The Proper Beracha for Breaded Chicken or Cheesecake by Rabbi Howard Jachter



              A problem in many households is what to do with leftover cheesecake after Shavuot. Contemporary Halachic authorities disagree about what the proper Beracha is for breaded chicken, which is covered with a thin crust of bread crumbs or Matza meal, or for cheesecake which has a thin layer of dough on the bottom.  Rav Pinchas Bodner (The Halachot of Berachot, p.78 note 60) cites Harav Yosef Eliyashiv as ruling that Borei Minei Mezonot should be recited on breaded chicken.  Rav Wosner (Teshuvot Shevet Halevi 4:23) rules similarly that one should recite Mezonot on cheese cake even if it has only a thin layer of dough.  On the other hand, Rav Elimelech Bluth (Letorah Vehoraah 5:21) cites Rav Moshe Feinstein as saying that a Shehakol is the appropriate Beracha for breaded fish and breaded chicken.  Rav Bodner (The Halachot of Berachot, page 78, note 61) cites Rav Yaakov Kamenetsky as agreeing with Rav Feinstein’s ruling.  Similarly, Dayan Krausz of the Manchester Beit Din (Mekor Haberacha, p.51) rules that one makes a Shehakol on cheesecake which has only a thin layer of dough.  Common practice is in accordance with the rulings of Rav Feinstein and Rav Kamenetsky.  In fact, Rav Aharon Lichtenstein, Rav Hershel Schachter, and Rav Mordechai Willig all told this author that they rule in accordance with the views of Rabbi Feinstein and Rabbi Kamenetsky.  In this essay, we shall seek to prove that a careful analysis of the Gemara, Rishonim, and Shulchan Aruch yields much support for the accepted practice.

Ikar V’tafel

              The Mishna (Berachot 44a) articulates a cardinal rule regarding the laws of Berachot, '% %,-- ,- :%&! 3*89 &3/& )5*-%, /"9+ 3- %3*89 &5&)9 !; %)5*-%, when there is a mixture of foods, one makes a Beracha on the "primary ingredient" (Ikar) and thereby is exempted from reciting a Beracha on the "secondary ingredient" (Tafel).  Acharonim (including Rav Soloveitchik and the Chazon Ish (Orach Chaim 27) have analyzed the nature of this rule.  They question if in principle the Tafel requires a Beracha, but the Beracha uttered on the Ikar is considered as effective for the Tafel or, perhaps by definition the Tafel does not require a Beracha simply because it is too insignificant to warrant a Beracha.  The example given by the Mishna is particularly instructive - that if one eats bread merely to soften the taste of salty food he is eating, he makes a Beracha only on the salty food.  We see that even bread can be classified as Tafel (see Berachot 44a Tosafot s.v. /"9+).

              It is often difficult to determine which component of a mixture is Ikar and which is Tafel indeed the laws of Ikar and Tafel are numerous and complex; see Shulchan Aruch Orach Chaim 208 and 212, Rav Pinchas Bodner, The Halachot of Berachot, pp.53-81, Rav Binyamin Forst, Laws of Berachot, pp.205-228, and Rav David Willig, Am Mordechai, pp. 202-208, for summaries of this issue.  The three basic rules are that (1) one goes by volume - the biggest ingredient is considered the Ikar, (2) if one ingredient clearly comes to serve the other, the former is a Tafel, (3) the Ikar is the ingredient which the individual prefers.

              The rules are quite different when one of the five species of grain (wheat, barley, oats, rye, spelt are involved).  Parenthetically, Most Rishonim (Rashi, Ran, Ritva, Meiri Pesachim 35a and Rabbeinu Gershon Menachot 70b, but see Aruch s.v. Shibol) translate Shibolet Shual, one of the five species, as Avenu, which is the Latin and French word for oats.  However, some modern scholars point out that oats appear very different from the rest of the five species of grain and hardly match the Gemara’s (Pesachim 35a) description of Shibolet Shual as being in the family of wheat (/*0 (*)*.).  While there are some authorities who rule that it is thus inadvisable to recite 3- %/(*% after eating foods made from oats, common practice is to regard oats as Shibolet Shual.  My colleague, Rabbi Baruch Simon informed me that Rav Shlomo Zalman Auerbach told him that it is the correct practice to act in accordance with the majority opinion of the Rishonim who identify Shibolet Shual as one of the five species.  The Gemara (Berachot 36b) presents Rav and Shmuel’s dictum that whenever a food contains one of the five species of grain, the Beracha of Mezonot is recited.  The Gemara discusses a mixture of honey and flour called Chavitz Kedaira, and concludes that the beracha for this item is Mezonot because of Rav and Shmuel's rule.  We shall refer to this Halacha as the "grain rule."

              The Rishonim (Rashba ibid s.v. Doovsha) agree that this is not an exception to the rule that one recites a blessing on the Ikar and not the Tafel.  Rather, as the Rashba explains, grain is regarded as the Ikar.  This appears to be the opinion of the Rambam as well, as the Rambam presents the "grain rule" in the same context as the Ikar and Tafel rule (Hilchot Berachot 3:5).  See also Ra’ah to Brachot 36b and Ribav (26a in the pages of the Rif) who articulate similar views.  This explains why the Gemara (Berachot 39a) presents the following exception to the "grain rule".  The Gemara states that if grain serves only as a binder (Debukei B’Alma), then one does not recite Mezonot on that food.  In such a situation, one can hardly describe the grain component of the food as Ikar.  Thus, a Shekol is recited on meatballs and gefilte fish, even if flour is added as a binder to these foods.

