Leafy Greens & Mixed Greens

Find out if you are covered by the FDA’s Food Safety Modernization Act (FSMA) Produce Safety Rule at www.coproducesafety.org.

Definitions:

  • Leafy Greens: refers to leafy vegetables that are grown and harvested for fresh market (i.e. fresh, unprocessed form), cooled, transported to retail outlets or offered for sale to the consumer and includes lettuce (head, romaine,green leaf, red leaf, butter, batavia), escarole, endive, spinach, cabbage (green, red and savoy), kale, arugula, chard, collard greens and other leafy vegetables that are sold in an unprocessed form.
  • Mixed Greens (or salad mix): refers to a fresh produce specialty item that may or may not be subject to post-harvest processing steps by the producer which may include a blend of baby lettuces, mustards, chards, spinach, arugula, chicory and other young leafy green vegetables that vary based on availability of supply. Sometimes mixed greens are also referred to as “minimally processed”  because they have been washed, cut, repackaged, or altered from their original, whole state. Mesclun is French for a mixture of tender young lettuces (baby greens) and other salad greens. The traditional mesclun mix includes chervil, arugula, lettuce and endive.

Harvest/Post Harvest:

  • Leafy greens are highly perishable and susceptible to microbial contamination; it is strongly recommended that they be stored and distributed under refrigeration.
  • Cooling, cold storage and refrigerated distribution/marketing of leafy green vegetables as raw agricultural commodities (keeping greens on ice) is not currently required in Colorado to maintain safety but that recommendation by FDA is under consideration.
  • Best handling practices include using tongs or disposable gloves when bagging leafy greens for customers at a farmers’ market. A market vendor would often be handling money and other produce items so bare hands could easily contaminate leafy greens before they are bagged and stored by the consumer.  Even if rinsed thoroughly before consuming, removing microorganisms from raw produce may be difficult, if not impossible.
  • To reduce the risk of foodborne illness associated with raw and minimally processed agricultural products, it is important to advise customers that the raw produce should be washed if it is to be eaten raw.

Food Safety: Between 1990 and 2009, the consumption of leafy greens was linked to 363 foodborne illness outbreaks involving 13,569 reported cases of illness (Klein et al., 2009). Lettuce and other leafy greens present multiple opportunities to employ food safety risk management practices to enhance their safety. In the production and harvest of leafy greens as raw agricultural commodities, Good Agricultural Practices (GAPs) are commonly employed to produce the safest products possible. The human pathogens most often associated with produce (Salmonella and E. coli O157:H7) cause infection and illness by the fecal oral route of food contamination and may involve vectors such as human hands, water, and soil. Once a leafy type of vegetable is contaminated, removing or killing pathogens is very difficult. Therefore, prevention of microbial contamination at all steps from production to distribution is strongly favored over treatments to eliminate contamination after it has occurred.

Water used during the post-harvest handling of produce usually involves a high degree of water-to-produce contact and may serve as a source of contamination. In addition, reusing the wash water may result in the build-up of microbial loads, including undesirable pathogens from the crop. Past outbreaks of foodborne illness associated with fresh and minimally processed produce have usually been the result of produce becoming contaminated with fecal material from water, food handlers, livestock, or wildlife.

Mixed greens are often displayed in a manner that suggests to the consumer that the product is a ready-to-eat food. The additional processing /handling steps and the marketing method may present an increased food safety risk because the consumer may not recognize that the product should be washed prior to consumption. Minimal processing at the farm, such as rinsing gross debris from raw produce, is not considered processing and, therefore, not subject to the GMPs.

Good Agricultural Practices/Good Manufacturing Practices: Following GAPs and GMPs for leafy green production, harvest, processing, packing, and transport may reduce the potential for microbial contamination.

Distribution Method (Expand All | Collapse All)

You are selling your product at a farmers’ market, CSA, roadside stand, or other direct to consumer outlet


Licensing: When it comes to licensing, appearance matters. The inspector at your market will determine if your mixed greens are processed or unprocessed. If you are selling leafy greens or mixed greens that are washed and represented as ready to eat, then you are selling a processed good and you will need a retail food establishment license, issued by your county health department.

Raw, unpackaged mixed greens with minimal or no post-harvest processing are not a ready-to-eat food and, therefore, are not subject to the Colorado Wholesale Food Regulations or the Colorado Retail food Establishment Rules and Regulations. The consumer should wash the product if it is to be eaten raw.

If a vendor is selling only unprocessed leafy vegetables, the vendor is exempt from retail food establishment licensure even if offering samples (Retail Food Establishment Interpretation #14-08 and #13-05). If samples of leafy greens are offered, it is very important to follow safe handling guidelines provided in Farmers’ Market Vendor Guide for Preparing and Offering Food Samples.

If you are selling leafy greens or mixed greens that you have purchased directly from a Colorado grower or from a wholesaler, you will also need a Farm Product Dealers License.

Labeling: If you are selling raw, unpackaged leafy greens or mixed greens with minimal or no post-harvest processing, there are no specific labeling requirements. Unpackaged, single ingredient foods like fruits and vegetables do not need labels. If you are selling packaged, ready-to-eat mixed greens you will need to follow the general labeling requirements.

Recommendation: CSU Extension recommends the following handling and labeling practices for bagged spinach or mixed salad greens for farmers’ market vendors:

  1. Use tongs or gloved hands for transferring spinach or mixed salad greens to plastic bags for selling to customers.
  2. Labels on bags should include:
    a. farm name and location
    b. the following message: These greens are not ready-to-eat and need to be rinsed thoroughly with running water before preparing for consumption.
    c. date harvested

Sales Tax Liability: General sales tax information.

Weights and Measures: If you are selling your product by weight, you must follow the Colorado weights and measures requirements. Leafy greens might also be sold by volume, refer to the fruits and vegetables section of weights and measures for guidelines.

You are selling your product to a store, restaurant, food cart, K-12 school, university, hospital, or other retail food establishment


Licensing: If you are selling leafy greens  or raw, unpackaged mixed greens that are not ready to eat and must be washed or otherwise processed by the end user that you have grown, there are no specific licensing requirements.

If you are selling leafy green or mixed greens that have been pre-washed and are a ready to eat product they are considered processed and you must first register with the Colorado Department of Public Health and Environment (CDPHE) as a wholesale food manufacturing facility. Once you have registered your food manufacturing business, you may be inspected by CDPHE. You should first contact the Division of Environmental Health and Sustainability at (303) 692-3620 for further information and visit their page on wholesale food program information and requirements.

If you are selling leafy greens or mixed greens that you have purchased directly from a Colorado grower or from a wholesaler, you will also need a Farm Product Dealers License.

Labeling: If selling raw, unpackaged mixed greens with minimal or no post-harvest processing, there are no specific labeling requirements. However, packaged, ready-to-eat salad mixes do require labeling.

Sales Tax Liability: General sales tax information.

Weights and Measures: If you are selling your product by weight, you must follow the Colorado weights and measures requirements. Leafy greens might also be sold by volume, refer to the fruits and vegetables section of weights and measures for guidelines.

Value Added Products: Mixed salads

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