From Amina Harris
Director, Honey and Pollination Center
Robert Mondavi Institute, UC Davis

For the past several months the FDA has been reviewing new Nutrition Labeling Guidelines for all foods. The tentative guideline for HONEY is of particular concern. The suggested ruling is very confusing requiring natural packaged honey to list both “Total Sugar” and “Added Sugar” at 17 grams.

The question? How can honey, which is a totally natural product, have sugar added to it?

The Answer: It can’t and it doesn’t.

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. Consumers, beekeepers and packers need to advise the FDA that the sugars in honey occur naturally. Requiring commercial honey producers and packers to adhere to this label guideline will confuse food consumers, and mislead the public about honey.

What you can do. Comment on the FDA Website by March 6th.

1) Go to https://www.regulations.gov/document?D=FDA-2016-D-4414-0002

2) Click on ‘Comment now!’ (upper right of page)

3) Write your own note concerning how confusing this regulation is or paste in our suggestion below.

Suggested entry:

"I join with the Honey and Pollination Center, Robert Mondavi Institute, UC Davis, the Pollinator Stewardship Council, and the American Honey Producers Association, to express concern of the FDA requirement for 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.”
Not only is this confusing for consumers, it is also incorrect. There are no added sugars in pure honey. Honey is a totally 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."

To review the Draft Guidance for Industry Questions and Answers on The Nutrition and Supplement Facts Labels Related to the Compliance Date, Added Sugars go HERE

NOTE: This label change will not affect all beekeepers or small businesses immediately. 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). Eventually, it will create confusion across the honey industry and mislead the consumer about a natural product.

Thanks for your help,

Amina