Rishonim - When Does the "Grain Rule" Apply?

              The Rishonim appear to differ regarding the question of when the grain constitutes the Ikar.  The Rambam (Hilchot Berachot 3:6) and the Ribav (26a in the pages of the Rif) write that as long as grain adds taste to the mixture, then one recites Mezonot.  The aforementioned ruling of Rav Eliashiv and Rav Wosner is in accordance with this Rambam.  Indeed, the Mishna Berura (212:1) seems to adopt this approach as normative.

              Other Rishonim, though, appear to take a different approach.  Tosafot (Berachot 36b s.v. kol) write that the grain must serve ,$* :*23&$ %-", to satisfy one’s appetite in order to recite Mezonot.  The Mishna Berura, Rav Eliashiv, and Rav Wosner may believe that Tosafot’s definition of when the "grain rule" applies does not differ from the Rambam’s.  Tosafot (38a s.v. Hai) seems to prove Rav Moshe's interpretation to be correct as Tosafot states explicitly that the "grain rule" does apply where the grain adds only taste.  The Rosh (Berachot 6:7) seems to take a similar approach to that of the Tosafot.  The Rosh writes "as long as the primary ingredient is grain, even if the majority of the food is not from grain, the Beracha is Mezonot."  The Rashba (Berachot 36b s.v. doovsha) also takes a similar approach to that of the Tosafot.  He writes that if the flour is added -%)3*/& &-%,9*:&, to improve taste and render the food edible then one recites Mezonot, despite the fact that the majority of the food consists of other ingredients.  Accordingly, it appears that Tosafot, Rosh, and Rashba disagree with the Rambam who rules that it is sufficient for the flour to contribute some taste to the food in order to warrant the Beracha of Mezonot.  These three Rishonim appear to believe that the flour must make a substantial contribution to the food in order for its Beracha to be Mezonot.

Tur, Shulchan Aruch, and Commentaries

              The Tur (Orach Chaim 208) seems to adopt the position of his father, the Rosh.  The Tur writes that a food from the five grains warrants a Mezonot even if one has added to the food a majority of items that are not from the five grains.  The Tur presents the "grain rule" as applying only when the flour is the essential ingredient, unlike the Rambam who believes that it is sufficient for the flour to add taste to the food mixture.  By stating "a food from the five grains" the Tur indicates that the most important ingredient of the food item is from grain.  Otherwise, he would not describe the item as a "food from the five grains."

              The Shulchan Aruch (O.C. 208:2-3) also seems to accept the approach of the Rosh and Tosafot and rejects the Rambam.  Rav Karo presents the rule (similar to the Tur) that if the primary ingredient (Ikar) of a food is from grain, then Mezonot is recited even if the majority of the food is from ingredients other than grain.  In paragraph three, Rav Karo presents the rule, sounding very much like Tosafot, that for the grain to be Ikar, it must have sufficient presence to satisfy one’s appetite.

              Accordingly, the Shulchan Aruch seems to reject the approach of the Rambam that flour is Ikar even if it merely adds taste to the food.  The ruling of the Magen Avraham (168:30) supports this interpretation.  He rules that if one crumbles thin pieces of bread into hot beer in order to improve the taste of the beer, one blesses Shekol...because the bread is Tafel, since his primary intention is to drink beer, and the pieces of bread are neither substantial nor significant.


              According to our approach, it would seem that the rulings of Rav Feinstein and Rav Kamenetsky are supported by the Shulchan Aruch.  Since the thin layer of crust in breaded chicken or cheesecake serves only to add taste but is not sufficiently substantial  to satisfy an appetite, the Beracha should be Shehakol.  Furthermore, even if one feels that the argument we presented is not conclusive, one would still have to recite Shehakol.  This is because even if our thesis is only possibly correct, it still implies a Halachic doubt or Safek, and in case of Safek, one recites a Shehakol.  One should not in this instance rely on the Chayei Adam’s (58:3) ruling that if one recited Borei Minei Mezonot, he has post facto fulfilled his requirement for reciting a Beracha, since this ruling is controversial and is rejected by some authorities (see Rav Akiva Eiger, Gilyon Hashas Berachot 36b commenting on Tosefot s.v. kol, see Rema 202:18 and Mishnah Berura 202:86).  For a different approach to defend Rav Feinstein and Rav Kamenetsky’s ruling, see Rav David Willig’s aforementioned essay.

              Finally, it should be noted that Rav Feinstein rules (see Halachot of Berachot p.79 note 62) that if the coating is thick then one should recite Mezonot.  This follows our analysis: if the grain component satisfies the heart, it is substantial and thus is the Ikar.  Very often,  breaded foods served in restaurants  have such a thick coating and may warrant a Beracha of Mezonot, according to Rav Feinstein.  In case of doubt, one should recite Shehakol or, even better, should eat such food within a bread-based meal (see Shulchan Aruch O.C. 208:3).  One should also consider the wholesomeness of a particular food before putting it into the body which God has presented to us.

              The issues discussed in this essay are likely to be relevant when determining the proper Beracha for a particular cereal that contains a grain product, from the five species, which merely adds flavor but cannot satisfy an appetite (this was pointed out to this author by Rabbi David Heber).  This also may be the relevant consideration in determining the correct Beracha for licorice which contains a considerable amount of flour.

              Next week, God willing, we will delve into the fascinating issue regarding the appropriate Berachot for papayas and raspberries.

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