Low acid energy drinks labeling

Hello community, I hope somebody can help me with this. I am working on a HACCP for energy drinks pH are higher than 4.6 they are currently ranging from 4.8 to 5.4 so they are in the category of low acid canned foods (21 CFR 113) they are also in dietary supplements (CFR 111) because of the added salts. and they go under treatment for 5 log reduction. I believe that if you demonstrate that your treatment is good enough to control clostridium you are in compliance. Also, they are kept refrigerated so the label has to stated they need to be kept under refrigeration. If i include all of those, i should be fine. right? i just wanted to make sure i am going in the correct path. Thank you.

What sort of shelf life as your expecting/wanting?  

Do you have a schedule process?

Hi Scampi, thank you for getting back to me. The shelf life is 6 months. We did a study with independent lab and the schedule process is HPP. Yesterday i was reading on the validation but i found that HPP does not have a validation for clostridium botulinum. I found out that if you control the pH (ph below 4.6) you can use HPP but if you do not then you have to pasteurize.