COLD

BREW COFFEE
TOOLKIT FOR INDUSTRY

Product Description,
Food Safety and
Stability Evaluation

National Coffee Association of U.S.A., Inc. The content of this document is for informational purposes only and should not be
construed as providing
Cold legal
Brewadvice.
Coffee:The NationalforCoffee
Guidance Association
Industry © - NCAof USA, Inc. makes
45 Broadway, Suite 1140 no warranty of legal applicability. You are responsible for knowing and complying with all
local, state, and federal laws relevant to your organization. You should not act upon any
New York, NY 10006, United States such information without first seeking qualified professional counsel on your specific matter
Table of Contents

Cold Brew Coffee Description..................3

Safety Considerations
for Cold Brew................................................................5

Shelf-life, Storage & Handling................... 7

Glossary........................................................................... 10

References.................................................................... 12

Appendix – Common Methods

of Preparation........................................................... 13

Important: About This Document. This document is intended as a starting point - not a
definitive prescription. Each individual manufacturing process is unique, distinct brands have different
goals, and industry, food science, and safety regulations continue to evolve. As a result, this document
should only be used as a reference and as part of an overall food safety program designed specifically
to meet the needs of your particular organization. Cold brew should only be produced under the guid-
ance of qualified individuals. These materials have been produced by a committee of industry experts
and are accurate and up-to-date at the time of publication and may be revised as new information
becomes available.

2 Cold Brew Coffee: Guidance for Industry © - NCA

Introduction
The cold brew coffee category of products is a well-established product platform. Consumers view it
as a premium product, which offers both convenience and quality. Many businesses are considering
cold brew as a potential revenue stream worth exploring, while others have already enthusiastically
entered the market.

This report was produced by a working group of NCA

members and experts from across the industry, in the interest
of maintaining the integrity of cold brew as a method to craft
premium quality and reliably safe beverages.

Our intent is to educate both the coffee industry and consum-

ers on what cold brew coffee is (and is not), as well as provide
best practices for preparation.

Cold brew coffee has unique food safety considerations.

By identifying the extensive and evolving range of product
formats in the marketplace, we can better understand the
industry’s food safety and quality needs and develop educa-
tional and resource tools to aid in compliance with standards
and regulations.

While this document focuses on cold brew coffee in the US, there are basic principles that can apply
to international markets. Note that each country has its own regulations, standards, and customs that
may also need to be taken into consideration, as appropriate.

The popularity of cold brew as a preparation method extends beyond coffee, to include products like
tea, cascara, and cacao. The scope of this report is focused on coffee. Other products have their own
safety concerns, which should be considered on their own. This document is not intended as legal
advice and should not be relied upon exclusively to ensure compliance with applicable local, state,
and federal laws.

Description of Cold Brew

Cold brew coffee is typically made with roasted and ground coffee. The roasted coffee is extracted
with water at ambient or cooler temperatures.

In most cases, the brewing process trades time for temperature – instead of brewing with very hot
water over a very quick duration, cold brewing typically uses ambient or cooler water and extended

Cold Brew Coffee: Guidance for Industry © - NCA 3

periods of time to extract an optimal flavor profile and solids from the beans. Large variations in
temperature may need to be controlled for to help guarantee consistency in extraction.

Factors such as contact time, temperature, roast level, grind size, pressure, or steeping method
may all influence the final brew composition and flavor profile.

Cold Brew FAQ

At its core, cold brew is a brewing method, not a serving method. Here are some common questions
to help clarify this concept:

Is all iced or cold coffee considered “cold brew”?

No. Coffee brewed with hot water extraction methods, whether served hot or cold, is
not cold brew. Cold brew is not simply a marketing term. It does not refer to coffee that
was extracted with hot water and then chilled prior to serving. Instead, it refers to coffee
extracted at ambient or cooler temperatures. The resulting product can then be chilled
or served over ice and be considered iced coffee or iced cold brew.

Is all cold brew coffee served as a cold beverage?

No. Cold brew coffee can be served hot. Again, cold brew refers to a brewing method,
not a serving method. Historically in the United States, cold brew coffee was brewed
as a concentrate, diluted with boiling water, and served primarily as a hot beverage.
(This was prior to iced coffee becoming popular.) Cold brew coffee is also used as an
ingredient in a variety of food and beverage products.

