Applicable legislation: EU Provision of Food Information for Consumers Regulation (Regulation (EU) 1169/2011) as enacted in UK Statutory Instruments and acts. The Honey (England) Regulations 2015 (with similar legislation for Northern Ireland, Scotland, Wales. The Food (Lot Marking) Regulations 1996. The information below is based upon my interpretation of the regulations and latest guidance. While I believe it is accurate I accept no responsibility for any loss resulting from any mis-interpretation. THE FOLLOWING MUST APPEAR ON THE PACKAGING - Expand a section to find our more.
Must be a name from this list:
- “baker’s honey” - honey that is suitable for industrial use or as an ingredient in another foodstuff which is then processed;
- “blossom honey” or “nectar honey” - honey obtained from the nectar of plants - can also just be named "honey";
- “chunk honey” or “cut comb in honey” - honey which contain one or more pieces of comb honey;
- “comb honey” - 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;
- “drained honey” - honey obtained by draining de-capped broodless combs - can also just be named "honey";
- “extracted honey” - honey obtained by centrifuging de-capped broodless combs;
- “filtered honey” - honey obtained by removing foreign inorganic or organic matters in such a way as to result in the significant removal of pollen;
- “honeydew honey” - honey obtained mainly from excretions of plant sucking insects (Hemiptera) on the living part of plants or secretions of living parts of plants - can also just be named "honey";
- “pressed honey” - honey obtained by pressing broodless combs with or without the application of moderate heat not exceeding 45° Celsius - can also just be named "honey".
Descriptions must be accurate.
Additional clarifying words may be applied to the name e.g. ‘clear’, ‘natural’, 'pure' provided they do not mislead.
Locality information. "The product name of a relevant honey may be supplemented by information relating to its regional, territorial or topographical origin but no person may trade in a relevant honey for which such supplemental information is provided unless the product comes entirely from the indicated origin." The Honey (England) Regulations 2015 (Part 4, (4)) You can call therefore call it 'HEREFORDSHIRE HONEY', or 'DUMFRIESSHIRE CUT COMB' provided the product comes from these regions.
How local you can be is a question for Trading Standards - but using the name or a village, parish or town would seem to be valid providing that is where the hives are.
Can I use my name or the name of my house or farm e.g. "Sarah's Honey", or "Red House Honey"? My opinion is that this would not be a legal product description but would be ok as a trade name - think Rowse Honey for example.
Forage information. To quote the act "The product name of a relevant honey may be supplemented by information relating to its floral or vegetable origin but no person may trade in a relevant honey for which such supplemental information is provided unless the product comes wholly or mainly from the indicated source and possesses the organoleptic, physico-chemical and microscopic characteristics of the source." You can only specify a floral source, e.g. 'HAWTHORN HONEY', 'WILD FLOWER HONEY' if the honey is derived wholly or mainly from the indicated source. 'HEATHER HONEY' is usually easy to define given that bees are taken to the heather and there is little to no other forage around.
Images - Although reference to the use of pictorial images is now no longer specifically covered within the new regulations, this is still covered by the FLR and Trades Descriptions Act which would make it an offence, for example, to use identifiable flowers on labels if honey is not derived wholly or mainly from that flower.
Honey quantity is given in weight. Honey may be sold in any weight but this must be specified in metric form and be the net weight. An imperial weight is optional, this must appear after the metric weight. For example "340 g 12 oz".
A 'Best Before' or 'Best Before End' date must be shown. This is the date after which the product is not at its best quality taste or texture - it is not a food safely issue. What is 'best' and when is honey not at its 'best'? If your customer has bought a jar of runny honey they may feel it is not at its best when it granulates as most honeys do. Two years is the usual period.
'Durability indication may be in the form best before or best before end for foods with a life of more than 3 months, Month and Year or Year alone may be used.' Examples “Best before yyyy” - or 'BBE yyyy', or if you want a month included 'BB Mmm yyyy'.
The date itself does not have to appear on the main label but information about where to find it must appear - e.g. "For Best Before See lid" with a small label showing the date in the indicated position.
This is the person/organisation taking responsibility for the product. For hobbyist and bee farmer beekeepers this is usually the beekeeper. But a beekeeper could supply honey to an organisation to market and take responsibility under their own name.
It must be a physical address - P.O. Box number, or email address are not acceptable.
Applies to food prepackaged for sale (e.g. a jar of honey or pack of cut comb) “lot” means a batch of sales units of food produced, manufactured or packaged under similar conditions.
In the event of a problem with a jar of honey - broken glass being an extreme example - all products in the same lot identification would have to be recalled. It makes sense to keep quantities in a lot as small as possible. My recommendation is to regard all honey bottled from the same source at the same time as a batch.
The code may be identified with the prefix "L" or "Lot" or "Batch".
You are highly unlikely to know in advance how much honey you will get in a year. You may also keep a glut of honey in bulk from year to year to offset what may be a poor harvest the following year. Ordering labels as and when you need them would be expensive because of having to pay multiple delivery costs. My recommendation is that you ask for uniquely numbered labels with three or four digits - for example 200 labels numbered from L001 to L200 - use the labels in order and keep a record of the start and end numbers in each batch.
This information is in addition to the food business operator's address. It is perfectly legal for a beekeeper to supplement their own supply by buying in foreign honey and selling it as the 'food business operator. provided they make no false claims about the origin of the honey.
There is no legal specification for the format of the wording so 'Harvested in England', or 'Produce of Wales', or Product of Scotland', or 'Irish Honey' are some options. 'Devon Honey' by itself or any other regional description is not acceptable, however 'Harvested in Devon, England' would be ok. As would including the country in the product description, for example 'Pure English Honey'. Including the country after the food business operator's address is not acceptable.
I will make sure that your labels are compliant but you may be interested in the following additional considerations.
There is a legal requirement for the height of printing of the metric quantity (2 mm not exceeding 50g; 3mm over 50g but not over 200 g; 4 mm over 200 g but not over 1 kg) and 6 mm for 1 kg or more). I'll ensure your labels comply and let you know if they don't.
All other text
Must be a minimum 'x' height (the height a lower case 'x' would be in the font being used) of 1.2 mm.
The Product name and Quantity information must be visible together - this would mean being on a single label. The other requirements can appear on the same label or on a second label elsewhere on the package.
While a single label is the lowest cost option splitting the information over two labels can provide a more attractive label for your customers.
An image must not mislead - for example a picture of clover being used when the predominant nectar used for the honey is not clover.
The composition of honey can be assessed by pollen analysis, if in doubt choose another image.
It is your responsibility as my customer to ensure that any images supplied for a label are copyright free or you own the copyright or have permission to use the image for commercial use.