The Ohio State Beekeepers Association is asking its members to take action today!
The American Honey Producers Association seeks your support concerning new honey nutrition label language. No matter the number of hives you manage, whether you sell your honey at farmer’s markets, or 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.” Keep in mind, 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 that is in actuality a healthier sweetener to add to food than processed white or brown sugar.
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To review the Draft Guidance for Industry Questions and Answers on The Nutrition and Supplement Facts Labels Related to the Compliance Date, Added Sugars go to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
Tim Arheit, President of OSBA
The Ohio State Beekeepers Association is asking its members to send your comments to FDA today and let them know pure honey does not contain added sugars.
- Copy the text of the comment letter below
- Select this link to submit your comment https://www.regulations.gov/document?D=FDA-2016-D-4414-0002 (Regulations.gov has been S-L-O-W to load in your browser, please be patient!)
- Paste the text into the comment box
- Enter the requested information (you can submit a comment “anonymously”)
- Click on the CONTINUE button. Follow the prompts on the screen
- Comments appear in the docket within 24-48 hours.
COMMENT LETTER you can copy and paste into the online docket
As a member of the Ohio State Beekeepers Association, I support the concerns of the American Honey Producers Association over 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.
As a small scale beekeeper, this label language will not affect me directly in my sales at farmer’s markets, and to individual customers. However, 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 that is in actuality a healthier sweetener to add to food than processed white or brown sugar.
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.
We 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.
We share the desire for clear, understandable nutrition information to aid consumer choice.
Our desire, as is the FDA’s, is to inform consumer food choices to 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.”