Manufacturing jam, jellies and other processed plant-based products in Georgia: what to
check before launch

Mandarin jam, berry jelly, fruit leather, dried fruits, vegetable sauces, marinades, purees, and other processed plant-based products look like a simple and straightforward business. It seems that all you need is a product, packaging, an Instagram account, and a few retail shops for distribution to get started.

In practice, things are much more complicated. As soon as a product is manufactured for sale rather than "for personal use," the business falls under food safety regulations. This entails requirements for facilities, food business registration, HACCP, traceability, labeling, advertising, consumer sales conditions, and, if exporting is planned, documentation required by the destination country.

The main risk is not that "an inspector will show up and ask for a single piece of paper". The risk lies elsewhere: a single customer complaint about mold, a bloated lid, incorrect ingredients, or a misleading statement on a label can trigger an investigation across multiple regulatory areas simultaneously.

This material is for manufacturers who produce or plan to produce products from plant-based raw materials in Georgia: jams, jellies, confitures, fruit purees, fruit leather, dried fruits, sauces, syrups, pickled vegetables, nut-based products, and similar items.

We will not delve deeply into company registration, taxes, personal data protection, or HACCP implementation. JUST Advisors has separate materials covering these issues:

• Business Registration in Georgia
• Legal Services for Companies in Georgia
• Comprehensive Corporate Legal Support

In this article, we will focus on what most frequently becomes a problem specifically for food manufacturers: food business operator status, labeling, advertising claims, Bio/Organic designations, export, and inspections.

A legal review does not begin with company registration or label design. It begins with a simple question: what exactly are you selling?

For example, "mandarin jam," "fruit dessert," "confiture," "puree," "sauce," and "paste" might look similar to a customer, but legally and for export purposes, they are not always the same thing. The product name must match its composition and production technology. If the front of the label reads "mandarin jam" while the bulk of the product actually consists of apple puree, this is no longer a minor marketing detail, but a potential risk of misleading the consumer.

Before launching sales, you must finalize the recipe, technology, composition, shelf life, storage conditions, packaging, target market, and export country. Without this, it is impossible to correctly prepare labels, HACCP documentation, and agreements with retail stores or distributors.

For standard production of jam or jellies from plant-based raw materials, the issue is usually not a "food license," but rather the correct registration of food activity and adherence to safety requirements. The Code requires a business operator to register their relevant activity and prohibits operating without registration.

In practice, this means you cannot simply set up an Instagram page, rent a kitchen, and begin selling jars as a commercial product. A separate "recognition" procedure does not apply to all manufacturers. It is especially critical for specific business categories, such as those involving products of animal origin. However, this does not mean plant-based processing manufacturers are exempt from oversight. The National Food Agency can still inspect the production facility, documentation, labels, traceability, and product safety.

For food manufacturers, HACCP is a way to prove that the business understands exactly where a product could become unsafe and knows how to control those points. For jam and jelly, critical points usually include receiving raw materials, sorting fruit, washing, cooking, preparing jars and lids, filling, cooling, storing, and releasing batches.

• For dried fruits: Raw material quality, drying, moisture levels, storage, pest control, and packaging.
• For sauces and purees: Heat treatment, acidity levels, containers, airtight sealing, and shelf life.

Traceability is of distinct importance. If a consumer complains about a specific jar, the manufacturer must quickly identify which batch it came from, what fruit was used, who the supplier was, when it was produced, where the rest of the batch went, and whether a product recall is necessary. If such a system is missing, even a minor complaint can escalate into a major issue.

A label is a manufacturer's official declaration about the product. Resolution No. 301 requires consumers to receive clear, accurate, and non-misleading information about a food product.

For products sold in Georgia, mandatory information must be provided in the Georgian language. Russian, English, or other languages can be used additionally, but the Georgian information must not be a superficial "sticker for the sake of appearances".

The following items are typically checked on a label: product name, ingredients, net quantity, shelf life, storage conditions, details of the responsible operator, batch number, country of origin or place of provenance, allergens, nutritional value (if mandatory or declared voluntarily), and instructions for use if the product could be used incorrectly without them.

Special attention is given to the front of the packaging, as it primarily shapes consumer expectations. If "100% Mandarin" is written in large text, but the ingredients include an apple base, syrup, or other fruit fillers, this must be legally verified before printing. If it says "sugar-free" but honey, syrup, or concentrate is used, this also poses a risk. If a product is labeled "for children," "medicinal," "for immunity," or "beneficial for colds," specific legal grounds are required, though it is often better to avoid such claims altogether.

A good case study: The Georgian Competition and Consumer Agency's case against natural juice manufacturer Campa LLC. The front of the packaging positioned the product as "100% Cherry and Pomegranate Juice," but the back label indicated in small print that the product contained 80% apple concentrate and only 10% each of cherry and pomegranate concentrates. The Agency ruled that such labeling misled the consumer and ordered the information on the packaging to be modified (For details, see the GCCA decision/news).

