Due to obscure historic reasons, honey enters under the competence of the General Board III, (Direction génerale III, E.1.Rond Point Schumann, 11 Bureau 3. 30. 1040 BRUXELLES, BELGIQUE)

Normally, the GB VI (Direction Génerale de l’Agriculture) administers the non-transformed agricultural product (which is the case for honey).

It is therefore logical that the European deputies, Consumers, National administrations and the Beekeepers have asked on numerous occasions, that the dossier come back to the GB VI, which it should have never left.

To this day, nobody, to our knowledge, has obtained a response.

This debate is not neutral and influences all the work to be done on the "simplification" of the Directive.

In effect, either honey is an agricultural product( as is a pear, a lettuce or wheat), and in this case it is for the GB VI to govern, or it is an Industrial product( like the syrups of maize, cane sugar and rice), where the GB III are legitimate in their role. In this case, one might as well conclude that : neither Bees nor Beekeepers are much use … Honey, who cares???

For Honey, the logic of the BG III is the same.

To the foreseen double question:

• Honey, is it or is it not honey, that is to say the product collected by bees from plants( therefore possessing thus their characteristics)?
• Is it a 100% natural food from which nothing whatever should be added or taken away?

Nobody has, to this day, dared to respond negatively.

The discussions on the "simplification" of the directive are therefore limited to a technical debate on three major points and other details(details that are also important…)

The 3 major points are resumed from the letter sent on the 19th March last by the F.E.H.P.D.. to the General Secretariat of the Council of the European Community. (F.E.H.P.D.. Federation of European Honey Packers and Distributors, that is to say the union for all the conditioners, French included).

We are in total disagreement with the position taken by F.E.H.P.D. on each of these 3 points, for the reasons developed below.

1. THE MAXIMUM LEGAL LIMIT OF HMF FOR THE CONSUMER

( fixed at the moment at 40mg/kg).

Hydroxymethylfurfural (HMF) is a sugar from the degradation of Fructose naturally present in numerous products and is totally harmless. It exists at trace levels in all honeys at the moment of harvest.

• 1 to 3 mg/kg in most cases
• 5 to 10 mg/kg for 3 or 4 particular monofloral honeys ( known to the laboratories).

The level increases with heating and ageing, and therefore acts as an excellent "witness of freshness"

Except for the 3 or 4 particular monoflorals, it is considered that a level of HMF

• below 10 mg/kg corresponds to a top quality honey
• between 10 and 20 mg/kg, it is a very good honey
• up to 30 mg/kg, the honey is correct.

Consequentially, the limit of 40 mg/kg authorised by the actual directive, is totally reasonable and possibly, with a few exceptions, could be slightly reduced without causing a problem for the conditioners.

However the F.E.H.P.D demand to push this limit to 60 or 80 mg/kg. That is totally unacceptable. At this level, all the independent specialists will confirm, everything passes: old honey badly conserved, overheated, stocked for 6 months in full sunshine in the worst of conditions, etc…

It needs to be known that:

1. In Europe, the Official Control Services,(DSV or DGCCRF) do not remove products from shop shelves unless they are toxic or dangerous.
2. Each time there is an enquiry on the quality of honey in commerce, there one finds a few pots (see previous tables) that exceed the 40 mg/kg authorised (Removal of the merchandise never takes place. The same if there is a procedure, the non-conforming merchandise stays on the shelf until there is a judgement. Thus there is ample time to sell out; this explains what one so often finds on the "special offers" shelf.

The argument developed by the F.E.H.P.D. is deceitful enough. It pretends, of course without the precision of the above context that the disposition is too constraining, even though, once again it is not a question of price. (Effectively, in the wholesale market, each lot is controlled. With pollen analysis, the humidity and HMF are the two principal criteria tested. The higher the HMF or humidity levels the cheaper the honey, since, normally it is destined for industry under the designation of industrial or baker’s honey. Therefore, each time honey is found to be over the HMF limit? It is not because the legal limit is too low but uniquely because, in the pure tradition of elementary rules of disloyal competition, the underhand conditioner has supplied at low price merchandise of second or third quality).

The HMF criteria are a "pillar" in the control of honey quality, and, if it needs to be modified, it needs to be decreased not increased.

This said, it would be good to get a response to the question: "In case of non-conformity, is it utopian to hope for a strict rule, guaranteeing the immediate removal for resale to industry, of this type of merchandise? (As the whole concerned lot carries the same number)"

Honey is an archetypal "local product".

