HACCP plan for home baking: what a cottage food baker writes down

If you bake at home to sell, you usually do not need a formal HACCP plan, but you do need to know which of your products are safe at room temperature and which are not. Cottage food laws let you sell low-risk baked goods such as bread, cookies and plain cakes from a home kitchen; they generally do not let you sell anything that needs refrigeration. A home baker's food safety plan has five parts: a product list that sorts what is allowed, ingredient and recipe control, clean kitchen and hand habits, labels with allergens, and records of what you baked and sold. This page shows how to write that plan and where a real HACCP plan starts.

Cottage food law is state law, and it differs a lot between states, so confirm every limit below with your state or county before you sell. Free logs are on the logs page; numbers on temperatures come from the FDA Food Code.

Do you need a HACCP plan to bake at home?

In most states, no. Cottage food laws exempt qualifying home bakers from the license, the inspection and the written HACCP plan that a commercial kitchen needs, in return for strict limits on what you may make and sell [1]. The common limits, which differ by state:

Only non-hazardous foods. The law lists bread, rolls, cookies, brownies, muffins, cakes without perishable fillings, fruit pies, some candies. Anything that needs refrigeration is out.
A yearly sales cap. Many states set a dollar limit; some have none.
Direct sales only. At a market, from home or online with local delivery, not through a store or restaurant, in many states.
A label with set information: your name and address, the product name, ingredients, allergens, net weight and often a statement that the food was made in a home kitchen.
A food handler card, a class or a registration in some states.
Home kitchen rules: no pets in the kitchen while baking, no use of the kitchen by children or others while you work, and so on.

A written HACCP plan comes into play when you step outside those lists: selling to a shop or a cafe, selling products that need temperature control, shipping across state lines, or vacuum packing. Then you need a licensed kitchen, and your health department or your state agriculture department will say what plan it wants [1]. Writing a simple plan now makes that step much easier.

Which baked goods are safe at room temperature?

The sorting rule behind most cottage food laws is the same as the Food Code's: a food that supports the growth of bacteria if left out is a time and temperature control for safety food, usually shortened to TCS. Baked goods are mostly dry or acidic enough that bacteria do not grow, which is why they are allowed. Two measures decide it: water activity (how much free water is in the food) and pH (how acidic it is). A food with a water activity below 0.85 or a pH of 4.6 or below is generally treated as shelf stable [2]. You do not need to measure these for bread and cookies, but you do need to know which products cross the line.

Product	Usually allowed?	Why
Bread, rolls, bagels, biscuits	Yes	Baked through, low moisture on the crust
Cookies, brownies, bars	Yes	High sugar, low water activity
Cakes and cupcakes with buttercream made of butter and powdered sugar	Often yes	High sugar; check your state
Cakes with cream cheese frosting, whipped cream or custard	Usually no	Perishable, needs refrigeration
Cheesecake, cream pie, custard pie, pumpkin pie	Usually no	Egg and milk custard supports growth
Fruit pies, double crust	Often yes	High sugar and acid; check your state
Pastry with meat, cheese, egg or vegetable filling	No	TCS food
Pizza with meat or cheese	No	TCS food
Cookie dough, raw dough, canned products	Usually no	Raw flour and egg; canning rules differ
Cinnamon rolls with cream cheese icing	Depends	Cream cheese icing is often a problem; check

When two sources disagree, use the stricter one. Your state's cottage food list wins over this table.

Raw flour and raw eggs

Two ingredients in a home bakery carry a hazard even in low-risk products. Raw flour can carry E. coli, as it is a raw agricultural product that is not treated to kill germs; CDC advises that raw dough is never tasted [3]. Bake dough all the way through, do not sell raw dough or batter unless your state allows it, and do not let customers taste raw cookie dough at a market. Shell eggs can carry Salmonella. Use clean, uncracked eggs, kept at 45°F or below, and wash hands after cracking. Use pasteurized eggs for anything that is not baked through, such as meringue buttercream or royal icing; the eggs plan has the full rules. Meringue and royal icing made with dried egg white powder or pasteurized whites avoid the raw egg issue.

The flow

Buy and store ingredients
Mix and shape
Bake
Cool and finish (glaze, icing, filling)
Package and label
Store, carry and sell

Buying and storing ingredients

Buy from stores that sell to the public or from licensed suppliers, not from unknown sellers. Keep a receipt or a note of where each ingredient came from; if there is a recall, you will want to know which flour or nut butter you used. Keep dairy and eggs in the refrigerator at 41°F or below (eggs 45°F or below) with a thermometer inside; keep flour, sugar and nuts in closed containers off the floor, away from pests. Nuts and seeds go bad faster than flour; use the date on the package. Check dates when you bake, not only when you buy.

Limit: refrigerator at 41°F or below; dry goods sealed, dry and within date.
Monitoring: read the fridge thermometer when you start to bake.
Corrective action: throw out dairy and eggs that were warm; clean up spills at once.

The walk-in cooler log guide shows how to read and record a cooler; a home fridge works the same way, with a thermometer on the middle shelf.

Keeping the kitchen clean

A home kitchen is a family kitchen, and the plan should show how you set it apart when you bake for sale:

Wash your hands with soap for 20 seconds before you start, after the bathroom, after touching your face, pets or trash, and before packaging.
Keep pets out of the kitchen while you bake and package. Many states require this by law.
Tie back hair, wear a clean apron, and do not bake if you are sick, especially with vomiting or diarrhea.
Wash, rinse and sanitize counters, bowls and tools; a household bleach solution (1 tablespoon of unscented bleach per gallon of water, left on for the label's contact time) works. Check your state's accepted sanitizer.
Use a separate sponge or cloth for the dishes you bake with.
Take out the trash before you start, and keep the baking area free of raw meat.
Use drinking-quality water.

