Honey Laundering: Raw Deal for Honey Labels

The European Parliament has approved an ambitious position ahead of talks with EU ministers on the overhaul of European honey marketing rules in a bid to stem floods of counterfeit imports mainly coming from China.

More transparent country of origin labelling on all imported honey is the main proposed tweak to the Commission’s revision of the so-called Breakfast directives European lawmakers agreed on in a plenary vote held in Strasbourg on 12 December. The main objective of the Parliament’s position is to reverse a spike in fraud affecting the honey sector. MEPs (Members of the European Parliament) specified that countries of origin should be mentioned in descending order on honey labels, indicating their respective share in percentage of the weight contributing to each pot.

A proposal to reform the ‘Breakfast directives’ was put forward by the Commission last April as part of the attempt by the European Commission to update the EU marketing standards of breakfast foodstuffs such as fruit juices, jams, and honey, some of which were more than 20 years old.

In March 2023, the EU Anti-Fraud Office (OLAF) issued a shocking report concluding that 46% of honey imported from third countries into the Single market was suspected of being non-compliant with the bloc’s legislation. The situation is expected to worsen as the official detection methods currently used do not pick up on all abuses, especially since the use of sugar syrups is extremely difficult to identify even with sophisticated analysis.

“We will stop fraudulent practices around honey labels, which in the future will have to clearly state the countries of origin,” MEP Alexander Bernhuber (Austria/European People’s Party) commented after the vote. Bernhuber, the Parliament’s rapporteur on the file, said the proposed measures would be enough to “protect consumers and beekeepers from adulterated honey and facilitate informed consumer choices through more transparency.”

Saving the UKs beekeepers

Climate change has already affected the EU’s honey production, while retailers and food processors seem to prefer cheaper imported honey – mainly from China and other Asian countries like Vietnam – over European products. According to the EU farmers lobby Copa-Cogeca, this combination of causes could lead to the loss of five million honeybee colonies in Europe by 2030.

China is currently the largest honey producer in the world with 473 million tonnes produced in 2021, accounting for 27% of global production. The EU follows with 228 million tonnes, accounting for 13% of global share. “In Hungary, in Italy, in France, just about everywhere in Europe, there are professional beekeepers who are dying because they can no longer sell their honey as they have to compete unfairly with honey from China. Well, Europe has to do something about it,” Yvan Hennion, chair of Copa-Cogeca honey working party, said.

MEPs went further by considering the new labelling requirements as just the first step in the implementation of a complete traceability system which should ensure access to essential information concerning not only the origin of honey but also the year of production and a unique producer identifier.

Lawmakers in the European Parliament would also like to empower competent authorities of member states to follow the entire chain back to the harvesting beekeepers or, in the case of imported honey, to the producer. “To ensure the accuracy of the information on the country of origin of the honey, the placing on the market should be conditional upon the accuracy of the information provided on the composition of the product,” the approved text reads.

Following the Parliament vote, interinstitutional talks with the EU Council will begin, and since ministers have already agreed on their negotiating positions, there is a strong chance that agreement will be reached before the Parliamentary term ends next year.

Honey is honey when it’s pure

A significant proportion of honey imported into the EU is suspected to be fraudulently adulterated with added syrups, according to a new Commission-led analysis, marking a substantial increase from previous years.  As it stands, the EU does not produce enough honey to meet demand and imports some 40% from third countries. But this has left European producers battling with increasing low-priced imports, notably from China, which European producers cannot compete with.

To get a clearer picture of the situation, the analysis was spearheaded by the European Commission’s DG SANTE, together with the national authorities of 18 countries that are part of the EU Food Fraud Network, the European Anti-Fraud Office (OLAF) and the European Commission’s Joint Research Centre (JRC).

The analysis, released on Thursday (23 March), found that 46% of the 320 samples of imported honey – taken randomly between November 2021 and February 2022 and analysed by the JRC – were likely tampered with. On this basis, there is a “strong suspicion that a large part of the honey imported from non-EU countries and found suspicious by the JRC of being adulterated remains present and undetected on the EU market”, it concluded.

While the testing method was insufficient to ascertain adulteration, it gives an idea that samples are “suspicious to be adulterated” and thus not compliant with the EU’s Honey Directive. Honey naturally contains sugars and, as per the EU rules on the matter, must remain pure, meaning that it cannot have ingredients added to it. Adulteration occurs when ingredients such as water or inexpensive sugar syrups are artificially added to increase the volume of honey. While the risk to human health is considered low, such practices defraud consumers and jeopardise EU producers who face unfair competition from products containing illicit, cheap ingredients.

For example, the EU average unit value for imported honey was €2.32 per kilogram in 2021, whereas sugar syrups made from rice were around €0.40/0.60 kilogram. The rate found in this most recent analysis was considerably higher than the one obtained in 2015-17, which stood at 14%, showing a worrying upward trend.  The highest absolute number of suspicious consignments originated from China (74%), but honey originating from Turkey had the highest relative proportion of suspicious samples (93%).

Meanwhile, honey imported from the UK had an even higher suspicion rate (100%), which researchers said was likely the result of honey produced in other countries and further blended in the UK before being re-exported to the EU. In total, more than half (57%) of the operators had exported honey consignments suspected of being adulterated with extraneous sugars, while more than 60% of the operators imported at least one suspicious consignment.

