Andrew M. Cuomo, Governor | Richard A. Ball, Commissioner

Guidelines for Preparation of Sushi Products at Retail

This document is a guideline for the preparation of sushi products in a retail setting where immediate consumption is not likely. Any firm manufacturing a sushi product using acidified rice should first do a hazard analysis of their processing procedures, establish critical control points and follow a HACCP-based plan, which includes appropriate recordkeeping.

Vinegar is added to rice used in sushi. Occasionally, a firm will add vinegar to the rice as a flavoring, but the product is cooled in accordance with the Retail Food Store Regulations, 1 NYCRR Part 271-2.11. These operators are not required to have a HACCP plan, approved variance, or acidification records.

Most retail sushi producers will add vinegar to rice and retain the acidified rice at ambient temperature throughout the day as sushi is prepared. Any producers of sushi who are holding acidified rice at ambient temperatures must have an approved variance on file for their process. The variance may require supporting scientific studies and / or a HACCP plan. In addition to the approved variance, the retail establishment must maintain production records for the product.


The following steps should be followed when a retail firm is producing acidified rice which will held at ambient temperatures.

  1. Follow written recipe requirements, especially regarding amounts of rice and water weights prior to cooking.
  2. Prepare acidification agent per recipe with target pH of 4.1 or less, but not to exceed 4.6.
  3. Cooked rice shall be placed into a clean container of such depth to promote uniform acidification.
  4. A calibrated pH meter shall be used, according to manufacturer's instructions, to monitor pH in each batch with results properly recorded. In lieu of a pH meter, pH paper can be used if the pH is 4.0 or less.


The following general sanitary expectations apply to all retail sushi operations.

  1. The employees should use only dedicated food preparation sinks for preparing ingredients.
  2. Bare hand contact with ready-to-eat food products is prohibited. Sanitary gloves, utensils or other such devices must be utilized. Adequate and properly equipped handwash facilities must be located in the sushi prep area. Clothing and hair restraints must comply with New York State Department of Agriculture and Markets Retail Food Store regulations.
  3. All food contact surfaces and utensils must be maintained in accordance with New York State Department of Agriculture and Markets Retail Food Store regulations.
  4. Ingredients must come from approved sources. Seafood products, if identified as a parasite hazard, must be obtained from a supplier who has frozen the product in an ambient temperature of –4°F (-20°C) or below or seven (7) days (total time) or in an ambient temperature of –31°F (-35°C) or below or 15 hours, or freezing at -31°F (-35°) or below until solid and stored at -4°F or below for 24hrs. If the species identified is a histamine producer, documentation from the supplier must show that temperature control from harvest through delivery was sufficient to prevent decomposition.
  5. Ingredients such as fresh cut vegetables and produce must be kept refrigerated at 41°F or less.
  6. Bamboo mats used for product formation must be wrapped in plastic wrap and rewrapped within 4 hours or between contact with different species of raw fish.

Products where the internal temperature has been reduced below 41ºF internally within 4 hours may be handled by the firm as any other refrigerated food.


Retail sushi operators must keep and make available during inspection, the following records. Records related to production of sushi should be retained for a period of 90 days from sale. Records related to supply chain verification are often updated on an annual basis. The most recent version should be retained for the covered time frame plus 90 days after receipt of a revised or updated record.

  1. Batch records showing date of production and pH test results; records of temperature checks; and any other records required according to the approved variance.
  2. Letters from suppliers (aka “letters of guarantee”) verifying hazards were appropriately controlled or addressed prior to use at retail.
  3. Copy of approved variance, where appropriate.
  4. Standardized formulations to assure the proper pH of all batches should be verified at frequent levels. All formulations and verification records shall be maintained.


  1. Products must be properly labeled.