Contains Nonbinding Recommendations 
 
 
 
Proper Labeling of Honey and Honey 
Products: Guidance for Industry  
 
Additional copies are available from: 
Office of Nutrition and Food Labeling 
Food Labeling and Standards Staff HFS-820 
Center for Food Safety and Applied Nutrition 
Food and Drug Administration 
5001 Campus Drive 
College Park, MD  20740 
(Tel) 240-402-2371  
http://www.fda.gov/FoodGuidances 
 
You may submit electronic or written comments regarding this guidance at any time.  Submit 
electronic comments to https://www.regulations.gov/.  Submit written comments on the 
guidance to the Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 
Fishers Lane, rm. 1061, Rockville, MD 20852.  All comments should be identified with the 
docket number FDA-2006-P-0207 listed in the notice of availability that publishes in the 
Federal Register. 
 
 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Food Safety and Applied Nutrition 
 
February 2018 
 
 
  Contains Nonbinding Recommendations 
Table of Contents 
 
 
 
I. Introduction
   
II. Background
   
III. Questions and Answers (Q & A)
   
 
 
 
2 
  Contains Nonbinding Recommendations 
Proper Labeling of Honey and Honey 
1
Products: Guidance for Industry  
 
 
 
This guidance represents the current thinking of the Food and Drug Administration (FDA or we) 
on this topic.  It does not establish any rights for any person and is not binding on FDA or the 
public.  You can use an alternative approach if it satisfies the requirements of the applicable 
statutes and regulations.  To discuss an alternative approach, contact the FDA staff responsible 
for this guidance as listed on the title page.  
 
 
 
I.  Introduction  
This guidance is intended to advise the regulated industry on the proper labeling of honey and 
honey products in accordance with sections 402 and 403 of the Federal Food, Drug, and 
Cosmetic Act (the FD&C Act) (21 U.S.C. 342 and 343) and its implementing regulations.  
Accurate and consistent labeling of honey and honey products helps to ensure that honey and 
honey products are not adulterated or misbranded and enhances consumers ability to make 
informed choices among products.  
FDA's guidance documents, including this guidance, do not establish legally enforceable 
responsibilities.  Instead, guidances describe our current thinking on a topic and should be 
viewed only as recommendations, unless specific regulatory or statutory requirements are cited.  
The use of the word should in FDA guidances means that something is suggested or 
recommended, but not required.  Throughout this guidance, you refers to firms that 
manufacture, process, pack, label, or distribute honey and honey products and to persons who are 
authorized to act on behalf of such firms.   
II.  Background  
We are issuing this guidance document, which includes a summary of the current legal 
authorities that are most relevant to the labeling of honey, to address key questions and answers 
on the labeling of honey.   
   
                                                 
1 This guidance has been prepared by the Office of Nutrition and Food Labeling, Food Labeling and Standards Staff, 
in the Center for Food Safety and Applied Nutrition at the U.S. Food and Drug Administration.   
3 
  Contains Nonbinding Recommendations 
Misbranding 
Under section 403(i) of the FD&C Act, a food is misbranded unless its label bears: (1) the 
common or usual name of the food, if there be any; and (2) the common or usual name of each 
ingredient, if the food is fabricated from two or more ingredients.  The common or usual name 
for a food may be established by common usage or by regulation (21 CFR 102.5(d)).  The 
common or usual name must accurately identify or describe, in as simple and direct terms as 
possible, the basic nature of the food or its characterizing properties or ingredients, and may not 
be confusingly similar to the name of any other food that is not reasonably encompassed within 
the same name (21 CFR 102.5(a)).  Moreover, under 21 CFR 101.4(a)(1), ingredients required 
to be declared on the label or labeling of a food must be listed on its label by common or usual 
name in descending order of predominance by weight.  Furthermore, under section 403(a)(1) of 
the FD&C Act, a food is misbranded if its labeling is false or misleading in any particular.   
Adulteration 
Under section 402(b) of the FD&C Act, a food is adulterated if: (1) a valuable constituent has 
been omitted in whole or in part from a food; (2) if any substance has been substituted wholly or 
in part; (3) if damage or inferiority has been concealed in any manner; or (4) if a substance has 
been added to a food so as to increase its bulk or weight, reduce its quality or strength, or make it 
appear to be better or of greater value than it is.     
 
