Foodlaw-Reading
Dr David Jukes, The University of Reading, UK
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FSA Enforcement Letter (ENF/E/16/047), 25 August 2016
To increase understanding and awareness of how Mānuka honey is sold in the UK. The Food Standards Agency (FSA) has carried out a surveillance activity to understand the types of Mānuka honey sold in England. The FSA also carried out additional work to identify consumers understanding about the marketing terms and other information on product labels.
This activity has provided a greater insight into what consumers perceptions are of Mānuka honey and will support the UK to work out how to better protect consumers and help them make informed choices.
The purpose of this letter is to highlight the findings from this work and to provide an update on the next steps.
Background
The UK market for Mānuka honey has developed significantly over the last few years, mostly due to the promotion of perceived increased antibacterial activity and health benefits. Previous work has demonstrated the complexity of the situation and the different approaches taken by industry to represent their product.
New Zealand’s Ministry for Primary Industries (MPI) published an interim Mānuka honey labelling guide in July 2014, which focusses on legislative labelling requirements and outlines interim characteristics of New Zealand (NZ) Mānuka-type honey (monofloral and multifloral). In the UK we consider the interim guidelines as a useful contribution and will continue to work with the MPI as part of our harmonised approach. MPI are continuing to identify the attributes of such a definition and validate test methods. This work is expected to be completed by the end of 2016.
We appreciate that MPI’s interim guidance is NZ guidance. There are, however, EU Directives and National legislation (the Honey Regulations 2015) and whilst this is not specific to mānuka, it provides legislative parameters to ensure labelling and the correct terminology is used on honey labels. The UK position has been that a product name specified in the Directive must be used along with descriptions stipulated by the Directive and only when honey is obtained wholly or mainly from a single floral or vegetable source can it use that additional descriptor in the product name. It should therefore, be clearly labelled with floral or pollens source. Enforcement action can be taken in accordance with the Honey Regulations 2015 enabling improvement notices to be served for a failure to comply with the provisions of the Honey Directive 2001/110/EC.
In continuing to support honey products on the market to ensure that they are true to label, discussions are on-going on the term ‘active’ and the numerical value present on the label. Analysis can be used to verify the numerical value present on the label and traceability paperwork should also confirm how the Food Business Operator (FBO) came to include that numerical value on the honey, otherwise the product would not be of the nature demanded by the customer. Any nutritional or health claims made should also be in line with EC Regulation 1924/2006 on nutrition and health claims made on food.
We are grateful to UK enforcement authorities for their support and request that they continue to ensure that UK honey suppliers are aware of the guidance and take necessary steps to ensure they are complying with regulations.
The surveillance work that has been carried out has highlighted that that consumers have a poor understanding of labelling and the numerical values with some linking them to perceived health benefits. Therefore, there is a need to raise awareness of this. These findings have been shared with the MPI to assist them in their continued work in this area.
In the UK, the next steps is to utilise the finding of this research to support further discussions at the European Union (EU) working group, and to discuss in more detail with other Member States to determine whether the labelling of these products are in line with Regulation(EC) No 1924/2006 on nutrition and health claims.
