The FDA and Marketing Your Honey

By Christopher J Cripps, DVM

"...from top to bottom it was nothing but one gigantic lie." -Upton Sinclair, The Jungle

In the late 1800s to early 1900s, many people sold food or medicine that was not what they claimed it was, all so they could make a quick buck. Medicines did not work as promised, and people got sick from eating food. The images conveyed by Upton Sinclair in The Jungle helped push Congress to create reform, and in 1906 the Food and Drugs Act was signed into law. That law (and others like it) have protected the general public from people that might change or adulterate food or drugs. Honey is food and protected by these laws as well.

A brief history of honey production and its laws

When we look at beekeeping and honey production back in that time, there is some important history to understand. The movable frame was invented in the mid-1800s, and the honey extractor came along just a few years later. As honey extractors became more popular and liquid honey became readily available, the temptation to dilute honey with less expensive additives (like water or corn syrup) was too much for some people to resist, and it was common that what was sold as "honey" was not pure honey. Consumers came to prefer buying comb honey because it was impossible to make fake comb honey. When they bought comb honey, they knew they were getting pure honey straight from the bees.  

Consumers today are looking for pure honey that does not have any additives unless they know about them (things like cinnamon, pepper, or even cannabidiol are frequently added to honey by some people). There are a lot of state laws as well as federal laws that require a food manufacturer to properly label the food they sell with the actual ingredients. The Food and Drug Administration's mission to protect the integrity of our food means that fillers and adulterants that aren't listed on the label cannot appear in your food. Regulating this kind of thing requires that the FDA obtain and test your honey, to make sure that you aren't doing anything inappropriate to it, and to make sure that it's real, pure honey.

Avoid making claims that honey is medicinal

As sellers of food, we must put the actual ingredients on the label, and we also must not make claims that are not justified. Violations of these FDA labeling laws are often easier for them to catch because they don't need to test your honey to accuse you of making an unjustified claim about it. The FDA looks at printed words that you might have on your bottle, website, pamphlets, and signs as extensions of the labeling for your food. The FDA does a lot of enforcement by complaint, but they also have people that are searching the web for claims that cross the line. 

One of the lines that is easy to cross is to claim health benefits of a food or item that is not approved as a drug by the FDA. Statements like "honey has been shown to slow cancer's growth," "honey kills bacteria," or "eat honey every day to make your allergies go away" all turn honey into a "drug" that does not have FDA approval. If you make these claims and someone turns you in, or if the FDA finds the claims on a website, the FDA will issue a Warning Letter. These warning letters are sent for many types of violations and they can be easily found online by searching "FDA warning letters." 

One of these letters talks about the company's webpage having a claim that one of their honey products "stabilizes blood sugar, lowers cholesterol levels, and provides relief from inflammation and pain," among other claims. Besides the website, the FDA also visited their Facebook page and listed more claims that have not been approved by the FDA. The warning letter goes on to explain that the items they sell, including honey, are not recognized as "generally safe and effective" treatments for the conditions listed, so they are now "new drugs." New drugs need to be approved by the FDA and must have complete directions for proper use or be limited for sale to licensed professionals. All the statements in that letter show the FDA has a case for a number of broken laws. The FDA then requires a response to show the violations have been corrected. 

This is just one example of a salesman making inappropriate claims about the health benefits of honey. Other examples can be found online, where the FDA posts these letters as an example to others. Even if you think honey helps with your allergies or improves your arthritis, until those claims are scientifically proven you cannot list those medical benefits as you try to sell your honey. The FDA has to be very strict about these things to protect our food supply and our medicine supply from food fraud and snake-oil remedies. 

Personal story of going through the FDA review process

As a veterinarian, I have been through this FDA review process personally, and while it is uncomfortable, the goal of the FDA was to make things safer for everyone who eats food. That case involved a farm that accidentally sold a calf that had been treated with antibiotics and other drugs prior to being sold for slaughter. The FDA investigator reviewed changes we made at the farm to improve recordkeeping and marking of animals that had received antibiotics. Everyone worked together to fix a mistake and prevent it from happening again. The goal was always to ensure a safe food supply for the general public. 

It is not illegal to treat sick animals with medicine, but after they are treated, the animal must not be slaughtered for human consumption until the medicine is out of their system. If the animal treated with medicine is a cow, her milk must be collected and disposed of separately from the milk going to the processing plant. Every single load of milk is tested for antibiotics prior to being processed. If the animal treated with medicine is a honey bee colony, then their honey cannot be collected during treatment, and possibly for a period of time after being treated. These "holdout" times are determined for each medicine that is approved by the FDA or EPA and clearly printed on the label. Make sure to follow the directions, including the holdout time, so people trust their honey supply. 

Final thoughts on FDA inspectors and laws

The FDA inspectors aren't "out to get beekeepers" who are just trying to sell a little honey. They're protecting everyone by ensuring that the wonderful products of the hive are properly labeled with the ingredients in the jar and without exaggerated claims. Sure, you might be able to sell a little more if you tell people your honey cures allergies, but we all benefit from a marketplace where honey is just a delicious food until it's scientifically proven to do more. Many people that buy honey from the beekeeper are ecstatic to buy pure, wholesome food from someone they know. Capitalize on that personal connection, not troublesome medical claims, to boost your honey sales!