The economics of selling what you dry.

The short version: Whether you can sell what you dry is decided by your own state's cottage food architecture, not by the food; the jurisdictions that name freeze-drying by name split in both directions, with California listing a category called "Dried, Dehydrated, and Freeze-Dried Foods" [1] and New York listing "Freeze-dried foods" among prohibited products [2]. Where a state does attach a verification condition, it is usually a water activity or pH number someone else has to certify, and that certification is a real line in your cost per bag. Everything below describes what agencies publish; it is not advice about your situation.

Is the product and method allowed: structure, not advice

The revenue ceilings alone span an order of magnitude: Florida's statute caps a cottage food operation at "annual gross sales of cottage food products that do not exceed $250,000" [10], while Oregon's March 2026 FAQ states "You are limited to $52,700 in annual gross sales" and adjusts that figure annually [20]. Georgia publishes none at all: "The Georgia Department of Agriculture does not have any limits on gross sales or the number of units that can be produced" [30]. A cap is a structural feature of one state's exemption, not a property of the category.

US cottage food regulation is not federal. It is a state-by-state exemption carved out of each state's general food establishment licensing law, populated by administrative rule, and in several states administered by a county. Florida's §500.80 exempts qualifying operations from the §500.12 permit [10]; Ohio's allowed products are enumerated not in statute but in Ohio Admin. Code 901:3-20-04 [9]; Illinois routes registration to the local health department [8]. Which agency owns it also varies, with agriculture in New York [2] and Pennsylvania [13], and health in California [33], Texas [11] and Arizona [4].

Two architectures produce opposite readings of the same silence. In an enumerated state, the allowed list is closed and a method that is not named is outside it. In an exclusionary state, the rule permits everything except a prohibited set. Texas expresses its permitted foods that way, and required a statutory amendment naming "dehydrated fruit or vegetables, including dried beans" to put drying inside it explicitly [11]. This is why "my state doesn't mention freeze-drying" is not one fact. It is two different facts depending on how the statute is built.

The load-bearing idea underneath all of it is the non-TCS concept. Penn State Extension states the pairing plainly: TCS foods have "high moisture (aw > 0.85) and/or low acid content (pH > 4.6)" [12]. Dried and freeze-dried products reach non-TCS status by removing moisture, and most cottage food statutes never defined a test for it.

Where freeze-drying is named, here is the record as published, date checked 2026-09-06:

New Jersey is the row that changes a business plan rather than a product list: the state's published position reaches the equipment itself, on the stated ground that "The process of freeze-drying or dehydrating fruits using a machine cannot reliably lower the moisture content to a safe level" [3]. The operative step, in any state, is to put the question to your own agency in writing and keep the reply.

What verification is typically required

Arizona publishes the two numbers most plainly: "Water Activity Testing: results must fall below 0.85 aw" and "pH Testing: results must test acidic at 4.6 pH or below" [4]. That is the exception, not the pattern. Across the published record, verification arrives in four different shapes, and only some of them cost money.

Two structural traps sit in this section. First, a pH ceiling can be written across a category that pH does not control: Pennsylvania's application packet states "Only products with a pH of 4.6 or below can be made from a limited food establishment" while offering "Dehydrated food" as a production type on the same form [13]; a product that is shelf-stable by low water activity alone does not sit comfortably inside that sentence. Second, agencies are specific about instruments where they are specific at all: Virginia's VDACS requires an electronic pH meter and states "Paper strips are NOT accurate enough" [26], while publishing no water activity threshold of its own.

On measuring water activity yourself, the extension record is candid. Virginia Cooperative Extension states that accurate determination "requires the use of a specialized meter" and that purchasing such equipment "is not cost-effective for many small and mid-size producers," pointing producers to a testing service instead [27]. The one extension-published jar-and-logger method, from University of Minnesota Extension, labels its own output "indicative only and aimed to provide directional information when developing recipes," and adds that "Professional commercial testing is strongly recommended to verify results" [28]. Sublime Pantry has bench-tested neither route.

A unit cost example, with every assumption labelled

Only one lab price appears anywhere in the sourced record: Illinois states "A pH test from a lab generally costs between $15-$40" [8], and that is for acidified products, not for a water activity report on dried fruit. No source retrieved publishes what an aw test costs. So the model below carries sourced figures where they exist, labelled assumptions everywhere else, and one line left deliberately empty.

The worked example: one 4 oz retail bag of freeze-dried strawberries. A1–A9 are assumptions, not findings.

Units per batch (A2, A3, A4). 10 lb fresh × (1.0 lb dry / 10 lb fresh) = 1.0 lb dry. 1.0 lb ÷ 0.25 lb per unit = 4 units per batch.

Fruit per unit (A1, A2). 10 lb × $2.50/lb = $25.00 per batch. $25.00 ÷ 4 units = $6.25 per unit.

Packaging per unit: the bag × price arithmetic, shown (A5, A6, A7). Buying in hundreds: 100 bags × $0.55 = $55.00; 100 absorbers × $0.09 = $9.00; 100 labels × $0.06 = $6.00. Total $55.00 + $9.00 + $6.00 = $70.00 for 100 packed units, so $70.00 ÷ 100 = $0.70 per unit. Substitute your own kit price: a 100-unit set of bags, absorbers and labels landing at $89.00 all-in is $89.00 ÷ 100 = $0.89 per unit, which is $0.19 more than A5–A7 assume. Price it against whatever else you are quoted and run the same division.

Electricity per unit (A8). $3.33 per batch ÷ 4 units = $0.8325, shown below as $0.83.