How does cold brew extraction work?

Cold brewing extracts at a lower temperature and generally for a longer time than
conventional hot water extractions. This unique combination of cooler temperature
and longer contact time may produce a unique sensory and quality profile in the
finished beverage.

What are the sensory and flavor characteristics that result from the cold brew
brewing method?
Flavor profiles of cold brew may vary significantly from coffees brewed at higher
temperatures. Common traits typical to cold brew include: less bitterness, smoother
taste, and the enhancement of more delicate flavors. The same coffee brewed by cold
or hot methods can taste either very similar or drastically different when evaluated
side-by-side.

4 Cold Brew Coffee: Guidance for Industry © - NCA

Cold Brew Safety Considerations
Hot, brewed coffee has a long tradition of being a low-risk beverage for food safety. Even so, there
are still important safety considerations for product preparation and manufacturing processes. Anyone
who makes or serves cold brew has an obligation to follow the appropriate steps to ensure the safety
of their product.

Additionally, the US Food Safety Modernization Act (FSMA) requires that certain establishments en-
gaged in manufacturing, processing, or packing food or beverages (including cold brew) comply with a
wide array of regulations and practices, such as completing a comprehensive food safety plan, con-
ducting a hazard analysis, and following Current Good Manufacturing Practices (cGMP).

Specific Cold Brew Considerations

When evaluating for food safety risk, maximum control must be used to mitigate any potential risk of
illness or death at every stop in the process – no matter how remote the risk may be.

Traditional roast and ground coffee (R&G) has a very long history of being safe. There has never been
a food poisoning outbreak related to coffee.

The reasons for this are several-fold:

66 The way that green coffee is grown and stored dry for long periods of time.
66 Coffee is exposed to high heat during roasting (Bonnlander et al, 2013).
66 Coffee grounds are exposed to near-boiling water during brewing prior to consumption, and
hot brewed coffee is typically consumed rapidly (with leftovers discarded once cool).
66 The anti-microbial compounds produced during roasting, and the (potentially) low level of nu-
trients present to support microbial growth (Daglia et al, 1994; Almeida et al, 2006; Arora
et al, 2009; Martínez-Tomé et al, 2011).

The cold brew process removes exposure to hot, near-boiling water before consumption. As such, an
initial assessment of food safety should be carried out by each manufacturer based upon their unique
production process. A re-assessment should be followed after any changes are made to the facility,
formula or recipe, or equipment.

Despite all these unknowns, there are some tried-and-true ways to ensure that cold brew coffee is
safe for consumption:

66 Robust cGMP’s should be in place in the facility that produces the product.
66 A thorough risk assessment by an expert of the facility, ingredients, equipment, finished prod-
uct, and process should be done (HACCP – Hazard Analysis and Critical Control Point, HARPC
– Hazard Analysis and Risk-Based Preventive Controls, Challenge Studies).

Cold Brew Coffee: Guidance for Industry © - NCA 5

 66 A comprehensive change management program that adapts food safety controls to any new
changes in facility, recipe, equipment, or process, and unique needs such as in a retail or man-
ufacturing setting.

Ready-to-Drink Cold Brew Coffee

Ready-to-Drink (RTD) products are beverages that may be consumed as-is without dilution or further
preparation. The RTD packaging and serving format offers convenience and accessibility to the consumer.

There are several key steps inherent to RTD, but important to cold brew processes in general, that
must be taken to avoid a food-safety related incident:

66 Potential food safety risks need to be identified (e.g. product characteristics, processing
techniques, and storage & distribution temperature and time)
66 Create and implement a food safety control plan to address
identified risks
66 Understand that the pH of the product must be closely controlled to
mitigate the risk of Clostridium botulinum, a deadly pathogen, in
hermetically sealed containers. pH control may occur by acidification
or thermal processing.
66 Hire a qualified Thermal Process Authority to write up a recipe and process
that will adequately control for C. botulinum
Challenge
66 Follow the Thermal Process Authority’s instructions to the letter. Studies
66 If there is any deviation from the instructions provided, consult the
Thermal Process Authority on their recommendations for disposing the finished product.
66 Complete challenge studies, which involve testing the ability of unwanted microorganisms to
grow in a product in use and abuse conditions (E.g., If a nitro cold brew is low-acid and pro-
cessed under low-heat conditions, such as in pasteurization, and uses a refrigerated supply
chain, a challenge study could assess for safety from spore-forming bacteria and compare
against an existing formulation as a control.) Designing a challenge study for food safety
determination is outside the scope of this document and should be managed by a qualified
food safety professional.
66 File the thermal process and any challenge study information with the FDA (FDA Site
Registration): https://www.fda.gov/food/guidanceregulation/foodfacilityregistration/acidifiedlac-
fregistration/default.htm

