No. Cutting (or otherwise separating) the edible portion of a RAC from the crop plant and
removing or trimming part of the RAC (e.g., foliage, husks, roots or stems) are harvesting
activities that are traditionally performed on farms for the purpose of removing RACs from the
place they were grown or raised and preparing them for use as food. Washing the leaves in this
context would be considered part of harvesting. Drying/dehydrating a RAC (e.g., fresh
peppermint) to create a distinct commodity (e.g., dried peppermint) is a manufacturing/processing
activity; however, it is provided for in the “farm” definition, as long as there is no additional
manufacturing/processing (e.g., chopping) done to the RAC. Therefore, if the peppermint farmer
cuts, trims, and washes the leaves, and then places the harvested leaves in a barn to allow them to
dehydrate, and no additional manufacturing/processing is conducted on the peppermint, the farm
would not be required to register.
