The response to this question depends upon the activities of the maple syrup producer. The
activities of maple syrup producers customarily consist of two types: gathering sap from sugar
maple trees and concentrating the sap through the application of heat to make syrup. Gathering
sap is “harvesting”, which is included in the definition of “farm” (21 CFR 1.227). Therefore, the
farm is exempt from registration. However, making maple syrup by concentrating sugar maple
sap (i.e., by evaporation using heat) is a form of “manufacturing/processing” (21 CFR 1.227).
Accordingly, a facility that concentrates sugar maple sap is performing a
“manufacturing/processing” activity and is required to register, unless all of the concentrated sap
is consumed on the farm or another farm under the same management or is exempt from
registration as a retail food establishment, as discussed in Question B.2.11 (21 CFR 1.227).