In summary, traditional roast and ground coffee is safe, but cold brew coffee must be evaluated to
prove it is safe. This is done by assessing the ingredients, brewing process, manufacturing facility,
cleaning and sanitation practices, and the finished product’s shelf life.

6 Cold Brew Coffee: Guidance for Industry © - NCA

A robust cGMP program will go a long way to reducing food safety risk. A competent risk assess-
ment (HACCP, HARPC, Challenge Studies) of the facility, ingredients, equipment, finished product and
process will significantly reduce food safety risk. A comprehensive change control program involving
food safety controls around any new changes in facility, formula, equipment or process will account for
almost all the remaining food safety risk.

RTD products are a special category of products which have special requirements, such as hiring a
qualified Process Authority when manufacturing and understanding the role of pH in controlling
C. botulinum and filing the thermal process with the US FDA.

Shelf-Life Testing, Storage & Handling

Shelf-life Testing Considerations
Initiating a shelf-life test of a cold brew product is important for understanding how different factors
may affect product quality or safety over time. These can include formulation and ingredients, the
manufacturing process, packaging type, or storage and distribution conditions.

Conducting shelf-life testing can provide invaluable information for establishing the product best-by
date, which is often determined by evaluating when a product fails to meet a minimum quality stan-
dard. This minimum standard is typically set by experienced and knowledgeable product formulators
or is based on consumer data gathered from sensory testing and consumer complaint information.

The best-by date should not be determined based on food safety. Food safety should be based on
following a comprehensive food safety plan and food safety principles.

This section will identify factors to consider in designing and conducting a shelf-life test to determine
product stability and quality. Due to the complexity of regulatory requirements and the impact to
human health, cold brew coffee manufacturers should conduct challenge testing using a qualified food
safety expert. Designing such a test is outside the scope of this document.

When initiating a shelf-life test, variables to consider in the experimental design may include:

Product Type: Cold brew product formats are often present as dry grounds in roast and
ground (R&G), in liquid form as concentrate, or ready-to-drink strength.

Packaging Format and Material: R&G is often sold in conventional cans, canisters, or bags,
or pre-measured into filter bags or sachets, which is often marketed for at-home or food ser-
vice preparation. Industrial liquid preparations are often bottled in plastic or glass bottles or
dispensed into stainless steel kegs. Choices in packaging material are made for reasons such
as cost, size and dimensions, barrier property for moisture or oxygen, recyclability and sustain-

Cold Brew Coffee: Guidance for Industry © - NCA 7

 ability, printability, and other functional attributes that are important to the retailer/customer and
end consumer. Packaging can also contain plasticizer, or cause flavor scalping (i.e. migration of
flavor components into packaging material).

Temperature and Time: The temperature at which a product is stored or exposed to over a
specified duration of time can significantly affect product stability and food safety. When designing
a shelf-life study, it is important to consider the range of temperatures the product may be exposed
to, and for what duration of time. Test designs often evaluate product at the main storage tempera-
ture predicted for the life of the product, and then may also stress the product by high or low tem-
perature to determine if key quality attributes change or are compromised. Results can then affect
how a product shelf-life date is set, as well as storage, handling, and distribution specifications.

pH: The pH of a food or beverage product is a measure of its acidity, neutrality, or alkalinity. It
can affect the storage stability of ingredients, the perception of sensory properties, and the favor-
ability or inhibitory property of the food matrix to inhibit the growth or survival of microorganisms.

Water Activity (aw): The aw (or % Relative Humidity/100) is indicative of the presence of free
water available in the food matrix. Differences in aw can affect product stability, such as accel-
erating losses in product quality. At higher levels, it can support the growth of microorganisms,
such as molds and yeasts (Jay, 2005).

