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Food Safety

EU coordinated action “From the Hives” (Honey 2021-2022)

About the EU Action

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In 2021, the European Commission organised the EU coordinated action called “From the Hives” to assess the prevalence on the market of honey adulterated with sugars.

The coordinated action included three stages:

  • 1. Collection of honey samples at EU borders and their analysis by the Commission Joint Research Centre (JRC), in Geel - Belgium.

  • 2. Recollection by Member States and the Food Fraud team in DG SANTE of the place of destination of the controlled consignments and information on suspected operators (past import operations registered within the TRACES system, non-compliances and food fraud suspicions already registered within the Alert and Cooperation Network).

  • 3. Investigations by Member States and EFTA States authorities with investigative support from the European Anti-Fraud Office (OLAF) at the place of import, processing, blending, and packing into the EU.

EU coordinated action - timeline

Findings of the EU Action

The coordinated action confirmed the initial assumption that a significant part of honey imported into the EU is suspicious of not complying with the provisions of the “Honey Directive” (46% based on 320 samples).

This rate was considerably higher than the one obtained in 2015-17 (14%). The highest absolute number of suspicious consignments originated from China (74%), although honey originating from Turkey had the highest relative proportion of suspicious samples (93%). Honey imported from the United Kingdom had an even higher suspicion rate (100%), likely the result of honey produced in other countries and further blended in the UK before its re-export to the EU.

More than half (57%) of the operators had exported honey consignments suspicious of being adulterated with extraneous sugars and more than 60% (66), of the operators imported at least one suspicious consignment.

To date, 44 EU operators have been investigated and seven have been sanctioned. Forensic investigations undertaken by Member States and OLAF based on on-site inspection, sampling and close examination of computers and phone records demonstrated complicity between exporters and importers and the following malpractices:

  • use of sugar syrups to adulterate honey and lower its price, both in non-EU countries and onto the EU territory
  • analysis in accredited laboratories to adapt honey/sugar blends to elude possible detection by clients and official authorities before import operations
  • use of additives and colourings to adulterate the true honey botanical source
  • masking of the true geographical origin of honey by forging traceability information and by removing pollens.

Based on the above, there is a strong suspicion that a large part of the honey imported from non-EU countries and found suspicious by the JRC of being adulterated remains present and undetected on the EU market.

Outcomes and way forward

The Commission will discuss an appropriate follow-up to this coordinated action with the relevant stakeholders and Member States authorities. The following course of action is being considered:

  • 1. Recalling the obligations to the food business operators and stress the need for corrective actions:

    Food business operators (including importers) operating in the honey sector at all stages of production, processing and distribution must:

    • (a) ensure that food placed on the EU market satisfies the requirements of the EU and national Food Law, which are relevant to their activities and ensure that the honey they are trading must comply with the EU marketing standards

    • (b) verify that such requirements are met (primary responsibility); and

    • (c) correctly identify the nature, composition, place or country of origin of the honey, business operators are placing onto the EU market or exporting outside the EU.

    The results of the coordinated action demonstrate that some food business operators are not complying or are not in a position to comply with their primary responsibility and thus jeopardise consumer confidence, undermine food value chains, create unfair competition for EU producers and operators and jeopardise food control systems' credibility.

  • 2. Inviting Member States to increase controls on the market and at the EU borders and to adapt their investigations techniques:

    Detecting and fighting food fraud is the responsibility of the Member States, notably under the provisions of the Official Control Regulation. It provides a comprehensive set of tools to tackle fraud, including provisions for cooperation in case of violations spanning across borders and gives the Commission a role in coordinating and enforcing the effective application of these measures at EU level.

    Analytical methods to ascertain honey authenticity exist but are lagging behind and lack sufficient sensitivity to detect low and intermediate levels of sugar adulterations. Fraudsters are adapting the level of adulteration with extraneous sugars in honey to this analytical capability. The same analytical limitations apply to border controls. The methods used by the JRC in the frame of the EU coordinated action have proved useful in identifying suspicions of fraud but are yet to be validated and pursued.

  • 3. Reinforcing import requirements and addressing the issue in exporting countries:

    The European Commission has already reinforced the EU import requirements by placing an authenticity requirement responsibility for the exporting countries in the certificate that accompanies imported honey (Commission Implementing Regulation (EU) 2022/36).

    The European Commission has also modified conditions for entry into the EU for honey and other apiculture products. Consignments of honey and other apiculture products (meaning beeswax, royal jelly, propolis or pollen) intended for human consumption are currently authorised for entry into the Union if they come from third countries listed in Annex I to Commission Implementing Regulation (EU) 2021/405 (approved control plans for residues of pharmacologically active substances, pesticides and contaminants) in accordance with the requirements of Commission Delegated Regulation (EU) 2022/2292. Whilst consignments must come from establishments complying with the requirements laid down Regulation (EC) No 852/2004 and must be accompanied by a health certificate drawn up in accordance with the model set out in Chapter 45 of Annex III to Commission Implementing Regulation (EU) 2020/2235, there was no requirement for those establishments to be listed in the EU's TRACES-NT database.

    The listing of third countries establishments exporting honey and other apiculture products intended for human consumption is an important measure to address the potential for fraud in this sector. Listing and verifying the compliance of establishments with EU hygiene rules will facilitate the traceability of imported consignments and the targeting of reinforced checks by the EU Member States on those establishments which are suspected of trading adulterated products.

    The Commission has thus amended Article 13 of Delegated Regulation (EU) 2022/2292 and adopted Commission Delegated Regulation (EU) 2023/2652 of 15 September 2023, published on 28 November 2023. The latter Regulation provides that consignments of honey and of other apiculture products intended for human consumption may only enter the Union if dispatched from, obtained and/or prepared in establishments that appear on lists drawn up and kept up to date in accordance with Article 127(3) of Regulation (EU) 2017/625. It also provides for a transitional period of twelve months from the date of publication of Delegated Regulation (EU) 2023/2652 of 15 September 2023 in the Official Journal of the European Union, i.e. 29 November 2024, after which consignments originating from establishments not listed will be denied entry into the EU.

    In practice, the procedure to list third countries establishments is to be performed in the "Establishment Amendments Lists" module of TRACES. Users' manuals demonstrating how to use that module can be provided on request to the TRACES support team at sante-tracesatec [dot] europa [dot] eu (sante-traces[at]ec[dot]europa[dot]eu).

    The Commission also engaged with competent authorities of exporting countries. All the countries concerned have been notified of the results of the EU coordinated action and asked to conduct investigations and sanction confirmed frauds appropriately.

Further information

Questions and answers surrounding Honey adulteration

Also downloadable in PDF format at the end of this section.

Download Q&As as PDF:

22 MARCH 2023
Q&As surrounding Honey adulteration