Hello and welcome back. I know it's been quite some time since I've posted to this blog and I'll tell you why in this post. To begin, I hope that all is well with you and your families and friends. We are living in strange times and I know for me, it has been difficult at times to continue with life as if all is well. Ultimately, I know that life goes on and in a few short months I will once again be foraging for mushrooms, anxiously watching wild plums, blackberries, huckleberries, and of course elderberries return to their splendor in full bloom.
After a relatively mild Winter, February hit us locally with it's full wrath. Unlike the poor souls in Texas and other states, we are well prepared for this with generator backup (thankfully not needed this year), a full pantry, a solid supply of firewood, full tanks of propane for cooking, and freezers full of food as well as a huge stock of frozen elderberries. At this point in time, temperatures have increased and the 3+ feet of snow we got in February has started to melt and that glorious burning orb in the sky (the sun) has returned. Hopefully the days of spending several hours plowing paths to the chicken coop, woodshed and driveway are once again behind us and daily snow shoveling won't resume for several months. I'm looking forward to starting to post more about our outdoor activities like bat house building and installation, raised bed garden replacement, composting, mushroom picking and such, but for now, it's all about Bitterroot Botanicals of Idaho Wildcrafted Elderberry Syrup.
When we started this endeavor about nine months ago, we knew we had a great product. We had been told for over 15 years by family and friends that we should market and sell it. In fact, when we moved to Idaho about eight years ago, that was one of our plans. Whenever I started to seriously consider it, I would become overwhelmed with the logistics of the process and once again abandon the idea in favor of a more traditional income stream. In the end, that traditional income stream had it's advantages, but was on the whole, unfulfilling. And so, the adventure began!
Since I've spent most of my adult life as a small business owner, I knew that in order to be considered a legitimate business, there would be a multitude of filings required. Business name registration, Federal and State EIN, LLC registrations, corporate entity filings, articles of incorporation, Certificate of Existence etc. And yes, in Idaho, a Certificate of Existence is actually a thing LOL. After all of the other filings, I received a notice of a required Certificate of Existence for a mere additional $75. Now, on the bright side, you can pay a company a nominal fee of around $1000 to insure that all of this paperwork is filed in the right places, in the right order, at the right time. I elected to take this "easier, softer route" and threw my money at them to get it done. This nominal fee also insures me of a lifetime of junk emails from other entities looking for a few bucks to provide me with crap I neither need nor want. I guess the ends justifies the means, and BAM, we were a business.
WTH IS A COTTAGE FOOD INDUSTRY?
Now that we were an official business, we wanted to sell our product and create income. We contacted our local Idaho Department of Health representative and inquired about the next steps. We were told that there were exemptions in Idaho for small businesses creating food products to be sold ONLY in Idaho. This would allow us to manufacture, market, sell, and deliver or ship our product within the State without jumping through the rest of the food product regulations and registrations. We were told at that time that in order to expand our sales to other States, we would have to produce the food in a commercial kitchen. And, oh yeah, there might be some other requirements. I nominate this verbage as Understatement of The Year. But it seemed like a good place to start, so we did. We chose and ordered our bottles, created and ordered labels with our new logo, and made a batch of Elderberry Syrup. BTW, most States have regulations similar to Idaho's Cottage Food Industry regulations and most of the Elderberry products you see for sale on Etsy, Facebook Marketplace and other social media platforms are in violation of State and Federal regulation. Bitterroot Botanicals of Idaho Wildcrafted Elderberry Syrup is fully certified, correctly labeled, and production, marketing and sales are regulated by the FDA and the Idaho Department of Health. This is no small feat as we are treated the same, and under the same regulations, as companies like Del Monte Foods, Ore Ida, Kirkland and other food product giants. Much more on how we got here later in this post.
NOW THAT WE'VE MADE A BUNCH OF THIS STUFF, WHAT DO WE DO WITH IT?
Internet marketing is obviously the current answer to this question. So, we needed a website. I'm not completely illiterate in the ways of technology, but this is where a member of a younger generation was needed for help and input. Our 18 year old son was of considerable help here. He did the necessary research looking for DIY website design platforms and found one that suited our needs and would incorporate informational pages, an online store with the ability for our customers to order, pay for, select shipping options, collect sales tax, and allow for future expansion into markets and other products. The actual content and design was a family effort with everyone making contributions of photos, backgrounds, product descriptions, pages, text fonts and presentations etc. This involved frequent family business meetings, and I'm happy to say general consensus on our final layout. I am certainly hopeful that it will remain adequate for our needs and will continue to evolve as our business does. This step required another "nominal" financial outlay, and further assured us of an endless supply of SPAM emails for our entertainment. After several months of relative trouble free operation, the website host decided that our product was "nutraceutical" in nature, and that we could no longer use their services for accepting credit card payments despite my continued assertions that this was in fact a food product. We also had difficulties advertising on FB, and at times would have our ads removed by them because of the nature of the product. Really frustrating when you can find the same product for sale by 20 other people on the same platform. This product is a food product ONLY. It is now registered with the FDA and IPH as a food product. Oh well! I guess Square will collect the credit card processing fees instead of WIX. We were still limited to marketing, sales, and delivery or shipment of our product to within Idaho because we were operating under Cottage Food Industry regulation. We found out that we could not even give the product to anybody out of State without being in violation. And so, we forged ahead.
