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.
Besides I would be willing to bet there is a lot more being done than you think. For one thing the WCO can’t just go in and post private land against hunting or perhaps even make an arrest on it without first jumping through a lot hoops which might include even sending a letter to the landowner telling them to cease and desist with bait. We as hunters might not like that but it is one of the things that got jammed down the throat of the Game Commission following the State Legislature getting all upset when some of their rich political contributors got busted for hunting over bait on their club lands a few year ago.
Nope, because it's naturally occurring. You didn't open a bag and dump the stream there. You can hunt over as many apples as you want too, as long as they are laying on the ground, where they fell from the tree above, that they grew on. Now move those same apples into a pile somewhere else, and you're hunting over bait.
Where did you come up with they have to warn you first. Guess again, they don't! WCO also may go on private land anywhere they want outside of buildings and curtilage in the performance of their duties.
Even if it were legal in PA, don't waste your money on the stuff. I live in NC now and you can bait with ANYTHING you want. I've tried some of the products like acorn rage and the like and some of them actually attract more coyotes and foxes than deer, especially the ones that are supposed to smell like fruit.
Plain old shell corn seems to work the best, but the deer aren't stupid and they mainly clean up the bait site at night. I don't even bother hunting over bait, I only do it if I'm looking to take an inventory of what's on a property using a trail camera. If you put 50 lbs of corn out you WILL get a lot of deer pics at night and they typically find the bait within 24 hours. Down here they will usually have all 50 lbs gone by day 3.