, recipe source, date, and quantity. Even where it is not required, a batch log with the date, recipe, lot codes of ingredients, and quantity made is the single most useful record you can keep if a customer ever complains of illness.
A few states also require training. Illinois cottage operators making certain higher-risk items need a Certified Food Protection Manager certificate (around $100, valid five years). California cottage operators need a Class A food handler card. Pennsylvania requires food-safety training for LFE permit holders. Most states require nothing beyond reading the cottage rules. Your state's department of agriculture or health website will say.
The 60-second way to check what your specific state requires: use the lookup tool. State, product type, and the result tells you cap, label wording, allowed foods, registration requirement, and whether you can ship in-state versus interstate.
04The free tier
What the HACCPlan Free tier actually does for a cottage operator.
The Free tier of HACCPlan is structured the way I would have wanted it in 2020. Free forever, no credit card, no trial countdown, no upgrade prompts inside the product. One user, one location. The features map directly to cottage operator workflow.
- 01
State law lookup, built into the app
Pick your state. The result tells you the current sales cap, allowed foods, required label disclosure wording verbatim, training requirements, and in-state versus interstate shipping rules. Updated as laws change. Covers all 50 U.S. states, plus 10 Canadian provinces and 3 territories. Standalone version available without an account.
- 02
Label generator with allergen statement
Enter your recipe. The system maps each ingredient to the Big 9 (plus mustard and added sulphites for Canadian operations) and generates the allergen statement automatically. Fills in the state-mandated cottage disclosure language. Output is a print-ready label PDF.
- 03
Batch log
A simple record for every batch — date, recipe, ingredient lot codes, quantity made, where it went. Critical for states that require batch records (most TCS or acidified states do). The single most useful record you can keep if a customer ever has a complaint, or if you ever scale to a commercial license.
- 04
Sales log with cap tracking
Every sale, with date, item, quantity, and price. Running total against your state's cap. Exportable to CSV for your accountant or for IRS Schedule C reporting.
- 05
Refrigerator and cleaning logs
For TCS-permitted states. Daily fridge temperature, daily cleaning before and after batch production. Not required in non-TCS states but smart to keep regardless — if a customer ever claims illness, "I cleaned my prep surfaces and the fridge was at 38 degrees" is a better defense than "I think I did."
- 06
Scaling readiness assessment
A two-minute questionnaire about your state, year-to-date revenue versus your cap, product mix, and customer venues. Outputs a readiness score and a plain-English recommendation. The industry rule of thumb is to start researching commercial-kitchen options at around 70 percent of your state's cap.
- 07
CSV export for everything, anytime
Your data is yours. Export the sales log, batch log, recipe list, and customer record to CSV whenever you want. In 2025 the largest cottage-operator-focused platform wound down and thousands of vendors lost their records. I designed Free to be the opposite of that — if you ever leave HACCPlan, you walk out with everything.
What the Free tier does NOT include
Free is one user, one location, and seven days of rolling record history (the underlying records are stored — you just see the most recent week in the main view; older records export to CSV on demand). Exports carry a small HACCPlan watermark. You do not get the multi-month rolling batch history, the recall-plan automation, the supplier-verification module, or brand-removable PDF exports — those live on the Starter tier ($49/month). The honest truth is that 90 percent of cottage operators never need any of those features. Free is built to be enough.
05My own story
Why I started here.
In 2020 I launched Nature Lion as a home-kitchen mushroom operation in Ontario. I sold grow kits and dried lion's mane direct to customers, mostly through Instagram and a basic Shopify storefront. My recordkeeping was a paper notebook. My labels were printed on adhesive sheets I cut to size with kitchen scissors. My "compliance system" was reading the Ontario home-based food guidance PDF once a quarter and hoping I had not missed anything.
I made one specific labeling mistake in my first year that I think most cottage operators make eventually: I left an allergen off a product because I did not realize the ingredient I was sourcing was on the major-allergen list. (It was a tree-nut-derived flavoring in a product I would not have associated with tree nuts.) Nobody got sick. Nobody complained. I caught it on my own and reprinted. But that was the moment I understood that "I am a small operation, the rules do not really apply to me" was the wrong mental model. The rules apply identically. The only thing that changes with size is how visible you are.
