A bubble tea franchise usually binds you to one supplier for tea, tapioca pearls, syrups and cups: in four 2025 to 2026 FDDs, restricted purchases run from 15% to over 95% of spending.
Key takeaways
- Sharetea’s Item 8 requires you to buy Premium Tea Leaves, Tapioca Pearls, Flavor Syrups, Toppings and Branded Cups “directly from our parent company or other suppliers we designate,” over 95% of purchases (Sharetea FDD, March 5, 2026).
- Kung Fu Tea’s affiliate Arms Global Inc. is the only permitted source of all tea, concentrates and cups, and received $19,777,632 from franchisee sales in 2025 (Kung Fu Tea FDD, Item 8).
- Gong cha estimates that designated or approved suppliers account for approximately 90% to 100% of opening purchases and 85% to 95% of ongoing costs, paid five business days before the clean bill of lading (Gong cha FDD, Item 8).
- Item 7 lines payable only to the franchisor or its affiliate range from $44,000 (Kung Fu Tea, low) to $213,300 (Sharetea, high) before the first drink is sold (our arithmetic from Item 7 of each FDD).
- Cooked tapioca is a heat-treated plant food, which the FDA Food Code 2022 (1-201.10) treats as time/temperature control for safety food unless pH or water activity data show otherwise: hold at 41°F or below, 135°F or above, or use a 4-hour limit (3-501.19).
Who must sell you the tapioca, tea and syrups?
In all four boba FDDs we opened, the franchisor or a company tied to it is a required or designated source of core drink ingredients. Sharetea names tapioca pearls outright, Kung Fu Tea routes all tea and cups through Arms Global Inc., Gong cha requires its Proprietary Products from GCPS, and Tapioca Express designates its affiliate Big Stage, Inc. for syrups, tea leaves and toppings.
Item 8 of every franchise disclosure document has to list these obligations. The FTC Franchise Rule at 16 CFR 436.5(h) requires each franchisor to name the goods you must buy, say whether it or an affiliate is the only approved supplier, explain how alternative suppliers are approved, and disclose revenue it earns from your required purchases. Our guide to reading a franchise disclosure document covers the other 22 items.
| Brand (alphabetical) | Required source of drink ingredients | Items the FDD names | Source |
|---|---|---|---|
| Gong cha | Gong cha USA Product Supplier, LLC (GCPS), a wholly owned affiliate, or another supplier the franchisor designates | All Proprietary Products; the franchisor may also designate the brand, maker and source of all other Supplies | Gong cha US Unit FDD issued March 25, 2026, Items 1 and 8 |
| Kung Fu Tea | Arms Global Inc., an affiliate; “You may not purchase these items from any other supplier” | All tea, coffee, concentrates and flavoring ingredients, packaging materials, cups, menu boards, signs | Kung Fu Tea FDD issued April 20, 2026, revised July 6, 2026, Item 8 |
| Sharetea | The parent company, Lian Fa (formed in Taiwan in 1992), or designated suppliers | Premium Tea Leaves, Tea Powders, Tapioca Pearls, Flavor Syrups, Concentrates, Sweeteners, Toppings, Branded Cups, Lids, Straws, Equipment | Sharetea FDD issued March 5, 2026, Items 1 and 8 |
| Tapioca Express | Tapioca Express, Inc., its affiliate Big Stage, Inc., or designated suppliers | System Supplies; Big Stage supplies syrups, powdered sugars, tea leaves, toppings, paper products, straws and utensils | Tapioca Express FDD issued September 18, 2025, Items 7 and 8 |
Sharetea is the only one of the four filings that prints the words “Tapioca Pearls” in its Item 8 purchase list. Kung Fu Tea’s list covers “flavoring ingredients” and “concentrates”, and Gong cha’s covers “Proprietary Products”, so a buyer of either system should ask which line the pearls fall under before signing.
How much of your spending is locked to approved suppliers?
