Honey Labeling Regulations, Information & Tips

One of the most important decisions that a food marketer has to make is what to put on the label of a food product. It needs to appeal to the consumer and stand out from other food packages on the shelf. There are also legal considerations. And let’s face it, when it comes to labeling a honey jar, there’s limited space.

Labels MUST communicate the following:

• The “Common” Name of the Product
  The word “honey” must be visible on the label. The name of a plant or blossom may be used if it is the primary floral source for the honey. Honey must be labeled with its common or usual name on the front of your package. (i.e. “Honey” or “Clover Honey”)
• Net Weight
  The net weight of your product (excluding packaging), both in pounds/ounces and in metric weight (g) must be included in the lower third of your front label panel in easy-to-read type. (i.e. Net Wt. 16 oz. (454 g)) When determining net weight, use the government conversion factor of 1 ounce (oz) = 28.3495 grams or 1 pound (lb.) = 453.592 grams. Round after making the calculation – not before. Use no more than three digits after the decimal point on the package. One may round down the final weight to avoid overstating the contents. When rounding, use typical mathematical rounding rules.
• Ingredients
  Single ingredient products (such as honey) do not have to name that single ingredient when already used in the common or usual name on the front panel. However, if there are ingredients other than honey, you must list them in an ingredient statement. Some exceptions are spices, flavorings and incidental additives (additives which have no functional role and with minimal presence in the finished product) which have special rules.
  
  The type size for ingredient listings must be no less than 1/16th inch as measured by the small letter “o” or by the large letter “O” if all caps are used in the declaration. There are exemptions that allow smaller type sizes for small packages.
• Contact Information
  The label must let consumers know who put the product on the market and how to contact that person. The name and the address of the manufacturer, packer or distributor of a packaged food product are required to appear on the label of the packaged food. This information, sometimes referred to as the “signature line,” must appear on the front label panel or the information panel. If space permits, include full address and telephone number. The information must be in a type size that is at least 1/16th inch tall.

In MOST cases, labels MUST also include:

• Nutritional Labeling
  Nutritional labeling is mandatory for most foods. 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). You may claim exemption by product. For example, if you produce Tupelo honey, Orange Blossom honey and crèmed honey, you would examine each product separately as exempt: Did you sell fewer than 100,000 units of Tupelo honey? If the answer is yes, then your Tupelo honey is exempt from nutritional labeling (provided you do not have more than 100 employees). You will need to apply for this exemption in writing. (However, if you are not an importer, have fewer than 10 full-time employees, and sell fewer than 10,000 total units, you do not have to file a notice.) To apply for the exemption, call the Food and Drug Administration’s Office of Food Labeling at 301-436-2371 or visit http://www.fda.gov/Food/LabelingNutrition/FoodLabelingGuidanceRegulatoryInformation/ SmallBusinessNutritionLabelingExemption/default.htm for the proper forms.
  
  There are several rules that make nutritional labeling a little simpler. For example, while there is a standard detailed nutritional label that gives consumers nutritional information for 13 nutrients, honey usually can qualify for simplified formats. Specially shaped products, such as honey stix, are given additional flexibility. Packages with less than 40 square inches or less of available label space may use a variation called a tabular format (nutrients in columns, no footnotes but special language about 2,000 calorie diet) and may bear the nutritional information on any label panel (not just near the ingredient list). When the tabular format does not work for these small to medium sized packages, a linear (string) format may be used. Minimal information is required for very small packages with less than a 12 inch area available for label space. They may include only a telephone number or an address from which consumers may obtain nutritional information.
  If you use certain descriptors such as “healthy” on your label, there must be a nutritional label on the product – even if the product is otherwise exempt. Whenever a nutrient content claim is made on a label, the claim must be accompanied by a “referral statement” directing the consumer to the panel on which the nutritional fact information is located (i.e. “See side panel for nutritional information”).
• Trans Fat Labeling Guidelines
  According to FDA, the following is required if a full format product label is used (listing all 14 ingredients). “Trans fatty acids should be listed as ‘Trans fat’ or ‘Trans’ on a separate line under the listing of saturated fat on the nutrition label. If a serving contains less than 0.5 grams, the content must be expressed as ‘0 g.’ A declaration of ‘0 g’ of trans fat is not required for products that contain less than 0.5 g of total fat in a serving if no claims are made about fat, fatty acid or cholesterol content. In the absence of these claims, the statement ‘Not a significant source of trans fat’ may be placed at the bottom of the table of nutrient values, in lieu of declaring ‘0 g’ of trans fat.”
  
