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Labelling our honey in NL for provincial sales

    At the end of the day, what we put on our labels is about much more than federal government regulations the main purpose of which is to protect consumers.  It’s also about protecting the integrity and reputation of honey and other apicultural products, and creating a level playing field for all beekeepers where ethical business practices are the norm.

     It’s best to label your honey “wildflower,”  unless you can guarantee to your honey customers that your product is monofloral – fireweed, goldenrod, white clover, etc. It takes certified laboratory analysis to provide this guarantee.

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A version of this text first appeared in The Buzz from Here, Spring 2019, http://nlbeekeeping.ca/data/documents/NLBKA-newsletter-spring-2019final.pdf

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 The following is the information we should put on our honey labels for provincial sales only ― in local stores, farmers’ markets, restaurants, tourist kiosks, etc. (no out-of-province sales).   Note that federal legislation and regulations in Canada do not mention honey specifically with respect to claims about the floral source or organic quality of the product, when sold within Newfoundland and Labrador (NL).  However, regulations related to false and misleading claims apply to our honey no matter where it is sold. 

  • The common name of the product ― honey!  You can use your brand name if it mentions honey.
  • Contact address and phone number (company or personal name; the address must be complete enough for someone to be able to reach you by mail).
  • Net quantity of the contents by weight or volume (most beekeepers use weight in grams)
  • The label must be bilingual if you are selling your honey outside the “local government unit”  where it was produced, as well as outside the units immediately adjacent to it. E.g., your honey label must be bilingual if it's produced in Central Newfoundland but you're retailing in St. John’s, but not if your sales are restricted to stores in your Town or Local Service District where it’s produced or a farmer’s market in a town which is in the adjacent local government unit.[1]
  • A nutritional facts table is required if someone else is selling your honey (this is not required if you are selling directly to the buyer, e.g., from a farmer’s market table or road-side stand).[2]

       Everything else you put on the label is discretionary if you are selling only within NL.  For example, the descriptions of the honey as “raw, unfiltered, unpasteurized, wildflower honey” are discretionary.[3]  In addition, a best before date is not required, and if our sales are confined to NL, we’re not required to grade or label our honey according to the federal classification system based on moisture content and colour (e.g., Canada No. 1 <17.8”, Canada No. 2 <18.6%, and Canada No. 3 <20%).[4] However, it’s good to ensure that we aren’t selling green honey, that is, with moisture content >20%, because it’s likely to ferment. You need a properly calibrated refractometer in order to test your honey for moisture content.

   It may be tempting to claim our honey is organic because there are no specific NL laws regarding organic labelling, and specific federal regulations regarding organics do not apply if honey sales are within provincial boundaries (except the organic logo). However, we risk violating subsection 6(1) of the Safe Food for Canadians Act (SFCA) that prohibits false, misleading or deceptive claims.  Note that many of our honey bee forage areas overlap with transmission line corridors, agricultural, residential, and other lands where insecticides and herbicides are used frequently.  Claiming that our honey is organic if our bees forage in pesticide exposed areas is a bit of a stretch!

     Whether we can claim that our honey is a varietal (monofloral) type such as “fireweed,” “goldenrod,” or “white clover” is somewhat more complicated.  Federal regulations prohibit the misrepresentation of the honey content.  However, there are no regulations in Canada specifying the manner in which monofloral content is to be proven to consumers.  Moreover, with the exception perhaps of the new NMR lab operated by Worker Bee Honey Company in Chilliwack, B.C., there are no laboratories in Canada where honey can be tested for floral source.[5] We can send honey to a European lab for testing, but they must be capable of analyzing honey for NL pollens.[6]

    Were we in Europe, the testing would have to show a certain minimum percentage of pollen in our honey for us to claim it as monofloral, and this percentage would vary depending on the floral species.  Table 1 provides examples of minimum pollen percentages for monofloral honeys in five European countries, according to their national regulations.    Note that three countries listed here give 45% as the threshold for “general monofloral” honeys. Louveaux, et al. (1978: 143-144) state that in general, “honey has been produced mainly from one plant (unifloral honey) if the pollen of that plant is predominant,” where “predominant pollen” means that >45% of the pollen grains counted in a sample were of the monofloral species.

Table 1. Minimum percentage of pollen required for the characterization of monofloral honeys in five European countries according to their national legislation: or provisions, decisions or guidelines (from Thrasyvoulou, et al. 2018: 90).

 

 

    Such rigour is apparently not required in Canada.  What some beekeepers do elsewhere in the country is to place colonies in monofloral landscapes (e.g., a clearcut area covered with fireweed flowers) for several weeks, and take the honey off prior to moving colonies to different floral habitat. Commercial beekeepers who provide pollination services to blueberry growers operate on the same basis; blueberry nectar yields a blueberry varietal honey.  Alternatively, beekeepers may select honey made during a honey flow when a particular species is the dominant floral source (e.g., goldenrod). 

    There may indeed be regions in NL with large monofloral landscapes (e.g., forest cutting blocks in the Cormack area) that can pretty much guarantee a monofloral honey which can be labeled as such without misrepresenting the content. However, in most parts of the province, our floral species composition is too diverse to provide such a guarantee.  This is why it’s best to label our honey “wildflower.”  Unless you can guarantee to your honey customers that your product is monofloral – fireweed, goldenrod, white clover, etc. – then label it “wildflower.” It takes certified laboratory analysis to provide this guarantee.