Each franchisor estimates in Item 8 what share of your purchases must come from approved sources or meet its specifications. The four estimates differ sharply: Kung Fu Tea says 15% to 20% at opening and 25% to 35% ongoing, Tapioca Express 75% to 90% and 50% to 65%, Gong cha 90% to 100% and 85% to 95%, and Sharetea over 95% for both.
| Brand | Share of opening purchases restricted | Share of ongoing purchases restricted | Source |
|---|---|---|---|
| Gong cha | approximately 90% to 100% | approximately 85% to 95% | Gong cha US Unit FDD issued March 25, 2026, Item 8 |
| Kung Fu Tea | approximately 15% to 20% | 25% to 35% | Kung Fu Tea FDD issued April 20, 2026, revised July 6, 2026, Item 8 |
| Sharetea | over 95% | over 95% | Sharetea FDD issued March 5, 2026, Item 8 |
| Tapioca Express | approximately 75% to 90% | approximately 50% to 65% | Tapioca Express FDD issued September 18, 2025, Item 8 |
Low end of each franchisor’s Item 8 estimate of purchases that must come from approved suppliers or meet its specifications. Source: four FDDs on Minnesota CARDS, accessed November 2, 2026.
The low Kung Fu Tea opening figure sits beside a sole-source rule for tea and cups. One reading of its own Item 7 is that build-out dominates opening spend: leasehold improvements and architectural costs run $40,000 to $150,000, payable to the landlord and independent contractors, while the initial inventory line is $15,000 to $25,000. The franchisor does not explain the number, so ask for the method behind it.
Kung Fu Tea’s Item 6 also prints a monthly figure for the restricted goods: inventory of tea, coffee, packaging materials, cups and other items for resale runs $2,500 to $35,000 per month, depending on sales volume, bought from the franchisor’s list. Our study of supplier restrictions and rebates in 259 FDDs places these four filings against the wider franchise sample.
Supply revenue on the franchisor side of the counter
All four franchisors, or their affiliates, report seven or eight figure revenue from franchisee supply purchases in Item 8. Arms Global Inc. took more than 99% of its 2025 revenue from Kung Fu Tea franchisees, Sharetea’s parent took about 42.42%, Tapioca Express 76%, and Gong cha 21%. These are company revenue figures that Item 8 must disclose, not shop sales.
| Brand | Company receiving the money | Revenue from franchisee purchases | Share of that company’s total revenue | Period and source |
|---|---|---|---|---|
| Gong cha | Gong cha USA Franchising, LLC | $2.56 million from unit franchisees | 21% of $12.22 million | Fiscal year ending December 31, 2025; Gong cha US Unit FDD issued March 25, 2026, Item 8 |
| Gong cha | GCPS (affiliate) | approximately $9.66 million from U.S. master franchisees | Not stated | 2025; Gong cha US Unit FDD issued March 25, 2026, Item 8 |
| Kung Fu Tea | Arms Global Inc. (affiliate) | $19,777,632 | more than 99% of $19,913,878 | 2025; Kung Fu Tea FDD issued April 20, 2026, revised July 6, 2026, Item 8 |
| Sharetea | Lian Fa (parent) | $15,546,866.71 | approximately 42.42% of $36,648,882.67 | Fiscal year ending December 31, 2025; Sharetea FDD issued March 5, 2026, Item 8 |
| Tapioca Express | Tapioca Express, Inc. | $1,328,335 from sale of goods | 76% of $1,749,026 | Fiscal year ending May 31, 2025; Tapioca Express FDD issued September 18, 2025, Item 8 |
| Tapioca Express | Big Stage, Inc. (affiliate) | $43,586.16 | Not stated | Fiscal year ending May 31, 2025; Tapioca Express FDD issued September 18, 2025, Item 8 |
Rebates are a separate channel. Tapioca Express says it received no revenue from suppliers in the year to May 31, 2025, and Kung Fu Tea says “We have not yet received any rebates from any supplier.” Gong cha reserves the right to keep supplier payments “as we deem appropriate,” and Sharetea says it is “under no obligation to pass any portion of these payments on to you” (Item 8 of each FDD).
