Honey Regulations

Official Gazette

Issue: 31107

COMMUNIQUÉ

From the Ministry of Agriculture and Forestry:

TURKISH FOOD CODEX HONEY COMMUNIQUÉ

(COMMUNIQUÉ NO: 2020/7)

Purpose

ARTICLE 1 – (1) The purpose of this Communiqué is to determine the characteristics that honey must possess during its production, preparation, processing, storage, transportation, and marketing stages in accordance with technical and hygienic standards.

Scope

ARTICLE 2 – (1) This Communiqué applies to honey produced by the honeybee (Apis mellifera).

Legal Basis

ARTICLE 3 – (1) This Communiqué has been prepared based on the Turkish Food Codex Regulation, published in the Official Gazette dated 19/2/2020 and numbered 31044.

Definitions

ARTICLE 4 – (1) Definitions within this Communiqué:

a) Honey: A natural product derived from the nectar of plants, the secretions of living parts of plants, or excretions of plant-sucking insects on the living parts of plants. It is collected by honeybees, combined with specific substances, transformed, and reduced in water content, then stored and matured in combs. By nature, honey may crystallize.

b) Frame: Material used for bees to directly build combs or for placing foundation combs.

c) Baker’s Honey: Honey with foreign taste or odor, or that has started fermenting, or has been subjected to high temperatures, intended for industrial use or as an ingredient in other food products.

d) Traditional Hive ("Karakovan"): Non-standard hives, such as baskets woven from shrubs or hollowed-out tree logs, that do not allow modern beekeeping techniques to be applied.

(2) Types of honey mentioned in this Communiqué:

a) By Source:

Blossom Honey: Honey obtained from plant nectar.
Honeydew Honey: Honey obtained from the secretions of living parts of plants or excretions of plant-sucking insects (Hemiptera).
- Pine Honey: A type of honeydew honey produced by honeybees collecting and transforming the sweet sap excreted by Marchalina hellenica, a pest feeding on certain pine trees (Pinus brutia, P. nigra, P. pinea).

b) By Production and/or Marketing Method:

Comb Honey: Honey stored in combs without brood, built with beeswax and marketed with fully or partially capped combs.
Natural Comb Honey: Honey produced without foundation combs in standard hives and marketed with its comb.
Traditional Comb Honey ("Karakovan Honey"): Honey produced in traditional hives without foundation combs, marketed with its comb.
Extracted Honey: Honey obtained by centrifuging broodless combs after uncapping.
Comb-Extracted Honey: Honey prepared with pieces of comb honey mixed into extracted honey.
Drip Honey: Honey obtained by natural dripping from uncapped combs.
Pressed Honey: Honey obtained by pressing broodless combs directly or after heating up to a maximum of 45°C.
Filtered Honey: Honey from which foreign organic or inorganic substances have been removed using filtration materials with pore sizes smaller than 0.2 mm, resulting in reduced pollen content.

Product Characteristics

ARTICLE 5 – (1) Honey presented to the market or used as an ingredient in any food product for human consumption under this Communiqué must comply with the criteria in Annex-1 and the following characteristics:

a) Honey primarily consists of different sugars, mainly fructose and glucose, along with organic compounds, enzymes, and pollen. No food additives or other external substances may be added. Honey must be free from organic and inorganic substances not naturally found in its composition.

b) Except for baker’s honey, honey must not have any foreign taste or odor, must not have begun fermentation, its acidity must not be artificially altered, and it must not be heated in a manner that deactivates or destroys its natural enzymes.

c) With the exception of filtered honey, pollen or other unique components of honey cannot be removed, except for unavoidable losses during the removal of foreign organic or inorganic substances. Filtration below 0.2 mm is not permitted at any stage for any honey other than filtered honey.

d) Honey’s taste and aroma must be characteristic of its botanical source.

e) Honey’s color may vary from water-white to dark amber. Honeydew honey must have a minimum Pfund scale value of 60.

f) Honey’s consistency may range from fluid to viscous or partially/fully crystallized.

g) Filtered honey cannot be added to honey labeled with its botanical, regional, or geographical source.

h) Honey labeled with a botanical source must conform to the pollen ratios specified in Annex-2.