“The EU is an importer of honey as the internal demand is higher than our domestic production. It is important that we remain vigilant against any abuse,” Ville Itälä, Director-General of OLAF, said. He added that while the most frequent type of fraud with honey happens via adulteration, a second investigation also found instances of origin fraud, with food labels claiming false origins of the product. “This action served to raise attention, call for order, and deter any fraudulent practices,” he concluded, calling for a proper follow-up of suspicions.

Reacting to the findings, the EU farmers’ association COPA-COGECA called on EU decision-makers to “act now to avoid the wrecking of the profession”, which they say could lead to a substantial decline of honeybees on the continent.  Stanislav Jaš, chairman of the EU farmers’ association COPA-COGECA’s honey working party, said that the findings explain “why we are going through a real agricultural disaster in the EU.”

Echoing recent calls from EU member states for tighter origin labelling and traceability, the association is calling for obligatory origin labelling with “percentage shares in descending order”, as well as reinforced national controls and systematic checks of imported honey batches based on improved methods combined with proof of traceability from hive to pot.

Winnie the Pooh and AA Milne get their say

It is not every day that a judge quotes Winnie-the-Pooh. But this week, one made the return to the Hundred Acre Wood when delivering an extraordinary judgment over what constituted “raw honey”. Judge Neville was asked to settle a row between a high-end Greek food firm and a London council over whether the company could call their product “raw” or “artisan”. The dispute, between Waltham Forest trading standards and the firm Odysea, brought out the storyteller in Neville, who began by reciting the author AA Milne in his written decision.

It read: “‘The things that make me different are the things that make me me’, said Piglet, who must have seen quite a bit of honey eaten over the years. If he treated Pooh to some ‘raw honey’, what would be different about it?”

It’s not the first time that legal proceedings have made calls on the definitions of food although it is usually around matters of tax. Earlier this year, Walkers was ruled to have to pay VAT on its Mini Poppadoms because they are really more like crisps. Previous VAT debates have involved McVitie’s Jaffa Cakes, which tax authorities in the 1990s unsuccessfully argued were biscuits.

Odysea, which has sold thousands of jars of honey proudly labelled as “raw”, argued that their honey was not heated above its natural temperature and underwent far less processing. However, Waltham Forest trading standards argued that all honey was raw because it has not been cooked, claiming the wording misled consumers by suggesting Odysea’s product was somehow different.

The company had to reprint its jar labels to say “artisan honey” instead but in an appeal, the tribunal was called to adjudicate on that decision. In the end, the judge decided not to conclude over what defines the term itself, refusing to agree with the council that by calling the product “raw” it suggested special characteristics. He ruled in favour of Odysea on appeal.

The judge concluded that the difficulty arose with the two parties asking the tribunal to rule between two different definitions of raw. He said: “The definition put forward by Waltham Forest, being ‘uncooked’, can be rejected. The average consumer would struggle to explain what ‘cooked honey’ might even look like.” But, he added, that rejection did not mean he was accepting Odysea’s definition. “The evidence shows that consumer perception is aligned with common sense: raw in this context takes the everyday meaning of ‘unwrought’, ‘unprocessed’, ‘in its natural state’.

“But a precise definition that sorts honey into ‘raw’ and ‘not raw’ is less obvious … To avoid continuing to labour the point, I look at Odysea’s own honey. Its ‘limited run, single source’ honey would satisfy just about everyone as being raw honey, although even then the odd person might take exception to the centrifuge and the pump.”

The judge concluded: “Ultimately, however, the tribunal’s task is not to be drawn into legislating a precise definition of ‘raw’, as both parties were apt to invite it to do, but to decide if this honey breaches the law in the way stated.” He rejected the idea that Odysea’s use of the word raw suggested special characteristics “that in fact all similar foods possess”, or was in any other way misleading.

He added: “Doing the best I can, the word accurately conveys the lack of processing, including but not limited to heating, undergone by Odysea’s honey when compared with many others. I decline to reach any conclusion on where the lower limit of processing lies before honey may no longer be described as raw, and it may be that clearer guidance or regulation would assist consumers and producers.”

 

Describing one of Odysea’s raw honey products, the panel at the Great Taste Awards complimented the “subtle pine and fir flavours, the perfect level of sweetness, the hint of saltiness, the sheer sexiness of this honey”.

The managing director of Odysea, Panos Manuelides, responding to the verdict, said: “We are delighted by the tribunal decision. Honey is not a very big business for us financially, our main business is olive oil and olives. “But it is an important part of our business and a fantastic product, produced in a village devastated by floods this year. It is a fantastic decision for them, and we have sold this honey for a long time and produced it with minimal processing … so we are delighted to be able to continue to sell it as it is, which is raw.”

The EU has agreed to change the labelling on honey jars and bottles to make it easier for consumers to know where it comes from — and if it has been overloaded with added sugar. The measure, agreed by EU member states and the European Parliament, is part of a packet of revised “breakfast directives” to improve transparency for honey, jams, marmalades and fruit juices.

Once formally adopted, the agreement on honey will replace the current system where labels indicate only whether the honey comes from the European Union or not, said a statement from the parliament. Instead they will have to specify which country the honey comes from, and the percentage of actual honey from the top four countries of origin.