A Spoonful of Sugar? Better Put It on the Label - FDA Issues Draft Guidance on Branding Honey

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Addressing concerns about adulterated honey products, the FDA has issued draft guidance clarifying labeling requirements. According to the guidance, purveyors of honey products must specify on the product label and in the ingredient list any additional ingredients added to the honey. Products labeled only as "honey" cannot contain any additives. So, for example, if the manufacturer has added corn syrup, the label cannot simply identify the product as "honey"; rather, the product must be labeled "blend of honey and corn syrup." The ingredient list also must include both ingredients in the order of each ingredient's relative composition. Honey purveyors need not specify the floral source of the honey, such as clover, but may do so if they can demonstrate that the source identified is, in fact, the chief source. While the guidance does not alter the Food, Drug, and Cosmetic Act, it does make clear that from the FDA's perspective, even minor additions of flavors or sweetener cause honey to lose its status as "honey," and further, if a floral source for honey is described on the label, producers must be able to substantiate it as the primary source.

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