  However, according to FDA, if a company is using a simplified format label (five core nutrients and other significant ingredients) for a product containing less than 0.5 grams of fat, trans fat does not have to be listed in the nutrition label, nor does the trans fat footnote need to be added, unless certain health claims are made.
• The composition of honey does not include fat, and therefore does not include trans fats.
  You may choose to show Total Fat = 0% on your nutrition facts label so there is no doubt in the consumer’s mind.

• The following are sample nutritional labels for a one-pound jar of honey.
   
  
  If you have any questions regarding nutritional labeling specifications, please refer to 21CFR 101.9 (CFR is the Code of Federal Regulation, 21 refers to the specific title covering food products) or contact the Food and Drug Administration .
• UPC - Universal Product Code (if selling in major retail outlets) Many retailers require a Universal Product Code (UPC) on packaging. A UPC is a scannable number and bar code that uniquely identified a product. In order for your company to include a UPC bar code on your labels, your company must become a member of the Uniform Code Council, Inc. When you become a member, your company will be assigned an identification number licensed for your company’s specific uses (this is the UCC Company Prefix). You will use this number to create your own UPCs. A UPC Bar Code Symbol is a pattern of black bars with white spaces. The complete symbol also includes readable numbers below the symbol. The symbol uniquely identifies each product. The group of numbers is referred to as the Global Trade Item Number (GTIN). The symbol is read by scanners in retail stores that capture the GTIN. When used in conjunction with computer software, retailers can track sales and product orders. The GTIN in a UPC is always 12 digits in length. For more information on obtaining a UPC for your product, contact the Uniform Product Code Council (address is at the bottom of this article).

Other items to CONSIDER on the label:

• Country of Origin Labeling
  If the honey comes from outside the U.S., the country of origin must be conspicuously included on the label with words like “Product of…”   These requirements are enforced by the Customs and Border Patrol (CBP) as authorized by the Tariff Act of 1930 and CBP regulations (19 U.S.C. 1304(a) and 19 CFR Part 134).  This law requires that every imported item must be conspicuously and indelibly marked in English to indicate to the ultimate purchaser its country of origin. Additionally, since 2009 packaged honey bearing any USDA marks or statements (such as U.S. Grade A) must display the country or countries of origin legibly and permanently in close proximity to the USDA mark or statement, such as on the same side(s) or surface(s), and in at least a comparable size to the USDA mark or statement, and are preceded by the words “Product of” or other words of similar meaning. This rule applies to domestic as well as foreign sources of honey.
• USDA Grading Standards
  (see information on honey.com Web site here)
• Questions about Honey, Allergens and Labeling:
  New labeling regulations, under The Food Allergen Labeling and Consumer Protection Act of 2004, will require food labels to identify in plain English if the product contains any of the eight major food allergens – milk, eggs, fish, crustacean shellfish, peanuts, tree nuts, wheat and soybeans. The Act does not include honey, and honey is not listed as an allergen. For more information on honey and allergens, click here.
• Is my honey organic?
  A growing number of consumers look for the word “organic” on a label. “Organic” is not just an adjective, nor is it synonymous with “natural.” The USDA has implemented a set of national standards that foods labeled “organic” must meet, whether produced in the United States or imported from other countries. Before a product can be labeled “organic,” a USDA-approved certifier inspects the farm where the food is grown to make sure the farmer is following all the rules necessary to meet USDA organic standards. The USDA accredits state, private and foreign organizations or persons to become these “certifying agents.” If you wish to produce or handle agricultural products that can be sold, labeled, or represented as “100 percent organic,” “organic” or “made with organic ingredients,” you must be certified by an accredited certifying agent. More information on how to become certified can be found on the National Organic Program Web site at www.ams.usda.gov/AMSv1.0/nop.
  
