The Torah commands that we separate challa when we eat “מלחם הארץ,” “from the bread of the land.” Bread, of course, is a broad term, which begs the question: Exactly which types of baked goods are obligated to have challa separated from them? All would agree that if one of the five grains are mixed with water, kneaded into thick dough (belila ava), and then baked with dry heat in an oven, the resultant bread is certainly a product which is obligated in challa. That is, after all, the standard recipe and process for producing bread. The matter becomes more complicated, however, in situations that deviate from this standard process. For example, one might bake loose, runny dough (belila raka), such as a cake batter. Alternatively, instead of baking thick dough in an oven, one may choose to cook it in a liquid, as is the case for deep-fried doughnuts.
While the primary sources do not explicitly address these issues, the Rishonim seek to prove from various Mishnayot and Gemarot how the halacha views these non-standard “breads.” Analyzing their opinions will also shed light on their notion of the “mechayev” of challa, the specific factor that triggers the obligation to separate challa.
At the heart of the issue lies the question of how to understand the ruling of the following Mishna in Challa (1:5):
עיסה שתחלתה סופגנין וסופה סופגנין פטורה מן החלה. תחלתה עיסה וסופה סופגנין, תחלתה סופגנין וסופה עיסה –חייבין בחלה.
Dough that is originally sufganin and ultimately sufganin is exempt from challa. If it is originally dough and ultimately sufganin [or] originally sufganin and ultimately dough, it is obligated in challa.
It is clear from the Mishna that if something begins or ends as “issa,” dough, it is obligated in challa; only if it is “sufganin” throughout the process is it exempt from challa. What remains to be clarified about the Mishna is the meaning of starting and ending as dough or starting and ending as sufganin. Three basic approaches in the Rishonim will be examined.
Rabbeinu Tam: Thick or Baked
Rabbeinu Tam explains that sufganin are a belila raka that are not baked in the oven, but are rather baked in the sun or cooked in liquid. Thus, according to Rabbeinu Tam, the rule of the Mishna is that something is only exempt from challa if it begins the way sufganin do (a loose batter) and ends the way sufganin do (baked in the sun or cooked in liquid). If, however, the food either starts as issa (thick dough), even if it is subsequently cooked like sufganin, or ends as issa (baked in the oven), even though it was originally a loose batter, it is obligated in challa. Two stringencies emerge from Rabbeinu Tam’s explanation: First, loose batter that is baked (such as cake) is obligated in challa. Second, thick dough that is cooked (such as doughnuts) is obligated in challa.
The first stringency is logical: despite the fact that this loose dough begins as sufganin, since it ultimately undergoes the baking process and becomes bread, it is sensible that it should be obligated in challa. What, though, is the logic behind the second stringency? Once the dough has been cooked, the product should no longer be considered bread and should be exempt from challa. Ostensibly, there are two possible explanations: Either a cooked dough is indeed considered by halacha to be bread, or there is something else that generates the obligation to separate challa. Insight into this question can be gleaned by examining the connection between the obligation to separate challa and the beracha of hamotzi.
Hilchot Challa and Hilchot Berachot
Tosafot write that Rabbeinu Tam initially maintained that while a thick dough that is cooked is obligated in challa, it is not considered bread with respect to berachot and therefore does not merit the beracha of hamotzi. He reasoned that there was ample room to distinguish between the obligation of challa and the beracha of hamotzi. As is evident from the language of the beracha (hamotzi lechem min ha’aretz), hamotzi can only be recited over lechem, bread. However, the obligation of challa is not dependent on the final product being classified as bread. Since the Torah uses the language of “arisoteichem,” “your dough,” it is sufficient for the product to begin as a thick dough to trigger the obligation of challa, even if that dough does not result in bread. Tosafot conclude that Rabbeinu Tam later retracted that distinction, proving from the Gemara that one recites hamotzi even on cooked dough.
