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Sandy, I personally know many cottage food operations in CA that make caramels and have had them approved. However, some counties are a little stricter than others, but I still don’t think any would say no. What county are you from? Of course, the only way to know for sure would be to talk to your county’s environmental health department.

The law says no “cream… fillings“. In the case of a caramel, the cream is incorporated into the candy (not a filling) at a lower ratio and thoroughly baked… it’s much different from a cream pie. In general, if something in the approved food categories doesn’t need to be refrigerated, as I’m sure your caramels do not, then it should be fine.