Most cooks say a tart is open-faced and a pie may be covered, but the dictionaries do not hold the line and the oldest recipes cross it. No American food law defines a pie in general. The one federal standard for a fruit pie was revoked in 2024.
The earliest English recipe for an apple pie is called a tart. A manuscript dated 1381, printed by Samuel Pegge in 1780 alongside the Forme of Cury, gives “For to make tartys in applis”: apples, spices, figs, raisins and pears, colored with saffron and baked in a “cofyn,” a pastry case. Around 1514 the first printed Dutch cookbook gave “Appeltaerten,” an apple tart filled to the brim and closed with a lid of the same dough.
The words arrived at about the same time. The Online Etymology Dictionary dates pie to about 1300, for a pastry filled with meat and covered with a thick crust, and tart to the late 14th century, from an Old French word for a flat, open-topped pastry. It adds that in the Middle Ages a pie had many ingredients in one pastry, and that fruit pies began to appear around 1600, a date the 1381 apple tart does not fit.
Modern dictionaries give the familiar rule and then blur it. Cambridge defines a tart as an open pastry case with a filling and a pie as meat, vegetables or fruit covered in pastry and baked. Merriam-Webster defines pie as a filling in a pastry shell or topped with pastry or both, which admits the open pie. Its first sense of tart reads “a dish baked in a pastry shell : pie,” then names the small open shell and the folded pastry as examples.
Americans drew the line by nationality. Henry T. Finck wrote in Food and Flavor in 1913, as quoted in Barry Popik’s citations, that the British substitute for the American fruit pie was the tart, which had only one crust. Simmons, a century earlier, had baked her apple pie in a paste listed among her “Puff Pastes for Tarts.”
The law has little to say. The FDA set standards of identity and quality for frozen cherry pie in 1971. When it revoked them in 2024 it noted that frozen cherry pie had been the only fruit pie, frozen or not, subject to such standards. The USDA’s meat inspection rules require only that a meat pie such as a beef or pork pie contain at least 25 percent meat by weight, crust included. Neither rule distinguishes a pie from a tart.
The working distinction most cooks use, a tart open and shallow and a pie deeper and often covered, rests on usage and on the Cambridge definition. It has no regulatory backing in the United States.