Can you bring in your own milk, fruit or a cheaper supplier?
Only Kung Fu Tea lets you buy perishables from local suppliers you pick, and even there it specifies the milk and fruit suppliers. All four require written approval for any outside supplier, decided in 30 to 60 days. Three price a penalty: $250 a day at Gong cha and $300 a day at Kung Fu Tea for unapproved products, and $20,000 per violation at Sharetea for buying from an unauthorized supplier.
| Brand | Local perishables | Decision time for a new supplier | Testing cost | Fee for unapproved products | Source |
|---|---|---|---|---|---|
| Gong cha | Not permitted outside Suppliers; no substitute materials without written approval | Generally 30 days; a supplier not approved within 30 days is deemed rejected | Charge not exceeding the reasonable cost of evaluation and testing | Prohibited Product or Service Fee: $250 per day, may rise by up to 25% over the term | Gong cha US Unit FDD issued March 25, 2026, Items 6 and 8 |
| Kung Fu Tea | Allowed, but “we specify your suppliers of milk and fruit” | Aims to begin investigating within 30 days; answer within 10 days after it ends | No franchisor fee; you pay any independent laboratory | Unauthorized product or service fee: $300 per day of use | Kung Fu Tea FDD issued April 20, 2026, revised July 6, 2026, Items 6 and 8 |
| Sharetea | All products from approved suppliers | 30 to 60 calendar days | Supplier Testing Fee US$0, but you or the supplier reimburse actual testing costs | Liquidated Damages for Buying from Unauthorized Supplier: $20,000 per violation, plus further damages | Sharetea FDD issued March 5, 2026, Items 6 and 8 |
| Tapioca Express | Items not designated may come from suppliers meeting specifications | Within 60 days of a complete request | Supplier Evaluation fee: actual costs, due within 14 days of invoice | No supplier-specific fee; Operations Non-Compliance fee of $450 to $1,000 per occurrence from the second occurrence | Tapioca Express FDD issued September 18, 2025, Items 6 and 8 |
Two clauses change cash flow more than the approval rules. Gong cha requires payment for orders, including logistics costs, five business days before the clean bill of lading, adds a $200 administrative fee for order changes after five business days, and promises 90 days’ written notice before raw material price increases. Sharetea warns that “certain franchisees may pay higher prices than they could receive from another supplier that is not approved” (Item 8 of each FDD).
How much of the boba franchise cost is paid to the franchisor before opening?
Item 7 puts a single traditional unit at $169,000 to $378,000 for Kung Fu Tea, $207,450 to $648,460 for Gong cha, $250,000 to $509,100 for Tapioca Express and $275,600 to $606,400 for Sharetea. Of those totals, lines payable only to the franchisor or its affiliate add up to $44,000 to $213,300, with Sharetea’s equipment and inventory lines driving the top of that range.
| Brand (alphabetical) | Format in Item 7 | Initial franchise fee | Opening inventory line and payee | Item 7 total | Source |
|---|---|---|---|---|---|
| Gong cha | Single unit | $37,000 | Initial Supplies and Inventory $25,750 to $61,800, to affiliates and the franchisor | $207,450 to $648,460 | Gong cha US Unit FDD issued March 25, 2026, Items 5 and 7 |
| Kung Fu Tea | Standard Unit | $25,000 to $37,000 | $15,000 to $25,000, to Arms Global Inc. and approved suppliers | $169,000 to $378,000 | Kung Fu Tea FDD issued April 20, 2026, revised July 6, 2026, Item 7 |
| Kung Fu Tea | Non-traditional Unit | $25,000 | Same supplier rules | $184,000 to $269,500 | Kung Fu Tea FDD issued April 20, 2026, revised July 6, 2026, Item 7 |
| Sharetea | Unit franchise | $12,000 | $30,000 to $45,000, to the franchisor | $275,600 to $606,400 (printed) | Sharetea FDD issued March 5, 2026, Item 7 |
| Tapioca Express | Traditional Cafe | $30,000 | $10,000 to $20,000, to the franchisor and suppliers | $250,000 to $509,100 | Tapioca Express FDD issued September 18, 2025, Item 7 |
| Tapioca Express | Kiosk Cafe | $25,000 | $10,000 to $20,000 | $154,000 to $351,900 | Tapioca Express FDD issued September 18, 2025, Item 7 |
We added every Item 7 line in each filing. Three totals match. Sharetea’s low-end lines add to $295,600, which is $20,000 above the printed $275,600 and equal to its Technology Transfer Fee; the high end adds to the printed $606,400. Ask Sharetea which figure is right before you budget. Our Item 7 study across 259 franchise systems shows how often printed totals and line items disagree.
