The Food and Drug Administration (FDA), U.S. Department of Health and Human Services and the Center for Food Safety and Applied Nutrition developed a Guidance document for Industry dealing with honey and honey products. This Guidance was created as non binding recommendations to reflect the FDA’s current thinking and for the purpose of providing industry with guidance on proper labeling of honey and honey products to minimize the chance that a product will be adulterated or misbranded.
Proper labeling of food is essential to ensure that products are not adulterated or misbranded. Food can be classified as misbranded if the label does not include the common name of the food, if any exists, and the common name for each ingredient, if it is made of two or more ingredients. If two or more ingredients are in the food, then the ingredients must be listed on the label by their common name starting with the ingredient with the most weight and descending to the ingredient with the least weight. Furthermore, food may also be misbranded if the labeling is misleading or incorrect.
However, a food can be further considered adulterated if a valuable ingredient is not included in whole or in part, any substance is substituted in whole or in part, damage or inferiority is hidden or an additional ingredient is added to the food to increase the weight, reduce quality, or embellish a product to be of greater value than it actually is.
While more information on labeling requirements can be found on FDA’s Food Labeling Guide at https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/LabelingNutrition/ucm2006828.htm, this guidance seeks to cover general information on the proper labeling of honey and honey products to avoid misbranding or adulteration.
Honey is a single-ingredient food and thus does not need to include an ingredient statement on the label. Furthermore, while it is not required to declare a floral source of the honey, you may include the name of the plant of blossom if there is information to support that said plant or blossom is the primary floral source of the honey. However, if the honey has any additional ingredients, such as sugar or corn syrup, you are required to label the honey sufficiently to distinguish it from the single ingredient honey. You can do this by including a statement of identity which provides a basic description of the honey, such as blend of honey and corn syrup (as previously mentioned, the ingredient with the most weight must be listed first), and the common or usual name of each ingredient should be listed in the ingredient statement. Failure to include additional ingredients present, such as corn syrup, will be deemed adulterated. Similarly, when food consists of honey and a flavor ingredient, you are required to select a name that will reflect the food and characterizing flavors. In addition, the statement of ingredients should include the common names of all ingredients included.
It is essential to follow these general guidelines because the FDA monitors imported products labeled as honey by using an import alert to screen for adulterated and misbranded products.