Stating straight away - I have no legal expertise, nor hold much ability in conversing with a
"weasel mind".
Both appear to be requirements when dealing with situations present in the global market.

Therefore my comments are the result of reading texts and drawing what to me are clear conclusions.

Referring to the E.U. Directive 2001/110/EC

There is a distinction for honeys that are "(a) suitable for industrial uses or as an ingredient in
other foodstuffs which are then processed and (b)
may:
— have a foreign taste or odour, or
— have begun to ferment or have fermented, or
— have been overheated."

They are termed "Bakers Honey"

This class of honey before use in (a), note above, must be labeled as "Bakers Honey.
Then:
Annex 1, point 2 (viii) of EU Directive, Filtered honey is defined as:
"Honey obtained by removing foreign inorganic or organic matter in such a way as to result in the
significant
removal of pollen."

But:
Bakers Honey mentions no restriction on what may happen to it before being included into a food
stuff.

Hence:
It may be dealt with in any manner to render it acceptable, and once included into a product - it
may be then labeled as "Honey"!

This surely is one manner in which the type of material being prepared by the Chinese industry, if
accepted, will make great inroads - displacing traditional materials.

In the Revised Codex Standard for Honey (Codex stan 12 - 1981, rev.1 (1987), rev.2 (2001). there is
no specific mention of the "Bakers Honey class.

Reading the definition of what is a honey and what may be done to it;

"Part 1 point 3 "Essential Composition and Quality Factors:
3.2 "Honey shall not be heated or processed to such an extent that its essential composition is
changed and/ or its quality is impaired"

Adding a certain percentage of water to a honey of what ever quality (in the case being discussed -
30* more) will be IMHO changing its essential composition, and therefore illegal.

But at the end of the document that I have obtained from FOA web site, Part 2 states:
"[Honey for Industrial Uses or as an Ingredient in other Foods]
This part is subject to further consideration."

There appears to be disparity between  FAO Codex material and such controlling documents, e.g.. as
produced by E.U., governing honey quality.

Attempts to degrade to the lowest possible legal level appears to be the end game for many
organisations in the processing end of the honey market. At a time when the opposite is being
continuously pushed at producers by government departments etc.

Its overdue to show what standard is really required!
One or the other - genuine or false produce - Which is it to be?

The market should not be allowed to dictate standards. Clients who want honey should get honey and
not be conned with a sticky, sweet manipulated substitute.

A continued and enhanced stand against adulteration by what ever means must be clearly imposed
towards individuals and organisations that attempt to manipulate the market.

This requires quality regulations - clear, straight forward wording in "Plain English (or any other
required language)" - and sort out the mess!

Yours, who is a little tired of being told about substances harmless to bees but then kill them
whilst at the same time having to protect honey from honey that is not honey. Talk about a "pincer
movement".

Peter

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