Learning

In the section we will provide various pieces of information that will hopefully help you in caring for your Bees and tips on how to do things.

Please send us any information you have found to be really good and we can post it here.

Registering as a food business with the local authority

Over the past few months “Beecraft” magazine has published a series of articles about selling honey
and complying with various regulations. The articles were put together by Andrew Beer, a retired
lawyer and current bee keeper. The first article outlined the requirement for those of us producing
honey for sale to register with our local authority. There is an exemption for “smaller” producers,
although no clear definition of what “smaller” means. The article also spoke about the need to
operate a documented food safety system based on the principles of HACCP (Hazard Analysis and
Critical Control Points) of which more later. The second article outlined the labelling requirements
when selling honey.
I have never registered as a food business and I am not sure if anyone else has. I sought guidance
from the Environmental Health department at Huntingdon District Council. The officer I spoke to
assured me that they were quite content for the situation to carry on as it is and that mandatory
registration is not something they are looking for. As part of my conversation I said that I would put
together a simplified HACCP plan for use by our members when they are extracting and potting up
their honey. This is a short form where you can record the date the honey was extracted, give the
batch a number (required) and generally confirm that things have been done in a hygienic manner. It
also has a section where you can confirm that you have correctly labelled your product. This form
should then be filed in case there are any questions about the honey at some future time. The form
and explanatory note will be available at the HBKA website. It will be there to use if you wish.
Further reading for those of you who might enjoy such a thing:
Direct supply of small quantities of primary products; Regulation 853/2004, Article 1(3)(c),(d) and (e).
Basically it may be seen that Article 1(3)(c) exempts “the direct supply, by the producer of small
quantities of primary products to the final consumer or to local retail establishments directly
supplying the final consumer”.
Ref: Andrew Beer, Beecraft magazine & David Parker, Beecraft magazine.
Nick Steiger

If you wish to notify the Local Authority then please click here to view / download the document and guidelines on all you need to know.

Using the term “raw” to describe the contents of a jar of honey

I am writing this advisory note for those of our members who may not have seen the correspondence on this topic in Beecraft magazine. There have been questions raised about using the term “raw” to describe the contents of a jar of honey.

  • The Association of Chief Trading Standards Officers (ACTSO) have endorsed guidance developed by the Food Standards and Labelling Focus Group in October 2017.
  • An opinion given by a local TSO in Yorkshire is worth noting. I have written the quotation in full:

“Food businesses should be advised NOT (my capitals) to use the descriptor “raw” when giving food information about honey. The remedy for this breach of Article 7(1) (c) of the Food Information for Consumers regulations (EC1169/2011) is the service of an improvement notice of the food business operator who applies this term to the product.

A notice can also be served on any food business operator who sells or supplies a product which to their knowledge does not comply with applicable food law, Article 8 (3) {to prevent the sale of product that is known to be non-compliant with applicable food information law}

  • In addition, I have consulted with another TSO and he adds the following, which again I have quoted in full:

“The labelling of honey is controlled by the Honey (England) Regulations 2015, including the equivalent legislation in the devolved areas, as well as the EU Food Information for Consumers Regulations 1169/2011 (FIC) and the Food Information Regulations 2014 (FIR).

The term “raw” is not in the list of specified Honey Products or reserved descriptions in the Honey Regulations 2015 and therefore is a term covered by the requirements of FIC/FIR. The term “raw” has been added to the legal name of the food “honey” by some manufacturers/packers who then charge a premium price for the product. The term implies a minimal amount of processing, especially in relation to the heat applied to the honey. The use of heat is part of the process to allow extraction and packing of the honey and is permitted provided it does not change the characteristics of the honey.

Schedule 1(8) of the Honey (England) Regulations 2015 states that honey cannot be heated in such a way that natural enzymes would have been destroyed or significantly inactivated. No temperature is listed at which this process would start to happen, however a temperature of up to 45ªC is given as a moderate temperature that can be used on “pressed honey”. Honey that has been heat treated in such a way as to change the enzymes has to be called “bakers honey” and can only be used as an ingredient in other foods.

The extraction and packing of honey from the comb is often (but not always) associated with an increased temperature (up to 45ªC) to assist with extraction; this process is permitted and considered to be normal practice in honey production.

If the composition of the honey remains unchanged throughout its processing and packing as required by Schedule 1 of the Honey Regulations 2015, it can be sold as honey. If all honeys, except for “bakers honey” comply with compositional requirements of Schedule 1 of the Regulations, then all honeys could be considered to be “raw”. There is nothing to suggest that this food, to which the term raw has been applied, possesses any special characteristics or has any different quality criteria from any other honey being marketed.

The term “raw” when applied to the name of the food , honey, then becomes misleading contrary to Article 7 (1) of the Regulation (EU) 1169/2011 as it suggests that this food possesses special characteristics, when all of this type of food have the same characteristics, which are laid down in Schedule 1 of the Honey Regulations 2015.

Food businesses/honey producers should be advised not to use the term “raw” when giving food information about honey.

Nick Steiger

(Ref: Beecraft Nov 2018, FSA website “Food.gov.uk”, D.Parker and M.Rowbottom; D.Barnes)

November 2018