"WHEN THE GOING GETS WEIRD, THE WEIRD TURN PRO" Hunter S Thompson
This quote from my favorite author pretty well describes the next phase of our journey. It was now late August, and sambucus negra elderberries were getting ripe at higher elevations. We knew that in order to have sufficient stock to succeed, we would have to turn our attention to wild harvesting these beauties for the next several months. It was gut check time. Shi+ or get off the pot to coin a crass phrase. We had invested so much time, energy, effort, and money at this point, we couldn't get off the pot. We began to spend days, with the entire family out crashing through brushy thickets, collecting this beautiful bounty of nature. Taking off at 6 am, water and tea jugs full, lunches packed, and eyes barely open, we were treated to some amazing sights. Sunrises over the Clearwater mountains and on the Salmon River, wildlife everywhere including all types of birds, ungulates, cougars.... It was an incredible opportunity to spend quality time with the family. After a day of picking we would get home, wash the berries, and prepare them for "shucking" or removing them from the stems and packaging and freezing them. We developed more efficient methods for the processes required. On days we didn't pick, we would continue our contact with the Idaho Department of Health, and now the Idaho Department of Agriculture, and FDA representatives asking what our next steps should be We were becoming Pros, except we still were not really able to make money since our ads were being deleted by FB and we could only market and sell in Idaho. Picking season ended abruptly the last weekend of October when a really hard freeze, even at lower elevations rendered any berries useless. And still, we continued forward.
AND NOW, FOR THE REST OF THE STORY!!!
A paraphrase from Paul Harvey's radio show seems to be a fitting title to the flurry of activity that occurred from November 2020 to today, 03/04/2021. Our elderberry harvest was complete, the woodshed was stocked, freezers were full even though availability was in doubt due to people suddenly deciding that they needed one (we needed six more), hunting season was mostly past, let's get the business up and running!! Eventually, my original contact at the Idaho Department of Health, which was the government entity we were primarily involved with at this point, seized upon an opportunity to pass our file on to a different inspector due to our physical location. I'm pretty sure he was more than happy to be rid of us since we had become a "squeaky wheel" and weren't going away. I would send an email requesting additional information on the next steps, wait a week or so, send a follow up email, and then call the next day and leave a message. Once our case was handed off to another inspector, we got a detailed list of what we needed to do. IT WAS MASSIVE!! It would have been much easier and cheaper to stand down and give up. But noooo, we were in for a penny, in for a pound. This was personal. It was also an opportunity to demonstrate to our son the benefit of perseverance, determination, and possibly the folly of stubbornness.
The following is a list of required steps we took to be able to manufacture, market, and sell our product legally. Keep in mind that most of the small manufacturers of this product have chosen not to accomplish these as they require a huge commitment of time, energy, and money. Each of these steps had fees associated with them, ranging from $50-$500, and many of them had to be repeated, you guessed it, with the fees being paid again.
1) Certificate of satisfactory completion of Better Processing School. This is actually a 5000 level college course. It is required under 21CFR (FDA regulation) for processing and packaging of acid foods, acidified foods, low acid foods, fermented foods, carbonated beverages. Basically anything other than meat, dairy, or poultry. Major food manufacturers, like Frito Lay, Nabisco, Coca Cola, Del Monte, are under the same regulation as Bitterroot Botanicals of Idaho. This course was anything but a no brainer. I did learn a lot from it, and in fact, put the information to use frequently. Yup, spent a few bucks on this one LOL
2) Certificate of satisfactory completion of Food Product Safety Manager course. This is actually a course required for restaurant managers, grocery store deli managers, caterers, and similar professionals. Ironically, I know restaurants that don't have this course certification. They were quite surprised to find out that I do have it under my belt, and offered me unlimited
burgers in exchange for listing me as their FPSM certificate holder. Nuh uh, pass it yourself. IMO this was a waste of
3) Certificate of Food Process Risk Analysis and Certified Process Letter. This was a dandy!! Basically it involved manufacturing, packaging, and labeling a sample and shipping it to an independent laboratory along with emailing a thorough description of the process, packaging, and pertinent details of the product. The details include PH measurements in various steps of the process, product temperatures at the time of PH measurements, product temperatures at the time of packaging, all ingredients used along with an incoming inventory log of where the ingredients came from and what date they were obtained, calibration records of PH meters and thermometers and manufacturers of this equipment. In return for this information and
we get a document either approving our product and process, or denying it. Oh yeah, we couldn't continue with the Idaho Department of Health without completing this and it takes 3-4 weeks. ;(
4) HACCP plan and review. Now we got to complete the Hazards Analysis and Critical Control Point plan for review. This is where we identified potential hazards in production and packaging and critical control points and explain how we deal with each. This plan required formal SOP's, training programs and logs, list of equipment, calibration procedures and training, product recall plans, inventory receipt and inspection logs, shipping logs, batch logs, food flowcharts and
These were just the highlights. There was also FDA nutritional content labeling, GS1 barcode registration, weights and measures regulation, commercial kitchen rental and more
As of yesterday, 03/03/2021, we completed our final health department commercial kitchen and documented process inspection. We made our first fully commercial and marketable batch. With all of these hoops, it's easy to see why most people elect to take their chances with being shut down. I suppose the adage "let the buyer beware" is appropriate here. I can see how undocumented food products and processes could be hazardous to the consumer. It's unfortunate that in order to legally produce and sell your product requires so much time and money. As usual, big corporations have successfully limited their competition by pricing small companies out of the market. Not us though!!! We were too stoopid to realize and accept that fact. BE WELL FOLKS, and try to ignore the craziness we are all surrounded by and subjected to on a daily basis. Remember, very soon apples will once again grow on trees, and that's always a sure sign for me that everything will be okay.