Formulation Ingredients: The addition of dairy or non-dairy whitener, sweeteners, acidulants,

chemical preservatives, flavor systems, stabilizers, and other ingredients can significantly affect
the quality and safety of a cold brew product, and its classification as cold brew. This includes
ingredients derived from coffee that are not made from ambient or cool temperature brewing.
The incoming quality and microbial load for each ingredient should be carefully reviewed and
evaluated for potential effects on product stability. E.g. When formulating a flavored cold brew
coffee product, consumers often desire natural flavors. A challenge in formulating is that natural
flavoring components often degrade more rapidly than flavors containing artificial constituents.
The flavoring carrier, such as in dry powder or liquid, can also significantly impact product quali-
ty and the characteristics of the flavor’s sensory profile or fidelity.

Processing Conditions: How a product is manufactured can have significant impact on quality
and food safety. Factors to consider may include thermal processing time, temperature, holding
conditions, impact of pressure, turbulent flow, exposure to light, oxygen, stabilizers, equipment
make and model, and settings.

Headspace Gas Composition: Atmospheric gases such as carbon dioxide (CO2), oxygen, or
nitrogen can have varying impact on product stability. Fresh roasted coffee actively degases,
giving off volumes of carbon dioxide (CO2), carbon monoxide (CO), and volatile organic com-
pounds (VOC). Oxygen exposure may also interact with the roasted coffee and contribute to
product oxidation. An inert gas, such as nitrogen, flushed into the product headspace may help
reduce the rate of oxidation.

Light: Light can contribute to sun-struck off-flavors and vitamin degradation in certain liquid
beverage types. Its impact to RTD cold brew coffee is unknown.

8 Cold Brew Coffee: Guidance for Industry © - NCA

An Example of a Shelf-life Test Experimental Design

Test Objective
To learn how storage temperature, time, and packaging material affect
product quality through storage.

Experimental Factors and Levels:

66 Temperature (e.g. 40°F, 70°F, 110°F)
66 Time (e.g. 0 days – 6 months)
66 Packaging (e.g. Clear glass bottle, stainless steel keg with screw cap)

Quality Attributes to Evaluate at Sample Pull Date/Time:

66 Sensory (e.g. A difference-from-control test, comparing against a control)
66 pH
66 Titratable Acidity
66 Opacity or Turbidity

When starting a test, it is desirable to take product produced from commercial-scale trials whenever
possible, as this is most likely to represent the real-world conditions under which sale-able product is
produced, distributed, and consumed.

The experimental design may also often include controls, which help to compare effects produced
by experimental factors or variables. The controls can represent both a negative control (i.e. a con-
trol group that is not subject to the experimental condition or intended to develop an effect) and/or a
positive control (i.e. a control group that is subjected to the experimental condition and is expected to
develop an effect). An action standard may also be set, setting a minimum benchmark against which
other products need to perform at parity or better through the duration of a test. When a product
consistently fails to meet minimum standards defined for safety or quality, then a product would
generally fail the test. If a product is distributed and sold at ambient conditions, then a shelf-life test
may often, but not always, be conducted to include a room temperature variant. When a product fails
to consistently meet minimum standards after being held at these conditions, then a shelf-life
determination can often be made from this evaluation. If a variant is stored at a higher temperature,
then this may often be called stressed or accelerated testing conditions. A determination to relate high
temperature to ambient testing conditions can only be made after the product type has been thor-
oughly evaluated at both temperatures and related for quality or safety attributes.

When determining the number of samples to put into the study, a common practice is to evaluate
samples at each time point in duplicate or triplicate. This helps to control for any outliers and minimize
sample error and variances.

Cold Brew Coffee: Guidance for Industry © - NCA 9

Glossary
Ambient: Ambient or “room temperature” refers to the temperature of the surrounding air and
is not necessarily correlated to a specific temperature range. For coffee brewing purposes, am-
bient temperature water is the same temperature as the surrounding air; ambient temperature
brewing is brewing conducted at room temperature, or the same temperature as the surround-
ing air and environment.

Bag in Box / BnB / BIB: A type of container used for the storage or transport of liquids. It often
consists of a strong inner bladder or bag, often composed of several layers of metallized film or
plastic and seated inside a corrugated fiberboard box.

