FDA Comment Period on New Honey Labels Ends March 6, 2017


By: Michele Colopy, Pollinator Stewardship Council Program Director

The Pollinator Stewardship Council joins with the American Honey Producers Association seeking your support concerning new honey nutrition label language. No matter the number of hives you manage, whether honey production is your livelihood you only sell your honey at farmer’s markets, or just share it with family and friends: we are all beekeepers!

The Food and Drug Administration (FDA) has issued guidance for nutrition labels. Beginning in 2018 FDA will require packaged honey to include on the nutrition label both “Total Sugars” and “Added Sugars”. However, FDA does not distinguish between the two. Labels will need to include the same amount of grams of sugar under each category e.g. “17 grams of Total Sugar” and “17 grams of Added Sugars.”

Products sold by companies qualifying for small business exemptions are one exception to this requirement. Small business exemptions are available for products sold in small volume (fewer than 100,000 units per year) by small companies (fewer than 100 employees). This label change will not affect all beekeepers immediately. Eventually, it will create confusion across the honey industry and mislead the consumer about a natural product.

The National Honey Board has presented research to the FDA showing “added sugars” on labels confuse consumers. The FDA’s new Guidance for Nutrition Labels is open for public comment. Beekeepers need to advise the FDA the sugars in honey occur naturally. Requiring commercial honey producers to adhere to this label guideline will confuse food consumers, and mislead the public about honey. To review the Draft Guidance for Industry Questions and Answers on The Nutrition and Supplement Facts Labels Related to the Compliance Date, Added Sugars go to
https://ahpanet.site-ym.com/resource/resmgr/ahpa_documents/Draft_Guidance_For_Industry-.pdf

The Pollinator Stewardship Council seeks your support to send your comments to FDA today. Let them know pure honey does not contain added sugars. Please submit your comments by March 6, 2017. Comments can be submitted to the docket at Regulations.gov. There is a “5000 character with spaces” limitation in the text box. A sample letter below is available for you to copy the text, select the link to Regulations.gov, click on the Comment Now button, and paste the text (which is less than 5000 characters) into the text box. Feel free to edit the sample comments and type your own, just remember you are limited to 5000 characters including spaces.

When you have completed your comment you will see a screen page with your confirmation number. If you provide your email, Regulations.gov will email you a confirmation. Comments typically appear in the docket within 24-48 hours.

Please submit your comments by March 6, 2017

Thank you for taking the time to submit comments to the FDA at Regulations.gov concerning honey nutrition labels.

Sample comment letter:

Dear FDA:
I join with the Pollinator Stewardship Council, and the American Honey Producers Association, to express my concern of the FDA requirement of packaged honey to include a nutrition label listing both “Total Sugars” and “Added Sugars.” This requirement does not distinguish between the two sugar types. Therefore, labels will need to include the same amount of grams of sugar under each category e.g. “17 grams of Total Sugar” and “17 grams of Added Sugars.” This will confuse food consumers.

If this label is implemented at the commercial beekeeping level it will begin the misinformation to food consumers that sugar is added to honey. Eventually, it will create confusion across the honey industry and mislead the consumer about a natural product.

As stated in 21 US Code §342 (b)(4), “A food shall be deemed to be adulterated… if any substance has been added thereto or mixed or packed therewith so as to…make it appear better or of greater value than it is.”

If consumers are informed through the Nutrition Facts label that honey contains “Added Sugars” then consumers may be led to believe that honey is adulterated, by the regulatory definition, with sugars added to develop or enhance its sweetness.

I realize that honey is added to foods in preparation or manufacturing and in that case it is clearly an added sugar in those foods and would therefore be labeled as “Added Sugars” on the Nutrition Facts label. However, pure honey, itself, does not contain added sugars.

I share the desire for clear, understandable nutrition information to aid consumer choice and promote public health without confusion or misbranding around pure honey.
As a beekeeper I encourage the FDA to consider listing the naturally occurring sugar content of 100% pure honey as a “Total Sugar” and not “Added Sugars.”