# Federal Requirements for Honey Labels



## psm1212 (Feb 9, 2016)

Many members of our state beekeeper association maintain, and in fact teach at association meetings, that the the FDA mandates numerous pieces of information on your honey labels: name, address, phone number, weight, etc. I have spent the past year searching for the source of these requirements. I have come to believe that they are mere myths.

I recognize that the different states have their regulations. I am not interested in any of those. I am most often pointed to the National Honey Board website, which declares that various things "shall" appear on a honey label. But this is not a federal entity with actual jurisdiction of anything. They appear to be nothing more than a trade association.

Can anyone cite me to any FDA or other FEDERAL regulation regarding requirements on honey labels? Thank you.


----------



## BadBeeKeeper (Jan 24, 2015)

FDA draft guidance:
http://www.fda.gov/food/guidancereg...ryinformation/labelingnutrition/ucm389501.htm

National Honey Board:
https://www.honey.com/honey-industry/honey-testing-and-regulations/honey-labeling/



> The label must let consumers know who put the product on the market and how to contact that person. The name and the address of the manufacturer, packer or distributor of a packaged food product are required to appear on the label of the packaged food. This information, sometimes referred to as the “signature line,” must appear on the front label panel or the information panel. *If space permits, include full address and telephone number.* The information must be in a type size that is at least 1/16th inch tall.


Note: The NHB guideline re: contact info, says "if space permits".

The NHB guide is pretty close to the FDA draft, though the FDA draft says it has not been enacted as a law/regulation (yet). However, pay attention to the requirements regarding ingredient labeling and 'misbranding', as this requirement is applicable in general for ALL food products.

So, there -are- Federal regulations to follow, as they pertain to ingredients and weight, though not codified specifically for honey labels.

Now you know the real story.


----------



## dr4ngas (Mar 19, 2014)

Rember you start with federal than the state which must have federal requirement meet first then their requirements. Then local requirements that meets the other two.


----------



## psm1212 (Feb 9, 2016)

BadBeeKeeper said:


> FDA draft guidance:
> http://www.fda.gov/food/guidancereg...ryinformation/labelingnutrition/ucm389501.htm
> 
> National Honey Board:
> ...


Not quite. The NHB is not a regulatory agency. Your quote is from the NHB. It is not law and I am not required to follow it.


----------



## psm1212 (Feb 9, 2016)

dr4ngas said:


> Rember you start with federal than the state which must have federal requirement meet first then their requirements. Then local requirements that meets the other two.


Yes I know. And I am attempting to determine exactly what the Federal law says.


----------



## Rader Sidetrack (Nov 30, 2011)

And the FDA document linked above is a _DRAFT_. It has never been implemented.

The USDA does have regulations for grading honey, and some states _might_ require grading honey by USDA grades. AFAIK, there is no Federal rule _requiring_ honey to be graded by USDA grades.

USDA Grading document: https://www.ams.usda.gov/sites/default/files/media/Extracted_Honey_Standard[1].pdf


----------



## BeeRoger (Sep 26, 2012)

Call your local health department. They are the ones that do inspections and enforcement in Ohio.


----------



## Hops Brewster (Jun 17, 2014)

psm1212 said:


> Many members of our state beekeeper association maintain, and in fact teach at association meetings, that the the FDA mandates numerous pieces of information on your honey labels: name, address, phone number, weight, etc. I have spent the past year searching for the source of these requirements. I have come to believe that they are mere myths.
> 
> I recognize that the different states have their regulations. I am not interested in any of those. QUOTE]
> This is what you do need to be interested in, for it (along with local regs) is what determines what is required on your labels. Not federal.


----------



## msl (Sep 6, 2016)

honey is food
https://www.gpo.gov/fdsys/pkg/CFR-2008-title21-vol2/xml/CFR-2008-title21-vol2-part101.xml


> 101.5Food; name and place of business of manufacturer, packer, or distributor.
> (a) The label of a food in packaged form shall specify conspicuously the name and place of business of the manufacturer, packer, or distributor.
> (b) The requirement for declaration of the name of the manufacturer, packer, or distributor shall be deemed to be satisfied, in the case of a corporation, only by the actual corporate name, which may be preceded or followed by the name of the particular division of the corporation. In the case of an individual, partnership, or association, the name under which the business is conducted shall be used.
> (c) Where the food is not manufactured by the person whose name appears on the label, the name shall be qualified by a phrase that reveals the connection such person has with such food; such as “Manufactured for ___”, “Distributed by ___”, or any other wording that expresses the facts.
> ...


----------



## psm1212 (Feb 9, 2016)

msl said:


> honey is food
> https://www.gpo.gov/fdsys/pkg/CFR-2008-title21-vol2/xml/CFR-2008-title21-vol2-part101.xml


Thank you for the citation msl.


