Labelling Requirements for Honey Nicki Rose Regulatory Services (Trading Standards)

Relevant Legislation The Honey (England) Regulations 2015 EU 1169/2011 - Food Information to Consumers Regs The Food Information Regulations 2014 The Food (Lot Marking) Regulations 1996 Weights and Measures Act 1985

EU 1169/2011(FIC) Food Information should not be misleading and should be provided in a clear accurate and easy to understand format so that the consumer can make “informed” choices

Food Information Regulations (FIR) Transposition of FIC FIR references FIC directly All in force as of 13 December 2016

FIC - Mandatory Food Information Section 1 – CONTENT & PRESENTATION Article 9 – List of Mandatory Particulars Article 10 – Additional mandatory particulars for specific types or categories of foods Article 11 – Weights and Measures Article 12 – Availability and placement of mandatory food info Article 13 – Presentation of mandatory particulars Article 14 – Distance selling Article 15 – Language requirements Article 16 – Omission of certain mandatory particulars Section 2 – DETAILED PROVISIONS ON MANDATORY PARTICULARS Article 17 – Name of the food Article 18 – List of ingredients Article 19 – Omission of the list of ingredients Article 20 – Omission of constituents of food from the list of ingredients Article 21 – Labelling of allergens Article 22 – QUID Article 23 – Net Quantity Article 24 – Min durability date, use by and date of freezing Article 25 – Storage conditions/conditions of use Article 26 – Country of origin/place of provenance Article 27 – Instructions for use Article 28 – Alcoholic strength Section 3 – NUTRITION DECLARATION Article 29 – Relationship with other legislation Article 30 – Content Article 31 – Calculation Article 32 – Expression per 100g or per 100ml Article 33 – Expression per portion or per consumption unit Article 34 – Presentation Article 35 – Additional forms of expression and presentation

Labelling Information requirements in FIC / FIR Information requirements in the Honey Regs IS IT PRE-PACKED?

FIR – Key Changes Allergen information emphasised in the ingredients list for prepacked foods Allergen information to be made available to consumers for non-prepacked food including catering Minimum font size for mandatory information

FIR – Key Changes Country of origin for fresh, chilled and frozen meat of sheep, pigs, goats and poultry Date of freezing or first freezing - meat / fish Compositional standards for minced meat High caffeine warning and caffeine content

Allergens

FIR – Key Changes Added water to be declared in name of food Meat products Appearance of cut, joint, slice, portion or carcass Fishery products Appearance of cut, joint, slice, portion fillet or whole Nutritional labelling required (most prepacked foods) and presented in a consistent format

Prepacked or Non-Prepacked Pre-packed – a food sold to the consumer in a packed form by a person not responsible for the packing e.g. Sale through a retailer Non Prepacked – all food that is not prepacked Pre-packed for direct sale e.g. A beekeeper sells only from the gate Loose foods Foods for immediate consumption

Why does it matter? Prepacked foods require full labelling Non prepacked foods require minimal labelling

Pre-Packed - General Labelling Requirement Name of the food List of ingredients Durability indication Storage conditions or conditions of use Name and address of either the packer or manufacturer or the seller Place of origin Instructions for use Allergens Nutrition

Name – Honey Regs Honey = the natural sweet substance produced by Apis mellifera bees from the nectar of plants or from the secretions of living parts of plants or excretions of plant-sucking insects on the living parts of plants which the bees collect, transform by combining with specific substances of their own, deposit , dehydrate, store and leave in honeycombs to ripen and mature Definition in legislation = a prescribed name Compositional standards = a reserved description

NAME – Honey Regs “HONEY” Blossom Honey Nectar Honey Honeydew Honey Drained Honey Extracted Honey Pressed Honey FULL NAME needed Filtered Honey Chunk Honey Cut Comb in Honey Comb Honey Bakers Honey

Supplementation of the Name Floral or vegetable origin Regional / topographical / territorial area Specific Quality Criteria e.g pure, fresh, natural Organic Other