  Organic food is produced by farmers who emphasize the use of renewable resources and the conservation of soil and water to enhance environmental quality for future generations. Organic food is produced without using most conventional pesticides; fertilizers made with synthetic ingredients or sewage sludge; bioengineering; or ionizing radiation. The USDA Organic seal on a product (shown below) indicates that a product is at least 95 percent organic. Organic labeling standards can be found at http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3004446&acct=nopgeninfo.
• Use of the word “Natural”
  Like organic, the word “natural” on the label can add value to the product in the eyes of many consumers. The Food and Drug Administration has a specific position on natural – nothing artificial or synthetic has been included or added that consumers would not expect to be in honey. However, this is not a formal rule.
• Use of the word “Kosher”
  The Hebrew word “kosher” means proper or fit. Kosher food must meet all the requirements of kosher dietary laws. To produce a kosher product, there are two areas of concern: 1) raw materials and 2) equipment and production. While honey in the hive is intrinsically kosher, it still needs to be certified because of processing. For products to be acceptable as kosher, they have to be certified by a recognized rabbinical authority whose approval is shown through recognized symbols on the label. 
• Graphical Elements
  An image may be added to your label to represent your honey. Images such as bees, bears, flowers, fruit, honey comb orbeekeeper images often appear on honey labels. Make sure that the image you use is simple and meaningful to your consumers.
• Color
  Research shows that color can have a major impact on a new product’s success. According to the Institute of Color Research in Chicago, certain packaging colors reflect certain feelings among consumers. For example, green says decaffeinated and low-fat, yellow says cheap, black can connote gourmet or upscale and blue is most often used with seafood because of its association with water.
• Descriptive Phrases
  Words such as “All Natural” on a honey label are a positive reinforcer of the quality and purity of the product.
• Recipes or Use Tips
  Simple recipes or use tips can help to expand your customer’s use of honey. Hang tags can draw additional attention to your product. The National Honey Board offers hang tags at a reasonable cost. Simply call (800) 553-7162 for more information.
  Several beekeeping supply companies offer preprinted labels for you to customize. Look to supply catalogues for more information.
  Consider hiring a graphic design firm or student to help you design your labels.
  Have people outside the beekeeping industry critique your label. What do they like? What would they change?
  

For more information on labeling:

Food and Drug Administration
Office of Food Labeling
Center for Food Safety and Applied Nutrition
200 C Street NW
Washington, DC 20204
Phone: (888) SAFEFOOD
FDA General Inquiries: (888) 463-6332
Food Safety Hotline: (800) 332-4010
Web site: www.cfsan.fda.gov/label.html

Food Marketing Institute
655 15th Street NW
Washington, DC 20005
Phone: (202) 452-8444
Fax: (202) 429-4519
Web site: www.fmi.org
National Association for the Specialty Food Trade Inc.
120 Wall Street 27th Floor
New York, NY 10005-4001
Tel: (212) 482-6440
Fax: (212) 482-6459
Web site: www.fancyfoodshows.com

Organic Trade Association
PO Box 547
Greenfield, MA 01302
Phone: (413) 774-7511
Fax: (413) 774-6432
Web site: www.ota.com
Small Business Administration
409 Third Street SW
Washington, DC 20416
Phone: (800) 827-5722
Web site: www.sba.gov
or consult your local phone book for an office near you.

GS1-US (formerly Uniform Product Code Council)
7887 Washington Village Drive
Suite 300
Dayton, OH 45459
Phone: (937) 435-3870
Fax: (937) 435-7317
Web site: www.gs1us.org
Email: .(JavaScript must be enabled to view this email address)