Does placing stickers on a raw agricultural commodity (RAC), such as fruit on a farm, amount to “manufacturing/processing” and, therefore, require registration of the farm at which the application of the stickers occurs?

Placing labels (e.g., stickers) directly on raw agricultural commodities (RACs), on boxes or other
containers holding packed RACs, or on consumer packages containing RACs, is a
manufacturing/processing activity that is within the “farm” definition and does not result in a farm
having to register. (See “farm” definition in 21 CFR 1.227 at (1)(iii)(B)(3) and at B.1.1. of this
guidance).