EU Legislation - Honey

EU legislation: Honey intended for human consumption

Introduction

Source: CBI Market Information Database • URL: www.cbi.eu • Contact: [email protected] • www.cbi.eu/disclaimer

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If you are an exporter of honey intended for human consumption, you have to make sure your honey complies with all EU requirements in order to be allowed EU market entry. The EU has laid down specific requirements on the definition, composition and labelling for honey and also restrictions on the use of certain veterinary medicines in honey. Moreover, only honey originating in countries and establishments that are permitted by the EU to import honey into the EU may enter the EU (pre-conditions). If you are an exporter of honey first check whether your country and establishment are EU approved. For more information on the EU legislation on honey not intended for human consumption, refer to the related document.

Outline of the legislation

The EU has laid down extensive legislation applying to the EU import of honey intended for human consumption. A summarised explanation of each legislation (presented in

order of importance) is given in the sections below. Please make sure you first check the requirements under A before even considering to export your honey to the EU. The requirements of B and C are only relevant when the requirements under A are met. A. Pre-conditions for the EU import of honey from third countries (click here)* B. Definitions, composition criteria and labelling requirements for honey intended for

human consumption marketed in the EU (click here) C. Maximum residue limits (MRLs) in honey (click here)

How to ensure a potential EU buyer of the quality of your honey? Before an EU buyer places an order, he needs to be sure your honey complies with the EU requirements and his own quality demands. EU buyers will therefore require documentation on chemical analyses of each batch of honey. Most EU honey importers make use of the internationally acknowledged chemical laboratory on honey, Applica, to perform analyses. On the request of EU buyers you have to let well-known inspection/verification organisations operating in your country take samples of each batch which is sent to a laboratory for analyses. After that, all barrels belonging to the same batch are sealed (coded). Only after positive results, your EU buyer will ask you to ship the batch. Upon arrival, the EU buyer will verify if the codes and composition of the honey correspond with the analytic report of the laboratory. Barrels that contain a different composition of honey will be sent back. Normally, costs of analyses are high and are charged to the beekeeper or exporter. For small-scale beekeepers in developing countries it is therefore recommended to work and export together with other beekeepers (e.g. through a cooperative). For more information on chemical laboratory Applica and its locations, refer to the external links section.

A. Pre-conditions Directive 2002/99/EC establishes that each batch of honey intended for human consumption to be imported into the EU must: 1. come from an approved third country; 2. be accompanied by an appropriate animal and public health

certification; and

* Click here for direct access to a summarised explanation of the legislation.

3. enter the EU through an approved EU Border Inspection Post.

1. Approved third country

First of all, your country should appear on the list of third countries authorised to export honey to the EU. If your country is not listed, you cannot export honey to the EU. Presently 35 countries are listed: Argentina, Australia, Brazil, Canada, Chile, China, Croatia, Cuba, El Salvador, Ethiopia, Guatemala, India, Israel, Jamaica, Kyrgyzstan, Mexico, Montenegro, New Caledonia, New Zealand, Nicaragua, Norway, Pitcairn Islands, Russia, San Marino, Serbia, Switzerland, Tanzania, Taiwan, Thailand, Turkey, Uganda, Ukraine, Uruguay, USA and Zambia. Please note that the procedure to appear on the list is the responsibility of the third country and not of you as an individual exporter or an organisation supporting honey exporters. If you are from a non-listed country and interested in exploring EU markets, it is appropriate to contact the national authorities for further activities that involve the EU approval of your country.

2. Animal and public health certificate

Each batch of honey must be accompanied by a health certificate signed and stamped by an authorised veterinary officer of the competent authority of your country. With this certificate, the national authority guarantees that the animal public health requirements equivalent as those in the EU are met. A model health certificate can be found in Appendix VI to Annex VI of Regulation (EC) 1664/2004. For more information on the model health certificate, refer to the external links section.

3. EU Border Inspection Post

Honey intended for human consumption may only be imported through an approved EU Border Inspection Post (BIP) where EU official veterinarians verify and check the honey and the accompanying certificates. Further checks may also be carried out at the final destination. For more information on a list of recognised BIPs, refer to the external links section.

