Is a truck-mounted operation required to register if it travels from one vineyard to another and bottles wine made from grapes grown and processed into wine at the vineyard?

Yes. A truck-mounted operation that travels from one vineyard to another and bottles wine is a
mobile facility that must be registered. Bottling wine is “packaging,” which is an activity
included in the definition of “manufacturing/processing” (21 CFR 1.227).
“Manufacturing/processing” is defined as “making food from one or more ingredients, or
synthesizing, preparing, treating, modifying or manipulating food, including food crops or
ingredients”. Bottling wine involves manipulation of the wine because it is preserving the
manufactured condition of the wine by vacuum-sealing it and corking it. Thus, the truck-mounted
operation that bottles wine is a facility that is required to register. Furthermore, the exception in
21 CFR 1.227 for farms (both primary production farms and secondary activity farms) that
perform packaging and labeling without additional manufacturing/processing only applies to
packaging and labeling of RACs, and wine is a processed food.