“
If your state's cap is $50,000 and you cleared $4,000 last year, you do not need $149 a month software. You need a label generator, a place to put your sales, and a quiet way to know when you are getting close to the line. That is the Free tier.
”Andrew Langevin — Nature Lion Inc., 2020–present
Between 2020 and 2023 I scaled from home kitchen to a CFIA-licensed facility in Brantford. The transition took roughly 18 months of paperwork, kitchen scouting, Preventive Control Plan writing, and inspector back-and-forth. The single most useful thing in that 18 months was the records I had been keeping at cottage scale. Not because they checked any commercial box — they did not — but because they let me describe what I had been making, in what quantities, to whom, with what ingredients. The CFIA inspector did not care about my pre-licensure records. The shared-kitchen manager I interviewed cared. The insurance agent cared. My future PCP author cared. Every commercial-side conversation got faster because I had a paper trail of what I had actually been doing.
That is the second reason I built the Free tier the way I did. Cottage operators rarely scale. Most stay cottage on purpose — it is a deliberate lifestyle and income choice, not a stepping stone. But the ones who do scale need their old records to still exist when they get there. CSV export is not a courtesy. It is the bridge.
06The competitive picture
Why nothing else quite fits.
Most people who land on this page have already shopped around and felt the gap. The general food-safety platforms are built for commercial SMEs — they start at around $79 per site per month and go up from there. They assume you already have a QA director or at least a dedicated compliance owner.
The cottage-targeted platforms have had a hard 18 months. The most prominent one wound down its consumer storefront in 2025 after an acquisition, leaving its vendor base scrambling to migrate orders, labels, and records. Cottage operators are a tough market to serve sustainably as a paid-only product — margins are thin and the customer is rightly skeptical of software fees.
There are excellent free reference sites for cottage food law — Forrager is the standard one, practitioner-curated and comprehensive. But it is a reference, not a tool. You read about your state's rule there and then go somewhere else to print a label or log a batch. General accounting tools (Wave, QuickBooks, Square) handle the bookkeeping cleanly but do not know what cottage food law is.
The gap is real: free, cottage-aware, operational, with a clear path forward if you ever scale. That is the lane the HACCPlan Free tier was built for.
07When you outgrow it
When the Free tier stops being enough.
Most cottage operators never outgrow Free. That is intended — the Free tier is the product for the cottage tier of operation, full stop. But a fraction of cottage operators do scale, and the honest signals that you are approaching that point look like this:
- 01
You are at or above 70 percent of your state's cap
Industry rule of thumb. If your cap is $50,000 and you are at $35,000 year-to-date in October, you are likely to either hit the cap or have to slow down to stay under it. That is the moment to start pricing shared-kitchen options and asking what a state commercial retail license would cost.
- 02
You are turning away wholesale, retail, or interstate orders
Cottage exemptions are for direct-to-consumer sales in your state. The moment a grocery store, restaurant, or out-of-state customer asks to buy from you in volume, you either say no (stay cottage) or you go commercial. There is no middle path.
- 03
You are adding a helper
Multi-user is not a Free tier feature for a reason — most cottage operations are solo. Once you hire a family member or assistant who needs to log batches, generate labels, or handle sales, the operation has moved past hobby-scale.
- 04
A customer or insurer asks you for a recall plan
Cottage exemptions waive HACCP but do not waive civil liability. If you sell at a venue (a co-op, a farmers market with insurance requirements, a wholesale buyer) that asks for a written recall plan, you have crossed into commercial-style obligations even though your sales volume has not.
- 05
You need 12-month rolling batch history for an audit or insurance application
The Free tier shows seven days of history in the main view (with full CSV export for anything older). A formal audit, a state retail license application, or a product liability insurance underwriter will ask for a continuous 12-month batch record. That is the Starter tier ($49/month).
The scaling readiness assessment inside the Free tier asks these questions for you and turns the answers into a recommendation. The point is not to push you to upgrade — most people will get back "stay cottage, you are fine." The point is to give you a quiet way to check, every quarter, whether the conditions of your operation have changed.