Which Item 7 lines go only to the franchisor or its affiliate?
Counting only lines whose payee column names the franchisor or its affiliate alone, Tapioca Express collects $48,400 to $49,000, Kung Fu Tea $44,000 to $57,000, Gong cha $62,750 to $98,800 and Sharetea $185,500 to $213,300. Lines split between the franchisor and outside suppliers, such as Tapioca Express inventory, are left out, so these are floors.
| Brand | Item 7 lines payable to franchisor or affiliate only | Low | High | Share of printed Item 7 total (low, high) |
|---|---|---|---|---|
| Gong cha | Franchise fee $37,000 + Initial Supplies and Inventory $25,750 to $61,800 | $62,750 | $98,800 | 30.2%, 15.2% |
| Kung Fu Tea | Fee $25,000 to $37,000 + training fee $12,500 + equipment from Arms Global $6,500 to $7,500 | $44,000 | $57,000 | 26.0%, 15.1% |
| Sharetea | Fee $12,000 + Technology Transfer Fee $20,000 + Store Pre-opening Fee $17,000 + Store Design Fee $3,000 + Security Deposit $10,000 + Equipment $91,000 to $103,000 + Utensils $2,500 to $3,300 + Inventory $30,000 to $45,000 | $185,500 | $213,300 | 67.3%, 35.2% |
| Tapioca Express (Traditional Cafe) | Fee $30,000 + refundable deposit $10,000 + Tea Machine Package $2,400 to $3,000 + Initial Marketing Fee $6,000 | $48,400 | $49,000 | 19.4%, 9.6% |
Sharetea’s equipment ($91,000 to $103,000) and inventory ($30,000 to $45,000) lines are payable to the franchisor, which lifts its total to $185,500 to $213,300. Source: Item 7 of four FDDs, accessed November 2, 2026.
The Tapioca Express Tea Machine Package is two calibrated tea machines bought from the franchisor or its affiliates when the agreement is signed (Item 7, Note 3). Sharetea’s $91,000 to $103,000 equipment line is payable to the franchisor “when you place the order.” This page is general information, not legal, financial or investment advice; the franchise costs guide explains how Items 5, 6 and 7 fit together.
Which FDA and Food Code rules reach tapioca pearls and dairy?
Three federal layers touch a boba shop’s supply chain. Importers of tea, tapioca and powders file FDA prior notice and run foreign supplier checks; milk sold in interstate commerce must be pasteurized under 21 CFR 1240.61; and the shop itself answers to the state or local version of the FDA Food Code, which treats heat-treated plant food, such as cooked pearls, as time/temperature control for safety food.
