Yes. CSA activities are not limited to only selling “crops.” For example, a farm mixed-type facility may sell strawberries it grows and strawberry jam that it manufactures directly to consumers through a CSA. Whether the on-farm manufacturing establishment is a retail food establishment, and thus exempt from registration, would depend on whether its primary function is to sell food directly to consumers. The sale of food directly to consumers through a platform that resembles a CSA but does not sell crops could still be used in determining the establishment’s primary function. It may be possible for an establishment to consider sales through that platform in determining its primary function if the establishment either:
- is located on a farm; or
- is a farm-operated business and the requirements applicable to farm operated businesses are met (see Comment 13 in the Registration Final Rule; 81 FR 45912 at 45923).