For jam manufacturers, this example is highly illustrative. A mistake on a label can be just as dangerous as a mistake in a contract.

The words "bio", "organic", "eco" cannot be used simply because a product is "natural", "homemade" or "from a village". The Code explicitly prohibits using these designations if the product does not comply with bio-production rules and lacks certification.

Resolution No. 198 regulates the production, processing, labeling, sale, and certification of organic products. This applies not only to the physical label. Risks also arise in brand names, product descriptions on websites, Instagram, marketplaces, or commercial offers sent to stores or export buyers.

For instance, the phrase "organic mandarin jam" without a verified status is not a creative marketing pitch; it is a legal claim. If a manufacturer lacks documentation for organic raw materials, a certified supply chain, and proper certification, using these designations is hazardous. It is wiser to decide in advance whether you are truly building an organic production facility or simply want to emphasize a natural ingredient list - these are completely different legal models.

If a product is sold through a website, Instagram, Facebook, Telegram, a marketplace, or an order form, the manufacturer must comply with consumer protection laws.

The buyer must understand who the seller is, what product they are purchasing, the price, the ingredients, the shelf life, how to store the product, how the order is delivered, how to file a claim, and under what circumstances returns are accepted. A common mistake among manufacturers is to prepare the label, website, and Instagram account in isolation from one another. As a result, the jar says one thing, the product page says another, and the advertisement says a third. For a regulatory body, this is not "marketing flavor," but a potential case of misleading consumers.

The National Food Agency can conduct audits, documentary checks, monitoring, sampling, and laboratory analysis. An inspection can be triggered not only by a scheduled plan but also by a complaint, a report of potential poisoning, a referral from another government agency, or a detected hazard.

NFA practice demonstrates that unscheduled inspections are frequently linked to specific incidents. For example, following a notification from the National Center for Disease Control regarding food intoxication cases, the NFA conducted an unscheduled inspection of the Food Gallery Georgia facility, identified critical non-compliances, suspended the production process, issued directives, and took samples (For details, see the NFA news report).

In another case involving suspected water poisoning in Bakuriani, the NFA launched an inspection upon notification, reviewed the technological cycle, and sampled water (For details, see the NFA news report).

Additionally, the NFA published information stating that during HACCP implementation, inspectors issued over 1,000 recommendations, and approximately 100 business operators were fined for failing to comply with directives (For details, see the NFA material).

For a manufacturer of jam, jellies, or dried fruits, this means an inspection can start from a single customer complaint. If you lack documents for raw materials, batches, shelf life, HACCP, labeling, and storage conditions at that moment, mounting a defense will be difficult.

If you plan to sell your product outside of Georgia, you must check the specific requirements of the destination country. There is no single universal export package that fits all markets.

Generally, you need to determine the commodity code, check destination country regulations, prepare an export label in the required language, align product composition with the importer, verify laboratory parameters, check packaging compliance, obtain a certificate of origin if necessary, and prepare customs paperwork.

The Revenue Service of Georgia provides information on certificates of origin and trade regimes. This is essential if a manufacturer wants to benefit from preferential tariffs, such as when exporting to a country with which Georgia shares a trade agreement (For details, see Revenue Service - Certificate of Origin).

If the product is intended for the EU market, complying only with Georgian law is insufficient. Specific rules apply to jams, jellies, and marmalades within the EU, including requirements regarding composition and product naming. General EU rules on providing food information to consumers also apply (For details, see EU rules on fruit jams and Regulation 1169/2011).

Practical conclusion: A label that is perfectly fine for sale in Tbilisi will not necessarily work for Germany, Poland, France, or the UAE. Your export model must be verified before the first batch is manufactured, not after.

Before launching sales, a manufacturer needs to ensure that:

• The legal model of the product is clear.
• Food activity is correctly registered.
• HACCP documents are prepared.
• Batch tracking is operational.
• Invoices/documents for raw materials and packaging are available.
• The label is finalized and approved.
• Marketing and advertising claims have been checked.
• Terms of sale are set up.
• A protocol for handling consumer complaints is in place.

If export is planned, you must separately verify the destination country, commodity code, ingredient requirements, label language, certificates, laboratory indicators, and the importer's required paperwork. This is not bureaucracy for the sake of bureaucracy; it is a system that allows a manufacturer to work confidently with retail stores, distributors, inspectors, and foreign buyers.

Manufacturing jam, jellies, and other processed plant-based products in Georgia can be a promising business. However, a safe launch does not start with a beautiful jar or a first delivery to a retail shop. First, you must understand exactly what you are manufacturing, how it is regulated, what claims you are making to the consumer, what liability you are accepting, and what documents you can present during an inspection.

The most expensive scenario is fixing labels, HACCP plans, contracts, and export paperwork after a complaint has been filed or a batch has been halted. It is far more reliable to integrate legal requirements into your business structure before making your first sale.
Have a task or a question? Reach out to JUST Advisors - we will help verify your production model, labels, and documents before they turn into a problem.