October 2022 Skep Talk Handout:
1. The website “Business Companion (Trading standards law explained)” has a comprehensive guide to the “Labelling of Honey”.
At the beginning it states: “This guidance is for England and Wales. Prepacked honey must be labelled with its name, the name and address of the producer / packer, country of origin, storage conditions, a best-before date, lot mark and weight marking. The product may only be called ‘honey’ if it complies with the prescribed compositional standards. This advice applies to all sales of honey to consumers and food businesses.”
The key contents of the rest of the guide are as follows:
- General labelling information
- Name (eg Honey) including “reserved descriptions” of honey
- Country or Countries of Origin
- Durability indication and Storage Conditions
- Lot Marking
- General Provisions
- Weight Marking
- Organic Claims
- Voluntary Labelling
The Key Legislation they have used to compile the guide is:
- Weights and Measures (Packaged Goods) Regulations 2006
- Regulation (EU) No 1169/2011 on the provision of food information to consumers
- Food Information Regulations 2014
- Food Information (Wales) Regulations 2014
- Honey (England) Regulations 2015
- Honey (Wales) Regulations 2015
This link takes you straight to the guide to the labelling of honey:
https://www.businesscompanion.info/en/quick-guides/food-and-drink/labelling-of-honey
2. Buying Plastic Containers for Honey Sales
Must be made of polyethylene terephthalate (PET). However not all PET is suitable for food use, so containers must be marked ‘for food contact’ or with the cup and fork symbol.
3) Article 7 of EU regs: why food information should not be misleading, even unintentionally. (eg ‘raw honey’ and possibly ‘pure’). Some of the key points are in bold.
“Fair information practices
1. Food information shall not be misleading, particularly:
a. as to the characteristics of the food and, in particular, as to its nature, identity, properties, composition, quantity, durability, country of origin or place of provenance, method of manufacture or production;
b. by attributing to the food effects or properties which it does not possess;
c. by suggesting that the food possesses special characteristics when in fact all similar foods possess such characteristics, in particular by specifically emphasising the presence or absence of certain ingredients and/or nutrients;
d. by suggesting, by means of the appearance, the description or pictorial representations, the presence of a particular food or an ingredient, while in reality a component naturally present or an ingredient normally used in that food has been substituted with a different component or a different ingredient.
2. Food information shall be accurate, clear and easy to understand for the consumer.
3. Subject to derogations provided for by [EU-derived domestic law or retained direct EU legislation] applicable to natural mineral waters and foods for particular nutritional uses, food information shall not attribute to any food the property of preventing, treating or curing a human disease, nor refer to such properties.”
4) Re-using Jars: Relevant legislation: Retained Regulations (EC) No. 1935/2004
The extracts below are from the letters page (pg176) of the May 2022 BBKA News magazine. The magazine says that the legislation requires: “The traceability of materials and articles intended to come into contact with food should be ensured at all stages to facilitate control, the recall of defective products, consumer information, and the attribution of responsibility.” This is possible for jars bought in bulk but keeping track of every single returned jar would become a bureaucratic headache.
It goes on to say that: ‘The Food Standards Agency (FSA) says refilling jars is a no-no.’ Paraphrasing the BBKA News: The main objection from Environmental Health officers is that of cross contamination. Milk bottles are re-used BUT the stringent cleaning they are subjected to in a dairy cannot be duplicated in our kitchens – blasting bottles with scalding sodium hydroxide solution!” The item concludes: ‘You can reuse jars for honey GIVEN to family and friends BUT not for selling.’