| Rule | What the text says | Who it binds | Boba point |
|---|---|---|---|
| 21 CFR 1.279 | Prior notice no less than 2 hours before arrival by road, 4 hours by rail or air, 8 hours by water | Whoever imports the food | Applies to imported tea, tapioca and powders before they reach a franchisor warehouse |
| 21 CFR 1.500 (FSVP) | “Importer means the U.S. owner or consignee of an article of food that is being offered for import” | The U.S. owner or consignee at entry | Falls on the shop owner only if you import directly instead of buying from the Item 8 supplier |
| 21 CFR 1240.61 | No milk or milk product in final package form in interstate commerce unless pasteurized; for example 161°F for 15 seconds, plus 5°F if fat is 10% or more or sweeteners are added | Anyone who ships or sells packaged milk | Covers the milk and cream in milk teas and foams |
| Food Code 2022 3-201.11 and 3-201.13 | Food from sources that comply with law; fluid milk from sources that comply with Grade A standards | Food establishments in jurisdictions that adopt the model code | A franchisor-specified dairy still has to meet Grade A sourcing |
| Food Code 2022 1-201.10, 3-501.16, 3-501.19 | Heat-treated plant food is a TCS food unless pH or water activity data show otherwise; hold at 41°F or below or 135°F or above, or use time as control for up to 4 hours with written procedures | Food establishments in adopting jurisdictions | Cooked tapioca pearls held at room temperature need a written time plan if your inspector treats them as TCS food |
| FDA Import Alert 12-13 (published May 22, 2026) | Detention without physical examination of milk and milk products manufactured under insanitary conditions | Foreign dairy firms on the alert’s list and their importers | Relevant to imported milk powders and creamers in a supplier’s catalog |
- Ingredient maker: tea leaves, tapioca pearls, syrups, powders and cups; Sharetea’s Item 8 supplier is its parent, Lian Fa, a company formed in Taiwan.
- U.S. importer (owner or consignee at entry): FDA prior notice 2 hours by road, 4 hours by rail or air, 8 hours by water (21 CFR 1.279), and foreign supplier verification duties (21 CFR 1.500).
- Required supplier named in Item 8: Big Stage, Inc. (Tapioca Express), Arms Global Inc. (Kung Fu Tea), GCPS (Gong cha), Lian Fa (Sharetea), as 16 CFR 436.5(h) requires.
- Your shop (state or local food code): food from sources that comply with law (Food Code 3-201.11), milk from Grade A sources (3-201.13) and pasteurized in interstate commerce (21 CFR 1240.61), cooked pearls as TCS food at 41°F or below, 135°F or above, or 4 hours (3-501.16, 3-501.19).
Gong cha’s own Item 1 flags the same exposure: “Certain jurisdictions may impose additional requirements for the importation, storage, and use of tapioca starch, tea leaves, and other imported ingredients commonly used in bubble tea preparation” (pages 7 to 8). The Food Code is a model that states and counties adopt, sometimes with changes, so confirm the 4-hour rule with your health department.
Do calorie labeling rules apply to a boba franchise?
Federal menu labeling under 21 CFR 101.11 applies to a “covered establishment,” defined as part of a chain with 20 or more locations doing business under the same name, regardless of franchise ownership. Kung Fu Tea (346 U.S. outlets), Sharetea (146) and Gong cha (203 stores system-wide) are above that line; Tapioca Express, with 15 outlets at May 31, 2025, is below it.
Gong cha’s Item 1 states: “Your Store must comply with the FDA’s menu labeling requirements under 21 CFR Part 101,” and names added sugars and customizable ingredient options. The text of 21 CFR 101.11 also lets a smaller chain register voluntarily under paragraph (d), and state or city rules can apply below 20 outlets.
Royalties, outlet counts and Item 19 in the same four filings
The supply terms sit on top of percentage fees. Royalties run 4% of gross sales at Kung Fu Tea and Tapioca Express and 6% at Gong cha and Sharetea, where Sharetea adds a US$1,200 monthly minimum. Two of the four filings include an Item 19 financial performance representation; we do not reproduce those figures, and Item 19 of each FDD is where to read them.