----------



## psm1212 (Feb 9, 2016)

Hops Brewster said:


> psm1212 said:
> 
> 
> > Many members of our state beekeeper association maintain, and in fact teach at association meetings, that the the FDA mandates numerous pieces of information on your honey labels: name, address, phone number, weight, etc. I have spent the past year searching for the source of these requirements. I have come to believe that they are mere myths.
> ...


----------



## BadBeeKeeper (Jan 24, 2015)

psm1212 said:


> Not quite. The NHB is not a regulatory agency. Your quote is from the NHB. It is not law and I am not required to follow it.


No kidding. I included the quote from the NHB to show how it was similar to the Fed _draft_, and I *bolded* and noted the line in the quote from the NHB with the statement _If space permits...'_ to show that it is *NOT* a "requirement". How did you not get that? Are you just wanting to be stubborn, and or to argue?

I also noted that there were other rules, applicable to food in general (which includes honey) that -DO- need to be followed.



Rader said:


> And the FDA document linked above is a DRAFT. It has never been implemented.


Yes. I noted that.

Maybe I need to take a break from here...before my frustration starts showing through in ways that will get me psanked...


----------



## Rader Sidetrack (Nov 30, 2011)

Here is what the OP asked ...


psm1212 said:


> Can anyone cite me to any FDA or other FEDERAL regulation regarding requirements on honey labels? Thank you.


So far, the only _mandatory_ federal regulations that anyone cited that _may_ apply to honey, are the FDA packaging rules cited in post #9. And those contain _some_ exceptions for sales of less than $500,000 per year. And that is 'packaged' honey (in final consumer size packages).

.


----------



## psm1212 (Feb 9, 2016)

BadBeeKeeper: 

From my OP: 
_ *"I am most often pointed to the National Honey Board website, which declares that various things "shall" appear on a honey label. But this is not a federal entity with actual jurisdiction of anything. They appear to be nothing more than a trade association"*_

You responded to my OP with a quote from the NHB and a statement that they were similar requirements. The fact of the matter is that what the NHB states as "mandatory" and what the CFR (the actual governing body) states are NOT the same and have differences. This was the entire point of my original post: That I was trying to determine the actual federal regulation and NOT the NHB interpretation of the Federal regulation. 

MSL understood what I was asking for and cited it for me.


----------



## psm1212 (Feb 9, 2016)

Rader Sidetrack said:


> Here is what the OP asked ...
> 
> 
> So far, the only _mandatory_ federal regulations that anyone cited that _may_ apply to honey, are the FDA packaging rules cited in post #9. And those contain _some_ exceptions for sales of less than $500,000 per year. And that is 'packaged' honey (in final consumer size packages).
> ...


The only thing I can add to that is there appears to be a requirement to state a Net Weight in pounds and/or ounces.


----------



## BadBeeKeeper (Jan 24, 2015)

psm1212 said:


> BadBeeKeeper:
> 
> *You responded to my OP with a quote from the NHB and a statement that they were similar requirements.* The fact of the matter is that what the NHB states as "mandatory" and what the CFR (the actual governing body) states are NOT the same and have differences.


No. I called the NHB material a 'guide' and 'guidelines', I absolutely did not say they were 'requirements', I merely noted the similarity to the FDA draft; further, I went so far as to note that the FDA draft had NOT been enacted and was NOT a 'law' or 'regulation'.

Your misinterpretation of that is -your- error. You are 'putting words in my mouth', and arguing against something that I did not say.

I was actually making a statement in -your favor-, _confirming_ the fact that the NHB 'guide' was not a regulation regarding honey, *and showing that the FDA had not enacted such a regulation either* (despite prodding from the NHB). You have created, and compounded, an argument that did not exist, just as a Fed regulation for honey does not exist.

Now, if you will please excuse me, I am going to go and bang my head against a brick wall.

Do you know what the best part of banging your head against a brick wall is? It feels so much better when you stop.


----------



## psm1212 (Feb 9, 2016)

I agree with you. You should take a break from this site.


----------



## DerTiefster (Oct 27, 2016)

BBK, I sympathize with you. It hurts when you try to speak/write precisely and provide the best information you can, offering as much as you can to others, and then have them persistently misread you in the face of guidance and correction. I've experienced it (and probably also committed the error myself). 

You offered information showing how the "requirements" are not actually required. For some people, this is Too Much Information. It won't be for all readers of this thread.

The existence of the draft shows that at some time and with little warning the recommendations might become regulation, and a wise person might try to keep an eye on the situation. Not everyone wants to be aware. Some readers will.

You attempted to provide guidance with the observation that general food labeling regulations may exist


> this requirement is applicable in general for ALL food products


I noted the "in general" and realized it was a pointer to consider the content of general food regs myself and not specialize to honey. Not everyone will appreciate the loan of a shovel when they clearly asked for someone to dig their ditch. I thought it was a good suggestion.

Sometimes it's just not worth replying. But someone might benefit, anyway.


