Depends on whether you are hunting over it. If you throw it out in your back yard just to watch the deer, it is food. If you hunt over it, it is bait. It contains food stuffs that attract game. I don't have the exact language from the rule book, but I would not chance it.
It says, "scents and lures that contain any form of natural or artificial food stuff, including, but not limited to, corn, apple, and acorns are not legal" in bold print in the General Regs section of the hunting digest.
Bait is not legal unless it has roots and those roots are still in the ground.