ı) Comb honey must have at least 80% of its comb capped.

j) Natural comb foundation must not contain paraffin, ceresin, tallow, resin, oxalic acid, or bleaching agents. Additionally, one gram of comb must not contain Paenibacillus larvae spores or vegetative forms causing American Foulbrood, or spores of Nosema apis and Nosema ceranae.

k) Traditional comb honey and natural comb honey cannot be marketed as extracted honey.

l) Honey marketed under the names traditional comb honey or natural comb honey must not contain broken combs or added extracted honey.

Additives

ARTICLE 6 – (1) No additives may be added to honey.

Flavorings and Flavoring Food Components

ARTICLE 7 – (1) No flavorings or flavoring food components may be added to honey.

Contaminants

ARTICLE 8 – (1) Products covered by this Communiqué are subject to the provisions of the Turkish Food Codex Regulation on Contaminants, published in the Official Gazette dated 29/12/2011 and numbered 28157 (Third Repeated Issue).

Pesticide Residues

ARTICLE 9 – (1) Products covered by this Communiqué are subject to the provisions of the Turkish Food Codex Regulation on Maximum Residue Limits for Pesticides, published in the Official Gazette dated 25/11/2016 and numbered 29899 (Repeated Issue).

Veterinary Drug Residues

ARTICLE 10 – (1) Products covered by this Communiqué are subject to the provisions of the Turkish Food Codex Regulation on the Classification and Maximum Residue Limits of Pharmacologically Active Substances in Animal Products, published in the Official Gazette dated 7/3/2017 and numbered 30000.

Hygiene

ARTICLE 11 – (1) Products covered by this Communiqué are subject to the provisions of the Turkish Food Codex Microbiological Criteria Regulation, published in the Official Gazette dated 29/12/2011 and numbered 28157 (Third Repeated Issue), and the Food Hygiene Regulation, published in the Official Gazette dated 17/12/2011 and numbered 28145.

Packaging

ARTICLE 12 – (1) Packaging of products covered by this Communiqué must comply with the provisions of the Turkish Food Codex Regulation on Materials and Articles in Contact with Food, published in the Official Gazette dated 5/4/2018 and numbered 30382.

Labeling

ARTICLE 13 – (1) Products covered by this Communiqué must comply with the Turkish Food Codex Regulation on Food Labeling and Consumer Information, published in the Official Gazette dated 26/1/2017 and numbered 29960 (Repeated Issue). Additional labeling rules are as follows:

a) Labels must state: "Do not feed honey to infants under 1 year of age."

b) For comb honey, net weight does not include the weight of the frame. Frames must display beekeepers’ operation numbers.

c) By source, honey is labeled as blossom honey or honeydew honey. If honeydew honey originates from pine, it is labeled as "pine honey," with "honeydew honey" optionally included.

...(Text continues with additional labeling, storage, transportation, and compliance provisions)...

What is an EU Coordinated Action?

Commission services can coordinate activities at the EU level upon request from one or more EU countries or on their own initiative. This occurs in cases where businesses operating in several Member States are suspected of involvement in a potential fraud scheme that poses either a health risk or significant socio-economic risks. The decision criteria for such coordination at the EU level consider the severity of these risks, the reliability of available information, and similarities with previous incidents. When suspicion involves imported products, the Commission communicates with the relevant non-EU countries to request targeted information and investigations.

Is honey currently regulated in the EU?

Honey, valued since ancient times for its sweetening properties, is a natural product. EU legislation aims to preserve the purity of honey as an unprocessed raw agricultural product and excludes changes to its chemical composition.

Council Directive 2001/110/EC, Annex 1, Article 1 defines honey as follows: "Honey is the natural sweet substance produced by Apis mellifera bees from the nectar of plants, the secretions of living parts of plants, or the excretions of plant-sucking insects on living parts of plants. Bees collect this substance, transform it by combining it with specific substances of their own, deposit it, dehydrate it, store it, and leave it in honeycombs to ripen."

The Directive also sets composition criteria (for human consumption) and related labeling requirements. Compliance with these requirements is mandatory for honey to be placed on the EU market.

What are the rules on sugar content in honey?

