# Do you really need to register your Honey house with the FDA?



## LSBees (Sep 24, 2009)

Registration of Food Facilities
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OMB Approval Number: 0910-0502
OMB Expiration Date: 08/31/2013
See OMB Burden Statement2.
The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (the Bioterrorism Act) directs the Food and Drug Administration (FDA), as the food regulatory agency of the Department of Health and Human Services, to take additional steps to protect the public from a threatened or actual terrorist attack on the U.S. food supply and other food-related emergencies.

To carry out certain provisions of the Bioterrorism Act, FDA has established new regulations requiring that:

Food facilities are registered with FDA, and
FDA be given advance notice on shipments of imported food.
The Bioterrorism Act requires domestic and foreign facilities that manufacture, process, pack, or hold food for human or animal consumption in the U.S. to register with the FDA by December 12, 2003.

Owners, operators, or agents in charge of domestic or foreign facilities that manufacture/process, pack, or hold food for consumption in the U.S. are required to register the facility with the FDA.

Domestic facilities are required to register whether or not food from the facility enters interstate commerce.

Foreign facilities that manufacture/process, pack, or hold food also are required to register unless food from that facility undergoes further processing (including packaging) by another foreign facility before the food is exported to the United States. However, if the subsequent foreign facility performs only a minimal activity, such as putting on a label, both facilities are required to register.


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## Vance G (Jan 6, 2011)

By all means! Bleat about this needing done! We need many more rules and regulations! Leave it alone. There are so many laws that we are all jailable at any given time anyway.


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## weavefish (Sep 24, 2011)

i think it may have been filtered down to state level. here in WA your supposed to register your hive... some of the blurbadge looks identical to the states.


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## Acebird (Mar 17, 2011)

Think about this people. If you have a back yard beehive do you think the FDA / Homeland Security is concerned about you and six others? They are concerned about 6000 or 6 million others not you and your neighbors. I don't ever expect to file anything with the FDA.


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## NGAnderson (Jun 14, 2011)

Who's the FDA?


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## Nabber86 (Apr 15, 2009)

On planet Ace? anything and everything.


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## Ted Kretschmann (Feb 2, 2011)

Yep, that sounds like the regulation as written that shut down two Georgia producers last year. Yep, if you sell honey to the public you are supposed to register your facilities. Should you do so? That I will not comment on. AS a Sioux member, those government boys pretty well know where the membership's processing plants are. I have not seen the plant inspectors yet, but suspect they will show up one day. They sure did a Sherman last year and stomped through Georgia. TED


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## Guest (Nov 11, 2011)

Vance G said:


> There are so many laws that we are all jailable at any given time anyway.


You are most unfortunately correct. We can get cut from the herd at any time. The weak live at the mercy of the strong.


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## deknow (Jul 17, 2006)

Our facility is registered with the FDA. It is also certified and inspected by the state and the city.
Registering with the FDA is.the least of it...I think it took about 5 min.

Deknow


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## KQ6AR (May 13, 2008)

Honey isn't a processed food, its no different than selling tomatoes, or corn from the garden.


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## Acebird (Mar 17, 2011)

Extracting honey is a process. Picking tomatoes and corn is not.


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## EastSideBuzz (Apr 12, 2009)

Acebird said:


> Extracting honey is a process.


So is getting out of bed sometime after a day working the bee's.


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## RDY-B (May 20, 2007)

Exempt from records maintenance are:
• Farms
• Restaurants
• Nonprofi t operations that prepare food for or serve food directly to consumers
• Fishing vessels not engaged in processing
• Persons regulated exclusively by the U.S. Department of Agriculture under various
statutes
Defi nitions
Farms are defi ned as facilities in one general physical location devoted to growing and
harvesting crops, the raising of animals, or both. The term “farm” also includes facilities
that pack or hold food provided that all food used in such activities is grown, raised or
consumed on that farm or another farm under the same ownership, and facilities that
manufacture/process food, provided that all food used in such activities is consumed on
that farm or another farm under the same ownership. A farm-operated roadside stand
that sells food directly to consumers as its primary function would be exempt from
registration as a retail food establishment.  RDY-B


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## Ted Kretschmann (Feb 2, 2011)

Seems to be a contradiction in the definitions listed above. The keywords are consumed on the farm. So what is the difference between a commercial beek like myself that sell the product to the packer and the little beek that sells it off the back of his pickup truck at a flea or farmers market to the public??? I really see no difference. Both scenerios are potential sources of contamination by Akmed the dead terrorist beekeeper. Beekeepers are a proud, honest bunch of people ,who are proud of the products of the hive they produce. But having said this, so far as an industry, we have been lucky. TED


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## Acebird (Mar 17, 2011)

Exposure Ted. You affect a lot more of the population and therefore are a greater risk.


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## Jim 134 (Dec 1, 2007)

Acebird said:


> Extracting honey is a process. Picking tomatoes and corn is not.


 So just sell comb honey.


