# Federal Requirements for Honey Labels (Part 2)



## Specialkayme (Sep 4, 2005)

Some help:

https://www.fda.gov/Food/GuidanceRe...yInformation/LabelingNutrition/ucm2006828.htm



> 8. What name and address must be listed on the label?
> 
> Answer: Food labels must list:
> 
> ...


Source: https://www.fda.gov/Food/GuidanceRe...ryInformation/LabelingNutrition/ucm064866.htm



> 1. What is the net quantity of contents and how is it expressed?
> 
> Answer: The net quantity of contents (net quantity statement) is the statement on the label which provides the amount of food in the container or package. It must be espressed in weight, measure or numeric count. Generally, if the food is solid, semisolid or viscous, it should be expressed in terms of weight. If the food is a liquid, it should be expressed in fluid measure (e.g., fl oz). 21 CFR 101.105(a)(b)(c)
> 
> ...


Source: https://www.fda.gov/Food/GuidanceRe...ryInformation/LabelingNutrition/ucm064877.htm

You can comb through the rest of that FDA guide. I just pulled out two specific references.

Short answers:
A) Yes, it needs to be in ounces and metric. I don't really know why you'd fight this, or bother NOT putting metric on your label. If you're printing labels, it costs you nothing extra.

B) No, you don't need to put a phone number. Although, getting a pre-paid phone with a 500 minutes card will cost you very little. If you get and make no calls on it, it will cost you nothing further. Then you aren't using any government property for personal use. 

Note: I avoided references to state laws, as clearly you aren't interested in those.


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## psm1212 (Feb 9, 2016)

That is an excellent source Special K. Thanks. I am still questioning the Guides statement regarding the requirement of metric measurements. It cites 21 CFR 101.105 and the Guide states unequivocally that you MUST use metric and U.S. Customary System. 

But if you go to the current version of the CFR off of the Government Publishing Office website and scroll to 21 CFR 101.105 (which is the code section cited in the Guide) it does not say that. It says that you must use avoirdupois pound and ounce. It goes on to state, later in that section, that you MAY also display it in metric on the main label but clearly it is not a requirement. 

Both are U. S. Government publications, by the way. 

In any event, that is on point to what I am seeking and I appreciate you finding it.


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## Specialkayme (Sep 4, 2005)

psm - if you're really that concerned about it, I think you need to hire an attorney and get an opinion. 

To me, it really isn't that complicated, it isn't that ambiguous, and not worth fighting over. I understand it might be for you.


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## psm1212 (Feb 9, 2016)

Specialkayme said:


> psm - if you're really that concerned about it, I think you need to hire an attorney and get an opinion.
> 
> To me, it really isn't that complicated, it isn't that ambiguous, and not worth fighting over. I understand it might be for you.


Special K: Ha! I am an attorney that spends the majority of his day in the CFR. I do not find the code ambiguous at all. It is all the guides, trade shops (like NHB) and fellow bee keepers that seem to baffle me. They seem to just be making requirements up out of thin air. I can't find a basis for it. Just trying to figure out if someone else can. Hell, even the FDA doesn't seem to interpret their own governing code correctly. 

But that is par for the course. RUS and FEMA are much worse in their attempts to "summarize" the CFR.


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## Specialkayme (Sep 4, 2005)

psm1212 said:


> I am an attorney that spends the majority of his day in the CFR.


Then you know the issue has nothing to do with the CFR or the FDA. It has to do with the store manager, local agent, county rep, or state health inspector that sees your bottles on the shelves, misinterprets the FDA regulations, and either pulls your items from the shelves or refuses to stock them in the first place. From there, you tell me what's easier: convincing the person who removed your items they're wrong, or putting "(__g)" on the label?


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## Michael Bush (Aug 2, 2002)

The metric requirement may be from either the "Metric Conversion Act of 1975", which put us on the metric system (which we ignored) or the "Omnibus Trade and Competitiveness Act of 1988" which made the metric system "the preferred system of weights and measures for the United States trad and commerce" which we also ignored.


