“At Last, A Standard of Identity for Honey”

Bee Culture (June 2006), Vol. 134 (6): 18-20




Malcolm T. Sanford



Considering the amount of time humans have been involved with honey it may seem ludicrous to some that no standard definition exists.  In retrospect, however, there are a good many reasons for this situation. 


A standard product means that practically any sample of a pool of that product is representative and has the same characteristics of the rest of those in the pool.  In fact, a whole arena of one of the activities that drives much of the modern economy exhibits this phenomenon, the commodities futures market.  Take soybeans, which are traded in hundreds of thousands of bushels on a daily basis.  The trade presupposes that a contract (5,000 bushels) of soybeans is pretty much the same whether produced in Brazil, the United States or elsewhere.  The same is true of other commodities such as frozen orange juice concentrate and silver bullion.


There is no honey futures market because the product is too variable to support one.  It’s difficult to compare tupelo honey produced in the Southeastern United States with clover extracted from the Midwestern section of the country.  Thus, a contract of honey might include either one or none of these sweets, and the characteristics and price would be different.


A general definition of honey has been in use for a long time: “A sweet viscous material produced by bees from the nectar of flowers, composed largely of a mixture of dextrose (glucose or grape sugar) and levulose (fructose or fruit sugar) dissolved in about 17 percent water; contains small amounts of sucrose, mineral matter, vitamins, proteins, and enzymes.”1   A variation of this also is found in nature, called honeydew honey or simply honeydew: “An excreted material from insects in the order Homoptera (aphids) which feed on plant sap; since it contains almost 90% sugar, it is collected by bees and stored as honeydew honey.”2

Because of its inherent value, there have always been attempts to water honey down or add materials that are less expensive and achieve an increased overall price by selling what is purportedly a “pure” product.   This “economic adulteration” of honey has been going on a long time and a quick glance through the history books shows some of the creative and some times not very benign substances that have been added to honey.  Most of these, including cane and glucose syrup, were fairly easy to detect, however, the rise of high fructose corn syrup meant that a substance extremely close in structure could be added with little chance of detection.  This adulteration took on epidemic proportions in the 1980s when it was discovered that some products labeled as pure honey had up to eighty percent corn syrup.  When one can sell corn syrup costing $.14 a pound in a container of honey costing $.50 a pound, it doesn’t take much figuring to see the incentive for adulterating the product.


Fortunately, wholesale addition of high fructose corn syrup has been somewhat curtailed, but certainly economic adulteration continues to this day.  However, new problems have emerged to challenge honey marketers.  One of the most significant is contamination by products used in the beekeeping industry to treat pests and diseases of bees.   Recently, Chinese honey was eliminated from the world market because it was found to contain a powerful antibiotic, chloramphenicol.  Argentinian honey was subsequently banned from much of its market when nitrofurans were detected.


In the United States, another situation has surfaced that concerns many beekeepers and packers.  This is mislabeling or misbranding  products, where the label implies a product contains a good amount of honey, when in fact the amount present in miniscule or even absent.  Among the prime culprits are breakfast cereals, but others too have been identified and constitute what one wag has published as “The Wall of Shame.”2


The current situation can no longer be tolerated by honey marketers and so a resolute group met December 2-4, 2005 in San Antonio, Texas.  Sponsored by the National Honey Board, this “Honey Industry Roundtable,” which included the U.S. largest beekeeping associations, honey cooperatives, and packers and dealers, promulgated several resolutions, among which was: “To support legislative action on a ‘honey standard.’ Co-opting parts of the CODEX standard as a U.S. standard was discussed as a possible alternative to the traditional ‘standard of identity’.”3


The Food and Drug Administration was the agency asked to develop a standard of identity for honey.  In this vein it is instructive to read the history of the development of the “Pure Food and Drug Act of 1906,” modified in 1938 and later years.   It turns out to be exhibited in “the peanut butter and jelly sandwich, which both assembled and contained the basic ingredients of the United States' food standards program in the twentieth century. Scrutiny of the jelly standard illustrates the use of food standards to insure value to consumers. The bread standards illustrate the short lived use of food standards of identity to control the safety of ingredients as well as their ongoing use to enhance the nutritive value of standardized foods. And the peanut butter hearings demonstrate the wisdom of abandoning earlier strict standards in favor of a more dynamic food standards agenda. The peanut butter and jelly sandwich, itself a staple in American life, will enter the twenty first century as a living history lesson on the importance of regulating, but not over-regulating a wide variety of foodstuffs in a dynamic marketplace.”4