The implication of Rabbeinu Tam’s retraction on the mechayev of challa is open to interpretation. On the one hand, one may claim that while initially Rabbeinu Tam felt that the classification of arisoteichem was enough to obligate separation of challa, this was only to explain how the same product could be obligated in challa, but exempt from the beracha of hamotzi. Once Rabbeinu Tam concluded that cooked dough is both obligated in challa and qualifies as bread for hamotzi, perhaps only that which qualifies as bread is obligated in challa, and there is no separate trigger of arisoteichem. Alternatively, Rabbeinu Tam’s conclusion may have been a local retraction in hilchot berachot to make hamotzi on cooked dough. He may, however, maintain his position that there is a parameter separate from the classification of bread which obligates one to separate challa, the mechayev of arisoteichem.
To test which of these two options is correct, let us consider a scenario which involves a thick dough, but one that is clearly exempt from the beracha of hamotzi for technical reasons. The Gemara (Berachot 37b) implies that in order to qualify for the beracha of hamotzi, a product must have “torita denahama,” “the appearance of bread.” Would a cooked dough that lacks the appearance of bread be obligated in challa? Pasta is a prime example of such a product. Initially, a thick dough, resembling that of bread, is kneaded. Then, the dough is cut into thin strips, dried, and cooked in water. The resultant product bears little resemblance to bread and does not qualify as hamotzi. Must challa be separated from pasta dough?
Rabbeinu Tam himself addresses this issue, ruling that challa must be separated from pasta dough. But Rabbeinu Yona disagrees; although he concurs with Rabbeinu Tam’s general rule that cooked dough is obligated in challa, he rules that pasta is exempt from challa because it lacks the appearance of bread. This dispute seemingly revolves around the aforementioned issue. Rabbeinu Tam sees it as plausible that a product may be obligated in challa even though it does not fall under the category of bread. Thus, he must hold that the obligation to separate challa can be generated simply by the thick dough (arisoteichem), even in the absence of bread. Rabbeinu Yona, conversely, maintains that the obligation to separate challa is only generated by bread. Therefore, pasta, which cannot be classified as bread due to its appearance, is exempt from challa.
Ramban: Intention Dependent
To review the rule of the Mishna, only bread which begins and ends as sufganin is exempt from challa; bread that either begins or ends as dough is obligated in challa. The Ramban takes issue with several aspects of Rabbeinu Tam’s interpretation of the Mishna. Ultimately, he concludes that the words of the Mishna do not allow for Rabbeinu Tam’s interpretation. Rather, the Ramban explains, the Mishna in its entirety deals only with belila ava (thick dough), as indicated by the first word in the Mishna, issa. Starting as dough or sufganin, therefore, does not refer to the consistency of the dough, but rather to the planned method (at the time of the dough’s creation) of heating the dough – baking in an oven or cooking in water/baking in the sun. Accordingly, ending as dough or sufganin refers to the method of heating the dough actually employed. With the Ramban’s definitions in mind, the Mishna means as follows: If a thick dough is kneaded with the intention of boiling it, and the dough is indeed ultimately boiled, it is exempt from challa. But if one either intended to boil the dough but ended up baking it, or intended to bake the dough but ended up boiling it, it is obligated in challa.
What triggers the obligation of challa according to the interpretation of the Ramban? Presumably, dough that one intended to boil, but ended up baking, is obligated in challa because the resultant product is bread. Conversely, the Ramban explains that dough that one intended to bake, but ended up boiling, is obligated in challa because although the final product is not bread, the obligation to separate challa already took effect from “sha’at gilgul,” the time that the dough was kneaded with the intention of baking it. Thus, according to the Ramban, one of two conditions can generate the obligation to separate challa from a thick dough: The product is bread, or the dough was kneaded with the intention of making bread.
In contrast to the opinion of Rabbeinu Tam, two leniencies emerge from the position of the Ramban. First, whereas Rabbeinu Tam obligated challa to be separated from a thick dough that is cooked (such as a doughnut), the Ramban would exempt such a product from challa, assuming that one’s intention was always to cook the dough. Second, while Rabbeinu Tam obligates a loose dough that is baked (such as a cake) in challa, Ramban strongly implies (from the fact that the entire Mishna discusses only thick dough) that only a thick dough can become obligated in challa. This is indeed how his disciple, Rabbeinu David, records his teacher’s position.
