Raw vs Processed Greens

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    Jackie
    Jackie
    Keymaster

    Where do you cross the line with raw & processed?  As in, if it is all one variety of greens it is raw, but if you mix lettuce and arugula and spinach is it considered processed?  Also, how about a plant with a root ball in a plastic clamshell package, is that processed?”

    #710 Reply
    Jackie
    Jackie
    Keymaster

    More information is needed as the wholesale and retail foods have some slightly different definitions when it comes to raw agricultural commodities and processing.

    Farmers Markets

    If we start by assuming your selling at a farmers’ market, based on what you’ve told us about the products, they likely would not need to be licensed under retail food as long, as your only doing a field wash and field cut, and they are not marketed as a ready-to-eat salad mix, or some such thing we would consider them exempt from licensure. If you’re pre-packaging them, you’ll need to label them, and you could work with us or your local sanitarian, if you need help on labels.

    I am assuming that the plant with a root ball has only undergone a field wash to remove the dirt from the roots. In this case, it would not be processed, if sold at a farmers’ market.

    Wholesaling

    Wholesaling is different. Wholesaling is the provision of food to a retailer who then provides that product to consumers.

    The Code of Federal Regulation provides a definition of processing. When you mix ingredients together at wholesale, you start crossing the line into the realm of potentially needing a license. If you get to that point, or are already there, we’d recommend working with your local sanitarian to determine exactly what you need in terms of licensure.

    21 CFR 1.227

    Manufacturing/processing means making food from one or more ingredients, or synthesizing, preparing, treating, modifying or manipulating food, including food crops or ingredients. Examples of manufacturing/processing activities include: Baking, boiling, bottling, canning, cooking, cooling, cutting, distilling, drying/dehydrating raw agricultural commodities to create a distinct commodity (such as drying/dehydrating grapes to produce raisins), evaporating, eviscerating, extracting juice, formulating, freezing, grinding, homogenizing, irradiating, labeling, milling, mixing, packaging (including modified atmosphere packaging), pasteurizing, peeling, rendering, treating to manipulate ripening, trimming, washing, or waxing. For farms and farm mixed-type facilities, manufacturing/processing does not include activities that are part of harvesting, packing, or holding.

    The CFRs apply to food manufacturers.

    Thank you,

    NINA HEINZINGER, PhD, RS

    Public Health Sanitarian

    Office (406) 444-0067 Fax: (406) 444-5055

    email: [email protected]

    DEPARTMENT OF PUBLIC HEALTH AND HUMAN SERVICES

    FOOD AND CONSUMER SAFETY SECTION

    Cogswell Building – Room C-214

    PO Box 202951

    Helena MT 59620-2951

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