## American Beekeeping Federation

3525 Piedmont Road

Building Five, Suite 300

Atlanta, GA 30305

- 1509

404.760.2875

abfnet.org

April 8, 2014

Mr. Brian E. Griffin

Standardization Branch, Specialty Crops Inspection Division, Fruit and Vegetable Program, Agricultural

Marketing Service, U.S. Department of Agriculture

1400 Independence Avenue SW., Room 0709, South Building; STOP 0247

Washington, DC 20250

Re: U.S. Standard of Identity for Honey

Dear Mr. Griffin :

Since the FDA rejected the industry proposal for a U.S. standard of identity for honey, the f ive national honey

bee and honey industry trade groups have met several times to revise the original proposal, and to decide on

next steps. The number of products on the shelves using honey on the label, but containing little or no honey is

increasing, and adulterated products continue to be a problem in the U nited S tates

. In the interim, a number of

states have enacted laws, administrative rules, or definitions that govern honey in those states. There are

significant differences

, between the adopted laws a nd rules, creating difficulties for the honey packing entities

doing business in the U nited S tates

.

Additionally, portions of several of the state statutes have been cited in class action law suits concerning

honey, claiming that filtering removes essential ingredients, thereby rendering the product no longer honey

and defrauding the consumer. These cases have worked their way through the court system at great cost to the

industry.

Thirdly, the USDA grade standards, which are largely voluntary, ar e at odds with several of the tenets of some

of the state laws, enacted and proposed. It seems clear that a federal standard would be useful in harmonizing

honey commerce in the U nited S tates

, and protecting the consumer from fraud.

As attachments, you will find a chart of states (as best we can find) that have honey standards. Also attached

, is the revised document the five industry trade groups have created as a draft proposal for a federal Standard of

Identity.

If there is any add itional information that we can assist you with, please do not hesitate to contact us.

Tim Tucker Gene Brandi George Hansen

ABF President AB F Vice

- President ABF Past President

# DRAFT

Standard for Honey

1. Scope

This standard applies to all honey produced by honey bees and covers all styles of honey

presentations which are processed and ultimately intended for direct consumption and to all honeys

packed, processed or intended for s ale in bulk containers as honey, which may be repacked for retail

sale, or for sale or use as an ingredient in other foods.

2. Description

2.1. Definition: Honey is the natural sweet substance produced by honey bees from the nectar of

plants or from secretions of living parts of plants or excretions of plant sucking insects on the

living parts of plants, which the bees collect, transform by combining with specific substances

of their own, deposit, dehydrate, store and leave in the honey comb to ripen and mature.

2.1.1. B lossom Honey or Nectar Honey is the honey which comes from the nectars of plants.

2.1.2. Honeydew honey is the honey which comes mainly from excretions of plant sucking

insects (Hemiptera) on the living parts of plants or secretions of living parts of plants.

2.2. Des cription: Honey c onsists essentially of different sugars, predominantly fructose and glucose

as well as other substances naturally derived from the collection of nectar by honey bees for

conversion into honey. The color of honey varies from nearly colorl ess to dark brown: the

consistency can be fluid, viscous or partly to entirely crystallized. The flavor and aroma vary,

but are derived from the plant origin.

3. Essential Composition and Q uality Factors

3.1. Honey sold as such shall not have added to it any foo d ingredient, including food additives.

3.1.1. Styles of Honey:

3.1.1.1. Filtered

– Filtered honey is honey of any type defined in the United States

Standards for Grades of Extracted Honey that has been filtered to the extent

that all or most of the fine particles, polle n grains, air bubbles, or other defects

normally found in suspension have been removed.

3.1.1.2. Strained

– Strained honey is honey of any type defined in the United States

Standards for Grades of extracted Honey that has been strained to the extent

that most of the particles, including comb, propolis, or other defects normally

found in honey have been removed. Grains of pollen, small air bubbles, and

very fine particles would not normally be removed.

3.1.1.3. Unfiltered/Unstrained

– Unfiltered/Unstrained honey is honey that has not

been filtered or strained as described by United States Standards for Grades of

Extracted Honey and may include extracted or non

- extracted honey andwhereas most of the fine particles, pollen grains, air bubbles, comb, propolis

and other defects n ormally found in suspension may be present

.

3.2. Honey shall not be filtered to less than 1.0 microns.

3.3. Chemical or biochemical treatments shall not be used in the packaging or processing of honey.

3.4. Moisture content: Honey Shall not have a moisture content excee ding 23%

3.5. Sugars Content

3.5.1. Fructose and Glucose Content (Sum of Both)

3.5.1.1. Honey not listed below

– not less than 60g/100g

3.5.1.2. Honeydew honey, blends of honeydew honey with blossom honey

– not less

than 45g/100g

3.5.2. Sucrose Content

3.5.2.1. Honey not listed below

– not more than 1 0g/100g

3.5.2.2. Lavendar ( Lavandula spp ), Borage ( Borago officinalis )

– not more than 15g/100g

3.6. Water Insoluble Solids Content

3.6.1. Honeys

– not more than 0. 5/ 100g



# DRAFTList of states. I think it’s important that we acknowledge that several states have Definitions for

honey.

official official Proposed Rely on

Standard Definition Standard FDA

Stand

Alabama AL X X

Alaska AK X

Arizona AZ

Arkansas AR

California CA X

Colorado CO X

Connecticut CT

Delaware DE

Florida FL X

Georgia GA X

Hawaii HI X

Idaho ID X

Illinois IL

Indiana IN X

Iowa IA

Kansas KS

Kentucky KY

Louisiana LA

Ma ine ME

Maryland MD X

Massachusetts MA X

Michigan MI

Minnesota MN X

Mississippi MS

Missouri MO

Montana MT

Nebraska NE X

Nevada NV X

New

Hampshire NH X

New Jersey NJ

New Mexico NM X

New York NY X X

North Carolina NC X

North Dakota ND

Ohio OH X X

Oklahoma OK X

Oregon OR X

Pennsylvania PA X X

Rhode Island RI XSouth Carolina SC X

South Dakota SD

Tennessee TN X

Texas TX

Utah UT X

Vermont VT

Virginia VA

Washington WA X

West Virginia WV X

Wisconsin WI X

Wyoming WY

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