Yesterday, we noted the verse in Parashat Shelach (15:20) in which the Torah draws a comparison between challa – the portion of dough which must be given to a kohen from one’s batter– and teruma – the portion of grain from the field that must be given to a kohen. Rashi, citing from the Sifrei, explains this analogy as establishing that challa resembles teruma in that there is no Biblically prescribed proportion that one must give. The Sages instituted a percentage the one should donate to a kohen from his crop (ideally 1/40th, but at least 1/60th), but as far as Torah law is concerned, “afilu chita achat poteret et ha-keri” – even a single stalk of grain suffices for an entire heap of produce. When the Torah likens challa to teruma, Rashi writes, it indicates that challa, too, has no minimum requirement on the level of Torah law. Chazal, however, enacted a required portion of 1/24th of the dough, and a smaller portion – 1/48th – for one who prepares baked goods commercially.
Surprisingly, Rashi appears to directly contradict this comment in his remarks to the very next verse (15:21). Noting the Torah’s formulation in that verse, “…titenu le-Hashem” – “you shall give to the Lord,” Rashi explains that the Torah requires giving “kedei netina,” or a meaningful quantity, an amount that can aptly described as being “given” to a kohen. Here, Rashi clearly points to a minimum quantity required by Torah law, as opposed to the previous passage, in which Rashi states that the Torah obligation of challa has no minimum amount.
This question was addressed by the Noda Bi-yehuda (Mahadura Tinyana, Y.D. 201), who suggests distinguishing between two aspects of the challa obligation – separating a portion of dough, and giving a portion to a kohen. When it comes the obligation to separate a portion of dough to make the batter permissible for consumption, the Noda Bi-yehuda asserts, there is no minimum requirement; even the smallest percentage of dough suffices. This is why the Torah compares challa to teruma in reference to the command of “tarimu” – to remove a portion of dough (15:20), indicating that there is no minimum amount required to fulfill this obligation. In the next verse, however, the Torah requires giving the separated portion to a kohen – “titenu” – and Rashi explains that this refers to “kedei netina,” a respectable amount of dough.
Interestingly, the Noda Bi-yehuda writes this is a novel theory that has never been suggested in the past – though in truth, it actually does appear in two earlier sources, as noted by Rav Asher Weiss – in the Tosefot Rid (Kiddushin 58) and the Maharam Chalawa (Pesachim 32b). According to this view, then, one who separates and gives to a kohen an insignificantly small portion of dough from his batter has fulfilled the first aspect of the mitzva of challa, and the remaining dough is permissible, but he has not fulfilled the second component – giving a portion to a kohen.