B. Definitions, composition criteria and labelling requirements

Directive 2001/110/EC specifies: 1. the types of honey and their designated product names; 2. composition criteria; and 3. labelling requirements.

1. The types of honey and their designated product names

The Directive recognises several types of honey, which have been designated product names. Only these types of honey may be placed on the EU market as honey intended for human consumption. Other specific EU import requirements apply to honey intended to be used in animal feed, pharmaceutical or cosmetic products. Designated product names According to origin

i) blossom honey or nectar honey: obtained from the nectar of plants ii) honeydew honey: obtained mainly from excretions of plant sucking insects

(Hemiptera) on the living part of plants or secretions of living parts of plants

Honey is the natural sweet substance produced by Apis mellifera bees from the nectar of plants or from secretions of living parts of plants or excretions of plant-sucking insects on the living parts of plants, which the bees collect, transform by combining with specific substances of their own, deposit, dehydrate, store and leave in honeycombs to ripen and mature.


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According to mode of production and/or presentation

i) comb honey: stored by bees in the cells of freshly built broodless combs or thin comb foundation sheets made solely of beeswax and sold in sealed whole combs or sections of such combs

ii) chunk honey or cut comb in honey: contains one or more pieces of comb honey

iii) drained honey: obtained by draining decapped broodless combs iv) extracted honey: obtained by centrifuging decapped broodless combs v) pressed honey: obtained by pressing broodless combs with or without the

application of moderate heat not exceeding 45oC vi) filtered honey: obtained by removing foreign inorganic or organic matter in

such a way as to result in the significant removal of pollen Baker’s honey

Suitable for industrial uses or as an ingredient in other foodstuffs which are then processed. Baker’s honey may have: a foreign taste or odour, or begun to ferment or have fermented, or been overheated

2. Composition criteria

Requirements Sugar content 1) Fructose and glucose content (sum of both):

blossom honey not less than 60g/100g honeydew honey, blends of honeydew honey with blossom

honey not less than 45g/100g

2) Sucrose content: in general not more than 5g/100g false acacia (Robinia pseudoacacia), alfalfa (Medicago sativa),

Menzies Banksia (Banksia menziesii), French honeysuckle (Hedysarum), redgum (Eucalyptus camadulensis), leatherwood (Eucryphia lucida, Eucryphia milliganii), Citrus spp. not more than 10g/100g

lavender (Lavandula spp.), borage (Borago officinalis) not more than 15g/100g

Moisture content in general not more than 20% heather (Calluna) an baker's honey in general not more than 23% baker's honey from heather (Calluna) not more than 25%

Water-insoluble content

in general not more than 0,1g/100g pressed honey not more than 0,5g/100g

Electrical conductivity honey not listed below, and blends of these honeys not more than 0,8 mS/cm

honeydew and chestnut honey and blends of these except with those listed below not more than 0,8 mS/cm

exceptions: strawberry tree (Arbutus unedo), bell heather (Erica), eucalyptus, lime (Tilia spp.), ling heather (Calluna vulgaris), manuka or jelly bush (leptospermum), tea tree (Melaleuca spp.)

Free acid in general not more than 50 milli-equivalents acid per 1000 grams Diastase activity and hydroxymethylfurfural content (HMF) determined after processing and blending

a) Diastase activity (Schade scale): in general, except baker's honey not less than 8 honeys with low natural enzyme content (e.g. citrus honeys)

and an HMF content of not more than 15 mg/kg not less than 3 b) Hydroxymethylfurfural content (HMF):

in general, except baker's honey not more than 40 mg/kg (subject to the provisions of (a), second bullet)

honeys of declared origin from regions with tropical climate and blends of these honeys not more than 80 mg/kg


3. Labelling requirements

In addition to the general labelling requirements for all food products (Directive 2000/13/EC), Directive 2001/110/EC establishes more specific labelling requirements for honey intended for human consumption.

For more information on Directive 2000/13/EC, refer to the related document.

Labelling requirements Product names The product names listed before may be replaced by the simple

product name ‘honey’ except in the case of filtered honey, comb honey, chunk honey or cut comb in honey and baker’s honey.

Baker’s honey In the case of baker’s honey, the words ‘intended for cooking only’ must be indicated on the label close to the product name.