BEE HAPPY Jim 134


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## Acebird (Mar 17, 2011)

I think that might fly if you picked a frame of honey out of your hive and sold it as is. I don't know what the classification would be if you cut it out of the frame and packaged it. It is hard to get by the packaging process if you are selling to the general public.


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## deknow (Jul 17, 2006)

whether extracting/bottling honey is processing or not seems to change depending on the circumstances, and who (in various health departments) you talk to.

At least here in Massachusetts, if you are buying in honey in bulk and bottling it yourself, you are required to be certified....although you can sell (I think) up to $50k bottled in your uncertified/uninspected kitchen.

Of course, it's common practice for beekeepers to buy in honey and pretend to their customers, and to their local health departments, that they produced it themselves (it is certainly often labeled that way).

Ted, beekeepers may be an honest bunch, but I don't know what to call such common (and well established) practices if not dishonest.

deknow


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## RDY-B (May 20, 2007)

Ted Kretschmann said:


> Seems to be a contradiction in the definitions listed above. The keywords are consumed on the farm


 THE key word is *OR*--sometimes its hard to distinguish the letter of the law from the spirit 
http://www.masterbeekeeper.org/pdf/bioterror.pdf -RDY-B


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## Ted Kretschmann (Feb 2, 2011)

Good link but still it is a contradiction....My honey goes to Sioux, which then test it severely in a lab that is regulated by the government. So all possible contaminents are then known. I even get a base line showing what pesticides have ever been used in my operation and at what levels.......Now who checks the local small beek that sells to roadside stands, flea markets and out the door of his house???? Does anybody even know what might be in there??? I am not saying the average beek does not do a very good job-they do. The wholesomeness of honey has been upheld but we have been lucky also..... Historically, when contamination of a food product or a medicinal product has occured. The intentional tapering was done by a disgruntled lone wolf individual with pyscotic tendencies. TED.


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## RDY-B (May 20, 2007)

All good points but lets not forget-the bioterorisum law of 03 is not directed towards the beekeeping industry
it just so happens we are caught up in its backwash -and I think the worry is more of what comes out of the 
packer-not what goes to the packer --thats the bottom line-and yes the industry dose a effort to police its self-
and there has been considerable effort of awareness in recent years--RDY-B


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## NGAnderson (Jun 14, 2011)

"Georgia beekeepers are not required to obtain a Food Sales Establishment License if they process and retail their own honey on their own premises, on a door-to-door retail route, or at an established place of business owned and managed by the producer and the honey is sold directly to a household consumer as the end user (including fairs, festivals, & farmers markets)....Honey Producers must register their facilities with the FDA to carry out provisions of the Bioterrorism Act unless only selling retail to the end user."
Source: http://www.caes.uga.edu/departments/ent/bees/documents/honeyprocessorguidelines.pdf


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## irwin harlton (Jan 7, 2005)

I am registered as a food facility with US FDA, because I ship bulk honey into the US, I am also reguired on the FDA form to have a US contact, a person who lives in the US and can act on my behalf or contact me.I named my US broker as my contact person, last month the same broker phoned me to inform me it would cost me $750 to have him as my US contact, nedless to say he is no longer my contact,....any volunteers


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## Lost Bee (Oct 9, 2011)

If your bees fly over the fence and sting the neighbour's 
dog are you now going to be labelled a terrorist?

:ws:

I shouldn't have said that. Here come's the frog men.


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## suttonbeeman (Aug 22, 2003)

Does anyone know the results of the "!georiga raid"?? What did FDA inspect/gripe about? What really infuratr fiates me is they can fond the time to raid georiga but can't/won't stop all the Chinese honey going g ho major packets contaminated with lead, chloramphenicol and other meds and ultrafiltered honey headed to Sioux city a d many other places in the usa.


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## Ted Kretschmann (Feb 2, 2011)

I dont know what the final results were beside the producers in question were shut down. Might ask Fred Rossman, who, what and where.....But you do have a valid point, Rick. The government with overregulation tendencies towards her own citizens, seems to look the other way when it comes to imports of honey. TED


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## Acebird (Mar 17, 2011)

That sounds like danged if they do or danged if they don't. What do you want the FDA to do? Open up ever shipment coming into the country and take a sample. Sampling makes the product unusable. Who pays? How big do you want the FDA to get to perform that task? Be careful what you wish for.


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## suttonbeeman (Aug 22, 2003)

Ace...I think you are out in left field
First pulling a sample out of a drum does not make it unuseable. All honey I have ever sold had a sample pulled out of a barrellor two. Lid is then put back on and later bottled. Who would buy honey and not check it? Second we all know how much honey is coming from china thru third world countries including India. Every shipment should have a sample pulled...any found ultra filtered should be destroyed. Once a sample/shipper has found with funny or adulterated honey every drum should bechecked at their cost. If they don't like it don't ship it. Honey with lead and antibotics are dangerous to the consu
mer. Why should we let this crap in?


