Jam and Jellies Standard of Identity and Regulations

We will be starting manufacturing of bake stable bakery fillings. However, they do not fall under the Jam and Jellies Standard of Identity as per FDA guidelines. How do we go about labeling and regulations for this product. It does contain fruit, about 30-40%, but no acid is added to the product.Some formulations have preservatives, some don't and we recommend refrigeration for the non-preservative ones. It is pectin based. Would it fall under the acidified food regulations? The Aw is high. Haven't measured the pH yet. 

Thanks.

Hello,

There are several things to consider if your product would fall under the acidified food regulations.  I am relatively new to these regulations but found a helpful guide with a couple of tables in it that helps you determine if your product falls under the regulations or not.  There was also a simpler 1 page document I have included called Is your product acidified. 

I hope you find these useful.