Best by date: Last date that guarantees optimal quality of the product.

Body: The way the beverage is perceived on the tongue. ‘Heavy’ body is
like full fat milk. ‘Thin’ body is like water.

°Brix: The percent of soluble solids in a given solution, and where the main
soluble solid is often dissolved sugars.

Challenge Studies: Microbiological testing of a product to determine its

capability of supporting or inhibiting the growth of microorganisms. Test-
ing can be performed at different aspects of a product’s lifecycle, e.g. from
initial formulation, processing at a specific time/temperature condition, at a
preventive control, or at shelf-life stressed or accelerated testing conditions.

Coffee Concentrate: Coffee that has been brewed stronger than typically
consumed or otherwise had water removed, concentrating the solids; It is
intended to be diluted prior to serving.
Iced Coffee
Heavy Body
Coffee Extraction: Coffee extraction, or brewing, is the process of dissolv-
ing soluble flavors and compounds from coffee grounds into water.

HACCP: Hazard Analysis and Critical Control Point. A defined process in which potential haz-
ards and means of controlling the hazards are identified. Hazards can be biological, physical,
chemical, or radiological in nature.

HARPC: Hazard Analysis and Risk-Based Preventive Controls. A provision of the Food Safety
Modernization Act (FSMA) that requires any entity handling food to identify hazards, implement
controls to reduce the hazards, conduct verification activities to show that controls function, and
implement corrective actions for any deviations that may occur in a process.

Iced Coffee: Coffee that has been brewed hot or cold and served chilled and/or over ice. Can
also be cold brew coffee served over ice. Note: Iced coffee cannot be considered cold brew
unless it is prepared following a cold brew process (i.e. methods described within this document
using ambient or cool water in extraction).

10 Cold Brew Coffee: Guidance for Industry © - NCA

Low Acid Food: “A low acid canned food is any food (other than alcoholic beverages) with a
finished equilibrium pH greater than 4.6 and a water activity greater than 0.85, excluding toma-
toes and tomato products having a finished equilibrium pH less than 4.7.” - https://www.fda.gov/
Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/AcidifiedLACF/default.
htm

Nitro Coffee: Brewed coffee that has been infused with

nitrogen gas. Nitro Coffee
pH: The concentration of hydrogen ions in solution; Also, a
measure of how acidic, neutral, or basic a solution is. The
pH of a food or beverage product is a measure of its acidity,
neutrality, or alkalinity. It can affect the storage stability of
ingredients, the perception of sensory properties, and the
favorability or inhibitory property of the food matrix to inhibit
growth or survival of microorganisms.

Ready to Drink (RTD): A beverage that can be consumed

as-is; no mixing or further preparation needed.

Shelf Life: The duration of time that the product maintains optimal quality.

Titratable Acidity: A measure of the total acidity in solution contributed by all constituents.
Total Dissolved Solids (TDS): Inorganic salts and some organic matter dissolved in water.

Cold Brew Coffee: Guidance for Industry © - NCA 11

References
Almeida, A.A., Farah, A., Silva, D.A., Nunan, E.A., & Gloria, M.B. (2006). Antibacterial activity of coffee
extracts and selected coffee chemical compounds against enterobacteria. Journal of Agricultural and Food
Chemistry, 54(23), 8738-8743.

Arora, D.S., Kaur, G.J., & Kaur, H. (2009). Antibacterial activity of tea and coffee: Their extracts and prepara-
tion. International Journal of Food Properties, 2, 286-294.

Daglia, M., Cuzzoni, M.T., & Dacarro, C. (1994). Antibacterial activity of coffee. Journal of Agricultural and Food
Chemistry, 42(10), 2270-2272.

Bonnländer, B., Eggers, R., Engelhardt, U.H., & Maier, H.G. (2005). Roasting. In R. Viani (Ed.), Espresso
Coffee: The Science of Quality (pp. 179-214). New York, NY: Elsevier.

Jay, J.M., Loessner, M.J., & Golden, D.A. (2005). Modern Food Microbiology. New York, NY: Springer.

