Labelling Honey

On the face of it, labelling is a complex legal minefield, but in reality so long as you follow a few simple and obvious rules you will be within all the regulations.

Be Honest.
Don’t call it Blossom Honey if it isn’t, in fact don’t call it anything it isn’t

Be Clever.
Do call it what it is, it’s a premium New Forest (or other area) product, put it on the label. The Label is a big selling point, some are bought to eat, many others as gifts so make it as appealing as possible.

Requirements:

The Jar:
Not labelling but also a legal requirement. The jars and lids must not be recycled, and must be sterile before use.

What is it?
Honey, you must label it Honey, you can call it Blossom Honey, New Forest Honey, Aunt Susan’s Honey etc, but it must be labelled Honey.

Country of Origin:
In this case UK

Contact Details:
Your Name: Contact Address: Town: Postcode: Contact number.

Best Before date:
If it’s packed properly, and it should be, it will last for years, so a couple of years will be fine

Weight:
Must be in grams, you can also add imperial should you wish. Grams must be bigger/bolder than imperial and must be at least 4mm high

Tamper Label:
A Tamper Evident Label or some other system is a legal requirement, as well as common sense. This label is put on BEFORE and underneath the main label

Optional:
Honey is not recommended for infants under 12 months, so you may wish to add a sticker for that.

Some honey can granulate, you may also want to put a sticker on for that, so if it does, the consumer doesn’t think they have an inferior product.

Now it stands to reason that most of you can make and design your own labels, but if you are reading this, a simple Google search will find many honey label companies that have online label creation software, so by simply filling in their forms, you will have covered all the bases. A quick Google search found me a company that would fulfil all the requirements for 8p per jar.

Trading Standards.

Following an enquiry, there is no need to register as a food producer. Below is the body of the reply.

Long and probably boring, but worth knowing .

” I have consulted with New Forest District Council Environmental Health
and done some further research and I was wrong to say there was a
requirement to register as a primary producer with us at Hampshire
County Council.

We do have an interest in those who pack and sell honey as the food
standards regulations and weights and measures requirements must still
be complied with see our leaflet at
https://www.hants.gov.uk/business/tradingstandards/businessadvice/food/foodlabelling/labellinghoney
[1] and clearly they must still ensure that any food they place on the
market is safe (Regulation (EC) 178/2002 Article 14) but they do not
have to contact us.

Most beekeepers / small honey producers are not only exempt from
registering with Environmental Health as the processing of honey at
their own premises is included in primary production (rather than food
processing) but there is also an exemption for registering as a primary
producer if they only supply small quantities direct to the final
consumer or to local retail establishments.

I was aware that processing of honey was not considered as “food
processing” when done at the beekeepers premises but falls under
primary production but I had forgotten the exemption in Article 1 (2)
(c) of EC Regulation 852/2004

_2. This Regulation shall not apply to:_

_(a) primary production for private domestic use;_

_(b) the domestic preparation, handling or storage of food for private
domestic consumption;_

_(c) the direct supply, by the producer, of small quantities of primary
products to the final consumer or to local retail establishments
directly supplying the final consumer;_

The attached guidance notes at page 3 makes clear what counts as primary
production when it comes to beekeeping as follows –

_HONEY AND OTHER FOOD FROM BEE PRODUCTION__: all the beekeeping
activities must be considered as primary production. This includes
beekeeping (even if this activity extends to having bee-hives at a
distance from the bee-keeper’s premises), the collection of honey, its
centrifugation and the wrapping and/or packaging at the beekeeper’s
premises. Other operations outside the beekeeper’s premises (e.g. the
centrifugation and/or wrapping/packaging of honey) cannot be considered
as primary production, including those carried out on behalf of
beekeepers by collective establishments (e.g. cooperatives). _

And at page 6 the centrifugation of honey to remove honeycomb is
specifically mentioned as being part of primary production and nothing
further –

_3.7. At the level of primary production, primary products may be
transported, stored and handled provided that does not substantially
alter their nature [see Annex I, Part A, point I.1(a) of the
Regulation]. _

_At the level of primary production, primary products are often subject
to operations so as to ensure a better presentation, such as: _

