it’s food.... he’s supposed to register with the FDA at about $3000/year.... they’ll come after him either because of this notice or once he reaches a certain level of income.
Do not know the law in his state but in most states you are covered under the Cottage Industry laws and do not need to register with the FDA until you reach a certain level of income and are selling across state lines.
The selling across state lines is the big one. Certain level of income is usually a state thing but crossing state lines or selling to government entities and it becomes federal.
And a major pain in the patootie.