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From:
Peter Armitage <[log in to unmask]>
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Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Thu, 28 Mar 2019 09:51:34 -0400
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Re. honey varietal labeling, our European colleagues have a somewhat complex history of legislating honey criteria and standards as far as monofloral sources and other qualities are concerned.

This article by Thrasyvoulou, et al. is of interest. 2018. “Legislation of honey criteria and standards.” Journal of Apicultural Research. 57(1): 88-96.  The U.S. is pretty much missing from this analysis except at the end of the article where the authors write, “Algeria has not (sic) legislation on bee product although this country has a very long tradition of beekeeping and USA is in the process to adopt new regulations on honey” (p.94).

What’s on the go in the U.S. re. new honey regulations?

I just finished a review of Canadian honey regulations with particular attention to monofloral honeys sold only within the province.  The key regulations relate to misrepresentation.  No matter where it’s sold, according to subsection 6(1) of the Safe Food for Canadians Act, “[i]t is prohibited for a person to manufacture, prepare, package, label, sell, import or advertise a food commodity in a manner that is false, misleading or deceptive or is likely to create an erroneous impression regarding its character, quality, value, quantity, composition, merit, safety or origin or the method of its manufacture or preparation.”

Subsection 199(1) of the Safe Food for Canadians Regulations identifies some, but not all, of the ways that labels can mislead with respect to net quantity and composition. "False, misleading or deceptive” labeling includes, but is not limited to:

- “any representation in which expressions, words, figures, depictions or symbols are used that may reasonably be considered to qualify the declared net quantity or that is likely to deceive a consumer with respect to the net quantity of a consumer prepackaged food; or

- any expression, word, figure, depiction or symbol that may reasonably be considered to imply that a consumer prepackaged food contains any matter that it does not in fact contain or that it does not contain any matter that it does in fact contain.” https://laws-lois.justice.gc.ca/eng/regulations/SOR-2018-108/page-21.html#h-54

However, while federal regulations prohibit the misrepresentation of the honey content, there are no regulations in Canada specifying the manner in which monofloral content is to be proven to consumers, and there are no laboratories where honey can be tested for floral source, with the exception of some new melissopalynological services provided by Melissa Girard via the Centre de recherches en sciences animals de Deschambault in Quebec. http://www.crsad.qc.ca/fileadmin/fichiers/fichiersCRSAD/Publications_Services_Conseils/Autres_sources/Fiche_coordonnees_et_echantillons.pdf 

I’m inclined to think along the lines of Gene Ash (separate thread re. apiary inspection) that the regulations regarding misrepresentation are not likely to be enforced unless there’s a complaint.  And even then, action by the Canadian Food Inspection Agency re. a prosecution would likely make for an interesting legal test case (e.g., no legal criteria in Canada to define monofloral honeys, etc.).

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