III.  Questions and Answers (Q & A)  
To further provide guidance to industry on the proper labeling of honey and honey products in 
accordance with our laws and regulations, we have developed the following questions and 
answers.   
1.  What is honey?  
Reference materials in the public domain define honey as a thick, sweet, syrupy 
substance that bees make as food from the nectar of plants or secretions of living parts of 
plants and store in honeycombs.2  FDA has concluded that this definition accurately 
reflects the common usage of the term honey.   
                                                 
2 Webster's New World College Dictionary (Wiley Publishing, Inc., Cleveland, Ohio 2010).  See also: Honey is a 
thick, sweet liquid made by bees from flower nectar,  Sharon Tyler Herbst and Ron Herbst, The Deluxe Food 
Lovers Companion (Hauppauge: New York, 2009); Honey [is a] sweet, viscous liquid food, dark golden in color, 
produced in the honey sacs of various bees from the nectar of flowers,  Encyclopedia Britannica Online, 2017, 
available at http://www.britannica.com/EBchecked/topic/270849/honey; and Honey is the natural sweet substance 
produced by honey bees from the nectar of plants or from secretions of living parts of plants . . . ,  CODEX 
Standard for Honey CODEX STAN 12-1981, available at: 
www.fao.org/input/download/standards/310/cxs_012e.pdf. 
4 
  Contains Nonbinding Recommendations 
2.  How shall I name my honey?  
If a food contains only honey, the food must be named honey, which is its common or 
usual name (see section 403(i) of the FD&C Act and 21 CFR 101.3(b)).  The common or 
usual name may also include the source of the honey, such as Clover Honey, on the 
label.  (See Q&A 3, below).  Because honey is a single-ingredient food, you do not need 
to include an ingredient statement on the label.    
 