Natural sugars are one of the main components of honey and vary in quantity depending on the botanical source. Council Directive 2001/110/EC sets two requirements for sugar content in honey:

The sum of fructose and glucose must be at least 60 g per 100 g for blossom honey and at least 45 g per 100 g for honeydew honey and their mixtures.
Sucrose content must not exceed 5 g per 100 g, although higher limits are set for a few specific botanical sources, such as French honeysuckle, eucalyptus, and lavender.

Why was honey selected for an EU Coordinated Action?

Producer organizations and consumer protection associations have repeatedly raised concerns about potential honey fraud. These concerns were supported by the results of the first Coordinated Control Plan conducted in 2015-2017, which found that at least 14% of the samples tested did not meet purity criteria (link: [link]) and by notifications in the Rapid Alert System for Food and Feed (RASFF) (link: [link]).

What are the most common fraud practices related to honey?

Honey, a natural substance produced by bees, must not contain any added ingredients (e.g., sugar, food additives, flavorings).

Honey can be adulterated with various substances, primarily sugars. Cheap sugar syrups are used to increase the volume of honey, and detecting such additions can be complex, even with sophisticated analytical methods. Claims about the botanical source or other attributes may also be falsified to alter perceptions of honey’s quality and value. Honey produced in a specific geographic region using defined production methods can be marketed as a quality product with special characteristics (PDO: Protected Designation of Origin or PGI: Protected Geographical Indication). Given the higher prices for PDO/PGI honeys, there is an incentive to falsely declare the origin of ordinary honey. Geographical origin claims may also be falsified to bypass certification rules. Other types of fraud may involve composition or labeling, such as unlawfully labeling a lower-quality product, like "baker’s honey," as "honey."

What drives honey fraud?

The surge in consumer demand for natural sweeteners has created a market where global honey prices are at their highest in years. In the EU, honey market demand exceeds domestic production, leading to significant imports. Market price varies significantly based on quality factors, not always visible or measurable without extensive analysis, creating opportunities for misleading practices aimed at unfairly increasing economic or financial gains. The price gap between genuine honey and sugar syrups, combined with the difficulty of detecting adulteration, offers tempting fraud opportunities for dishonest operators.

What are the direct and indirect consequences of adulterating honey with sugars?

While the health risks for consumers are considered very low (assuming added sugar syrups are suitable for human consumption), adulterating honey with sugars undermines consumer confidence, weakens trust in the EU food chain, creates challenges for operators, and harms honey’s reputation. In 2021, the average unit value of imported honey into the EU was €2.17/kg (excluding New Zealand honey), whereas sugar syrups derived from rice cost approximately €0.40-€0.60/kg. Diluting honey with sugar syrups gives fraudsters an unfair advantage. Faced with these cheaper alternatives and potential unfair competition from fraudsters, professional beekeepers in the EU may be discouraged from continuing their activities, adversely affecting the amount of honey produced within the EU.

Does feeding sugar syrups to bees lead to honey adulteration?

Feeding bees sugar syrups may be necessary during certain periods, typically coinciding with honey harvests, to ensure that bees have enough nutrition to survive the winter. Residual bee feed left in the combs must be separated from the next harvested honey intended for marketing. Otherwise, it contaminates the honey, making it non-compliant with the EU Honey Directive.

However, feeding bees sugar syrups during the main nectar flow period contradicts the legal definition of honey, which states that honey must be produced either from plant nectar ("blossom honey" or "nectar honey") or from the secretions of living parts of plants or excretions of plant-sucking insects ("honeydew honey").

...(Text continues with additional details about the EU Coordinated Action "From the Hives," analytical methods, fraud detection, and outcomes)

§52.1391 Product Definition

Extracted honey (hereinafter referred to as honey) is honey that has been separated from the comb using centrifugal force, gravity, straining, or other methods.

§52.1392 Varieties

The type of extracted honey does not factor into the final product’s quality classification, as the type of extracted honey depends on its preparation and processing methods and is therefore not a quality factor for classification. Extracted honey may be prepared and processed as one of the following types:

(a) Liquid Honey: Honey that is free from visible crystals.