Each honey possesses of course characteristics of the plants from which it was gathered. But, as for wine, according to the soil, the same plants may give the honey a different taste and colour from one region to another. As a result, three items of information should appear on the label:

As for our product: Honey (this at least!)

Thus, the consumer may distinguish it from a maple syrup, a preserve or any other product.

Each plant gives a different fruit. Honey is a by-product of a plant. Each plant secretes nectar from which a particular honey results: taste, consistence, colour, smell, therapeutic properties, etc…

For polyfloral honeys, the vocabulary is not lacking, enabling a clear indication for a multifloral origin (Blossom, Mixed Flower, etc…).

We remain with the same logic as found in the two previous points. Today’s consumer is a free and responsible individual who is master of his or her choice. Amongst others, It wishes to know the source of all that it consumes, as well as price per kilo, the weight and the date limit for consumption.

This is true even for basic foodstuffs.

So, for honey, the fact that it comes from such and such place is not without consequence : it is not the same product. We are therefore once again dealing with a fundamental question of principle .

The F.E.H.P.D. pretend that this too complicated to organise. Taking into account the fluctuations in price and harvest throughout the world, the conditioner continually change their suppliers(this is the argument put forward). They have no way of predicting the origin of the honey that is to go into pots. ?!?!? In place of an obligatory indication of geographical origin, the F.E.H.P.D. suggests a coverall statement "Blend from more than one country".

This argument is particularly fallacious : As in effect, already the pots carry the lot number and B.B.D.* which changes from day to day. This has not posed the slightest technical problem.

*Best Before Date.

The obligation to indicate the geographical origin is not a coercive or vexing measure imposed on the conditioners. Even so, the "hard" refusal of the latter to accept this elementary disposition of transparency and the respect for the consumer is particularly equivocal.

The technical aspects of Germany area good example to study succinctly, as with over 80,000 tonnes/year, it is the largest honey importer in Europe.

If one calculates the statistical average for imports over several years, they show:

To summarise, 90% of the honeys are imported

• from Asia (more than 30%)
• from South America (more than 50%)
• from the Danube Valley (more than 10%)

If the consumer wishes to know the origin of the product, it is not such a surrealistic particularity.

The final choice to the degree of precision rests with the conditioner who may label, according to the case:

if there are several regions concerned,

if there are several regions concerned,

Yucatan Honey, see from Chiapas or Mexican Honey

if there are several regions concerned,

If on the other hand, the conditioner is active in a less segmented sector, it may very well, if supplied from one or several countries of the continent, label as :

The origin of the honey is correct and the consumer correctly informed.

One may also envisage the case where a conditioner wishes to blend certain honeys from Asia and from South America. Nothing is simpler. It is sufficient to label:

There again, we are in a logic that poses no technical problems, strictly conforming to the obligation to indicate the origin and is perfectly respectful to the consumer.

This reasoning may be applied to any country or continent.

One remarks in passing that, under pressure from the integralists for "a free market" the French law n°76/717(even though the relevant passage is nothing more than a limpid draft), allows for the honeys of the European Union not to indicate the geographical origin.

This is abnormal.

Whatever the country, the consumer wants to know the origin of that which he or she is buying, region, island, country, peninsula, or group of countries. It’s a right, and would not halt any commerce.

In that which concerns us, we are unable to be anything than clashing head on with this scandalous claim(demand)of the F.E.H.P.D. who have in fact, no other motivation than to be able, in maintaining a certain haziness regarding labelling, to trick the less attentive consumer. It is in the same logic that the mention "Honey from different origins" is used. This is done so that the client understands "Blossom Honey".

For the moment , the administration against fraud is in accord with this situation. It would be desirable if the consumer associations took an interest in this problem as well.

3. ULTRA-FILTRATION

We have saved until the end the most revolting : ultra-filtration.

Filtration: At extraction,(that is to say in the honey house of the Beekeeper) the honey passes through a filter(800 microns to 1mm.mesh) made from nylon or stainless steel: The craftsman’s equivalent to the household sieve.

At the conditioner’s, steel tubular filters(400 to 500 microns) are used.

This is normal, legal and respectful for the product since the size of the pollen grains varies according to plant species, on average between 10 and 100 microns. It also happens that, either at the Beekeepers, or at the conditioners, honey settles for several hours before being conditioned to allow for air bubbles to rise to the surface.