| Brand | Royalty (Item 6) | Brand or marketing fund (Item 6) | U.S. outlets at end of last fiscal year (Item 20) | Item 19 included? | Source |
|---|---|---|---|---|---|
| Gong cha | 6% of weekly Net Sales | 1% of weekly Net Sales | 38 in the franchisor’s own table; 203 stores including master franchisees (2025) | Yes, based on Net Sales of 222 stores | Gong cha US Unit FDD issued March 25, 2026 |
| Kung Fu Tea | 4% of Gross Sales | Marketing fee 2% of Gross Sales | 346 (344 franchised, 2 company-owned, 2025) | No | Kung Fu Tea FDD issued April 20, 2026, revised July 6, 2026 |
| Sharetea | 6% of Gross Monthly Sales, minimum US$1,200 per month | Percentage not yet determined; fund not established | 146 franchised (2025) | No | Sharetea FDD issued March 5, 2026 |
| Tapioca Express | 4% of Gross Sales | Brand Development Fund 1.5% of Gross Sales | 15 (13 franchised, 2 company-owned, fiscal year to May 31, 2025) | Yes | Tapioca Express FDD issued September 18, 2025 |
Two figures in widely read boba roundups do not match these filings. A guide updated in September 2026 lists Tapioca Express at a “$15K” fee and “2.5%” royalty; its September 18, 2025 FDD prints $30,000 for a Traditional Cafe and 4% of Gross Sales (Items 5 to 7). A 2025 roundup puts Kung Fu Tea above 2,000 U.S. stores; Item 20 of its July 2026 FDD counts 346 at the end of 2025. Our royalty rate study, Item 19 study and coffee and drink franchise statistics report show where these terms sit in the wider sample.
A sourcing decision table for the FDD you are reading
Read Item 8 before Item 7 in any boba FDD, because the supplier clause sets your cost of goods for the full term. The table pairs what a filing may say with the question it should trigger, using thresholds printed in these four documents. Kung Fu Tea’s sole-source rule and Gong cha’s 90-day price notice are the two clauses most worth putting in writing.
| If the FDD says | Then ask or do | Threshold seen in these filings |
|---|---|---|
| An affiliate is the only source of tea, tapioca or cups | Ask for the current price list and compare the affiliate’s Item 8 revenue with its total revenue | Arms Global Inc.: more than 99% of 2025 revenue from franchisees |
| Restricted purchases exceed 85% of ongoing costs | Ask how price increases are announced and whether volume discounts reach franchisees | Gong cha 85% to 95%; Sharetea over 95%; Gong cha gives 90 days’ notice |
| Orders are prepaid before shipment | Budget working capital above the inventory line | Gong cha: 5 business days before the clean bill of lading; Item 7 additional funds $10,300 to $86,500 |
| The franchisor specifies your milk supplier | Confirm the dairy delivers to your address and meets Grade A sourcing (Food Code 3-201.13) | Kung Fu Tea specifies milk and fruit suppliers |
| A fee or liquidated damages apply to unapproved products or suppliers | Get written approval before any local substitute, even for one topping | $250 per day (Gong cha); $300 per day (Kung Fu Tea); $20,000 per violation (Sharetea) |
| The system has fewer than 20 U.S. outlets | Check state and city calorie labeling rules instead of relying on 21 CFR 101.11 | Tapioca Express: 15 outlets |
| Printed Item 7 total differs from the sum of its lines | Ask which figure the franchisor stands behind, in writing | Sharetea: $295,600 in lines vs $275,600 printed |
A franchise consultant can turn these seven rows into written questions for a discovery call. Item 8 also sets insurance minimums, such as Gong cha’s $5,000,000 per claim cyber cover and Kung Fu Tea’s $2,000,000 per occurrence general liability, which our franchise insurance requirements study compares across systems.
How we compiled this
On November 2, 2026 we opened four Clean FDDs on file with the Minnesota Department of Commerce (CARDS): Gong cha, Kung Fu Tea, Sharetea and Tapioca Express, the four U.S. boba systems named in our brief, chosen as examples, not ranked. We read Items 1, 5 to 8, 19 and 20, summed every Item 7 line, and read the federal texts at eCFR, the FDA Food Code 2022 and Import Alert 12-13. We excluded Item 19 figures and franchisee names.
Frequently asked questions
How much does a boba franchise cost?
Item 7 of four current FDDs puts one unit at $169,000 to $378,000 for a Kung Fu Tea Standard Unit, $207,450 to $648,460 for Gong cha, $250,000 to $509,100 for a Tapioca Express Traditional Cafe and $275,600 to $606,400 for Sharetea. Initial franchise fees run from $12,000 (Sharetea) to $37,000 (Gong cha). Sharetea’s low-end lines add to $295,600, so ask which total applies.
