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Apr 28

FDA Publishes Draft Guidance on Honey Labeling

On April 11, 2014, the U.S. Food and Drug Administration (“FDA”) published a draft guidance document, entitled “Draft Guidance for Industry: Proper Labeling of Honey and Honey Products” (“Guidance”). The Guidance provides industry with guidelines on how to properly label honey and related products in order to ensure that these products are not labeled in a misleading manner pursuant to the requirements of the Federal Food, Drug and Cosmetic Act (“FFDCA”) and accompanying FDA regulations.

The Guidance sets forth the Agency’s current thinking pertaining to honey labeling. In particular, the FDA notes the proper uses of the term “honey” in labeling and notes that labelers may state the name of the source of honey, such as plant or blossom, depending on whether this source is the chief floral source of the honey. More information about the labeling of honey can be found here.

In addition to honey labeling issues, the FDA monitors the importation of honey and honey products to check for adulteration caused by the addition of corn sugars and sugar cane. Under sections 402(b)(1) through 402(b)(4) of the FFDCA, a food is considered to be adulterated if an important component has been withheld from a food, any element has been fully or partially replaced or a component has been added to the food in order to inflate the weight or size, decrease quality or to make it seem superior in quality. Accordingly, products labeled as honey that contain added corn sugars, sugar cane or other substances would not be released into American distribution until the FDA finds that the honey has not been adulterated.

In sum, in order to import honey products without issue, industry is responsible for ensuring honey labeling is compliant with regulations and that honey products, as formulated, are not otherwise found to be adulterated under federal law. If you need assistance with honey labeling, importing or maintaining compliance with the laws and regulations enforced by the FDA, contact us at contact@giannamore-law.com.

FDA Attorney

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