Question: May one warm up a quiche, meat, or other such foods which contain sauce on an electric hotplate on Shabbat but when they are cold, the sauce is congealed?
Answer: We have explained that it is permissible to warm up a food on Shabbat if has already been cooked before Shabbat, for this does not pose a concern of cooking since “there is no cooking after cooking.” Nevertheless, this only applies to a dry food; however, it is forbidden to warm up a liquid food on Shabbat, such as soup or water, since “there is cooking after cooking with regards to liquid foods.” (There is a permissible way to warm even such foods up on Shabbat as we have discussed.)
The Opinion of Maran Ha’Shulchan Aruch
Regarding congealed foods, Maran Ha’Shulchan Aruch writes (Chapter 318, Section 16): “One may place an Empanada (dough filled with meat and fat-based gravy) opposite the fire in a location where it can reach the temperature of ‘when one’s hand recoils’ although the fat congealed inside it will liquefy.”
This means that something that is congealed because it is cold is not considered a “liquid” with regards to the law of “cooking after cooking” since at the time it was placed next to the fire it was dry, not liquidy.
The Opposing Views and the Bottom-Line Halacha
Several Poskim, including the Levush, disagree with Maran on this law. However, Maran Rabbeinu Ovadia Yosef zt”l rules (in his Chazon Ovadia-Shabbat, Volume 4, page 371) that the Halacha follows Maran and one may act leniently. He proceeds to provide reasons and sources to support his opinion and writes that many Rishonim rule likewise.
Summary: Something which is usually a liquid but is now congealed because it is cold, such as fat, sauce, and the like, may be placed on an electric hotplate on Shabbat in order to warm it up although the heat will cause the congealed item to liquefy.
Based on the above, it will be permissible to heat a jelly donut (“Sufganiya”) on an electric hotplate on Shabbat since at the time the donut is placed on the hotplate, the jelly is congealed and not a liquid. Hagaon Harav Shlomo Zalman Auerbach zt”l and other Poskim rule likewise. (There are several other reasons for leniency regarding jellies and jams.)