Do boba franchises make you buy tapioca pearls from them?
Sharetea’s March 2026 FDD says so directly: Tapioca Pearls, tea leaves, syrups and cups must come from its parent company or designated suppliers. Kung Fu Tea requires all tea, concentrates and flavoring ingredients from its affiliate Arms Global Inc., and Gong cha requires its Proprietary Products from GCPS. Ask each franchisor in writing which category its pearls fall under in Item 8.
Is a bubble tea franchise profitable?
We do not publish earnings figures. Tapioca Express and Gong cha include an Item 19 financial performance representation in their current FDDs; Kung Fu Tea and Sharetea do not. Owner results depend on the Item 6 royalty (4% to 6% here), the restricted supply share in Item 8 (15% to over 95%) and the Item 7 build-out, so read Item 19 alongside those three items.
Which bubble tea franchise operates in London?
We do not rank brands. Gong cha’s U.S. FDD, issued March 25, 2026, says there were 2,172 Gong cha stores in 32 markets at December 31, 2025, including the United Kingdom, and lists a London address for its parent entities in Item 1. U.S. FDD terms, fees and Item 8 suppliers do not govern a UK shop, so request the UK agreement separately.
What happens if a franchisee buys boba supplies from an unapproved vendor?
The current FDDs print the charges in Item 6. Gong cha’s Prohibited Product or Service Fee is $250 per day an unapproved product is offered, Kung Fu Tea charges $300 per day of use of unauthorized products, and Sharetea sets liquidated damages of $20,000 per violation for buying from an unauthorized supplier. Kung Fu Tea’s Item 8 adds a right to terminate.
Are cooked tapioca pearls a food safety concern for inspectors?
Under the FDA Food Code 2022 definition in 1-201.10, a heat-treated plant food is time/temperature control for safety food unless pH or water activity data show otherwise. That means holding at 41°F or below or 135°F or above (3-501.16), or using time as the control for up to 4 hours with written procedures (3-501.19), where your state has adopted those sections.
Sources
- Gong cha USA Franchising, LLC, US Unit Franchise Disclosure Document, issued March 25, 2026, Items 1, 5 to 8, 19 and 20, Minnesota CARDS document 35583-202603-08 (accessed November 2, 2026).
- KF Tea Franchising LLC (Kung Fu Tea) Franchise Disclosure Document, issued April 20, 2026, revised July 6, 2026, Items 5 to 8, 19 and 20, Minnesota CARDS document 37009-202607-08 (accessed November 2, 2026).
- Lilian USA LLC (Sharetea) Franchise Disclosure Document, issued March 5, 2026, Items 1, 6 to 8, 19 and 20, Minnesota CARDS document 35982-202604-13 (accessed November 2, 2026).
- Tapioca Express, Inc. Franchise Disclosure Document, issued September 18, 2025, Items 5 to 8, 19 and 20, Minnesota CARDS document 34840-202509-08 (accessed November 2, 2026).
- 16 CFR 436.5, Disclosure items (Item 8), Electronic Code of Federal Regulations (accessed November 2, 2026).
- 21 CFR 1240.61, Mandatory pasteurization for all milk and milk products in final package form, eCFR (accessed November 2, 2026).
- 21 CFR 101.11, Nutrition labeling of standard menu items in covered establishments, eCFR (accessed November 2, 2026).
- 21 CFR 1.279, When must prior notice be submitted to FDA?, eCFR (accessed November 2, 2026).
- 21 CFR 1.500, Foreign Supplier Verification Programs definitions, eCFR (accessed November 2, 2026).
- Food Code 2022, January 18, 2023 version, U.S. Food and Drug Administration, sections 1-201.10, 3-201.11, 3-201.13, 3-501.16 and 3-501.19 (accessed November 2, 2026).
- Import Alert 12-13, Detention Without Physical Examination of Milk and Milk Products Manufactured under Insanitary Conditions, FDA, published May 22, 2026 (accessed November 2, 2026).