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## Acebird (Mar 17, 2011)

LOL, I think you are out in left field.
You want somebody on the docks to open up barrels, take a sample and then reseal the barrel. I hope you get that one.
If it were ever going to happen, samples would be prepared as part of a shipment that represents the batch being shipped with documentation to prove such. If you are talking about an AQL you have to have a facility to accept the shipment, a labor force to open the packages for sampling and if there is a chance that the product could be used you would need a specific procedure and protocol for repackaging. That ain't ever going to happen at the FDA. You are talking dream land my friend.


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## sqkcrk (Dec 10, 2005)

When and if it becomes a real health problem such practices and procedures will be put into use. It's done w/ other imported items.

Anybody hear about the guitar company raided and fined for having wood that came from endangered trees? If they do that for guitar wood why not for honey?


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## Keth Comollo (Nov 4, 2011)

It isn't a honey house but I did just register my three hives with the State of Vermont. If a bear gets into them the State helps you buy new hives and reimburses you for lost honey. Just free insurance.


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## sqkcrk (Dec 10, 2005)

LSBees said:


> Registration of Food Facilities
> Login / Create Account1
> OMB Approval Number: 0910-0502
> OMB Expiration Date: 08/31/2013
> ...


bump


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## KQ6AR (May 13, 2008)

Hi Mark,
I'm not sure if this is the whole regulation, because someone told me there was an exemption for people selling under a certain dollar amount per year. I don't see that mentioned in LSBees post.


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## sqkcrk (Dec 10, 2005)

It's probably 10,000lbs of honey I imagine.


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## mudlake (Nov 26, 2007)

If you didn't notice nothing is FREE. Free comes along with your change. Come on up to New York and ck it out. Tony


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## wildbranch2007 (Dec 3, 2008)

from post #22

the laws in georgia so my guess if they are interpreting it every other state other than N.Y. would interpret it the same way.

Honey Producers must register their facilities with the FDA to carry out provisions of the Bioterrorism Act unless only selling retail to the end user. Registrants must complete FDA Form 3537 which can be found at: so if you only retail to end user you don't need to register, that means everyone with more than a few hives must register


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## Daniel Y (Sep 12, 2011)

sqkcrk said:


> Anybody hear about the guitar company raided and fined for having wood that came from endangered trees? If they do that for guitar wood why not for honey?


Yes I am, I am involved fairly heavily in the purchasing of exotic woods from around the world. various laws and regulations are fairly complex so one must tred carefully when dealing with wood.

Your statement that the wood came from endangered trees is not at all correct even though the story is usually told as such. The issue was that wood was purchased from Both India and Madagascar in a form that violates the laws of those countries. no no US law was broken and India wrote a letter to the justice department stating Gibson broke no India laws with their purchase of exotic woods. (note this was lie on Indian governments part in order to preserve the business of a huge customer)
Why did the justice department feel it was necessary to conduct not one, but two, hostile raids on Gibson’s manufacturing plants with their officers dressed in full SWAT uniforms and armed with drawn automatic weapons in their hands? When no US law was broken?

Some of the above was copied and pasted from this source on the story.
http://www.davidstuff.com/opinion/gibson.htm

I was aware of this story in similar detail at the time it was happening. I and others I know commonly purchase rosewood and mahogany from various foreign countries and this definitely got our attention.

The story on this page is scewed a bit to put the government alone in a bad light. but the facts presented are sound and correct as to actual events. What the article does not mention is the scope of the department of justices jurisdiction. They enforce both importing and exporting of goods in regard to not only US but some foreign laws. Mainly any country the US is attempting to foster trade or relations with. India in recent years is one of those. I myself have purchase good from India in the recent past. Something that could not have been done easily just a few years ago.

In my opinion Gibson screwed up by not knowing the laws for the country of origin. I also believe that is why they settled. They knew they where in the wrong. Just not for the reasons most people think.


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## sqkcrk (Dec 10, 2005)

Thanks DanielY. I didn't really bump this Thread to discuss wood, but you do bring up somethings we aught to be aware of, so Thanks.

I bumped this Thread because of the recent Honey House Inspections.


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## psfred (Jul 16, 2011)

In the Gibson case I believe a good deal, if not all, of the wood in question was purchased long before the law was in effect and had been stored at the factory for quite some time. Someone got a wild hair because "if they had that much they must have violated the law" -- i. e. a competitor could not obtain as much as they wanted and stirred up trouble. 

If I remember correctly the fuss died down and Gibson didn't pay a fine since they actually had proper records of aquisition, price, and condition. 

So far as I know, Indiana does not require registration of hives or honey houses so long as you label your product and sell only to the general public. I'll have to check on that as I was thinking of selling some when I have a large surplus to my buddy who runs a local brewery to use in his Honey Ale. Might not, though, if it requires a ton of work and FDA inspections since we would have to buy a new extractor, I think. At least expoy paint the old one anyway, it's galvanized.

If that's not an option, I'm sure I can sell to the local apiary if I can't sell all I want to. Probably not a problem once I have enough to sell, as all the guys in the homebrew club keep asking for it!

Peter


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## Acebird (Mar 17, 2011)

If you sell to a local apiary then you are not selling to the end user so what is the difference?


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