Baking and cooling

Bake to a color and an inside temperature that you note in the recipe. Most breads are done at around 190 to 210°F inside; cakes and quick breads at around 200 to 210°F; those are baking-quality guides, not Food Code limits, but a probe tells you faster than a toothpick. Cool baked goods on a rack, uncovered, until completely cool before you wrap or ice them; steam trapped in a wrapped loaf grows mold and makes cookies soft. Add fillings, icings or glazes only to fully cooled items.

Limit: baked through, per the recipe; cooled completely before wrapping or icing.
Monitoring: probe a sample; check the rack.
Corrective action: bake longer, or do not sell items that are doughy or damp inside.

Labels and allergens

Allergens are the biggest real-world risk of a home bakery, because buyers cannot ask you at a distance. Under federal law, packaged foods list the nine major allergens: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soy and sesame [4]. Cottage food labels in most states must show them. The plan should hold a one-page ingredient file for each product, updated when a recipe changes, and a rule that nobody sells a new recipe until the label matches. Cross-contact matters too: if you use peanut butter on Tuesday and bake a "nut-free" cake on Wednesday, wash the tools and wipe the counters first, or do not claim nut-free.

List ingredients in order of weight, as on a store label.
Say "Contains: milk, wheat, eggs" or use the allergen in the ingredient list.
Add your name, address (some states let you use a phone or email) and the "made in a home kitchen" statement if your state requires it.
Put the net weight and the date.

Packaging, carrying and selling

Package when baked goods are cool, in new, clean, food-grade bags, boxes or wrap. Keep them off the floor in the car, away from pets, chemicals and raw food. In hot weather, keep iced or filled items in the shade; a car left in the sun can melt chocolate and glaze and speed up spoilage. At a market, hand-washing water and soap, a covered display and a no-sampling-raw-dough sign are common conditions. Online, deliver within your state if the law is limited to direct sales.

Records for a home baker

Records are a few minutes a bake and save you if a customer asks what was in a loaf, or if a recall happens. Keep:

The ingredient list and allergen sheet for each product.
A batch record: date, product, flour and egg brand, the amount made.
Fridge temperature, if you store eggs or dairy for sales.
Sales: where and how many, for your cap and for taxes.
Complaints: what the customer said and what you changed.
Your license, registration or class certificate.

When do you need a real HACCP plan?

You step into HACCP territory when you:

sell perishable products, such as cheesecake, cream-filled pastry, quiche or sandwiches;
wholesale to a cafe, shop or restaurant (the buyer will ask for your kitchen license);
pack in reduced-oxygen packaging, can, or make low-acid shelf goods;
ship across state lines; or
sell above your state's cap.

At that point move to a licensed kitchen or a shared commissary and write the plan for it. The HACCP plan for a bakery covers custards, fillings, the display case and the full plan that a commercial bakery writes. The food safety plan template shows the eight parts.

Worked plan rows for a home bakery

Step	Hazard	Limit	Monitoring	If it fails	Record
Buy ingredients	Unsafe source	Retail or licensed supplier; in date	Receipt, date check	Return or discard	Ingredient file
Store eggs and dairy	Growth	Fridge 41°F or below (eggs 45°F)	Fridge thermometer	Discard if warm over 4 h	Fridge log
Mix	Raw flour and egg; hands	Clean hands and tools; no tasting raw dough	Visual	Re-wash; remake	Batch record
Bake	Underbaking	Baked through per recipe	Probe a sample	Bake longer or do not sell	Batch record
Cool and finish	Mold; growth in fillings	Fully cool; non-perishable fillings only	Touch and check	Do not wrap warm	Batch record
Label	Allergen	Label matches ingredient file	Check before sale	Relabel; hold the batch	Label file
Carry and sell	Heat; contamination	Clean covered boxes; shade; no raw dough samples	Visual	Discard spoiled items	Sales log

Common mistakes

Selling cheesecake or cream pie under a cottage food license. It needs refrigeration, so it is outside the law in most states.
Assuming a recipe change does not change the allergens. A little almond flour is a tree nut.
Wrapping warm bread. Mold follows.
Letting the pet in the kitchen "just while I package."
Selling above the yearly cap without noticing.
Using a label from another state.
Tasting or sampling raw cookie dough.

Questions

Do I need a license to bake at home and sell?

It depends on the state. Many states have a cottage food law that waives the commercial license for low-risk foods up to a sales cap; some require a registration, class or permit. Check your state's health or agriculture department.

Can I sell cheesecake from my home kitchen?

Almost never under a cottage food law, because it needs refrigeration. You would need a licensed kitchen.

What do I put on a cottage food label?

Typically your name and address, the product name, ingredients in weight order, allergens, net weight and a home-kitchen statement. Your state sets the exact list.

Is a buttercream cake allowed?

Often yes when the icing is butter and powdered sugar and it is kept at room temperature; cream cheese, whipped cream and custard are generally not. Check your state's list.

Do I need to take temperatures when I bake at home?

You need to know the fridge is at 41°F or below if you store eggs and dairy, and that the product is baked through. Beyond that, a probe is a useful habit, not a legal requirement in most states.

Where do I get logs?

Use the free sheets on our logs page and keep a simple batch and fridge record.