Rash and Rosh: Compromise
The Rash (Rabbeinu Shimshon of Shantz) assumes a compromise approach (commentary to Challa 1:5). Like Rabbeinu Tam, he obligates the separation of challa from a loose dough that is baked. However, like the Ramban, he explains that the Mishna only obligates challa to be separated from dough that was either baked or intended to be baked. But a dough that was intended to be cooked and was indeed cooked is exempt from challa. This approach was also embraced by the Rosh.
Fundamentally, the Rash appears to agree with the Ramban about the mechayev of challa: Either the presence of bread or dough kneaded with the intention of making bread generate the obligation to separate challa. They disagree though about the definition of bread. While the Ramban is of the opinion that only a thick dough can become bread halachically, the Rash believes that even a loose dough, if baked in an oven, is considered bread. Their disagreement about the obligation to take challa from such a product is a direct outgrowth of their definitions of bread.
The Shulchan Aruch (Y.D. 329:2-3) rules in accordance with the compromise opinion of the Rash and Rosh. According to his ruling, cake (loose batter which is baked) would be obligated in challa, while doughnuts (thick dough which is cooked) would be exempt from challa since one’s intention was always to deep-fry them.
The Shach comments that it is proper to act stringently out of concern for the opinion of Rabbeinu Tam. Therefore, he advises one to separate challa from cooked dough in accordance with Rabbeinu Tam, but not to make a beracha on the separation, in accordance with the Rishonim who exempt such a product from challa.
 Bamidbar 15:19
 Wheat, barley, spelt, oat, or rye. See Mishna, Challa 1:1.
 Sefer HaYashar 344 . His opinion is also recorded in Tosafot (Berachot 37b, s.v. lechem) and Tosafot (Pesachim 37b, s.v. dekulai) as well as in other Rishonim.
 See Rabbi Yochanan (whom the halacha follows) quoted in Pesachim 37a.
 See Yerushalmi, Challa 1:3.
 Berachot 37b, s.v. lechem
 Bamidbar 15:20-21
 See the translation of Onkelos (Bamidbar 15:20-21), Rosh (Pesachim 2:16), Rashi (Bamidbar 15:20-21), and Tosafot (Berachot 37b).
 Evidently, only thick dough (belila ava) is defined as arisoteichem.
 Berachot 37b records that the Kohanim used to recite the beracha of hamotzi before eating menachot, some of which were deep-fried in oil. Evidently, even deep-fried (the equivalent of cooked) dough is hamotzi.
 Sefer HaYashar 344 , Tosafot (Berachot 37b), Tosafot (Pesachim 37b), Mordechai (Pesachim 592), and Rosh (Pesachim 2:16).
 Berachot 27a in the pagination of the Rif, “umizeh”
 Darkei Moshe (Y.D. 329:2) infers that Rabbeinu Yona’s exemption of pasta is even according to Rabbeinu Tam’s understanding of the Mishna in Challa. See, however, Pitchei Teshuva (Y.D. 329:1) in the name of Panim Meirot (1:68), who disagrees. See also Chazon Ish (Zeraim, Likutim 5:2), who supports the Darkei Moshe.
 Hilchot Challa, 26a-b
 Indeed, many of the Mishnayot indicate that “sha’at gilgul” is the critical point which determines whether the product will be obligated or exempt from Challah. See Mishna, Challa 3:2,3,5,6.
 Pesachim 37a, s.v. hasufgenin. See also footnote 30 there and Rav Mordechai Willig in דין חלה והמוציא בבלילה רכה, Beit Yitzchak Vol. 43, page 147.
 Challa 1:5
 See Rav Mordechai Willig, p.149.
 Pesachim 2:26, as understood by his son, the Tur (Y.D. 329). See also Beit Yosef there.
 YD 329:4.
 Another solution presented by the Shach is to bake one small piece of the dough, thus obligating the whole dough in challa. See Shulchan Aruch (Y.D. 329:4). With regard to the beracha in such a situation, see Shach (Y.D. 329:6).