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## psm1212 (Feb 9, 2016)

My personal issue was with the phone number, not the metric issue. 

However, I am really not trying to solve my personal problem as simply wanting to find the correct answer to the question. 

SpecialK's find of the FDA guidance led me to a 1992 congressional act which specifically amends the THEN-existing 21 CFR 101.105 to require metric units. So it is not coming "out of thin air" as I had earlier suspected. 

However, the current version of that CFR does not reflect the metric requirement, and, in fact, seems to specifically state that metric is only an option, not a requirement. 

I cannot find where the 1992 act was repealed, but that doesn't mean that the language could not have been subsequently changed (again). 

So we have the current version of the CFR which does not require metric. We have a 1992 act that amends the Code to require metric. And we have a 2013 FDA guidance issuance that states we must show metric. 

I still don't know the correct answer with regard to metric, but I do have a better understanding of the conflicting views. 

And, yes, I know the easier path is to post the metric.  But that does not give me my answer.


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## psm1212 (Feb 9, 2016)

Michael Bush said:


> The metric requirement may be from either the "Metric Conversion Act of 1975", which put us on the metric system (which we ignored) or the "Omnibus Trade and Competitiveness Act of 1988" which made the metric system "the preferred system of weights and measures for the United States trad and commerce" which we also ignored.


Might be. That will be a plow to figure out. 

Years ago we had a governor, Fob James, who decided the State of Alabama was going to convert to the metric system. One of the first things he did was to change the highway markers from miles to kilometers. Of course, no one bothered to change the exit numbers (which had corresponded to the mile posts) to the now-corresponding kilometer number. You can imagine how that went over with a semi-literate citizenry. Needless to say, Alabama's venture into the metric system was quickly aborted.

Much to my chagrin. Life is just easier in the metric system. At least in my opinion it is.


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## Michael Bush (Aug 2, 2002)

The reason we didn't convert was the way they taught the metric system. They made us convert back and forth from metric to standard and standard to metric. That's not how you use a system of measurement. But it gave us all the impression that we would be doing that all the time to use the metric system. Well most of us. I grew up in a print shop with a pica pole and I didn't care what you measured anything in as long as it was on my ruler or other measuring device. Instead of just moving a decimal point around, I get to constantly change from 1/8s of an inch to 100ths and 100ths to 1/8s and tenths of a foot to inches and inches to tenths of a foot and feet to miles and miles to feet...


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## aunt betty (May 4, 2015)

Name, phone number, weight, and I put the city it's from so I can claim it's local. 
Selling face to face, producer to consumer, therefore am exempt from a lot of the labeling and inspection stuff until I sell at least 3 tons/year. Illinois has a special law to protect small honey producers.


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## SWM (Nov 17, 2009)

Psm1212 if your issue is with the phone number then chill out and forget about it. While many include a phone number on honey labels it is not a requirement under federal law. As you probably know, food labeling is governed federally so as not to impede interstate commerce. If someone tells you that your phone number is required then tell them to go pound sand.


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## GaSteve (Apr 28, 2004)

The first line of the GA state label requirements says:

"All packed product labels should meet the FDA labeling requirements found in 16 C.F.R. Part 500." 

Then they list the rules from that CFR that apply to honey - in plain language. Metric weights are not an option. I have city, state, email, and phone number on my labels. I don't put a street address.

When I first started, I was a bit hesitant about putting my personal cell number on every label, but it hasn't been an issue and has led directly to new business.

Not sure about AL, but in GA the state is the entity that approves the labels and does the inspections so they are the only ones I'm concerned with.

Alabama - a semi-literate citizenry??? - that's a low blow. I expect metric conversion attempts in other states would probably meet the same fate.


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## psm1212 (Feb 9, 2016)

16 CFR Part 500 are rules promulgated by the Federal Trade Commission, not the FDA, though I have been thinking this is where the source of the "metric rule" is coming from. The FDA rules do not require the metric unit displayed in Title 21 and instead, the current version states that only avoirdupois weight is required. 

