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FDA Issues Guidance on Labeling of Honey

The Food and Drug Administration (FDA) has issued a draft guidance document on labeling of honey and honey products.

According to FDA, “honey” is the common or usual name for “a thick, sweet, syrupy substance that bees make as food from the nectar of flowers and store in honeycombs.”  The floral source of honey may be included on the label (e.g., “orange blossom honey,” “clover honey”), provided that (1) the particular plant or blossom is the chief floral source of the honey; and (2) the producer, manufacturer, processor, packer, or distributor can show that the designated plant or blossom is the chief floral source.  See also Compliance Policy Guide Section 515.300 (Honey – Source Declaration).  Honey, when sold as such, is a single-ingredient food and does not need to bear an ingredients declaration.

Only products made exclusively of honey may be called “honey.”  A product consisting of honey and another sweetener must bear a common or usual name that accurately describes the product (e.g., “blend of honey and sugar” if honey is the predominant ingredient, or “blend of sugar and honey” if sugar is the predominant ingredient) and include an ingredients declaration listing its ingredients in descending order of predominance by weight.  Similarly, a product consisting of honey and another ingredient, such as a flavoring, must bear an appropriate common or usual name (e.g., “raspberry flavored honey”) and an ingredients declaration that lists the other ingredient(s).

There have been some reports in recent years claiming that much of the honey on the market is not real honey (see, e.g., Andrew Schneider, Tests Show Most Store Honey Isn’t Honey,, Nov. 7, 2011).

The draft guidance discusses FDA’s enforcement authority and notes that passing off diluted products as honey may result in both misbranding and adulteration (i.e., economic adulteration) charges. FDA also has several import alerts relevant to imported honey, including an import alert for honey adulterated with corn or cane sugar (Import Alert 36-01) and an import alert recommending detention without physical examination for honey that appears to contain unsafe drug residues (e.g., chloramphenicol, fluoroquinolones) (Import Alert 36-04).

The draft guidance notes that FDA received a petition from the American Beekeeping Federation in 2006 requesting the agency to establish a standard of identity for “honey” based on the Codex Alimentarius Commission’s standard for honey, but FDA concluded that a standard of identity was unnecessary and denied the petition.  FDA believes the integrity of honey can be protected under existing laws.

A few states have enacted their own standards of identity for honey that impose additional restrictions beyond those in FDA’s draft guidance.  For example, Utah’s standard of identity for honey provides that it may “not be heated or processed to such an extent that its essential character is changed or its quality is impaired.”  Utah Administrative Code Sec. R70-520-4.  In the absence of a federal standard of identity, there is no federal preemption of such state laws.

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