commercial-kichen Cold filling hot sauce in facility with no cannery license?

Hey everyone! I had a question that I am hoping some more experienced hot sauce makers could shed some light on.
How is it possible to produce and bottle hot sauce in a rented commercial kitchen in squeeze plastic bottles without the need of a cannery license?
One of the commercial kitchens I did my first production run in recently posted a picture of a hot sauce company filling clear plastic squeeze bottles with hot sauce, and that hot sauce brand is sitting on shelves in NY Whole Foods. 
I was super confused because I've been on a very expensive and confusing quest to get my proper licensing and permits in place for cannery in order to produce a hot sauce the "correct" and "legal" way, and this has been the biggest blocker for me. I know for a fact that this commercial kitchen does not have a cannery license since I worked with them before and also confirmed again with them today. I also know that this company's hot sauce is not hot filled due to the clear plastic squeeze bottles.
I really want to work with this facility again and do my second run of hot sauce, and I am happy to adjust my recipe in ways that can allow me to bottle without a cannery license, but I'm honestly just super confused now.
Does anyone have an idea on how this might be possible? My hot sauce was tested recently via process authority and rated at a max of 3.5pH. When I emailed the commercial kitchen, they said that the hot sauce company that was bottling was "shelf stable and under pH parameters and its not a canned product" but the ingredients are relatively the same stuff I use. So what is the differentiating factor that allows them to produce there without a cannery license and legally sell in stores and ship?
Sorry for the long post, but I'm very eager to know so I can start producing sauce again but also very anxious because I have no idea what to do  haha.
Thanks everyone!
Jumping back into this thread with some additional curiosity. I spoke with a PA today about doing a cold fill process. He mentioned if the pH was below 3.0, we could do it. Therefore allowing us to fill into PET without a hot fill process. Being a real stickler for playing it safe, this still has me a bit uneasy and going down rabbit holes trying to figure more out about this and how Yellowbird, Heartbeat etc... are managing to fill their sauces into PET, also without additional preservatives. I did test Yellowbird sriracha and the pH was 2.97.

Anyways, @The Hot Pepper and @salsalady do you have any new thoughts on this? More companies are using PET squeeze bottles, and I am just trying to figure out how it is done safely..
Well the Yellowbird Sriracha has vinegar, tangerine juice concentrate, and lime juice concentrate, so all acidic ingredients, but they figured out a balance of flavors and sweetness so it wasn't too intense. Agave nectar is also high on the list so this sweetens it all up but not in the sugary cane way, a smoother sweetness, so it works to balance out all that acidity without being overbearing.
Thank you for the response! I agree with you about their ingredients and the balance in flavors. However, I am more curious about what their process is. Hot fill, or cold fill. Being that they are in PET squeeze bottles, I am guessing cold fill. And, that makes me curious how? Information on cold filling has absolutely eluded me everywhere I look. Is it purely their pH being below 3.0? OR, is there another step in the process of allowing this to be a safe product?
Tabasco is cold filled. The pH will allow this yes, glass, PET, etc. My point was they get the pH to below 3 with those ingredients.
If the PA says 3.0 or below, I'd go with that. Newer plastics have a higher heat tolerance, and commercial processing lines have more precise temperature controls than most small processors. If the PET tolerance is 185f and the line is set to 182f...all good.
Yeah, I'm not sure of the exact question here anyway. They want to cold fill, do they already have >3 pH? Are they worried that even if they do it will spoil, which is why they mentioned preservatives? Do they not trust the PA's info?
The exact question here does regard cold filling below 3.0 pH. No, I do not particularly trust the PA that I have been speaking with. I am familiar with the previously stated companies ingredients and that there are no preservatives in use. The question as I posed before is: What other safety control points are there in the manufacturing process for these sauces via cold fill? The companies I mentioned are not using heat set PET as you were referring to (tolerance of 185, which most heat set can actually go up to 190). I have spoken with suppliers of their bottles even. So, yes they must be using a cold fill or heat no higher than 145. As for sauces at 3.0 pH and lower, the FDA guidance does not mention anything in Title 21 parts 113 or 114 regarding pH other than the 4.6 and below statement. Is there another control guideline chapter for cold filling?? Anyways, I hoped to find some new knowledge here. Sorry to have bothered. I will follow up if I can find any more definitive guidelines regarding cold fill safety control points.
No, I do not particularly trust the PA that I have been speaking with.
Talk to Cornell:
Any update on this?

I recently learned that acidified products with pH of 3.8 or less can be cold filled if the acidulent is acetic acid (e.g., apple cider vinegar) or benzoic acid (at least 0.1% of the formulation weight for the benzoic acid). Must be held at 50°F (10°C) or higher for at least 48 hours to allow the acid to kill off any vegetative bacteria cells.

This seems to be little known. I only learned it while taking the acidified food manufacturing course from NC State. I plan to speak with a process authority about this asap.
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Got some information on cold-fills. The first screenshot is from a document shared with me from UTennessee. The document originally came from NC State. These are basic parameters for a cold fill. The second screenshot provides more details and was shared with me from NC State. I think some of their professors were involved in the research. The table in this second screenshot is basically a grid that tells you all the details of the parameters needed for a cold fill. To level set on this table, suppose you have a sauce with a pH of 3.5 or below and your sauce contains 1.5% acetic acid (apple cider vinegar) then you can do a cold fill if you add 0.1% benzoic acid and hold your bottles at 50 degrees or above for 3.6 days (4 days in practice). If you have pH of 3.5 and 0% acetic acid you can still do a cold fill if you add 0.1% benzoic acid and hold for 14.5 days (15 days in practice).

FYI - NC State said plan to be at least 0.10 below their thresholds. In other words if your pH is right at 3.5 that's probably not gonna cut it because they'll require you to be at 3.40 or less so there is some wiggle room

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