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If a plant is botanically a perennial and identical to a fruit tree, but it grows within a few inches of the ground, many authorities say its fruit warrants a borei pri ha'adama, as if it were a vegetable. Others ignore the height issue, and say the difference between ha'etz and ha'adama is botanical only.

According to the former opinion, could you say Birkat Ha'Ilanot on, say, a wild blueberry bush that's only 20 inches tall? Is it a "fruit tree" for this purpose?

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We find that a caper bush is halachically considered a tree, and one says ha'eitz on its berries (Shulchan Aruch, Orach Chaim 202:6, from Berachos 36a). And for purposes of the berachos on spices, the definition of "tree" is even more elastic: plants such as rosemary and jasmine get the berachah borei atzei besamim, even though their stems are only semi-woody (ibid. 216:7; Seder Birchos Hanehenin of R' Shneur Zalman of Liadi, 11:2).

So it would seem likely, though I don't have any solid proof for this, that fruit-bearing bushes ought indeed to be considered trees for purposes of birkas ha'ilanos.

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As the Bracha is called Birhas Ha'Ilonos I would say it can only be said on a tree, not on a shrub.

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That's just restating the question, isn't it? Who says that woody shrubs don't fall under the Halachic classification "ilan" even if they don't count botanically as "trees"? (Just like Yonah could have been swallowed by a whale, even though we conventionally translate "dag" as "fish," which is a word that zoologically doesn't include whales.) – Isaac Moses Feb 17 '11 at 22:14
There is also "Safek Brachos L'Hakel" to contend with. I did write that I would say no. – Gershon Gold Feb 17 '11 at 22:32
Yonah was inside a Dagah, which is a whale - not a Dag – Gershon Gold Feb 18 '11 at 1:07
והדגה אשר ביאור תמות (Ex. 7:18); זכרנו את הדגה אשר נאכל במצרים (Num. 11:5). Were there whales in the Nile, and did the Jews eat them? – Alex Feb 18 '11 at 5:18
When referring to the class of fish as a whole then דגה is used. When דגה is used for a single sea creature that swallowed a man it most likely refers to the female whale (as opposed to the male whale that also swallowed Yonah.) – Yahu Feb 18 '11 at 6:12

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