Martínez-Tomé, M., Jiménez-Monreal, A.M., Garcia-Jiménez, L., Almela, L., García-Diz, L., Mariscal-Arcas,
M., & Murcia, J. A. (2011). Assessment of antimicrobial activity of coffee brewed in three different ways from
different origins. European Food Research and Technology, 233, 497-506.

https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/AcidifiedLACF/
default.htm

https://www.fda.gov/food/guidanceregulation/foodfacilityregistration/acidifiedlacfregistration/default.htm

12 Cold Brew Coffee: Guidance for Industry © - NCA

Appendix: Common Methods of Preparation
Whether brewing at home, in a café or at a production scale, the basic preparation methods for mak-
ing cold brew remain virtually the same. But if you look more closely at the brewing method, there are
several variables that can be manipulated to greatly change the resulting extract. As we illustrate in
the Definition section, some changes to the brewing parameters render the coffee materially different
than cold brew coffee.

The primary variables in the brewing process are grind size, water temperature and steeping time.
Let’s take a closer look at several common preparation methods to understand how these variables
can be altered.

Full Immersion: Cold brewing with full immersion is the process of steeping coffee grounds in
water – quite a few brewing devices on the market utilize this concept in one form or another.
With full immersion, the coffee and water stay in contact during the full duration of brewing; at
the end of the brewing duration, the coffee extract liquid is filtered from the coffee grounds.
The variables at play are typically:

Grind Size: Grind size can impact the extraction rates of various chemical compounds, and
therefore can impact flavor profiles, total dissolved solids (TDS) and body.

Brewing Duration: Also referred to as dwell time, the amount of time that the water and
ground coffee come into contact will impact the extraction of some compounds.

Water Temperature: Water temperature impacts the extraction of temperature-sensitive com-

pounds, the release of gas from the grounds and impacts the water’s ability to permeate dry
pockets of ground coffee.

Ambient Temperature: The temperature of the surrounding air and environment, often con-
sidered room temperature.

Filtration: The process of separating coffee liquid extract from solids through a porous me-
dium, where the mesh or pore size can impact the amount of coffee solids, flavor, body, and
shelf-life of the final extract.

Agitation: Creating motion by mixing, shaking, or stirring, which for coffee can impact the wa-
ter’s ability to saturate all coffee grounds evenly, and can speed the release of gas from ground
coffee and increase extraction rate.

Pressure: The amount of force exerted over a specified area and over which that force is then
dispersed.

Cold Brew Coffee: Guidance for Industry © - NCA 13

 Drip Tower: Making cold brew with a drip preparation differs from full immersion in that drops
of water pass through a bed of coffee grounds throughout the full duration of the brew. As the
coffee grounds become saturated, the coffee extract exits the bed of coffee grounds drop-
wise. The variables at play are typically:

Drip Rate: The speed of the drip impacts the amount of time that the water and ground coffee
come into contact over the total duration of the brew and will impact the extraction of some
compounds.

Batch Size / Vessel Size: Batch size and vessel size can change how long it takes to get all
the coffee grounds wet enough to extract and therefore can also impact the total amount of
time that water and coffee come into contact.

66 Grind Size
66 Water Temperature
66 Ambient Temperature
66 Filtration

Hot Bloom: Hot bloom is a modification on the above preparation methods where near-boil-
ing water is added at the beginning of the brewing process to initiate a “bloom,” followed by a
quick dousing of cold water to stop hot water extraction and transition to cold water extraction.
This hybrid brewing method aligns with some parts of the cold brewing definition and still has
many of the same inherent food safety concerns. The addition of hot water, however, puts the
hot bloom preparation method into a brewing method gray zone, as it creates a significant
departure from many of the common characteristics of cold brew coffee. This is differentiated
from the cold brew preparation method, as cold brew uses ambient or cool water throughout
the entire duration of the brew process. In cold brew, no hot water (or water greater than ambi-
ent in temperature) should come into contact with the grounds.

Continuous Extraction: A method by which coffee is extracted continuously for a set time.
Ice Brew: Brewing coffee hot and then flash chilling.

* Certain variables, such as the specific coffee beans selected, water quality, water-to-coffee ratios, and the cleanliness of the brewing equipment
are relevant to all preparation methods. Many of these variables are also relevant in hot water brewing methods.

14 Cold Brew Coffee: Guidance for Industry © - NCA