Commentary for Kiddushin 76:7

This mishnah (Orlah 3:9) outlines the obligation of three soil-based mitzvoth outside the land of Israel: 1) the prohibition of eating new grain (hadash) before the Omer sacrifice on the sixteenth of Nissan; 2) the prohibition of fruit from a tree during the first three years of its growth (orlah); 3) the prohibition of mixed seeds (kilayim).

Amoraim disagree over the implication of the word “halakhah,” the status of the prohibition of orlah outside of the Land. To Shmuel the prohibition is a law of the country. Rashi explains that this means that the observance of this prohibition was dictated by the sages who lived outside the Land. R. Yohanan gives it a higher status—it is an oral tradition that goes all the way back to Moses at Sinai.