_• Washing of vegetables, removing leaves from vegetables, the sorting
of fruit etc. _

_• The drying of cereals, _

_• The slaughter, bleeding, gutting, removing fins, refrigeration and
wrapping of fish. _

_• Centrifugation of honey to remove honeycombs. _

_Such operations must be considered as normal routine operations at the
level of primary production and must not lead to the need to satisfy
food safety requirements in addition to the ones already applying to
primary production. _

_On the other hand, certain operations carried out on the farm are
likely to alter the products and/or to introduce new hazards to food
e.g. the peeling of potatoes, the slicing of carrots, the bagging of
salads and the application of preservation gases. These operations
cannot be considered as normal routine operations at the level of
primary production nor as operations associated with primary
production._

So anything done on the beekeepers premises resulting in a jar of honey
is considered primary production.

If it is primary production for private domestic use – exempt from
registration.

If it is direct supply by the producer of small quantities to the final
consumer or to local retailers also exempt.

What is a small quantity? The EU guidance notes attached looks at what
small quantities means

_3.3. “Small quantities” of primary products as referred to in
Article 1, paragraph 2(c) of the Regulation _

_The Regulation does not apply to small quantities of primary products
supplied directly by the producer to the final consumer or to local
retail establishments directly supplying the final consumer. _

_In general terms, the notion “small quantities” should be broad
enough to allow inter alia: _

_• Farmers to sell primary products (vegetables, fruits, eggs, raw
milk6 etc.) directly to the final consumer e.g. farm gate sales or sales
at local markets, to local retail shops for direct sale to the final
consumer and to local restaurants. _

_• Individuals who collect products in the wild such as mushrooms and
berries to deliver their yield directly to the final consumer or to
local retail shops for direct sale to the final consumer and to local
restaurants. _

_Pursuant to Article 1, paragraph 3 of Regulation (EC) No 852/2004, it
is up to Member States to further refine the notion of small quantities
depending on the local situation, and to lay down under national law the
rules necessary to ensure that the safety of the food is guaranteed
(risk based approach). _

_In general, the rules under national law established by the Member
States in respect of small quantities as referred to in Article 1,
paragraph 2(c) should allow current practices to continue to apply,
provided they ensure the achievements of the objectives of the
Regulation_

_ _

The FSA code of practical guidance also repeats this includes –

_Registration is not required for establishments undertaking the
following food activities:_

_……_

_ _

_• Primary production for private domestic use or the domestic
preparation, handling or storage of food for private domestic
consumption; _

_• Small quantities4 of primary products supplied directly by the
producer to the final consumer or to local retail establishments
directly supplying the final consumer;_

The footnote 4 states _4 For further information see guidance on
approval of food establishment at footnote 5._

_ _

The link at footnote 5 is no longer operational but the latest guidance
on approval of food establishments which relates to 853/2004

_20. In general terms the notion of “small quantities” should be
broad enough to allow amongst other things: _

_ _

_ Farmers to sell primary products directly to the final consumer
e.g. farm gate sales or sales at local markets. This exemption also
covers sales to local retail shops and local restaurants directly
supplying the final consumer with the exception of raw drinking milk and
eggs (see below) _

_ Fishermen who harvest live shellfish products and fishery products
such as crabs and lobsters to deliver directly to the final consumer or
to local retail shops for direct sale to the final consumer and to local
restaurants _

_ _

_21. The expression “small quantities” is not defined in
Regulations, the FSA, therefore, suggest the following in Table 2 as
maximum amounts, which could be considered as small quantity for
individual products of animal origin_

The table does not include honey but for instance for fishery products
the amount stated is 25 tonnes per calendar year and other products are
similar amounts so I am fairly certain most of your beekeepers are going
to fall into that exemption.

I have also been sent a note when the question was asked of the FSA and
the reply was

for other products it’s usually assessed on a case by case basis, and
we leave for LAs to decide. So for example, HONEY, if it’s ‘hobby
sized’ production will be small quantities compared to commercial
production.

I hope that helps and I can only apologise again for my error,

Regards

Kate

KATE HOLME

Trading Standards Officer “