On some farms, vegetables are removed from the ground, field trimmed, washed, and then transferred to a truck in the field where they are placed in a consumer package, cooled, and held before being moved off the farm by a transport vehicle. The truck (i.e., mobile operation) that packages and cools the RACs is a separate operation (i.e., is under different management) from the operation that performs the other activities, and the truck performs this function on multiple farms. Is the operation performing activities before the vegetables are transferred to the truck for cooling and packaging or the truck operation where the vegetables are cooled and packaged required to register with FDA?

The operation removing vegetables from the ground, field trimming, washing, and transferring
them to a truck is a primary production farm. All of these activities, as conducted by the
operation, are performed on RACs and can be classified as “harvesting” and/or “holding” within
the “farm” definition. Therefore, it is not required to register.
The mobile operation also is not required to register. The cooling conducted by the mobile
operation is considered to be a “harvesting” activity because it is performed on RACs in the same
general physical location where the RACs were grown or raised. This harvesting activity makes
the mobile operation a primary production farm, and primary production farms may also package
RACs (providing the packaging involves no additional manufacturing/processing) within the
“farm” definition.