Pre-Packed - General Labelling Requirement Name of the food List of ingredients Durability indication Storage conditions or conditions of use Name and address of either the packer or manufacturer or the seller Place of origin Instructions for use Allergens Nutrition

Ingredients Honey is exempt – single ingredient food whose name is that of the ingredient

Pre-Packed - General Labelling Requirement Name of the food List of ingredients Durability indication Storage conditions or conditions of use Name and address of either the packer or manufacturer or the seller Place of origin Instructions for use Allergens Nutrition

Durability / Storage Honey – Best Before Month and Year as minimum “Best Before End” Nov 2019 “Best Before” 20 Nov 2019* Storage – to maintain the quality until the Best Before Date

Pre-Packed - General Labelling Requirement Name of the food List of ingredients Durability indication Storage conditions or conditions of use Name and address of either the packer or manufacturer or the seller Place of origin Instructions for use Allergens Nutrition

Name and Address Name of packer, seller or manufacturer Sufficient to identify the responsible party

Pre-Packed - General Labelling Requirement Name of the food List of ingredients Durability indication Storage conditions or conditions of use Name and address of either the packer or manufacturer or the seller Place of origin Instructions for use Allergens Nutrition

Country of Origin From a single country From multiple countries NO format set Must be COUNTRY Produce of UK Produce of England UK Honey Specific wording “Blend of EU honeys” “Blend of non-EU honeys” “Blend of EU and non-EU honeys”

Pre-Packed - General Labelling Requirement Name of the food List of ingredients Durability indication Storage conditions or conditions of use Name and address of either the packer or manufacturer or the seller Place of origin Instructions for use Allergens Nutrition

Nutrition Exempt – FIC Annex V Unprocessed product that comprise a single ingredient Food directly supplied by the manufacturer of small quantities of products to the final consumer or to LOCAL retail establishments directly supplying the final consumer

Nutrition Back of Pack Back of small pack

Back of Pack (BOP) Labels Required Optional Must be in order Declared values must be average Figures to be given as SOLD Unless statement to say as prepared for consumption Must be provided per 100g or 100ml Can include per portion Must state quantity AND number of portions Serves X Can include Reference Intake per 100g or 100ml or per portion Must state “Reference Intake of an average adult (8400kj/2000kcal)”

Front of Pack (FOP) Labels Traffic Lights No lights

Information Requirements for Pre-Packed foods On packaging OR On label attached to the packaging OR On label visible through the packaging Intelligibility Field of Vision

Pre-Packed for Direct Sale Applies to honey sold at the farm gate and at farmers markets Requires Name of the food Country of Origin Weight

Lot Marking Must be on a label or on the packaging Easily visible Clearly legible – can be handwritten Indelible Preceded by the letter L unless obvious Use the best before date (D/M/Y)as a lot number

Weight Marking Previously – prescribed quantities April 2009 – any amount Must be metric

Weight Marking - Units Unit Symbol Kilogram kg Gram g Pound lb Ounce oz

Weight Marking - Size > 1 kg 6mm > 200g < = 1kg 4mm > 50g < = 200g 3mm <= 50g 2mm e 3mm

Weight – how? Minimum Each jar contains at least the declared weight (net) Average Each jar may contain slightly more or less than the declared weight (net)

Weighing Minimum System Average System Weigh each jar ( don’t forget the lid) Establish the base tare weight OR weigh each jar Fill jars Check a proportion Refill any underweight jars

Average System - Records Time Date Weights found – including tare used Batch indication (lot mark) Any refilling (details as above) KEEP RECORDS FOR A YEAR

OFFENCES Weights and Measures Not using reserved description as required Not labelling correctly Improvement Notices Penalty = £5,000.00

Voluntary Code of Practice “Unsuitable for Children Under 12 months” BHIPA Voluntary Code of Practice “Unsuitable for Children Under 12 months”