(Please note that this answer pertains solely to how you name your product; other 
labeling requirements (e.g., net weight, nutrition facts) apply to the product.  For more 
information, see FDAs Food Labeling Guide at 
https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformati
on/LabelingNutrition/ucm2006828.htm.)  
3.  Do I have to declare the floral source of honey?  
No.  You do not have to declare the floral source of honey on the label.  However, you 
may label the honey with the name of the plant or blossom if you or the honey producer 
has information to support the conclusion that the plant or blossom designated on the 
label is the chief floral source of the honey.  Names such as Orange Blossom Honey, 
Clover Honey, or Wild Flower Honey are acceptable.  (See FDA Compliance Policy 
Guide, section 515.300.)  Any claims about the floral source of the honey must be 
truthful and not misleading (see section 403(a)(1) of the FD&C Act).   
4.  If a food consists of honey and a sweetener, such as sugar or corn syrup, can I label 
the food as only honey?  
No.  A product consisting of honey and a sweetener cannot be labeled with the common 
or usual name honey because [t]he common or usual name of a food . . . shall 
accurately identify or describe . . . the basic nature of the food or its characterizing 
properties or ingredients (21 CFR 102.5(a)).  Identifying a blend or a mixture of honey 
and another sweetener only as honey does not properly identify the basic nature of the 
food.  You must sufficiently describe the name of the food on the label to distinguish it 
from simply honey (21 CFR 102.5(a)).   
5.  If a food consists of honey and a sweetener, such as sugar or corn syrup, how shall I 
label the food?  
For a food consisting of honey and a sweetener, the label must, among other information, 
include both of the following: 
a.  A statement of identity, which must accurately identify or describe the basic 
nature of the food or its characterizing properties or ingredients (see section 403(i) 
of the FD&C Act, 21 CFR 101.3(b), and 21 CFR 102.5(a)):  for example, Blend 
of honey and corn syrup, if the food has more honey than corn syrup 
(conversely, Blend of corn syrup and honey, if the food has more corn syrup 
than honey).  
5 
  Contains Nonbinding Recommendations 
b.  The common or usual name of each ingredient in the ingredient statement.  In this 
case, the ingredient statement would show honey and the common or usual 
name of the sweetener (e.g., sugar, corn syrup), in descending order of 
predominance by weight (see section 403(i) of the FD&C Act and 21 CFR 
101.4(a)(1)). 
You should also refer to section 403 of the FD&C Act and 21 CFR part 101, as other 
labeling requirements (e.g., net weight, nutrition facts) apply to your product.  For more 
information, see FDAs Food Labeling Guide at 
https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformati
on/LabelingNutrition/ucm2006828.htm.   
6.  If a food consists of honey and a flavor ingredient, such as natural raspberry flavor, 
what are the labeling requirements?   
a.  If your labeling makes any direct or indirect representations with respect to the 
primary recognizable flavor (e.g., by word or vignette), other than through the 
statement of ingredients, the product is considered to have a characterizing flavor 
and must be labeled in accordance with 21 CFR 101.22(i).  In such a case, you 
should choose a name that accurately describes the food with its characterizing 
flavor, such as raspberry-flavored honey (see section 403(i) of the FD&C Act, 
21 CFR 101.3(b), and 21 CFR 102.5(a)).   
b.  In the statement of ingredients, the label must follow the requirements set forth in 
21 CFR 101.4.  The labeling must include the common or usual name of each 
ingredient in the ingredient statement.  For a food consisting of honey and natural 
raspberry flavor, the ingredient statement would show honey and natural 
flavor, in descending order of predominance by weight (see section 403(i) of the 
FD&C Act, 21 CFR 101.4(a)(1), and 21 CFR 101.22(h)(1)). 
You should refer to section 403 of the FD&C Act and 21 CFR part 101, as other labeling 
requirements (e.g., net weight, nutrition facts) apply to your product.  For more 
information, see FDAs Food Labeling Guide at 
https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformati
on/LabelingNutrition/ucm2006828.htm.  
7.  How would consumers know whether the food is honey, a blend of honey and 
another sweetener (e.g., sugar or corn syrup), or a honey product that contains 
other ingredients?  
Consumers would know what the food is and what the food contains by reading the label.  
A properly labeled package of only honey would show the name of the food as honey, 
and it would not need an ingredient statement because it would only contain one 
ingredient.  By comparison, a properly labeled package of a blend of honey and a 
sweetener or other ingredients would have a statement of identity that accurately 
describes the food, such as blend of honey and sugar, blend of honey and corn syrup, 
or another appropriately descriptive term, and an ingredient statement that lists each 
ingredient, such as honey and sugar, or honey and corn syrup.   
6 
  Contains Nonbinding Recommendations 
8.  How would consumers know if a food product that contains two or more ingredients 
contains honey?  
Consumers would know that a food product contains honey as one of the ingredients by 
reading the ingredient statement.  A properly labeled food product would list the 
ingredient by its common or usual name, honey, in the ingredient statement.   
9.  What enforcement authorities does FDA have for food products that are 
represented solely as honey, but contain other ingredients?  
FDAs enforcement authorities for food products that are represented as honey, but 
contain other ingredients, are described below.   
Case A:  A product is labeled as honey, but it contains natural raspberry flavoring.  The 
ingredient statement lists only honey.   
According to section 403(i) of the FD&C Act, a food is misbranded unless the label 
bears: (1) the common or usual name of the food, if there be any; and (2) the common or 
usual name of each ingredient, if the food is made from two or more ingredients.  In this 
case, the name of the food, honey, does not accurately describe that the food is a 
raspberry-flavored honey, so honey is not an appropriate common or usual name under 
21 CFR 102.5(a).  Moreover, the ingredient statement lists only one ingredient, honey, 
while the food contains honey and natural flavoring.  Therefore, the product fails to 
satisfy the requirements under 21 CFR 101.4(a)(1) and section 403(i)(2) of the FD&C 
Act, and FDA would consider such product to be misbranded.  
Case B:  A product is labeled as honey, but it contains honey and another sweetener, 
such as sugar or corn syrup.  The ingredient statement lists only honey.   
Under section 402(b) of the FD&C Act, a food is adulterated if any valuable constituent 
has been omitted in whole or in part, if any substance has been substituted wholly or in 
part, or if any substance has been added so as to reduce the quality of the food or make it 
appear to be better or of greater value than it is.  In this case, the food is represented as 
honey when another sweetener (e.g., sugar or corn syrup) has been substituted in part for 
honey.  Products that contain only honey and no other ingredients are considered more 
valuable than a food that contains both honey and sugar or both honey and corn syrup.3   
Therefore, we would consider such product adulterated under section 402(b)(1) of the 
FD&C Act because a valuable constituent (honey) has been omitted in part; under section 
402(b)(2) of the FD&C Act, because a substance (sugar or corn syrup) has been 
substituted in part; and/or under section 402(b)(4) of the FD&C Act, because a substance 
(sugar or corn syrup) has been added to the honey so as to increase its bulk or weight or 
make it appear better or of greater value than it is.   
                                                 
3 Honey is more valuable than other sweeteners.  See Sugar and Sweeteners Yearbook Tables, United States 
Department of Agriculture Economic Research Service. 2017.  Available at: https://www.ers.usda.gov/data-
products/sugar-and-sweeteners-yearbook-tables.aspx. 
 
7 
  Contains Nonbinding Recommendations 
Further, we would consider such food misbranded under section 403 of the FD&C Act 
due to improper labeling of the food:  i.e., the name of the food and the ingredient 
statement (see Case A and Q&A 5).  
10. How does FDA monitor imported products labeled as honey to ensure that they 
contain only honey as the sole ingredient?  
We have a long-standing import alert for surveillance of honey for adulteration with cane 
or corn sugars (see Import Alert 36-01 at 
https://www.accessdata.fda.gov/cms_ia/importalert_108.html).  Such a product would be 
detained until we determined that the product was not adulterated or misbranded.   
8