Given the above history, the FDA has discouraged adoption of new standards in recent years, saying to the American Beekeeping Federation and others that many of the standards for processed foods were aimed at reducing competition.5   However, the petition was submitted under a different section of the law that seeks to coordinate U.S. with international standards.  Thus, a variation of the Codex Alimentarius has been recommended.  “The Codex Alimentarius Commission was created in 1963 by Food and Agricultural Organization of the United Nations (FAO) and World Health Organization (WHO)  to develop food standards, guidelines and related texts such as codes of practice under the Joint FAO/WHO Food Standards Programme. The main purposes of this Programme are protecting health of the consumers and ensuring fair trade practices in the food trade, and promoting coordination of all food standards work undertaken by international governmental and non-governmental organizations.” 6

The U.S. standard lists some deviations from the Codex standard, including:

1.      Deleting voluntary annex to the Codex as not applicable.

2.      Deleting subsections (a) and (b) from section 3.4 moisture content, no honey should exceed 23% moisture content.

3.      Deleting contaminants as these are controlled by U.S. laws and regulations.

4.      Deleting hygiene as these too are controlled by U.S. laws and regulations.

5.      Deleting labeling and 6.2 labeling of non-retail containers.

6.      Deleting methods of sampling and analysis as these could be different in the U.S.

The American  Beekeeping Federation (ABF) has announced that the petition asking the U.S. Food and Drug Administration to develop a Standard of Identity for honey was filed on Mar. 7. The petition was signed by ABF, American Honey Producers Association., Sioux Honey Association., National Honey Packers & Dealers Association., and Western States Honey Packers & Dealers Association.  The full text is available from the ABF web site.7


Comments can be sent supporting the honey standard now, according to the ABF. It is not necessary to wait until the comment period soon to be noticed in the Federal Register.  There is yet to be a dedicated email portal for comments, but your company comments can be sent electronically [or otherwise] to FDA at the address below:


Reference: Docket # 2006P-0101.


Division of Dockets Management

Food and Drug Administration

5630 Fishers Lane, Room 1061 (HFA-305)

Rockville, MD, 20852

Email: fdadockets@oc.fda.gov

Phone: 301-827-6860

Fax: 301-827-6870

TTY/TDD Users: 1-800-735-2258


I have in my possession a letter written by Florida Commissioner of Agriculture, Charles Bronson March 31, 2006 supporting the petition.  In part it states:


“Mislabeled or misbranded products bearing the word honey in the product name or front label induce customers to purchase these products under the false belief that they are either 100% honey or contain honey as their principal sweetener.  The increasing presence in the market of these misbranded products threatens the image of honey as a pure, natural and healthy sweetener.  Beekeepers work extremely hard to harvest the high quality product that consumers have come to expect.  FDA’s adoption of a Standard of Honey will not only help guard against the negative pricing impacts  that come from deceptive labeling by an inferior product but will give regulators, both FDA and state agencies, the tools they need to facilitate regulatory actions on these products, particularly in cases of adulteration or fraud.  The adoption of this standard will go a long way toward ensuring the viability of our domestic honey industry in years to come.”


The leadership of the Florida State Beekeepers Association is now formulating a response in support of the petition.  It is hoped that others in the beekeeping industry will follow suit. 


According to the ABF, adoption of the proposal is expected to take a year or longer.   Its progress can be tracked online at http://www.cfsan.fda.gov. Under "Dockets" enter that number (#2006P-0101) and anything filed should be accessible. You should be able to enter comments on the proposal online as well, although at the present time this feature has not been implemented.


The adoption of a honey identity will go a long way in helping the beekeeping industry bring the marketing of its principal sweet up to modern standards with associated protection and control.  It’s been a long time coming, but no doubt one that beekeepers in the future will say was worth the wait and effort.  Now its up to the rest of us to do our part in ensuring that the efforts of many others have not been in vane.




1.      Apiservices Web Site, <http://www.beekeeping.com/goodies/beekeeping_glossary.htm#h>, accessed April 20, 2006.

2.      Fischer’s Bee Quick Web Site, <http://bee-quick.com/wall/>, accessed April 20, 2006.

3.      National Honey Board Web Site, <http://www.nhb.org/buzz/roundtable2004report.html>, accessed April 20, 2006.

4.      Suzanne White Junod. 1999: Society for the Social History of Medicine

Spring Conference 1999 Aberdeen, Scotland "Science, Medicine and Food Policy in the Twentieth Century,"  <http://www.fda.gov/oc/history/slideshow/default.htm>, accessed April 20, 2006.

5.      American Beekeeping Federation Web Site,<http://abfnet.org/?p=90>, accessed April 20, 2006.

6.      Codex Alimentarius Web Site, <http://www.codexalimentarius.net/web/index_en.jsp>, accessed April 20, 2006.

7.      <http://abfnet.org/images/Standard_of_Identity_Petition.pdf>, accessed April 20, 2006.