Country of origin The country of origin must appear on the label. If the honey originates in more than one country, the indication can be replaced by one of the following as appropriate:

‘blend of EC honeys’ ‘blend of non-EC honeys’ ‘blend of EC and non-EC honeys’

C. Maximum residue limits (MRLs) in honey

Maximum residue limits regarding honey are laid down for: 1. Veterinary medicinal products; and 2. Pesticides.

1. Veterinary medicinal products

Regulation (EC) 470/2009 in conjunction with the annexes of Regulation (EC) 2377/90 establish MRLs for the use of authorised veterinary drugs applied to honey bees. The use of veterinary drugs containing pharmacological substances not listed in the annexes is prohibited.

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Residues MRLs Amitraz (Tactic, Apivarol) 0.2 mg/kg Chloramphenicol Zero tolerance* Chloroform Zero tolerance Chlorpromazine Zero tolerance Colchicine Zero tolerance Coumaphos (Perizin) 0.1 mg/kg Dapsone Zero tolerance Dimetridazole Zero tolerance Flumethrin (Bayvarol) Not restricted Metronidazole Zero tolerance Nitrofurans (including furazolidone) Zero tolerance Oxalic acid Not restricted Ronidazole Zero tolerance * These residues should not be found in honey.

Authorisation of substances for use in veterinary medicinal products Honey exporters in developing countries marketing honey produced by bees that have been treated with a veterinary medicinal product, have to make sure that they have not used substances not authorised in the EU. Otherwise their honey will be refused to enter the EU market. In the EU it is the European Medicines Agency (EMEA) to which an application for a marketing authorisation must be directed. Ultimately, it is the European Commission that based on EMEA risk assessments will decide to grant, refuse, revoke or suspend a marketing authorisation.


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For more information on the authorisation procedure of EMEA, refer to the external links section. Antibiotics One effective treatment to fight common bee diseases is the use of antibiotics as a prophylactic medicament. However, honey exporters should be aware that only therapeutic medicaments are allowed. Using antibiotics to prevent or cure bee-illnesses is not permitted in the EU and is subject to a so-called “Zero tolerance” policy (see above restrictions). Honey producers may face difficulties to comply with this requirement since it is hard to avoid residues of antibiotics whenever they are used. For example: contamination resulting from other treatments can lead to traces of antibiotics in honey

(e.g. residues of sulphanilamide in honey due to the use of the herbicide Asulam); it is difficult (and very expensive) to ensure that bee wax used for building walls in the hive

does not contain residues which can migrate into the honey. To be able to comply with the EU requirements, it is important to implement good beekeeping practices that have shown to be the most effective measure to avoid bee diseases. Also training for beekeepers and veterinarians in good bee keeping is advised. Moreover, it is recommended to contact bee institutes, European beekeepers associations and other related organisations to get more information on best practices in the sector. For more information on European beekeepers associations, refer to the website of EPBA (European Professional Beekeepers Association) available through the external links section. Links to the national associations and bee institutes of several EU Member States can be accessed through this website.

Pesticides

Regulation (EC) 396/2005 is another legislation that lays down MRLs. This is however related to the use of pesticides used in beekeeping, such as varroacides or wax moth control agents. If no MRL is explicitly mentioned, a default MRL of 0.01 mg/kg applies. Residues MRL (mg/kg) Carbendazim and Benomyl (sum) 1 Thiaphanat-methyl 1 Boscalid 0.5 Thiacloprid 0.2 Gibberelic acid 0.1 DDT, Dinocap, Epoxiconazole, Etofenprox, Fenoxaprop-P, Flonicamid, Flusilazole, Haloxyfop incl., Haloxyfop-R, Meptyldinocap, Methiocarp

0.05

Chlordecone, Metaflumizone, Tetraconazole 0.02 Aldrin and Dieldrin, Chlordane, Chlorthal-dimethyl, Endrin, Fipronil, Heptachlor, Pyroxsulam

0.01

Supply chain management Please note that your company is also part of a supply chain and therefore your EU buyer might set requirements related to his supply chain management. You might have to pass on some requirements to your supplier as well in order to fulfil the requirements of the EU markets. For more information on supply chain management and how it can help you to comply with your EU buyers’ requirements, refer to the related document.

Last updated: August 2009

EU Legislation - Honey

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