As we have learned, the mitzva of ḥalla applies to dough intended for baking bread, as the Torah states: “When you eat of the bread of the land… from the first of your doughs you shall give a gift to the Lord throughout your generations” (Bamidbar 15:19–21). In this context, “bread” includes all grain-based baked goods: cakes, crackers, biscuits, pastries filled with meat, cheese, or vegetables, pretzels, breadsticks, and baklava.
There is, however, an important difference between ordinary bread and other baked grain products. Bread is the food on which people normally establish a meal, and therefore one always recites ha-motzi and Birkat Ha-mazon over it. Other baked goods are generally eaten casually. Therefore, when one establishes a meal on them, he recites ha-motzi and Birkat Ha-mazon; but when he eats them in their usual manner, as a snack, he recites mezonot and al ha-miḥya. Cooked grain dishes, however, always remain in the category of cooked foods rather than bread. Therefore, even if one establishes a meal on them, he still recites mezonot and al ha-miḥya.
This is the general rule: baked grain products are considered bread for purposes of ḥalla, and one must separate ḥalla from them. Cooked grain dishes are not considered bread, and no ḥalla is separated from them. This is the view of most poskim, as explained in the next section.
The distinction between baking and cooking is therefore crucial. Both use heat, but cooking takes place in boiling liquid, while baking occurs when the dough is heated without being immersed in liquid. A baked good may contain liquid – indeed, that moisture allows it to bake properly rather than burn – but during baking it is not sitting in liquid. Baking is usually done in an oven, but it can also be done in a frying pan or pot placed over a fire. Even if a small amount of oil is added to the bottom of the pan or pot to prevent sticking or to add flavor, the food is still considered baked, since the dough is surrounded by only a minimal amount of liquid. Therefore, one separates ḥalla with a berakha from foods such as malawaḥ and mufleta, which are baked in a pan, and kubaneh and jaḥnun, which are baked in a pot. If one establishes a meal on them, he recites ha-motzi and Birkat Ha-mazon.[11]
[11]. It is explained in both the Bavli and Yerushalmi that Reish Lakish is of the opinion that only dough baked in an oven, or in a pan that was heated before the dough was placed in it, is considered baked. R. Yoḥanan, however, maintains that any dough prepared in a pan or pot without a significant amount of surrounding liquid is considered baked (Pesaḥim 37a; Yerushalmi, Ḥalla 1:3). Though Rabbenu Ḥananel rules in accordance with Reish Lakish, the overwhelming majority of Rishonim rule like R. Yoḥanan, including She’iltot, Behag, Rambam, Ri, Rosh, and Rashba. This is also the ruling of SA YD 329:2.
Some authorities raise doubt regarding kubaneh and jaḥnun, since they are baked in a closed pot with a great deal of moisture (Shulḥan Arukh ha-Mekutzar YD 170:18). Others have a similar concern regarding malawaḥ and mufleta and therefore instruct separating ḥalla from them without a berakha (Hilkhot ha-Aretz 12, note 3). However, one should not create unnecessary doubts. These foods are made from thick dough. Even when a great deal of liquid is mixed into the dough, as long as the dough is not liquid enough to be poured and is not placed in a significant amount of liquid while being prepared, it is considered baked. Therefore, one must separate ḥalla from all these foods, and one who establishes a meal on them recites ha-motzi and Birkat Ha-mazon.
Similarly, I wrote above that even if a small amount of oil is placed in the pot or pan for flavor, the food is still considered baked. Some understand that this is true only when the oil is used to prevent sticking (see Rema OḤ 168:14). It seems, however, that the defining issue is whether a significant part of the dough is submerged in liquid. Only then is it considered cooked rather than baked. This is implied by Meiri, Pesaḥim 37a, and Rash, Ḥalla 1:4, and is stated by Mikdash Me’at 329:2.
