Bob said: > Ultra filtration makes it very hard to catch adultrators of honey. Not at all! It is a big red flag. They might as well stencil the drums "Funny Honey". Finding that honey merely shows the characteristics of "ultra-filtration" is clear and compelling proof that either: "adulteration, damage, or inferiority has been concealed." [US FFDCA, "Adulteration", Section 402 (b)(3)] or: " a substance has been... mixed.. so as to... make it appear better or of greater value than it is." [US FFDCA, "Adulteration", Section 402 (b)(4)] Either one is clearly adulteration. You see, at least in the USA, evidence of "concealment" alone is enough to get a specific shipment of food seized and returned or destroyed. Read the section on "Adulterated Food" in the US Federal Food, Drug, and Cosmetic Act. http://www.fda.gov/opacom/laws/fdcact/fdcact4.htm "SEC. 402. [342] A food shall be deemed to be adulterated ...(3) if damage or inferiority has been concealed in any manner; or (4) if any substance has been added thereto or mixed or packed therewith so as to increase its bulk or weight, or reduce its quality or strength, or make it appear better or of greater value than it is." Here is a typical example of what happens when "evidence of concealment" is the only hard evidence that the FDA has when looking at honey. http://www.fda.gov/ora/fiars/ora_import_ia3601.html Yes, they eventually got confirmation from an outside lab that the sugars mix was highly unusual, but they made the decision to reject the honey based solely upon the evidence of "concealment" alone. There have been many similar cases with foods more common than honey where the "evidence of concealment" is the primary or sole evidence available, a classic one being the manipulation of orange juice: Citric and amino acids are added to orange juice to "conceal damage and inferiority" [402(b)(3)] or to "make the food appear to be of greater value" [402(b)4)]. Why would one do this? To cover up the adding of cheap sugars. It matters not that both citric and amino acids are "found in natural orange juice". In fact, the mere evidence that the packer bought a quantity of citric acid is enough evidence. But if the clear and simple language of 402(b)(3) is not enough to convince you that we have a solid footing, we can go further. Ultra-filtration is also clear and compelling evidence of "attempting to enhance the appearance", which is illegal under 402(b)(4). Let's walk through it slowly: "if any substance has been added thereto or mixed or packed therewith so as to increase its bulk or weight, or reduce its quality or strength, or make it appear better or of greater value than it is." So, let's compare the process to the law: a) The water is mixed with the honey. b) The water is later removed. c) The result is honey with a "better" color grade. d) The result is honey with a "better" moisture content. e) Honey with a "better" color grade is worth more. f) Honey with a "better" moisture content is worth more. g) Therefore, the process makes the honey appear "better or of greater value than it is." Note that the law does not say that its ok to add something and then attempt to remove it later in the process. The adding or mixing alone is all that matters. We are aware that the net result of this adding and mixing makes "dark" honey appear to be "water white". That's deception. The names and numbers for color grades vary from country to country, but "light color" honey is worth more than "dark" honey, both at wholesale and retail. Since it is clear that ultra-filtration has no purpose other than to artificially "enhance" the color and "enhance" flavor by removing inferior flavors, it clearly has a wide range of applications that would be unethical. It is easy to detect, due to the startling lack of components that would be found even in honey filtered by flash-heat and micropore filtration. > The common practice of filtering with DI earth is allowed so > how could you ever stop the using of only water to filter > with when the end product has the same amount of water as > when the filtration process started. Filters made from "diatomaceous earth" are simply filters. One runs the honey THROUGH the DI earth, and no DI earth remains in the end-product honey. In the case of the water added to honey, it should be clear to even the casual observer that some of the added water WILL show up in the final end-product. It is statistically impossible to add so much water, and then remove only the added water, some portion of the original water is replaced by the added water in this process. This is complicated, so let me explain. Let's take some honey (which contains H2O), and add lots more H2O. Then, we will remove all but 18.6% of the water. But which water is which? One clearly cannot claim that one somehow removed only the specific water added, leaving the specific water that was there at the start of the process. Therefore, the end-product honey has been adulterated. This may be a highly "technical" view, but anyone who wants to argue the point can quickly be exposed as a person with something to hide. > I see the move to ultra filtration to solve a problem with > honey and has nothing to do with the safety of the consumer. "Safety" may be the biggest stick with which we can beat ultra-filtration about the head and shoulders. Let's assume for a moment that something unfit for human consumption is contaminating a large lot of honey. While it is technically possible to use ultra-filtration to remove the contamination, it is illegal to do so, since one may not "de-contaminate" food once it has been contaminated. But is the mere use of this filtering technology evidence that the honey was contaminated with something nasty? Not directly, but why ELSE would one go to the additional trouble and expense of this newer and more robust filtering? There is also the direct evidence of overt adulteration that is inherent in the process itself. Read the beginning of Section 402 "SEC. 402. [342] A food shall be deemed to be adulterated... (2)(A) if it bears or contains any added poisonous or added deleterious substance..." Is "moisture" and "water" a "deleterious substance"? Most countries have standards for Honey "Grades". (This is not the same thing as "color grade") in the USA, the grades have to do with water content: "US Grade A", "Fancy" 18.6% moisture max "US Grade B", "Choice" 18.6% moisture max "US Grade C", "Standard" 20.0% moisture max "U.S. Grade D", "Substandard" more than 20% moisture So, a) Clearly, water in excess of 20% is a "deleterious substance" in regard to honey. b) Clearly, water in excess of 20% is added to the honey in ultra-filtration. c) Later, attempts are made to conceal the adulteration, by removal of the water. Don't like the above? Think I'm pushing it, and reading too much into the law? Let's see what the law says in 21 CFR 71.22: http://www.cfsan.fda.gov/~lrd/cfr71-22.html "The Commissioner shall refuse to issue a regulation listing a color additive, if in his judgment the data before him show that such proposed use would promote deception of the consumer or would result in misbranding or adulteration within the meaning of the act." So, is water a "color additive"? Heck yes!!! You add water, you filter, you remove water, and for sure, the color is suddenly "better". (Is this "bleached honey"? What else might you call it?) Does the process that used water as color additive "promote deception of the consumer"? Again, not only yes, but heck yes! They get what looks like "water white" honey, but never was. But let's slog on through the legalese: "The issuance of a regulation for a color additive authorizing its use generally in or on a food, drug, or cosmetic shall not be construed as authorization to use the color additive in a manner that may promote deception or conceal damage or inferiority." So even though water is permitted generally in or on food, the use of water in this manner is not legal, in that it "may promote deception or conceal damage or inferiority." Note that one need not prove that it >>IS<< "promoting deception". One only need observe that it >>MAY<< promote deception. Slogging further: "The use of a color additive to promote deception or conceal damage or inferiority shall be considered as the use of a color additive for which no regulation has issued pursuant to section 721(b) of the act, even though the regulation is effective for other uses." So, no matter what other regulations might say, if it >>MAY<< "promote deception or conceal damage or inferiority", then it is not legal. So, to review: We need not even claim that any specific lot of honey is or was contaminated, substandard, or adulterated. We need not test any further than is required to show that the honey was "ultra-filtered". The ultra-filtration itself is inherently deceptive. We need no new regulations or laws. Existing regulations clearly prohibit this process in multiple ways, and on multiple grounds. So, who is going to explain this "ultra-filtration" to the poor overworked guys who do enforcement and inspection of imports? Anyone know these folks? I don't. Once someone explains the process, the result will be a slam dunk. jim (Who speaks legalese fluently, and loves 4-move checkmates) :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: -- Visit www.honeybeeworld.com/BEE-L for rules, FAQ and other info --- ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::