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 five 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 United States. 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 and rules, creating difficulties for the honey packing entities

doing business in the United States.

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, are 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 United States, 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 additional information that we can assist you with, please do not hesitate to contact us.

 Tim Tucker Gene Brandi George Hansen

 ABF President ABF 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 sale 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. Blossom 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.Description: Honey consists 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 colorless 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 Quality Factors

3.1.Honey sold as such shall not have added to it any food 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, pollen 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 and 
whereas most of the fine particles, pollen grains, air bubbles, comb, propolis 

and other defects normally 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 exceeding 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 10g/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 

DRAFT
List 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

Maine 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 X
South Carolina SC

X

South Dakota SD

Tennessee TNX

Texas TX

Utah UTX

Vermont VT

Virginia VA

Washington WAX

West Virginia WVX

Wisconsin WIX

Wyoming WY

9 17