Registration per unit (A9, [23]). $65.00 ÷ 120 units = $0.5417, shown below as $0.54.

Check the total: $6.2500 + $0.7000 + $0.8325 + $0.5417 = $8.3242. At the $0.89 packaging figure instead, $8.3242 + $0.19 = $8.5142, or $8.51. Neither number is a finding about your operation; it is A1 through A9 with one sourced fee, and every input above is yours to replace.

What the model deliberately does not contain: any projection of weekly or monthly revenue. Unit economics answer what one bag costs. They do not tell you how many bags sell, and no source retrieved publishes a sales rate for a home operation.

Price from all the work

Compliance costs are small, published, and easy to underweight: Pennsylvania states "New Registrations are $35.00, at time of the first inspection," with routine on-site inspection and, for non-public water supplies, a water test [13]; Illinois caps its registration fee: "The fee to register is capped at $50 by law" [8]; Montana charges "a one-time registration fee of $40.00" [32]; Rhode Island $65.00 annually [23]. Georgia is the caution: its cottage food page describes House Bill 398 as removing the state licensing requirement, while the department's own still-published rule states "A person must not operate as a cottage food operator without registering with and obtaining a license from the Department" at "$100 license fee" annually [30][31]. Two state sources, unreconciled, and a fee you may or may not owe.

The cash cost above ($8.32 per unit) omits the two largest real inputs in a one-person operation: your hours, and the compliance work nobody invoices you for. Price them explicitly.

Labor (A10, A11, assumptions). 45 minutes hands-on per batch at a self-set $25.00/hour = 0.75 h × $25.00 = $18.75 per batch. $18.75 ÷ 4 units = $4.6875, shown as $4.69 per unit.

Fully loaded cost. $8.3242 + $4.6875 = $13.0117, i.e. $13.01 per unit.

Price at a target margin (A12, assumption: 60% gross margin). Price = cost ÷ (1 − margin) = $13.0117 ÷ 0.40 = $32.5293, i.e. $32.53. Check it back: $32.53 − $13.01 = $19.52, and $19.52 ÷ $32.53 = 0.600, a 60.0% margin. Price from the cash cost alone and the same formula gives $8.3242 ÷ 0.40 = $20.81; the $11.72 gap between the two is what your unpaid hours are worth at A10 and A11.

Two things the published record adds to a pricing decision. Sales channel is often narrower than the cap suggests: Washington's statute requires the state to review its cap every four years and "increase the cap by expedited rule making" [29], while the same chapter restricts where product may be sold. And packaging can be regulated independently of the food: Ohio's rule states flatly "Cottage food products may not be packed using reduced oxygen packaging" [9], which is a rule about the bag, not the fruit.

Keep a decision record

The single most repeatable finding across the sourced state material is that agencies contradict each other, contradict their own documents, and revise pages without notice. The same California category name appears in a current list revision and not in a county-hosted copy still in circulation [1][33]. A decision record is how you survive that: not a compliance artifact, a dated log of what you read and what you were told.

What to write down each time, at minimum:

• The date you checked and the exact URL or document title, because the page you relied on may not say the same thing next quarter.
• The sentence itself, quoted, not your summary of it. "Freeze-dried foods" on a prohibited list [2] and "Low acid fruits may be freeze-dried" [21] are both short enough to copy exactly.
• Who told you, and in what capacity. An extension service answering a question is not the agency that administers the rule; Michigan's commercial-dryer condition comes from extension while the agency's own pages state no such condition [14].
• Your written question and their written reply, kept together.
• Every assumption you priced from: A1 through A12 above, with the numbers you actually used, so a later price change is traceable to an input rather than a mood.
• What you could not establish, stated as such, with the search you ran.

The same discipline applies to verification. If a state conditions your product on documentation from a processing authority [6], or a county may request testing at its discretion [25], the record of who said what, when, is the difference between a delay and a rebuild.

What we could not source

• The price of a water activity test. One lab price appears in the entire record: Illinois' "$15-$40" for a pH test on acidified products [8]. No source retrieved publishes an aw testing price, so the verification line in the cost model is left empty rather than filled with a plausible number.
• Whether an oxygen absorber counts as reduced oxygen packaging under Ohio's rule [9]. No retrieved source addresses it, which leaves the packaging question genuinely open in that state.
• Any laboratory water-activity filing requirement in California, Texas, Florida, New York, Pennsylvania, Illinois or Ohio. Searched; none published in the materials retrieved. Illinois comes closest and phrases it as "aim for" [8].
• Georgia's current fee after HB 398. The department's summary of the bill and its own published rule disagree, and the bill text could not be retrieved [30][31]. No post-HB-398 fee figure is asserted here.
• Michigan's current statutory cap. The agency one-pager and the available statute snapshot state different figures; the amending act text was not retrievable [14].
• Accuracy of consumer water-activity devices. The manufacturer specification and the one peer-reviewed evaluation located were both unretrievable, so no accuracy figure is published here, only Minnesota Extension's own characterization of its method as "indicative only" [28].
• A permissiveness ranking of states. No source publishes one. None is invented here.
• Any operator results of our own. Sublime Pantry has bench-tested no freeze dryer and no food, and has no operator practice. Every figure above is either somebody else's published claim, cited, or a labelled assumption.

Next

• Finding your state's cottage food authority — who decides what you are allowed to sell.
• What it costs to run a freeze dryer — the machine cost inside every unit price here.
• What water activity measures — the test several states name, and what it does not settle.