So what does that mean? Why would FDA (Health and Human Services) say avoirdupois only and FTC (Justice Department) say avoirdupois and metric (which is exactly what it states)? 

These two sections clearly conflict, yet they both have application to the labeling of honey (best I can tell). 

I think the right answer is that they are both right. The FTC would simply state that it does not care what the FDA requires on the label. It (FTC) requires both and failure to comply is a violation. Simply because the FDA does not require it, does not mean it is not required. 

But one does wish they could all actually get their [email protected] together and make things a little easier.


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## psm1212 (Feb 9, 2016)

GaSteve said:


> Alabama - a semi-literate citizenry??? - that's a low blow.


1 in 4 were illiterate during Fob's administration. It probably is a low blow to point it out - - but it is not incorrect. I expect you are right that it would not have gone over well in many states though.


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## CoryM465 (Jan 26, 2016)

psm1212 said:


> 1 in 4 were illiterate during Fob's administration. It probably is a low blow to point it out - - but it is not incorrect. I expect you are right that it would not have gone over well in many states though.


Prove it. 

This is ignorant at best, disingenuous at worse. Alabama put men on the moon. Madison has more PHDs per capita than any other county in the country.

That switch over to metric would have failed in any one of the 50 states or our territories. It was another horrible, half way thought through government program.


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## psm1212 (Feb 9, 2016)

CoryM465 said:


> Prove it.
> 
> This is ignorant at best, disingenuous at worse. Alabama put men on the moon. Madison has more PHDs per capita than any other county in the country.


Literacy Council of West Alabama says that 1 in 4 Alabamans are illiterate CURRENTLY.
http://literacywa.org/literacy-facts-2/

Here is an article on a 2000 study confirming the same.
http://www.atmoreadvance.com/2000/0...very-four-alabamians-functionally-illiterate/

Here is a study showing a 21% literacy rate in Alabama in 1992.
http://m.andalusiastarnews.com/2009/01/08/state-literacy-rate-improves-by-6-percent/

Wehrner Von Braun put man on the moon. He was German. 

No doubt, Huntsville has some of the brightest minds in the country right now, thanks in large part to Von Braun's legacy. Birmingham has some one of the best medical communities and teaching facilities in the country with thousands of brilliant people making that possible.

I graduated from a high school in south Alabama. There were 118 of us on stage at graduation. 2 of us left for 4-year colleges. 6 were pregnant. Madison, Shelby and Lee counties are beacons in a state where some counties have a roughly 1/3 illiteracy rate. Bullock, Greene and Wilcox counties have illiteracy rates that exceed 30%.

My statement was neither ignorant nor disingenuous. It is accurate, even if it is sad and makes us a little defensive. Perhaps it is mean-spirited, though I did not originally intend it that way.


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## gww (Feb 14, 2015)

Have you ever wondered about how merrit is put to statistics. I have always thought that everybody is differrent and have differrent tallants. Not everyone will excel at school (me). I wonder if the girl who got married right out of high school or the other one who became a doctor and made a million bucks and then woke up at 40 thinking is this what life is about, which had the better life or made a better contrabution to sociaty? I think everybody has that (is this what life is about moment at some time). I knew about a guy that trapped muskrats, skinned them and sold peices of that skin as something that makes the bow hunters bow quiet. Happyness and success can be measured in many ways.

Some good people on this list.
http://www.businessinsider.com/top-...made-millions-without-a-college-degree-2011-1

I always look up to poeple that pursue whatever they are doing to improve themselves even if formal schooling is part of that improvement, or not.

I wonder how many people just have a "green thumb" on things like bees or farming or mechanical apptitude where all the other stuff is just fluff that gets in the way.

I don't know if a stitistic saying 3/4 of the poeple are illiterate should be a put down or a badge of honor. It would take more info to make a determination. I know there are a lot of good bee keepers in alabama.
Cheers
gww

Ps I also think most people are proud of the path that they took and that this does not have to be a put down of other paths.


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