05/29/2014
URGENT~!!!~
Please pay attention to this serious issue that can have a direct impact on the honey industry.
It is extremely important that your organization submit comments and distribute this communication to your membership so they can also submit comments and ensure the honey industry maintains an active role in rule-making events.
Please feel free to contact me with questions regarding the submission of comments: [email protected]
The FDA has issued a draft Guidance for Industry: Proper Labeling of Honey and Honey Products
The full text can be found here: http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/labelingnutrition/ucm389501.htm
To ensure your comments are considered by the FDA before the final draft is published, submit either electronic or written comments on the draft guidance by June 9, 2014.
Submit electronic comments on the draft guidance to: http://www.regulations.gov
Submit written comments to:
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane
Rm. 1061
Rockville, MD 20852
Key Bullet Point items to include with comment submissions to FDA regarding the Draft Guidance for Industry: Proper Labeling of Honey and Honey Products
Agency/Docket Number: Docket No. FDA-2006-P-0207
Document Number: 2014-07925
Reference materials in the public domain do NOT accurately define the common usage of the term “honey.”§ 9 states have adopted Standards of Identity for Honey.
20 states have adopted Definitions of Honey.
No 2 state Standards or Definitions are identical, indicating there is no “common usage” of the term Honey.
A Federal Standard of Identity for Honey is required for any Guidance for Industry on the Proper Labeling of Honey to be effective.
Question regarding labeling of floral source: What percent or measure is used to declare a “floral source” as the “chief floral source” on the label?
Inconsistent labeling of honey blends: It is inconsistent to label an item containing “honey” and “sugar” as “blend of honey and sugar” while labeling “honey” and “raspberry flavor” as “raspberry flavored honey”. Is it acceptable to label “honey” and “sugar” as “honey flavored sugar” as well as labeling “honey” and “raspberry flavor” as “blend of honey and raspberry flavor”?
Identifying misbranding: The definition the FDA notes as adequate does not contain the composition of honey. How can the FDA test for misbranding or honey containing other ingredients if the basic composition of honey is not solidly identified?
Identifying adulteration: The definition of “a thick, sweet, syrupy substance that bees make as food from the nectar of flowers and store in honeycombs” contains no valuable constituent information regarding honey. Only a standard of identity would have the level of comprehensive information needed for the FDA to find the food item adulterated under section 402(b) of the FD&C Act.
Honey imports: There is concern that the FDA monitoring for adulterated honey products may be inadequate if the monitoring is based on the diluted definition of “a thick, sweet, syrupy substance that bees make as food from the nectar of flowers and store in honeycombs”. The definition lacks the specificity required to identify adulteration of honey with cane or corn sugars.
The honey industry and all member participants would benefit from a federal Standard of Identity for Honey. Please consider a collaborative effort to engage the honey industry organizations to finalize and adopt a federal Standard of Identity for Honey
The following is a basic letter that can be used in part or whole as submission to the request for comments.
Simply copy/paste.
Be sure to include signature, organizational identifier and contact information at the conclusion of the letter.
JUNE 9, 2014 is the deadline for the open comment period.
Division of Dockets Management (HFA-305) DATE, 2014
Food and Drug Administration
5630 Fishers Lane
Rm. 1061
Rockville, MD 20852
Agency/Docket Number: Docket No. FDA-2006-P-0207
Document Number: 2014-07925
Dear Sir/Madam,
Please consider the comments submitted and address each prior to proceeding with a final “Guidance for Industry: Proper labeling of Honey and Honey Products”
Within the draft Guidance, Section III notes several Q&A points (identified by blue font) that deserve comment.
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 flowers and store in honeycombs.” 2,3 FDA has concluded that this definition accurately reflects the common usage of the term “honey.”
Reference materials in the public domain do NOT accurately define the common usage of the term “honey.”§ 9 states have adopted Standards of Identity for Honey.
20 states have adopted Definitions of Honey.
No 2 state Standards or Definitions are identical, indicating there is no “common usage” of the term Honey.
A Federal Standard of Identity for Honey is required for any Guidance for Industry on the Proper Labeling of Honey to be effective.
·
However, you may label the honey with the name of the plant or blossom, if:
The particular plant or blossom is the chief floral source of the honey, such as “Orange Blossom Honey” or “Clover Honey” and
You, or the honey producer, can show that the plant or blossom designated on the label is the chief floral source of the honey.
What percent or measure is used to declare a “floral source” as the “chief floral source” on the label?
How would consumers know whether the food is honey, a blend of honey and another sweetener (e.g., sugar or corn syrup), or honey that contains flavoring agent (e.g., natural raspberry flavor) or other ingredients?
It is inconsistent to label an item containing “honey” and “sugar” as “blend of honey and sugar” while labeling “honey” and “raspberry flavor” as “raspberry flavored honey”. Is it acceptable to label “honey” and “sugar” as “honey flavored sugar” as well as labeling “honey” and “raspberry flavor” as “blend of honey and raspberry flavor”?
FDA’s enforcement authorities for food products that are represented as “honey,” but contain other ingredients…
The definition the FDA notes as adequate in the opening section of the draft guidance does not contain the composition of honey. How can the FDA test for misbranding or honey containing other ingredients if the basic composition of honey is not solidly identified?
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 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.
The definition of “a thick, sweet, syrupy substance that bees make as food from the nectar of flowers and store in honeycombs” contains no valuable constituent information regarding honey.
Only a standard of identity would have the level of comprehensive information needed for the FDA to find the food item adulterated under section 402(b) of the FD&C Act.
Some imported packages of honey are adulterated with cane or corn sugars while some are adulterated with residues. How does FDA monitor such adulterated honey products?
There is concern that the FDA monitoring for adulterated honey products may be inadequate if the monitoring is based on the diluted definition of “a thick, sweet, syrupy substance that bees make as food from the nectar of flowers and store in honeycombs”. The definition lacks the specificity required to identify adulteration of honey with cane or corn sugars.
In closing, the honey industry and all member participants would benefit from a federal Standard of Identity for Honey. Please consider a collaborative effort to engage the honey industry organizations to finalize and adopt a federal Standard of Identity for Honey.
Sincerely,
Name
Identifier (example: Beekeeper, Importer, Associate Member of XYZ Club)
Contact information
This guidance advises firms on the proper labeling of honey and honey products to help ensure that honey and honey products are not adulterated or misbranded under sections 402 and 403 of the Federal Food, Drug, and Cosmetic Act (the FD&C Act) (21 U.S.C. 342 and 343).
