TCS Food (Time/Temperature Control for Safety)

A TCS food, short for time/temperature control for safety, is one that has to be kept cold, kept hot, or sold within a set time, because pathogens can grow in it or make toxins at room temperature. The FDA Food Code (2022 edition) uses the term in place of the older "potentially hazardous food". The Code's list covers raw or cooked animal foods; cooked plant foods; raw seed sprouts; cut melons, cut leafy greens and cut tomatoes; and garlic-in-oil mixtures, unless modified so germs can't grow. The Code's water activity and pH tables (Tables A and B in §1-201.10) can take a food off that list, or flag one as needing a product assessment. A typical cookie is cooked, so it starts on that list, but it comes off because it is dry enough. The Code holds TCS food at 41°F (5°C) or below, or 135°F (57°C) or above.

For a home baker, the difference shows up on the menu. Cookies, brownies, breads and dry mixes are not TCS foods, so they keep on a shelf. Cheesecake, custard and cream pies are: they are moist and need the fridge to stay safe. Jams sit on both sides: a standard high-sugar fruit jam is shelf-stable, while low-sugar jams can be TCS foods, and pepper jellies are often treated as acidified foods that need a tested pH, so many states leave them out.

The line matters because most US cottage food laws only cover non-TCS foods, so a fridge food usually needs a licensed kitchen. A few states now allow some TCS foods from a home kitchen under extra rules. Arizona has allowed them since 2024. Texas has since September 2025, with registration, a made-on date on the label, and temperature-controlled storage and delivery. Tennessee has since July 2025, for food sold in person by the producer or an agent. Wyoming and Utah allow them under their food freedom laws. Rules differ by state and change often, so check your own state agency before adding a fridge food to the table; Ardent Seller's per-state cottage food guides are a starting point.