Coordinated control plans are an agreed concerted action to address common control issues (Regulation (EC) No 882/2004 on official controls, Article 53). They are useful tools to better understand the extent of non-compliances including of fraudulent practices in a certain sector. They typically prescribe sampling and methods of analysis to be implemented by the participating Member States and run for a limited period. Results are typically presented in a summary report.
The European Parliament's report adopted in 2014 on "The food crisis, fraud in the food chain and the control thereof" identified 10 products, including honey, as being most at risk from fraud.
The objective of the control plan was to assess the prevalence on the market of honeys adulterated with sugars and honeys mislabelled with regard to their botanical source or geographical origin.
All 28 Member States, plus Norway and Switzerland, participated in the coordinated control plan by gathering samples of honey from across the supply chain and submitting them to a series of
- documentary, identity and physical checks to verify geographical origin,
- labelling of botanical source and
- sugar composition.
Samples which passed these tests were then submitted to the Joint Research Council for additional testing as described below.
The sampling methodology for the control plan was set out in Commission Recommendation C(2015)1558. It stipulated that honey should be sampled by the Member States at various points of the production and supply chain, i.e. border inspection posts, producers, processing establishments, distribution and retail. To cover the various geographical origins of honeys, sampling was divided into three parts:
- Part A: 20% of collected samples to come from the same Member State collecting the samples;
- Part B: 40% of collected samples to have a declared origin outside the Member State where the samples are collected, which could be both in the EU or outside, but not including blends;
- Part C: 40% of the collected samples should be either a blend of EU honeys, or a blend of non-EU honeys, or a blend of both EU and non-EU honeys.
The Recommendation established a three-tier approach for the analysis of the honey samples. Tiers 1 and 2 checked sensory characteristics, pollen profiles and sugar analysis and were performed by the Member States. Tier 3 consisted of stable carbon isotope analysis by elemental analysis-isotope ratio mass spectrometry (EA-IRMS) and a combination of EA-IRMS and LC-IRMS (liquid-chromatography coupled to isotope ratio mass spectrometry – these tests were (for the majority of MS) carried out by the JRC.
The JRC found that 14% of the samples they tested contained added sugar. This was further broken down according to geographical origin, point of collection (i.e. producer, packager or retailer) and type of honey as follows:
Geographical origin of the samples (as indicated on the labels):
- 19.3% of samples from a single EU Member State;
- 19.8% of samples of blends of EU honeys;
- 20% of samples from a single non-EU country (20%);
- 10% of samples from blends of non-EU honey;
- 9.4% of samples from blends of EU and non-EU honeys.
Type of honey: 36% honey dew honey and 12% blossom honey.
The samples collected by the Member States at different stages of the supply chain was not done at a uniform rate, therefore it is not possible to accurately state which parts of the supply chain are most prone to fraud. The results do however indicate a higher degree of non-compliance in samples collected at packagers (13.8%), retailers (16.3%) and wholesalers (17.9%).
A validated method providing the same features is not currently available. Nevertheless the method used by the JRC, is the most sophisticated currently available. The combination of EA-IRMS (stable carbon isotope ratio mass spectrometry analysis) and LC-IRMS (liquid chromatography hyphenated to stable carbon isotope ratio mass spectrometry) methods can detect adulteration by the two main types of sugar, C4 (e.g. sugar cane, corn syrup) and C3 (e.g. beet, rice, wheat and agave etc.) thereby covering all forms of adulteration.
As recommended by the JRC, the validation of emerging analytical methods could be dealt with by the International Honey Commission or another Standard Developing Organisation.
The results were never expected to provide a full representation of the EU market for honey but to provide an idea of the extent and nature of fraudulent practices taking place for honey. However, the results indicate that honey of both EU and non-EU origin is being adulterated by sugar.
The sampling plan and the testing protocol have not been designed to produce figures of significance at country level.
The resources required to establish and maintain an official bio bank of honeys and a European centralised honey reference database would be substantial and require long-term and regular input from MS experts and industry stakeholders. Additional discussions with Member States and stakeholders would be needed to evaluate if there is sufficient interest. It must be noted that other means of combating fraud and ensuring EU standards on honey quality are respected should be explored first.
The control of fraudulent practices in the food chain is primarily the responsibility of Member States; however the Commission has provided support via strengthening the legal framework for combating food fraud. The new Official Controls Regulation (due to be adopted this Spring 2017) enables and requires Member States to target their controls on those areas of the food chain they deem to be most at risk of fraud. It also requires that the financial penalties imposed by Member States reflect the economic advantage gained by the operator or a percentage of their turnover. There are also new provisions for the protection of whistle-blowers.
There are no control plans scheduled for individual food products in the immediate future. However a control plan on the e-commerce of food products with medicinal claims and selected unauthorised novel foods is planned later in 2017.
Yes. Council Directive 2001/110/EC lays down the legal definition of honey as well as the major types of honey. The Directive also sets out the composition criteria (for human consumption) and associated labelling requirements. These requirements have to be met before honey can be placed on the market in the EU.
The legal definition of honey can be found in Council Directive 2001/110/EC, Annex 1, point 1: "Honey is the natural sweet substance produced by Apis mellifera bees from the nectar of plants or from secretions of living parts of plants or excretions of plant-sucking insects on the living parts of plant, which the bees collect, transform by combining with specific substances of their own, deposit, dehydrate, store and leave in honeycombs to ripen and mature".
