The definition of “holding” provides that holding includes “activities performed incidental to
storage of a food (e.g., activities performed for the safe or effective storage of that food, such as
fumigating food during storage, and drying/dehydrating raw agricultural commodities when the
drying/dehydrating does not create a distinct commodity) . . . but does not include activities that
transform a raw agricultural commodity into a processed food as defined in section 201(gg) of the
Federal Food, Drug, and Cosmetic Act” (see definition of “holding” in 21 CFR 1.227).
Generally, a facility that fumigates food is manufacturing/processing, packing, or holding food
and therefore is required to register. However, if the fumigation is performed on a farm for the
safe or effective storage of a RAC, this activity would not be one that requires the farm to register
because fumigation is considered a “holding” activity and holding RACs is within the “farm”
definition.
