Request: the introduction of a bill into the New York State legislature amending the current law, “Defining Honey”, Circular 911 Article 17 (Section 205 ), with a more comprehensive definition: the Standard of Identity for Honey .

Background

In 1996, the courts issued a favorable ruling on the anti-dumping suit against the Peoples Republic of China and imposed a 215% tariff on honey imported into the U.S.

Honey prices were rising at an unprecedented rate, and packers were scurrying to find available store of U.S. honey. Yet some members of the beekeeping industry were not so euphoric. They believed the high prices caused by low supply could cause the market to soon be flooded with adulterated honey, and since no compositional standard had ever been established, the impact of product adulteration on the U.S. honey industry would be disastrous.

In response to this critical condition, in March, 2006, the American Beekeeping Federation, American Honey Producers Association, National Honey Packers and Dealers Association, Sioux Honey Association and Western Packers & Dealers Association petitioned the FDA to adopt the “1987/2001 Revised Codex Standard of Identity for Honey (with certain deviations)”.

On August 31, 2006, Barbara Schneeman, Director, Office of Nutritional Products, Labeling and Dietary Supplements, Center for Food Safety and Applied Nutrition (FDA), wrote Kristen C. Gunter, attorney representing the industry groups, stating the Food and Drug Administration (FDA) had not been able to reach a decision on the petition within the first 180 days because of “other agency priorities and the limited availability of resources.” Schneeman concluded, “We will complete our review of your petition and consider any amendments to our regulations as warranted and in the context of other program priorities within the Center.” The news was devastating…

U.S. Senator Conrad Kent and fifteen U.S. Senators appealed to the U.S. Department of Agriculture, yet the FDA showed no indication they would re-consider a review anytime within the near future and have instead looked to the states to enact legislation to accomplish enforcement. As a result, the U.S. honey producers are facing ruin; some say beyond hope. Millions and millions of barrels of honey, adulterated with high fructose corn syrups, cane syrups, beet syrups, high fructose rice syrups, hydrolyzed inulin syrups, beet invert syrups, or maybe some new-generation sweetener are sold as pure honey or sold as honey blend, a euphemism for a product that looks like honey, a product that from the label consumers believe is honey, but is not honey; counterfeiters are trading in the currency of honey and no standard of identity for honey to stop them…

In August, 2007, The Florida State Beekeepers Association, feeling they could no longer wait for the FDA to take action, endorsed a resolution asking the Florida Department of Agriculture & Consumer Services to adopt the U.S. Version of Revised Codex as the standard of identity for honey in Florida. On July 14, 2009, Commissioner of Agriculture, Charles Bronson, announced the adoption of the standard of identity for honey, the first honey standard in the U.S.  In October 2009, California adopted the standard; Wisconsin adopted a honey standard this year; in Utah, the bill is proceeding through the Department of Agriculture; in Maryland, Oregon, and New York, the bill has been proposed. Other states, Kansas, Oklahoma, Arkansas, Colorado, Delaware, Georgia, Indiana, Idaho, Iowa, Missouri, Massachusetts, North Carolina, North Dakota, Ohio, Nebraska, Texas, Washington, Pennsylvania, South Dakota, Louisiana, Tennessee, Kentucky, Virginia, West Virginia, Montana and Minnesota are at various stages in the adoption process. The American Honey Producers Association, the American Beekeeping Federation and the National Honey Packers & Dealers Association have endorsed a state-by-state adoption of the honey standard in their 2010 resolutions. On June 9th our own Senator Charles Schumer challenged the importation of honey from China, and called for a standard of identity for honey.

Justification

New York State has always been a strong advocate in protecting the purity of honey and supporting the beekeeper. Laws protecting honey bees first appeared in New York Statutes in 1883, and laws against adulteration and misbranding of honey go back as far as 1902, predating the Federal Pure Food & Drug Act of 1906, which was promoted by President Theodore Roosevelt.

The recognizable concern of imports coming into the United States which may not meet our nation’s and more specifically the State of New York’s purity laws is definitely increasing public apprehension. Some laws may require changes in consideration of Twenty-First century global trade and technology. In fact, the New York Regulation, “Defining Honey” (Section 205) has been unchanged since its inception, 108 years ago.

A consumer study conducted in 2005 for the National Honey Board suggests that U.S. consumers are very confused about what “honey” means in terms of the food’s composition. Forty-two percent of those interviewed believed that pure honey contains additives and 17% of those interviewed believed “honey” contains added syrup. With a variety of blended sweeteners and “honey pretenders” being introduced into the market, consumer understanding of the meaning of the term “honey” is likely to erode. Most troubling is that the study found that many consumers are many consumers are aware of honey blends, have previously purchased a honey blend, and have demonstrated a positive intent to purchase a honey blend in the future. The Board’s conclusion: “This trend, if not further explored, may affect the future of honey.”

Clearly the U.S. honey industry and ultimately New York honey producers are facing destruction without definitive standards of identity for honey to preserve the wholesomeness of honey in the eyes of the consumer and to provide possible civil recourse when the honey is found to be adulterated.  Having a pure product is much better than having a product that is of poor quality, potentially tainted and at the worst causing sickness.

Conclusion

Adulteration hurts the reputation of honey as a high quality wholesome and natural food, imperils the viability of beekeepers and packers through unfair competition, and threatens the health and confidence of consumers. The adoption of a standard of identity for honey will be further evidence of the State of New York’s continued acknowledgment of the importance of honey bees and the recognition of the need to provide consumers with a standard of purity for nature’s sweetener. Protection of New York beekeepers and honey producers from unfair mixing, blending and sale of cheap inferior products gives the industry the strength and professionalism to elevate the product and the producers in offering the Pride of New York. This can be accomplished, not by placing additional financial burden on the State of New York, but by giving beekeepers a standard which will allow them to create self-enforcement within their industry and preserve for the consumer, nature’s perfect food.

  8/2010