 

Federal honey labelling regulations in Canada

                 The labelling requirements for our honey are set by the federal government; our provincial government has no such requirements unlike Ontario which has a regulation 119/11, Produce, Honey and Maple Products, under their Food Safety and Quality Act, 2001.[7]  In general, labelling requirements depend on whether the honey is sold only within the province or sold outside the province, nationally or internationally.  Relevant federal legislation and regulations include the Food and Drugs Act (FDA), the Food and Drug Regulations (FDR), the Safe Food for Canadians Act (SFCA) and the Safe Food for Canadians Regulations (SFCR). “Among other purposes, these acts and regulations are intended to enable consumers to make informed food choices based on information that is truthful and not misleading.”[8]  Here’s key points relevant to how we should label our honey.

    According to the CFIA, “Most prepackaged foods sold in Canada require that a label be applied or attached to it….[and only] once a label is required do other labelling requirements apply, such as a list of ingredients or common name.”[9]  Prepackaged foods are those packaged in a container for sale to other people.  Under the SFCR all food sold in Canada, even within province, must comply with the traceability and labelling requirements. 

    The core labelling elements can be found under the main labelling page here - http://inspection.gc.ca/food/general-food-requirements-and-guidance/labelling/for-industry/eng/1383607266489/1383607344939   All food sold in Canada must have these elements if sold across provincial borders. They include bilingual labelling, common name, date markings/storage instructions, name and principle place of business, list of ingredients, net quantity, and a nutritional facts table.[10] 

    No matter where it’s sold, according to subsection 6(1) of the SFCA,

            [i]t is prohibited for a person to manufacture, prepare, package, label, sell, import or advertise a food commodity in a             manner that is false, misleading or deceptive or is likely to create an erroneous impression regarding its character,             quality, value, quantity, composition, merit, safety or origin or the method of its manufacture or preparation.

 Subsection 199(1) of the SFCR identifies some, but not all, of the ways that labels can mislead with respect to net quantity and composition. "False, misleading or deceptive” labelling includes, but is not limited to:

  • “any representation in which expressions, words, figures, depictions or symbols are used that may reasonably be considered to qualify the declared net quantity or that is likely to deceive a consumer with respect to the net quantity of a consumer prepackaged food; or
  • any expression, word, figure, depiction or symbol that may reasonably be considered to imply that a consumer prepackaged food contains any matter that it does not in fact contain or that it does not contain any matter that it does in fact contain.” [11]

    Regarding organic honey, the SFCR define an organic product as “a food commodity that has been certified as organic under subsection 345(1) or certified as organic by an entity accredited by a foreign state that is referred to in subparagraph 357(1)(a)(ii). (produit biologique).”[12] Part 13 of the SFCR is “designed to protect consumers against false and misleading organic claims and to govern the use of the organic logo. All aspects of food labels and advertising contribute to the overall impression a food product makes. Therefore, foods making organic claims must also comply with the General Principles for Labelling and Advertising.”[13]

     However, Part 13 of the SFCR does not apply to products sold only within province “unless the product bears the Canada Organic Logo. At the federal level, these are subject to the Food and Drugs Act and the Safe Food for Canadians Act, which prohibit false or misleading claims in labelling and advertising. Producers of intraprovincially traded products bearing organic claims are expected to be able to demonstrate that the product is organic.”[14]

    Newfoundland and Labrador (NL) does not currently have an organic certification system in place unlike Nova Scotia, New Brunswick, Quebec, Manitoba and British Columbia.

 References

 Thrasyvoulou, et al. 2018. “Leglislation of honey criteria and standards.” Journal of Apicultural Research. 57(1): 88-96.

 Endnotes

[2] See nutrition label options, http://honeycouncil.ca/new-nutritional-facts-tables-nft-now-available/

[3] In this context, “unfiltered” means that the honey has not been filtered with anything finer than the stainless steel mesh sieves we use to catch bits of bee anatomy, wax, and other debris.

[4] For a complete description of this classification system, see http://www.inspection.gc.ca/about-the-cfia/acts-and-regulations/list-of-acts-and-regulations/documents-incorporated-by-reference/canadian-grade-compendium-volume-6/eng/1523388139064/1523388171017#a3

[5] Very recently, the Centre de recherches en sciences animals de Deschambault (CRSAD) in Quebec offered a melissopalynological service, operated by Melissa Girard.  The CRSAD service does not provide the full range of honey analysis services provided by European labs, and the quality of their work is unknown. Re. the Worker Bee Honey Company NMR facility, see https://www.vicnews.com/news/watch-cutting-edge-b-c-lab-opens-to-detect-fake-honey/ 

[6] Trevor Weatherhead, of the Australian Honey Bee Industry Council, wrote of problems with European honey testing labs regarding the analysis of monofloral Eucalpytus honeys in a post to the BEE-L LISTSERV on 30 Jan. 2019. He questioned the validity of European tests of Australian honeys because they are reliant on European and Brazilian pollen databases not Australian ones.

[7] Among other requirements, section VI.25 of these regulations states, “No person shall include any false or misleading information on any label, package, container or master container of produce, honey or maple product, or in any advertisement for the produce, honey or maple product or retail display sign for produce…”