----------



## psm1212 (Feb 9, 2016)

DerTiefster:
All I wanted was a cite to the Federal regs. I made that all clear in the OP. I did not want someone's version of the Fed requirements. I did not ask for the NHB's take on the Fed requirements. While I appreciate BBK's response, it was not "the real story." It was not even responsive to the question. I made that clear in my response and then he lost his **** in a tirade that stretched out a couple of posts. I didn't mean anything in my first response other than it did not answer my question and I was still seeking the answer. Go back and read it. It is you that has misread the post.

I also did not personally attack him. It was me who was called "stubborn" and was accused of just wanting to argue. I don't get where the angst came from. I was simple looking for a **** statute.


----------



## Rader Sidetrack (Nov 30, 2011)

I found an FDA page that should be of interest for most _part-time_ honey producers:


> *Small Business Nutrition Labeling Exemption
> *
> The Federal Food, Drug, and Cosmetic Act requires packaged foods and dietary supplements to bear nutrition labeling unless they qualify for an exemption (A complete description of the requirements). One exemption, for low-volume products, applies if the person claiming the exemption employs fewer than an average of 100 full-time equivalent employees and fewer than 100,000 units of that product are sold in the United States in a 12-month period. To qualify for this exemption the person must file a notice annually with FDA. Note that low volume products that bear nutrition claims do not qualify for an exemption of this type.
> 
> ...


So, if you gross less than $50,000 annually in 'food' sales, it appears that FDA nutrition labeling requirements do not apply to you. 


FYI, there is now a newer related thread, here:
http://www.beesource.com/forums/sho...abels-including-Honey-in-2018-out-for-comment


----------



## BadBeeKeeper (Jan 24, 2015)

psm1212 said:


> All I wanted was a cite to the Federal regs...While I appreciate BBK's response, it was not "the real story." It was not even responsive to the question...I was simple looking for a **** statute.


It *was* responsive to the question. You wanted a cite to the Fed regs, I was showing you that the Fed Reg _did not exist_. You were looking for a statute that you weren't going to find, because there was no statute. I pointed you to the Fed horse's mouth that *said* there was no statute.

I gave you a link to the FDA page that says:



> Contains Nonbinding Recommendations
> Draft–*Not for Implementation*...
> Guidance for Industry
> Proper Labeling of Honey and Honey Products
> This draft guidance, when finalized, will represent the Food and Drug Administration’s (FDA’s) current thinking on this topic. It does not create or confer any rights for or on any person and *does not operate to bind FDA or the public*.


Did you follow the link and read the page? That page is the "real story" and tells you everything you need to know, including 



> On March 8, 2006, the American Beekeeping Federation and *several other honey-related associations submitted a citizen petition requesting that FDA adopt a U.S. standard of identity for honey* based on the 2001 Revised Codex Alimentarius Commission’s Standard for Honey (reference 1). The petitioners asserted that a U.S. standard of identity for honey would achieve the following goals: (1) clarify what the term “honey” means with respect to the food’s composition and therefore promote honesty and fair dealing in the interest of consumers; (2) combat economic adulteration of honey by aiding enforcement and industry compliance; and (3) promote honesty and fair dealing within the food trade in general, where pure honey is used as an ingredient in other foods.
> 
> *In a letter of October 5, 2011, we denied the petition* because the petition did not provide reasonable grounds for FDA to adopt the Codex standard for honey.


Perhaps I could have just said "There is no Federal regulation" and left it at that. But, there are plenty of people who just say stuff and expect other people to believe it, without providing any source or foundation for their statements, and I happen to think that that is lazy, irresponsible, and can oftentimes be misleading. So, I went to the trouble of hunting down an official source document and providing you with a link to it so that you would be able to confirm the facts and the truth.

I gave you *exactly* what you needed to know...and yet, you claimed that I didn't. *That* is what was/is so frustrating. I fail to see how you could not get that unless you just read the post and didn't bother to follow the link to the FDA that I provided, which gave the "real story" and tells you that the NHB's 'guidance' is not legally binding. How much more could you have possibly asked for? Should I have pasted the whole FDA page into a quote?


----------



## psm1212 (Feb 9, 2016)

BadBeeKeeper said:


> It *was* responsive to the question. You wanted a cite to the Fed regs, I was showing you that the Fed Reg _did not exist_. You were looking for a statute that you weren't going to find, because there was no statute. I pointed you to the Fed horse's mouth that *said* there was no statute.


BBK: Where we are not connecting on this is that you maintain that there is no statute that governs honey labeling. I believe you are incorrect. The statute that msl cited applies to honey labeling. It does not apply EXCLUSIVELY to honey labeling, but it definitely applies to honey labeling. 

You were citing to the FDA's 2011 denial of a petition to *"adopt a U.S. standard of identity for honey."* You have repeatedly pointed to this 2011 denial and told me that it means *"There is no Federal regulation."* That statement is not accurate. There is a federal statute (at least one), cited above, that applies to honey labeling. The fact that the FDA denied the honey industry's petition to adopt a "standard of identity for honey" does not change this fact.


----------