08The commercial transition
What "going commercial" actually costs (if you ever do).
The jump from cottage to commercial is a step function, not a slope. You do not gradually become a commercial operator. You either are or you are not. The day you stop being cottage you owe:
- 01
A commercial kitchen
Shared commissary or co-op at roughly $15 to $50 per hour, leased dedicated space at $1,000 to $3,000 per month for a small footprint, or built-out from scratch starting at $40,000. Most operators start shared — lowest commitment, the inspector treats you the same.
- 02
A state retail or wholesale food license
Typically $100 to $500 per year plus an initial inspection. Some states tier by product type (a low-acid canned-food endorsement adds a separate fee).
- 03
A written HACCP plan
Required for any wholesale operation and for many state retail licenses depending on product type. Budget 20 to 60 hours of focused work for the first draft.
- 04
Product liability insurance
Roughly $400 to $1,500 per year for a small operation. Your homeowner's policy does not cover business activity. This matters at cottage scale too, but underwriters get serious at commercial scale.
- 05
Possibly FDA Food Facility Registration
Required for any facility that manufactures, processes, packs, or holds food for U.S. consumption, with carve-outs for retail establishments and some farms. Interstate or wholesale, you are likely on the hook. Free to register, biennial renewal — but you become subject to FSMA (Food Safety Modernization Act) preventive-controls requirements under 21 CFR Part 117 once registered (unless a qualified-facility exemption applies).
I made the jump in 2023 and the part nobody warned me about was the step-function nature of it. The day before my CFIA license issued, I was a cottage-style direct-to-consumer mushroom seller. The day after, I had a Preventive Control Plan, a biannual inspection schedule, and product going under three brand names through one kitchen. Same kitchen. Same products. Different category of operator. The records I had been keeping at cottage scale were the only thing that made that transition feel less than overwhelming.
Start free — no card, no trial countdown
Sign up for the cottage-tier Free plan, or take the 2-minute scaling readiness assessment first
Free forever — labels, state law lookup, batch and sales logs, scaling readiness assessment, CSV export. One user, one location. No upgrade prompts inside the product. When you outgrow it (most operators never do), Starter is $49/month and your data and workflow come with you.
Email required to save your work. No credit card.
09Free templates
Free templates — for the logs you might want even before signing up.
If you are not ready to set up an account yet, here are the underlying logs in fillable PDF form. Print them to a clipboard or fill them on a tablet. No email gate, no signup. The refrigerator and cleaning logs in particular are smart to keep even in non-TCS states — they are the records that protect you if a customer ever claims illness from your product.
Free templates for cottage operators
Free, ungated. Fillable on a tablet or computer in any PDF viewer. Print blank and fill on a clipboard. No account needed.
Most cottage operators run on the free PDF logs for a few weeks or months before deciding whether to set up an account. That is the right order. Get the records filled out reliably on paper first; the software is just the version that keeps the records integrated, time-stamped, label-aware, and ready to travel with you if you ever scale.
Footnotes
1.Texas DSHS — Cottage Food Production (SB 541 implementation) — dshs.texas.gov
2.FDACS — Florida Cottage Foods (Section 500.80) — fdacs.gov
3.National Agricultural Law Center — Cottage Food Laws: Recent Trends and Major State Changes — nationalaglawcenter.org
4.Institute for Justice — "Baking Bad" Cottage Foods Survey (2023) — ij.org
5.FDA — Food Allergies (Big 9, FASTER Act, sesame effective January 1, 2023) — fda.gov
6.LA County DPH — Microenterprise Home Kitchen Operation (MEHKO) — publichealth.lacounty.gov
7.PA Agriculture — Limited Food Establishment (interstate-permitted cottage tier) — agriculture.pa.gov
8.21 CFR Part 117 — FSMA Preventive Controls for Human Food — ecfr.gov
9.FDA — How to Start a Food Business — fda.gov
10.Forrager — Cottage Food Laws by State (practitioner reference) — forrager.com
Andrew Langevin·CFIA-licensed facility, Brantford ON· Published 2026-06-04· 12 min read· Wikidata Q139112497