The EU definition is in line with recognised international standards for honey (Codex Standard for Honey).
Natural sugars are one of the main constituents of honey and can be present at varying amounts depending on the botanical source. Council Directive 2001/110/EC relating to honey establishes two requirements for the sugar content:
- the sum of fructose and glucose content shall not be less than 60g/100g for blossom honey, and not less than 45g/100g for honeydew honey and related blends;
- sucrose content shall not exceed 5g/100g. However higher limits have been established for several specific botanical sources such as French honeysuckle, Eucalyptus and lavender.
It is compulsory for the geographical origin for honey to be included on the label. Directive 2001/110/EC provides that the country or countries of origin where the honey has been harvested shall be indicated on the label. However if the honey originates in more than one Member State or third country, that indication may be replaced with one of the following, as appropriate:
- "blend of EU honeys" (e.g. a mix of honey from more than one Member State),
- "blend of non-EU honeys" (e.g. a mix of honey from more than one country outside the EU),
- "blend of EU and non-EU honeys" (e.g. a mix of EU and non EU honey).
The declaration of the botanical source of honey (for example "chestnut honey") is not compulsory, but it may be specified if the product comes wholly or mainly from the indicated source and possesses the organoleptic, physic-chemical and microscopic characteristics of the source. This can be checked using pollen analysis; the general rule is that honey is considered to have been produced mainly from one plant if the pollen of that plant is predominant.
The declaration of the botanical source for honey related products such as baker's honey and filtered honey cannot be provided since these cannot legally bear the name "honey".
In addition to the declaration of the botanical source, other features referring to quality or to production methods may also be provided, on a voluntary basis, on the label of products bearing the name "honey". This information may relate to:
- regional, territorial or topographical origin, if the product comes entirely from the indicated source (for example "Algarve honey");
- specific quality criteria, such as the texture of the honey ("liquid honey", "creamy honey" etc.), to the season it was collected ("spring honey", "summer honey" etc.) or to other features that the operator wants to promote. This information shall be accurate and shall not be ambiguous, confusing or misleading for the consumer. Moreover, any nutrition or health claim shall be done in accordance with Regulation (EC) No 1924/2006 on nutrition and health claims made on foods;
- marks, symbols or terms referring to organic production, to registered quality schemes or to other quality attributes such as "mountain", when the relevant requirements are met.
The general rules on food identification (Directive 2011/91/EU on indications or marks identifying the lot to which a foodstuff belongs) and on the provision of food information to consumers (Regulation (EU) No 1169/2011 on the provision of food information to consumers) equally applies to honey and related products. As non-perishable single ingredient products the list of mandatory indications, in addition to the geographical origin, is limited to:
- the name of the food ("honey", "baker's honey" or "filtered honey");
- the net quantity expressed in units of mass;
- the date of minimum durability, "best before" and any special storage conditions and/or conditions of use;
- if relevant, instructions for use where it would be difficult to make appropriate use of the food in the absence of such instructions;
- the name and the address of the food business operator responsible for the food information (the operator under whose name or business name the honey is marketed, or the importer into the European Union if that operator is not established in the European Union);
- the identification of the lot to which the product belongs.
Honey is the natural substance produced by honeybees. It must not have any ingredient added to it (e.g. sugar, food additives, flavourings etc.) other than honey. Its market price varies significantly according to aspects of quality that are not always visible or measureable without thorough analysis, this provides opportunities for misleading practices intended to unduly increase economic or financial gains.
Honey is adulterated with several substances such as sugar or water, but sugar is the most common adulterant. Inexpensive sugar syrups are used to increase the volume and their effective detection remains a complex issue even with sophisticated methods of analysis.
The declaration of the botanical source or other attributes is also subject to fraudulent practices intended to modify the consumer perception of quality and value of the honey. The declaration of the geographical origin may also be falsified to circumvent bans or tariff rules.
Other compositional or labelling-related fraudulent practices also take place, for example the name "honey" may be illegally given to a product consisting partially or totally of a lower quality product such as "baker's honey".
The feeding of bees with sugar syrups may be necessary in certain periods of the year. This often coincides with the removal of a honey crop, in order to ensure that the bees have sufficient stores to prevent starvation during winter. It may also be emergency feeding when bees are short of stores and are likely to starve.
However, intensive feeding of bees with sugar syrups during the main nectar flow period would conflict with the legal definition of honey. According to this definition, honey must be produced either from the nectar of plants ("blossom honey" or "nectar honey") or from secretions of living parts of plants or excretions of plant-sucking insects on the living parts of plants ("honeydew honey").
Since sugar is the main constituent of honey with a total amount of sugar content that may vary from 45g to almost 90g/100g (depending on the botanical source) it can be difficult to determine the extent of any adulteration by additional sugars.
According to available studies, the capability of the current methods of analysis to detect the presence of exogenous sugars in honey as a consequence of feeding of bees is limited. It depends on the type of sugar used in the sugar syrup, its concentration and the quantity fed to the colony. It is particularly challenging to distinguish between those sugars occurring naturally from those which have been added since the adulterated product can show very similar physical properties to unadulterated honey.