(b) Crystallized Honey: Honey that has solidified into a granular or crystalline state; it may also be referred to as granulated, fondant, creamed, or spreadable crystallized honey.

§52.1393 Styles

(a) Filtered Honey: Any type of honey defined in these standards that has been filtered to remove most or all fine particles, pollen grains, air bubbles, or other materials normally present in suspension.

(b) Strained Honey: Any type of honey defined in these standards that has been strained to remove most particles, such as comb, propolis, or other defects, but may still contain pollen grains, small air bubbles, and very fine particles.

§52.1394 Definition of Terms

Unless the context otherwise requires, the following terms in these U.S. standards mean:

(a) Freedom from Defects: Refers to the degree to which honey is free of comb particles, propolis, or other defects that may be in suspension or have settled at the bottom of the container. Classifications for freedom from defects as a quality factor are:

Practically Free: Honey contains very few defects that do not affect the product's appearance or edibility.
Reasonably Free: Honey contains defects that do not significantly affect the product's appearance or edibility.
Fairly Free: Honey contains defects that do not seriously affect the product's appearance or edibility.

(b) Air Bubbles: Numerous small visible pockets of air in suspension that may contribute to reduced clarity in filtered honey.

(d) Clarity: Relates to filtered honey and indicates the visual transparency or clearness of the honey and the degree of freedom from air bubbles, pollen grains, or other fine particles in suspension. Classifications for clarity as a quality factor are:

Clear: Honey may contain air bubbles that do not significantly affect the appearance and may show traces of pollen grains or other fine particles that do not affect the appearance.
Reasonably Clear: Honey may contain air bubbles, pollen grains, or other fine particles that do not significantly affect the appearance.
Fairly Clear: Honey may contain air bubbles, pollen grains, or other fine particles that do not seriously affect the appearance.

(e) Comb: Refers to the waxy, cellular structure that bees use to store brood, pollen, and honey. Comb fragments in suspension are defects and contribute to reduced clarity in filtered honey.

(f) Crystallization: Refers to the formation of crystals in honey.

(g) Flavor and Aroma: Denotes flavor excellence and aroma typical of the predominant floral source. Classifications for flavor and aroma as a quality factor are:

Good Flavor and Aroma for the Predominant Floral Source: Product has good, normal flavor and aroma for the floral source or a blend thereof, free from objectionable flavors caused by caramelization, fermentation, smoke, chemicals, or other factors.
Reasonably Good Flavor and Aroma for the Predominant Floral Source: Product has reasonably good, normal flavor and aroma for the floral source or blend, practically free from caramelized flavor, and free from objectionable flavors caused by other factors.
Fairly Good Flavor and Aroma for the Predominant Floral Source: Product has fairly good, normal flavor and aroma for the floral source or blend, reasonably free from caramelized flavor, and free from objectionable flavors caused by other factors.

(h) Floral Source: Refers to the flower from which bees collect nectar to produce honey.

(i) Granulation: Refers to the initial formation of crystals in honey.

(j) Pfund Color Grader: A device used by the honey industry to classify honey by color. This device is not officially approved for applying these U.S. quality standards.

(k) Pollen Grains: Dust-like microspores collected by bees from flowers. Pollen grains in suspension contribute to reduced clarity in filtered honey.

(l) Propolis: A resinous substance collected by bees from various plants, varying in color from light yellow to dark brown. Propolis can stain combs or frames and may be present in strained honey.

§52.1395 Suggested Sample Unit Sizes

(a) Color Determination: An amount sufficient to fill the color comparison cell of any approved device used to determine honey color.

(b) Quality Factors and Analysis: 100 g (3.5 oz).

§52.1396 Recommended Container Fill

Recommended container fill is not a quality factor for final product classification. However, it is recommended that each container be as full as practicable. For containers with a capacity of one gallon or less, honey should occupy at least 95% of the total container capacity.

§52.1397 Color

The color of extracted honey is not a quality factor for classification.

§52.1398 Color Determination

(a) The color of extracted honey (after adjustments for cloudiness) is determined using USDA-approved color standards as shown in Table I.

(b) Relevant color determinations, the applicable range for each color, Pfund scale ranges, and optical density of freshly prepared caramel-glycerin solutions are presented in Table I.