Ultra-filtration, forbidden up to the present moment for honey, requires, after heating to a high temperature, the use of:

• Either ceramic filters,
• "Diatomic" filters,
• or any other technique of filtering that descends to a level of at least 50 microns.

Point n° 3 in the F.E.H.P.D. letter

• Demands the legalisation of filtering down to 100/150 microns.
• Explains that above 70 microns, there is a disagreeable sensation of "sand" on the tongue(which is false),
• And recognising that the grains of pollen are "trapped by insect and different minerals"(not only is the Chinese honey not filtered, but as well it contains earth, sand, and different minerals. The conditioners themselves admit that ,legally, they haven’t the right to sell this product other than under the name of "industrial honey" or "baker’s honey". They are profiting, on the way, "to arrange" reality a little bit in affirming that the pollen grains measure from 10 to 30 microns. Reality is less simplistic Most pollen grains are situated between10 and 100 microns. Even so, at the extremes, one finds pollen at 2 or 3 microns for the smallest, up to 200 or 300 microns for the largest.)

Briefly, in a manner particularly perverse and underhand, what is being asked for, is no more and no less than the legalisation of ultra-filtration. One is able to note elsewhere (table 19 page 24) that the two honeys purchased in England are already ultra-filtered.

If the "simplification" of the directive gives rise to such a ignominy, there will be nothing left to simplify. In a very short period of time, the inescapable disappearance of pure and true honey to the profit of industrial syrups will take place.

The pollen spectrum of a honey, is its "identity card". With ultra-filtration, as all or most of the pollen would be eliminated, the representative native pollen spectrum will be no longer be interpretable. Effectively, the same if nectar or honeydew are the origin of honey, one finds grains of parasitic pollen that do not modify taste or composition. They come from flowers visited by the bees as well as arriving on the wind. The mellissopalynological examination, will therefore always be the first analysis to be done, to verify its authenticity, whether origin floral or geographical as well as its state of freshness( fermentation yeast’s) and conservation. All the other analysis’s can only follow or flow from this one, and as well, it is undertaken at a reasonable charge.

With ultra-filtration all frauds become possible. One can even imagine the following operation: extract all the pollen from any monofloral honey, and add others from another different source, thereby "making" what ever you want. Of course there is not a sufficiently lucrative market at the present to support such a "heavy" manipulation, but, with ultra-filtration integrated into the "simplification" of the directive, this would become legal. This said, there is nothing to worry about: it will be much simpler to make honey from industrial syrups.

It is not possible to conclude the chapter on the "simplification" of the directive without evoking the manner in which the negotiations of the "working group" take place. For France, around the table, there are only administrators. We asked that for each meeting the two specialised technicians from the C.N.E.V.A. and D.G.C.C.R.F. laboratories may be present. It is really frustrating to note that whilst dealing with such "touchy" subjects, the best technicians are held from the debate.

Note: in the dossier on the AOC Fir Honey of the Vosges, the S.M.P.F. had to put down a appeal to the State Council. This procedure taking place concerns a technical detail. So promulgated, this AOC is "dead before it hatches. This the reason for which we are supported by the experts from I.N.R.A.,C.N.E.V.A. and the D.G.C.C.R.F. A mistake again in the honey sector is all that is required for the administration to simply pass the technical dossiers to their own technicians who are:

1. competent
2. independent
3. and paid for that

In most of the industrial sectors, the businesses generally have in place methods to combat it.

However, it is not evident that even with this support that it will be sufficient to rapidly solve the problem.

Possibly there exists a radical solution, to moralise and clean up the honey market: obtain the mobilisation and active participation of the Supermarkets. (1)

Things are simple: in France, the regulation is the Honey Law n° 76/717 dated 22/7/1976. The Supermarkets could very easily, collectively, impose on all their suppliers precise conditions imposing:

1. The total and scrupulous respect of this law, and in particular articles 1,2,5 and 6,

2. The engagement on the part of the conditioners to no longer incorporate Chinese honey, neither pure or from a blend, into pots to be sold as table honey.(Even under the denomination of "industrial honey" or "bakers honey", for industrial preparations, this product is not conform.)

3. The obligation to furnish for each lot coming from a high risk country, an analysis of d 13C according to the AOAC method (Hungary in particular, but also other origins in function of the blind controls which the concerned laboratories will not be lacking in the weeks to come).

(1) This has no similarity to Utopia. In effect, the claimed role of the supermarket, is to supply the consumer at the lowest price.